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Tishman Environment and Design Center
Last updated December 2023
For questions, please contact: lamy@newschool.edu
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Implementing Agency/AuthorityTypeYear, StatusCumulative Impact Link/TitlePurpose of ApplicationDefinition of Cumulative Impact Social and Environmental Indicators Thresholds Threshold calculations
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Federal
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Council on Environmental Quality (CEQ) Agency Guidance1997 (Response to 1994 executive order) Environmental Justice; Guidance Under the National Environmental Policy Act (NEPA)
In light of Executive Order 12898 (1994 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations) the CEQ issued this guidance that includes six principles for environmental justice analyses to determine any disproportionately high and adverse human health or environmental effects to low-income, minority, and tribal populations.		States agencies should consider relevant public health data and industry data concerning the potential for multiple or cumulative exposure to human health or environmental hazards and assure meaningful community and tribal representation. Cumulative environmental exposure means exposure to one or more chemical, biological, physical, or radiological agents across environmental media (e.g., air, water, soil) from single or multiple sources, over time in one or more locations, that have the potential for deleterious effects to the environment and/or human health.No specific indicators, broad categories of indicators - Agencies should (1) recognize the interrelated cultural, social, occupational, historical, or economic factors that may amplify the natural and physical environmental effects of the proposed agency action (2) Consider the composition of the affected area to determine whether low-income, minority or tribal populations are present and whether there may be disproportionately high and adverse human health or environmental effects on these populations and (3) Consider relevant public health and industry data concerning the potential for multiple exposures or cumulative exposure to human health or environmental hazards in the affected population, as well as historical patterns of exposure to environmental hazardsNeither the Executive Order nor this guidance change the prevailing legal thresholds and statutory interpretations under NEPA and existing case law. For example, for an EIS to be
required, there must be a sufficient impact on the physical or natural environment to be “significant” within the meaning of NEPA. Agency consideration of impacts on low- income populations, minority populations, or Indian tribes may lead to the identification of disproportionately high and adverse human health or environmental effects that are significant and that otherwise would be overlooked.		No specific threshold calculations mentioned
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Council on Environmental Quality (CEQ) Report1997 (NEPA enacted in 1970)Considering Cumulative Effects Under the National Environmental Policy Act (NEPA) Council on Environmental Quality (CEQ) regulations implementing the procedural provisions of NEPA, which defined cumulative effects. A handbook providing a framework for advancing environmental impact analysis by addressing cumulative effects in either an environmental assessment or environmental impact statement. Outlines CI principles and provides information on methods of cumulative effects analysis and data sourcesThe definition of Cumulative Effects under NEPA:

The impact on the environment which results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions. 		Cumulative effects need to be analyzed in terms of resources, ecosystems, and human communities - Environmental and socio-economic stress factors; governmental regulations, standards, and plans; and environmental and social trends. See pages 27-35 (Characterization of Stress Factors). Indicators of environmental stress can be either exposure-oriented (e.g., contamination levels) or effects-oriented (e.g., loss or degradation of a fishery) (page 28) No specific thresholds mentionedNo specific threshold calculations mentioned
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U.S. EPA Agency Guidance1997EPA Guidance on Cumulative Risk Assessment. Part 1. Planning and Scoping , Science Policy Council, U.S. Environmental Protection Agency

Guidance focus (Part 1.) initially on risk assessments that integrate risks of adverse health and ecological effects from the narrower set of environmental stressors.		Guidance on risk assessments that integrate risks of adverse health and ecological effects from the narrower set of environmental stressors Cumulative risk assessment: term covers a wide variety of risks. EPA assessments describe and where possible quantify the risks of adverse health and ecological effects from synthetic chemicals, radiation, and biological stressors. As part of planning an integrated risk assessment, risk assessors must define dimensions of the assessment, including the characteristics of the population at risk. These include individuals or sensitive subgroups which may be highly susceptible to risks from stressors or groups of stressors due to their age (for example, risks to infants and children), gender, disease history, size, or developmental stage.

