Cumulative impacts analysis evaluates the combined effects of multiple stressors and burdens—social, environmental, health, historical, cultural, and economic—to inform more comprehensive and equitable decisionmaking. After decades of efforts by advocates and experts, the US Environmental Protection Agency (EPA) issued a new framework in November 2024 for the use of cumulative impacts in policymaking and requested public comment. Since January 2025, however, the Trump administration has made changes that undermine environmental justice and public health, including the EPA’s ability to use the Cumulative Impacts Framework, and has not responded to any comments on the Framework.
The Union of Concerned Scientists (UCS) reviewed and analyzed public and tribal community comments on the Framework. UCS also convened four meetings of experts with previous EPA experience to review the Framework. In the absence of federal leadership, this report will help inform efforts to advance cumulative impacts policies and practices.
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Citation
Ellickson, Kristie, Darya Minovi, Robin Morris Collin, Alan Walts, Carol Ann Gross-Davis, and Samuel Kay. Unfinished Business: A Review of Public Comments on the Environmental Protection Agency’s Cumulative Impacts Framework. Cambridge, MA: Union of Concerned Scientists. https://doi.org/10.47923/2026.16224