A New EPA Plan Offers a Roadmap on Environmental Justice and Cumulative Impacts

February 29, 2024 | 8:51 am
twisty road signAaron Hill/Pexels
Kristie Ellickson
Kendall Fellow

In a past blogpost, I described the concept of “cumulative impacts” as a doctor visit in which, rather than getting a quick screening of one issue, a patient receives a holistic assessment and treatment. The US Environmental Protection Agency (EPA) just released an updated 2023 Equity Action Plan explaining how the agency intends to “imbed equity, civil rights, and environmental justice” into all aspects of its work.

Part of this plan discusses the agency’s priorities on cumulative impacts, which it defines as “the totality of exposures to combinations of chemical and nonchemical stressors and their effects on health, well-being, and quality of life outcomes.” A close look can give us a better understanding of how the EPA plans to decrease the real gaps in environmental health impacts experienced by low income and communities of color. But first, a bit of background is needed.

A push toward environmental justice

The Biden Administration has focused on environmental justice (EJ) issues by ensuring voices with EJ lived experience are heard in the White House, removing barriers for disadvantaged communities in accessing clean energy solutions, and directing federal agencies to imbed equity in their work through executive orders. In January 2021, the Biden Administration’s Executive Order 13985, “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government,” required federal agencies to assess barriers that prevent underserved communities from accessing federal government benefits and opportunities, and write plans to address these barriers.

EPA has been working on EJ issues for years, but more recently has ramped up its commitments. In response to the 2021 order, EPA wrote a plan (2022 Equity Action Plan) recommending six priority actions it will take to address environmental injustices.

Then in April 2023, the Biden Administration released Executive Order 14096, “Revitalizing our Nation’s Commitment to Environmental Justice.” This order requires federal agencies to develop and update EJ strategic plans, thus the EPA’s new 2023 plan came into being.

First steps

In its 2022 plan, EPA announced that its first priority action would be to develop and implement a comprehensive framework for considering cumulative impacts in decisions. In effect, this meant that the agency was developing a kind of scaffolding for how it might study, implement, and make decisions based on cumulative impacts.

EPA’s next priority was to build capacity in underserved communities with an overall goal of participating in more community-led projects. In support of that, EPA proposed to develop its internal capacity to engage with underserved communities. In addition, EPA prioritized actions to continue work linking environmental regulations and civil rights and improve its capacity in community-based participatory science. Part of EPA’s improvements in their community-based science has meant hiring social scientists in order to integrate their skill sets in studying social systems and interactions among people. Finally, EPA prioritized a continued effort to make their procurement and contracting more equitable.

New developments

EPA’s latest 2023 plan builds on this work at the agency and charts a path toward more equity-centered environmental policy. This plan also provides an update on the agency’s progress in addressing cumulative impacts. Interestingly, the new plan moves from describing a series of priority actions to describing a series of priority strategies. Priority actions might set governmental action in motion, but priority strategies outline a plan and reasoning for moving toward achieving a longer-term goal.

EPA’s first priority strategy is to improve access to funding and assistance programs for communities—especially those with environmental justice concerns. This relates to a series of centers around the country that are set up to build capacity and remove barriers in communities to receiving federal grant funding, primarily for the Justice 40 program.

Where the 2022 plan focused on developing and implementing a cumulative impacts framework, the 2023 plan focuses on actions to actually reduce cumulative environmental and health impacts in communities, again particularly those with EJ concerns.

In the updated plan, EPA provides a snapshot of their progress, notably that the cumulative impacts framework is still in development. We need to keep watch for that framework because it will help us understand how EPA is thinking about incorporating cumulative impacts into its work and what strategies and tactics it might take to get there.

Based on my reading, EPA is developing a strong research program around cumulative impacts but it still has much work to do to integrate cumulative impacts into regulatory decisionmaking. So, its priority strategies are an important indication of how it hopes to accomplish that.  

EPA is also continuing its work to link environmental protection and civil rights. Many organizations and agencies are carefully choosing how they will work for racial justice especially with regard to recent court decisions. EPA also discussed protecting children from pollution with a focus on equity, which is important for many types of pollutants especially those that impact developing brains. According to this plan, rural communities will be a focus of efforts to decrease injustices. Many times when we think of environmental justice, we think of cities, but rural areas can also benefit from a strong focus on equity. EPA has committed to removing barriers to services and opportunities for people with disabilities to ensure that they have full environmental health protections. And finally, a lot of EJ work is supported by the development of maps that visualize environmental, health, and social disparities. These maps require the agency to bring together disparate data sets. Data and analytic capacity are an EPA priority, and something that also helps overall efficiency in finding and connecting information.

Holistic approach

One of the really promising aspects of this plan is that EPA lists collaborating federal agencies in each of its priority strategies. This reflects an effort to provide what they call a “whole of government approach” which is sorely needed to address complex issues such as climate change and cumulative impacts.

Communities experiencing cumulative impacts have multiple environmental, social, and health stressors; advocating to improve each of them requires navigating a challenging web of government services and opportunities at a variety of government agencies. Because of this, the agency’s “whole of government approach” makes a lot of sense.

While EPA is not required to implement the strategies in these plans, they do help us understand how the agency is thinking about their equity work and how it plans to implement changes. In government work, planning is important. By putting aspirational goals down on paper, it means that, barring big changes in EPA structure, the agency is on a solid path toward getting them done. The plan can also help us figure out the best ways to get involved.

Incorporating cumulative impacts into environmental decisionmaking is central to achieving environmental justice because it is based on the realities of longstanding inequities regarding who bears the burden of environmental pollution. Redressing these inequities must include a transition toward a focus on equity for the people in frontline communities, and not solely providing a level playing field for all regulated communities. Real progress for communities remains in the offing. But EPA’s new plan offers a roadmap supporting this transition.