Cumulative Impacts, included in risk assessment terminology are the sum of all individual impacts occurring over time and space, including those of the foreseeable future (CEQ, 40 CFR Sect. 1508.7)

Cumulative effects, included in the same terminology are 1) the sum of all environmental effects resulting from cumulative impacts (Liebowitz et al., 1992), and 2) the combination of effects from all pesticide chemical residues which have a common mechanism of toxicity (Food Quality Protection Act, 1996). 		Six dimensions for analysis are used: sources, stressors, pathways, population, endpoints, and time frames.

● Population has three categories: 1. Humans, 2. Ecological Entities, and 3. Landscape or Geographic Concerns expanded in detail on page 7-9.
● Source, two categories: 1. Single source (point sources (for example, industrial or commercial discharge, superfund sites) and nonpoint sources (for example, automobiles, agriculture, consumer use releases) and natural sources (for example, flooding, hurricanes, earthquakes, forest fires) and 2. Multi-sources (Combinations of those above)
● Stressors, ten categories: 1. Chemicals, 2. Radiation, 3. Microbiological or biological (these range from morbidity to ecosystem disruption), 4. Nutritional (for example, diet, fitness, or metabolic state), 5. Economic ( for example, access to health care), 6. Psychological (for example, knowledge of living near uncertain risks), 7. Habitat Alteration (for example, urbanization, hydrologic modification, timber harvest), 8. Land-use changes (for example, agriculture to residential, public to private recreational uses), 9. Global climate change, and 10. Natural Disasters (for example, floods, hurricanes, earthquakes, disease, pest invasions)
● Pathways, three categories: 1. Pathways, more than one of the following involved: Air, Surface Water, Groundwater, Soil, Solid Waste, Food, Non-food consumer products, pharmaceuticals 2. Routes of Human and single species exposures, Ingestion (both food and water), Dermal (includes absorption and uptake by plants), Inhalation (includes gaseous exchange), Non-dietary ingestion (for example, "hand-to-mouth" behavior) 3. Routes of Exposure within communities and ecosystems: Direct Contact or ingestion (without accumulation), Bioaccumulation, Biomagnification,Vector transfers (for example, parasites, mosquitoes)
● Endpoints, two categories: 1. Human Health Effects for example as based on animal studies, morbidity and disease registries, laboratory and clinical studies, or epidemiological studies or data i.e. Carcinogenic, Neurotoxicology, Reproductive dysfunction, Developmental, Cardiovascular, Immunologic, Renal, Hepatic, Others, 2. Ecological Effects such as: Population or Species, Community, Ecosystem
● Time frames, three categories: To assess relevant time frames: Frequency, Duration, Intensity and Overlap of Exposure Intervals for a Stressor or Mixtures of Stressors such as 1. Acute, 2. Subchronic and 3. Chronic or effects with a long latency period, 4. Intermittent

* All risk dimensions expanded in detail page 7-9
No specific thresholds mentionedNo specific threshold calculations mentioned
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U.S. EPA Agency Guidance1999Consideration Of Cumulative Impacts In EPA Review of NEPA Documents- U.S. Environmental Protection Agency, Office of Federal Activities (2252A) EPA 315-R-99-002

Guidance is to assist EPA reviewers of NEPA documents with an emphasis on the effects of projects on ecological resources specific issues and critical areas of EPA's review of NEPA documents under Section 309 of the Clean Air Act. Offers practical suggestions on how to prepare comments to address cumulative impacts in NEPA documents		Guidance to assist EPA reviewers of NEPA documents in providing accurate, realistic, and consistent
comments on the assessment of cumulative impacts. 		This guidance emphasizes the effects of projects on ecological resources, other resources and areas that should be considered include socioeconomic resources, human health, recreation, quality of life issues, and cultural and historical resources.

Cumulative Impacts result when the effects of an action are added to or interact with other effects in a particular place and within a particular time. It is the combination of these effects, and any resulting environmental degradation, that should be the focus of CI analysis. CI differ from direct and indirect impacts as it takes into account all disturbances since cumulative impacts result in the compounding of the effects of all actions over time. CI can be viewed as the total effects on a resource, ecosystem, or human community of that action and all other activities affecting that resource no matter what entity (federal, non-federal, or private) is taking the actions .



