Cumulative Impacts and Mandatory Emissions Reductions Team
There is a fundamental problem with the way the US regulates chemical pollution.
Cumulative impacts are the combined chemical and non-chemical stressors on a community’s health, well-being and quality of life.
Federal agencies have the power to determine whether chemicals are safe, and whether the facilities that produce them are safe. But right now, regulators aren’t seeing the big picture. When we regulate chemical pollution, we can’t just think about the safety of one chemical or one facility at a time. Instead, we have to think about the health of a community holistically. Is a community being exposed to lots of different toxic chemicals from a cluster of facilities? What happens when people breathe, drink, or are exposed to these chemicals in combination? Is public health already stressed in this community, and why? For example, are cancer and asthma rates higher than average in this community? Has this community faced systematic racial discrimination, by being targeted for highway construction and industrial development, or being shut out of home loans via redlining policies? Are there accessible and quality hospitals, grocery stores and green spaces in this community?
By looking at cumulative impacts, we are able to see which communities have been harmed the most, and must be restored, strengthened and repaired. One way to do this is through mandatory emissions reductions that will require chemical facilities to decrease, and ultimately eliminate the toxic chemicals they are releasing into communities. Right now, companies are given permission to pollute into communities, via permits. We believe that no amount of toxic emissions into communities should be considered “safe” or acceptable, especially given that emissions from multiple sources add up and take a heavy toll on residents’ health.
About us
We are a collaborative working group of the Coming Clean network. We support and mobilize environmental organizations and directly impacted community members to speak and submit comments to the EPA and other governmental agencies tasked with regulating pollution, to ensure that these bodies hear from people most affected by new methods and policies, listen to their concerns and implement their recommendations. Our long-term goals are to reduce harm from cumulative impacts and to require mandatory emissions reductions, in alignment with the Louisville Charter for Safer Chemicals.
Get involved
If you are a member, send an email to Kathy Curtis (see directory) to ask about current action opportunities, how to join our bi-weekly meetings, and learn more about our work! If you are not yet a member, email Jim Irby jirby@comingcleaninc.org to inquire.
Recent federal advocacy
- In November 2023 we submitted comments encouraging EPA to strengthen its proposed Air Emissions Reporting Requirements for sources of hazardous air pollution.
- In March 2023, we commented on the EPA's Draft Proposed Principles of Cumulative Risk Assessment under the Toxic Substances Control Act (TSCA), arguing that TSCA already requires EPA to consider the real-world, cumulative risks that toxic chemicals pose to communities.
- In November 2022, EPA revised its definition and framework for cumulative impacts analysis, in response to community feedback.
- In March 2022 we provided critical input on the EPA’s draft Fenceline Assessment Approach, i.e. the way it plans to measure exposures and risks to fenceline communities when it evaluates chemicals under the Toxic Substances Control Act (TSCA). Problematically, EPA proposed only considering risk from a single facility and a single chemical at a time, ignoring cumulative harm that communities face from multiple facilities and chemicals, and additional health stressors. Read our public comment submitted by 25 organizations. And watch video of our testimonies to the Science Advisory Committee on Chemicals.
Research from the Coming Clean network
Addressing Environmental Injustice Through the Adoption of Cumulative Impacts Policies: A 2021 Louisville Charter Policy Brief by Drs. Nicky Sheats and Ana Baptista defines cumulative impacts and highlights model policies to address them, with a focus on New Jersey state legislation.
Environmental Justice for Delaware Mitigating Toxic Pollution in New Castle County Communities: A 2017 report by the Union of Concerned Scientists, EJHA, Delaware Concerned Residents for Environmental Justice, Coming Clean and partners, shows that EJ communities in Delaware face substantial cumulative health risks from exposure to toxic air pollution that are much greater than those faced by wealthy white neighborhoods.
Life at the Fenceline: Understanding Cumulative Health Hazards in Environmental Justice Communities A 2015 report by Coming Clean and EJHA shows that people on the fenceline live under the threat of chemical disasters, have limited access to healthy food, and experience higher rates of cancer and respiratory illness.
Related News
October 16, 2024
“Community Guide to Cumulative Impacts” breaks down the science and organizing needed for stronger pollution-prevention policies at the state and local level
On October 16, 2024, Coming Clean and the Union of Concerned Scientists published The Community Guide to Cumulative Impacts, a resource to drive policy changes at the state and local level to protect overburdened communities from cumulative chemical and pollution harms. The Guide is available in English and Spanish. The Guide was co-developed with over eight local organizations across the country, including Los Jardines Institute, Clean + Healthy, and COPAL (Communidades Organizando el Poder y la Acción Latina), that have long advocated for holistic policies that can reduce stressors on community health. The Guide defines cumulative impacts as “the combined chemical and non-chemical stressors on a community’s health, well-being, and quality of life.” It compares various metrics and mapping tools that can help environmental justice communities show policymakers that their community is experiencing multiple, reinforcing health stressors, such as proximity to many highly polluting facilities releasing multiple chemicals, lack of access to affordable healthcare and housing, and language barriers.
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October 16, 2024
These three states have already passed laws to reduce cumulative impacts
Over 125 organizations in the Coming Clean network agree that reducing cumulative impacts on environmental justice communities is one of our collective policy goals, as outlined in the Louisville Charter for Safer Chemicals. We know that environmental justice communities are not exposed to only one polluting facility or one health-harming pollutant at a time. When reviewing permits for polluting facilities, regulators should have to take into account the combined harm of existing industry on community health, and should have the authority to deny permit applications from facilities that add to disproportionate pollution burdens and existing health stressors. Passing cumulative impacts legislation at the state and local level is one promising way to make this possible. In 2021, Coming Clean released a policy brief by Drs. Nicky Sheats and Ana Baptista on state cumulative impacts legislation that passed in New Jersey, which we hoped would serve as a model for other states and cities. Since then, New York, Minnesota, Massachusetts and Connecticut have also passed cumulative impacts laws. Cities and counties are also pursuing creative ways to assess and reduce cumulative impacts, while involving impacted community members in decision making. Could your state or city be next? Read our Community Guide to Cumulative Impacts!
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January 11, 2023
Albuquerque Air War: Big Business, Bipartisan Politicos Attack Environmental Justice Rule
Promoting a tourism mystique, the marketers of Albuquerque, New Mexico, peddle images of clean skies, diverse culture and delicious cuisine. The icons encompass soaring hot air balloons, majestic Sandia Mountain vistas and the ubiquitous chile pepper, red or green. But if current political trends hold, the postcard visitors send grandma might depict more spewing emissions, sickly skies and gagging residents. At least that’s the implication of recent actions by the Albuquerque City Council that sacked the current members of the joint Albuquerque-Bernalillo County Air Quality Control Board (JAQCB) and blocked a proposed Health, Environment and Equity Impacts rule (HEEI) aimed at protecting low-income communities of color in Albuquerque and Bernalillo County from further, disproportionate air pollution impacts, including the cumulative effects of pollution. Both Minnesota and New Jersey previously adopted similar environmental justice measures. The rule, which would require review and consideration of environmental and health impacts for air permits, was proposed to the JAQCB last year by the Mountain View Coalition of Albuquerque’s South Valley.
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