A panel of EPA’s National Environmental Justice Advisory Council (NEJAC) recently released draft recommendations for how EPA should more effectively address cumulative impacts. NEJAC recommends EPA’s work “center” on four principles:
- Decrease disproportionate cumulative burden
- Move beyond traditional risk assessments
- Take historic burden seriously
- Prioritize precaution over a high burden of proof
These four principles were the first of eight themes in the draft report. Here are the other seven themes:
- EPA should workshop, translate, and improve the Office of Research and Development definition of cumulative impact before full-agency adoption
- Comprehensive - Solution Oriented - Community Driven” Programs
- EPA must determine and communicate a set of principles to guide the practice of cumulative impact assessment
- Validating “lived experience” and incorporating it into assessments and processes through co-design and shared leadership
- EPA must incorporate structural drivers such as colonialism and racism into its cumulative impacts practice and framework
- Climate justice
- Accelerating progress of and innovative approaches for cumulative impacts implementation
At the same time, recent departures from environmental justice-related EPA offices have raised the potential that EPA guidance on cumulative impacts and other environmental justice efforts may be delayed. These departures include Lilian Dorka, EPA’s Office of Environmental Justice & External Civil Rights (OEJECR) deputy assistant administrator for external civil rights, and Anhthu Hoang, acting director of EPA’s External Civil Rights Compliance Office within OEJECR, who both moved to different roles in EPA. Before these moves, EPA senior EJ advisor Robin Morris Collins left in February, and Matthew Tejada, deputy assistant administrator for environmental justice in OEJECR, left in December 2023.