Landscaping is used as an example for setting indicators, the following indicators for landscaping were included:

● The total change in land cover as an indicator of biotic integrity
● Patch size distribution and distance as indicators of species change and level of disturbance
● Estimates of fragmentation and connectivity as indicators of magnitude of disturbance, ability of species to survive in an area, and ecological
integrity
● Water quality and watershed integrity i.e. levels of nitrogen, phosphorous, turbidity, dissolved oxygen, and temperature
● Condition of riparian buffer zones i.e. soil erosion, sediment loading, and contaminant runoff

*Social indicators were mentioned as "other resources that should be considered" i.e historic and archeological sites, socioeconomic services and issues and community structure and character. Also mentioned as other resources and areas to be considered: socioeconomic resources, human health, recreation, quality of life issues, and cultural and historical resources		No specific thresholds mentionedChange is evaluated in terms of both the total threshold beyond which the resource degrades to unacceptable levels and the incremental contribution of the proposed action to reaching that threshold. E.g. thresholds for determining adverse change in the functioning of a wetland could include % of historic wetland loss in the region, occurrence of species at risk, ambient water quality data that exceed standards, and estuarine pollution susceptibility index.

*Without a definitive threshold, the NEPA practitioner should compare the cumulative effects of multiple actions with appropriate national, regional, state, or community goals to determine whether the total effect is significant.

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U.S. EPA Report/Framework2003EPA Framework for Cumulative Risk Assessment (2003)

This framework for Cumulative Risk Assessment emphasizes chemical risks to human health in its discussion and also in the context of the effects from a variety of stressors, including non-chemical stressors. Some important topics that could be characterized as “cumulative risk,” such as global climate change, are beyond the scope of this report. Provides a 'flexible structure for the technical issues and define key terms associated with cumulative risk assessment' 		Purpose is to offer a structure for conducting and evaluating cumulative risk assessment within the EPA.
This EPA Framework for CRA is represents an advancement in EJ because: (1) It utilizes a population-based and place-based analysis, (2) promotes a comprehensive and integrated assessment of health and environmental risk, (3) It posits an expanded definition of vulnerability to include biological and social factors and (4) it involves multiple stressors, chemical and non-chemical (NEJAC, 2004)		CI analysis was done in part to develop a framework of Cumulative Risk Assessment (CRA) which the EPA’s Risk Assessment Forum committee of EPA scientists were charged with developing for Agency-wide use.

In this report Cumulative Risk Assessment (CRA) means an analysis, characterization, and possible quantification of the combined risks to health or the environment from multiple agents or stressors.

A Cumulative Risk (CR) means the combined risks from aggregate exposures to multiple agents or stressors. There is no limitation that the “agents or stressors” be only chemicals; they may be, but they may also be biological or physical agents or an activity that, directly or indirectly, alters or causes the loss of a necessity e.g habitat.

A cumulative human health or ecological health risk assessment is different from a cumulative impact analysis (CIA) such as is conducted under NEPA, as changes in quality-of-life factors may affect the vulnerability of a population i.e. health or ecological risks and consequently may be part of the considerations in a cumulative risk assessment (CRA).

NEPA's Cumulative Impact definition from CEQ 1997 is cited along with National Center for Environmental Assessment and Cumulative Risk Initiative of Illinois and Indiana		The following indicators were provided from individual assessments of studies that make up the overall framework:

● Ratios or toxicity weighted emission estimates are used to derive indicators of cumulative hazard and mapped to identify geographic areas where elevated hazards and individuals with greater susceptibility are collocated. In addition pollutant hazard information and data on existing human disease rates and indicators are collected.

● Geographically based measures of hazards: GIS systems that display complex, multidimensional matrices on a map can help in visualizing locations of areas with multiple stressors and are potentially useful cumulative measures.
Example given about the indicator for hazards implemented under Superfund (USEPA, 1989a). The hazard index is a number whose decision threshold is usually given as 1.0, so that when the hazard index is greater than 1, additional action is indicated. The actual value of a
hazard index is not that informative: a value of 6 is not necessarily twice as bad as a value of 3.		The Hazard Index (HI) formula for oral exposure is implemented by Superfund assessors (p.49):

HI = sum[ HQj ] = sum[ Ej/RfDj ]

• where Ej and RfDj are the daily exposure and reference dose of chemical j.
• The RfD is itself a kind of decision index in that it reflects a dose that is selected to be sufficiently low that any toxic effects are judged highly unlikely.
• All available dose-response data on all effects are considered in determining each RfD.

