TAKE ACTION: Submit Comments on EPA's Cumulative Impacts Framework!
What Are Cumulative Impacts?
Cumulative impacts is the term used to describe the combined effects of exposure to multiple sources of pollution. For example, if you live near a power plant, truck depot, factory, and highway, the air you breathe is polluted by all of those sources. However, in the way permitting is done for these sources of pollution, the regulatory agency only reviews the pollution being generated by the facility seeking the permit - not the overall combination of pollution from these other sources.
In 2022, we helped pass a law in New York State to change that, forcing the state to consider cumulative impacts as part of its environmental permitting process for facilities in communities of color and low-income. And now the U.S. Environmental Protection Agency (EPA) is considering incorporating cumulative impacts into its regulatory guidance.
EPA Draft Framework on Cumulative Impacts
On November 22, 2024, EPA released the Draft Interim Framework on Consideration of Cumulative Impacts (PDF). It describes the principles and a process for EPA to consider cumulative impacts in EPA decisions. These principles include:
Centering cumulative impacts work on improving human health, quality of life, and the environment in all communities.
Focusing on the disproportionate and adverse burden of cumulative impacts.
Applying a fit-for-purpose approach to assessing and addressing cumulative impacts.
Engaging communities and incorporating their lived experience.
Using available data and information to make decisions and take action.
Operationalizing and integrating ways to consider and address cumulative impacts.
Your Chance to Submit Feedback
We have been working to get fellow advocates and other organizations to submit feedback as part of the EPA public comments period, which ends at 12:00 PM EST on Wednesday, February 19, 2025. And now we are encouraging other organizations and individuals who have yet to submit comments to do so. You can read the framework here (PDF) and an abbreviated fact sheet here (PDF). And you can submit comments here (you must include the Docket ID Number: EPA-HQ-OLEM-2024-0360).
Public comments do not need to be lengthy. In addition to the Docket ID Number (EPA-HQ-OLEM-2024-0360), they should include a description of your community and, if you are submitting comments for an organization you work for, be sure to include a description of that organization as well.
You should also describe why cumulative impacts are important to consider for your community, how this EPA framework could benefit your community, and any suggestions you may have to improve the framework. For example, you can describe the types of pollution and non-environmental stressors (e.g. socioeconomic status such as race and income, high density of vulnerable populations, history of redlining, etc.) exist in your community and how that impacts community health. We also suggest you include any statistics on these factors that are available and can help you compile a community profile.