Uncertainties in the RfD will differ across the chemicals, making the uncertainty in HI difficult to characterize.

• In regards to chemical accidents and transportation related spills, source term modeling is recommended for their wide variety of published calculation methods.
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National Environmental Justice Advisory Council ReportReport2004National Environmental Justice Advisory Council (NEJAC) - Ensuring Risk Reduction in Communities with Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts (Report)
This report contains recommendations to the EPA that are not enforceable but serve as a set of stakeholder comments for agency advisement and consideration.		Purpose was to propose/recommend to the EPA to (1) Initiate Community-Based, Collaborative, Multimedia, Risk Reduction Pilot Projects, (2) Develop Toolkit of Implementable Risk Reduction Actions, among others.
*Emphasis on enhancing public participation plan. 		NEJAC distinguishes between two common understandings of cumulative risks and impacts.:

(1 ) Environmental regulators and risk assessors see cumulative risks and impacts as a set of stressors (risks, impacts, and burdens) that have already been combined into an output using qualitative or quantitative valuation.
(2) Multimedia approaches: Impacted communities and the general public see cumulative risks or impacts to mean a collection of individual stressors that occur simultaneously and multiply (synthesized output that combines multiple stressors vs list of individual stressors that combine in some way). This report argues for this comprehensive, integrated, and unified approach towards multiple environmental hazards in overburdened communities.
*NEJAC argues that the term 'multiple stressors' should be used as a starting point, because there are contradictory understandings of what is meant by cumulative risks and impacts.

Report discusses the 2003 EPA Framework for Cumulative Risk Assessment definition of 'stressor' which encompasses socioeconomic stressors such as lack of health care to assess comprehensive risk. Report discusses aspects of this Framework that make it key to ensuring the goal of environmental justice for all communities and includes recommendations for implementing the EPA Cumulative Risk Assessment Framework, such as adopting a community-based, collaborative problem-solving model.

The report discusses four different types of vulnerability that may help to identify relevant indicators, including:
● Susceptibility/Sensitivity: Facing an increased likelihood of sustaining an adverse effect due to a life state (e.g., pregnant, young, old), an impaired immune system, or a pre-existing condition, such as asthma.
● Differential Exposure: A subpopulation can be more vulnerable because it is living or working near a source of pollution and is therefore exposed to a higher level of the pollutant than the general population. Social, economic, cultural factors, background/historical exposures within a subpopulation can contribute to vulnerability. (pg. 23)
● Differential preparedness: refers to subpopulations less able to withstand an environmental insult. This is linked to what kind of coping systems an individual, population, or community has (e.g. poor access to preventive health care , poverty, poor nutrition, or psycho-social stress may affect the strength of one’s coping system). (pg. 24)
● Differential ability to recover: Some subpopulations are more able to recover from an insult or stressor because they have more information about environmental risks, health, and disease; ready access to better medical and health care; early diagnosis of disease; or better nutrition. Related social factors can include income, employment status, access to insurance, discrimination in the health care system, language ability, the existence of social capital, and economic, racial, and linguistic isolation, which can be measured using a dissimilarity index.

In addition the "Pollution Burden Matrix for Community Characterization" (p.36) and the Multiple, Aggregate, and Cumulative Risks and Impacts in the Mississippi River Industrial Corridor Matrix (p.5) names the following indicator categories:
● Demographics
● Pollution sources
● Existing health problems and conditions
● Unique exposure pathways
● Social/cultural conditions
● Community capacity and infrastructure/social capital

Specifically, suggested indicators for pollution include: Total criteria air pollutant emissions (TCE), Total toxic air contaminants emissions (TTE), Population-weighted air emission burden (PWTE), Facility density -- High, Medium, and Low Emitting Sources (FDL, FD-M, FD-S), Total Length of Major Roadways (TLR), Number of Superfund sites (NSS) , Total release of toxic chemicals from Toxic Release Inventory (TRI) facilities, Presence/number of QOL-reducing entities (QOL), Acreage of Parks/Greenbelts (APG), Total cancer risk (TCR), Incidence of asthma (IOA), Drinking water quality (DWQ), and Number of leaking underground fuel storage tanks (LUST) (p. L-4)


Only pollution thresholds mentioned.
A report from the Environmental Law Institute, Opportunities for Advancing Environmental Justice: An Analysis of U.S. EPA Statutory Authorities, mentions a pollutant threshold in chapters 13 and 17.

● Carrying capacity analysis is proposed as a method to identify thresholds (as constraints on development) and provide mechanisms to monitor the incremental use of unused capacity.
● A proposed method for pollution thresholds is to use the Pollution Burden Matrix, and for each selected pollution indicator, the top 25% of values would be considered as having “high” burdens, the middle 50% would be “medium,” and the bottom 25% have “low” burdens. (p. L-3)
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U.S. EPA Agency Guidance2016EPA - Technical Guidance for Assessing Environmental Justice in Regulatory Analysis (Report)

This document identifies internal Agency policies and recommended procedures for EPA employees. The technical guidance presents key analytic principles and definitions, best practices and technical questions to frame the consideration of environmental justice in regulatory actions. It also includes
recommendations that are designed to enhance the consistency of our assessment of potential environmental-justice concerns across all regulatory actions.This document is not a rule or regulation but rather a guidance document subject to ad hoc application on the agency. 		Mapping and technical guidance on integrating potential EJ concerns into regulatory analyses.Cumulative impact is characterized by minority populations, low-income populations, or indigenous peoples that are impacted by exposure to multiple environmental hazards, such as contaminants from industrial facilities, landfills, and leaking underground tanks, transportation-related air pollution, poor housing, pesticides, and incompatible land uses (p. 18). The report notes that research and community stakeholders advocated for the EPA to consider exposure to multiple chemicals and other factors, as compared to using a single-chemical risk assessment approach.

To assess CI, the EPA's Framework for Cumulative Risk Assessment (CRA) (U.S. EPA, 2003) can be used, where CRA is defined as “evaluating an array of stressors (chemical and non-chemical) to characterize – quantitatively to the extent possible – human health and ecologic effects, taking into account factors such as vulnerability and background exposures.” Categories of stressors can include chemical, physical, environmental, social, and biological. 		Examples of possible social and environmental indicator categories include:
• Exposure to a stressor e.g. air emissions from several facilities in different industries, industrial facilities, landfills, and leaking underground tanks, transportation related air pollution, poor housing, pesticides, and incompatible land uses

• Non-chemical stressors, such as crime may exacerbate the effects of some chemical exposures e.g., changes in immunological response due to increased presence of stress hormones

• Potential risk-modifier is socioeconomic status, which does not by itself elicit a biological interaction, but has a complex association with health states

• Susceptibility to an environmental stressor as a determinant of the occurrence/severity of an adverse effect. Factors include: genetics, diet, nutritional status, pre-existing disease, psychological stress, co-exposure to similarly acting toxins or chemicals, and cumulative burden of disease resulting from exposure throughout life

• Environmental stressors. Encompass the range of chemical, physical, or biological agents, contaminants, or pollutants that may be subject to a regulatory action.

• Population groups of concern are determined through "exposure pathways" and "in some contexts" populations are analyzed by categories in combination – for example, low-income minority populations – or to evaluate diversity within the population groups of concern (e.g., life stage, gender), particularly when some individuals within population groups may be at greater risk for experiencing adverse effects. (p. 6)		CEQ’s Environmental Justice: Guidance Under the National Environmental Policy Act (1997) suggests analysts use “annual statistical poverty thresholds from the Census Bureau’s Current Population Reports, Series P-60 on Income and Poverty” to define low-income populations.

For purpose of E.O. 12898, the term minority means “individual(s) who are members of the following population groups: American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic origin; or Hispanic” as minority in an area affected by the policy action if “either:
• the minority population of the affected area exceeds 50% or
• the minority population% of the affected area is meaningfully greater than the minority population % in the general population or other appropriate unit of geographic analysis” (CEQ, 1997).
No specific threshold calculations mentioned. However, examples were provided for ID of measurements and technical assessment in data rich and data scarce environments. Models provided: "Spray Drift Modeling", "Risk Based, Multi Pollutant Modeling", and "Data Quality and Spatial Resolution in the Context of Air Regulations".

• Analytical considerations: Geographic and temporal scope, comparison group, spatial ID, aggregating effects, ID and analysis of potential hot spots, statistical significance and other considerations.

*Links provided in Text Box 5.1, page 24 for Guidance on Cumulative Risk Assessment
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Federal Interagency
Working Group on Environmental
Justice & NEPA Committee		Report2016Promising Practices For EJ Methodologies in NEPA Reviews
Compilation of methodologies gleaned from current agency practices identified by the NEPA Committee concerning the interface of environmental justice considerations through NEPA processes. It is not and should not be viewed as formal agency guidance, practices exposed here are not legally binding or create rights and benefits for any person. 		Intended as a way for agencies to compare and improve their methodologies for considering environmental justice now and in the future by applying methods established in federal NEPA practice (NEPA impacts permitting decisions), provides guidelines for 'meaningful engagement' of minority populations. Cumulative impacts result from chemical and non-chemical stressors, exposures from multiple
routes or sources, and factors that differentially affect exposure or toxicity to communities.		Where an impact from a proposed action initially appears to be identical to both the affected general population and the affected minority population and low-income population, additional factors should be taken into account. Some factors, such as unique exposure pathways, social determinants of health, or even community cohesion, can actually make an impact disproportionately high and adverse. Amplifying factors include (page 43):
• Proximity and exposure to chemicals and other stressors;
• Vulnerable populations;
• Unique exposure pathways;
• Multiple or cumulative impacts;
• Ability to participate in the decision-making process, including barriers to participation;
• Adequacy of physical infrastructure, such as roads, housing, water; and
• Non-chemical stressors, such as economic or social impacts.
Agencies should also consider factors that could amplify the impact on minority populations and low-income
populations of a proposed action ) such as: social determinants of health, community cohesion, cultural practices, existing health conditions		For low income populations poverty data that is used in the Census Bureau’ poverty thresholds and the U.S. Department of Health and Human Services’
poverty guidelines. Methods for calculating thresholds for low income populations and minority populations mentioned in the Threshold Calculation column. 		Identify minority populations through: Fifty Percent Analysis, Meaningfully Greater Analysis, or No-Threshold analysis (see pages 23-25 for specific steps.)
Identify low income populations through: Alternative Criteria analysis, Low-Income Threshold Criteria analysis (see pages 26-27 for specific steps)
Identifying appropriate comparison group or groups within the affected area can be helpful in determining disproportionality. (A comparison group is not the same as a “reference community” which is used to determine the percentage of minority or low income persons or households present in an affected area). The comparison group allows consideration of likely differences in pathways and exposures with the minority population or low-income population. More than one comparison group may be appropriate in some instances.
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U.S. House of Representatives Legislation2021, IntroducedH.R.2021 - Environmental Justice For All Act
To restore, reaffirm, and reconcile environmental justice and civil rights, and for other purposes. 		Requires consideration of cumulative impacts in permitting decisions, enhanced reporting and participation, and EJ Grants programs

EJ Grants programs entity eligibility: shall be a nonprofit, community-based organization that conducts activities, including providing medical and preventive health services, to reduce the disproportionate health impacts of environmental pollution in the EJ community at which the eligible entity proposes to conduct an activity that is the subject of the application process found in paragraph (3)

Specific definitions apply to the benefits section
• Transit to Trails Grant Program
• Access to Parks Outdoor Spaces and Public Recreation Opportunities		Cumulative Impacts means any exposure to a public health or environmental risk, or other effect occurring in a specific geographical area, including from an emission, discharge, or release including: environmental pollution released routinely; accidentally; or otherwise; and from any source, whether single or multiple; and as assessed based on the combined past, present, and reasonably foreseeable emissions and discharges affecting the geographical area; and evaluated taking into account sensitive populations and other factors that may heighten vulnerability to environmental pollution and associated health risks, including socioeconomic characteristics.”.Includes language to amend the Federal Water Pollution Control Act and the Clean Air Act, section 501 of the Clean Air Act (42 U.S.C. 7661), to include submission of a CI analysis for each census tract or Tribal census tract located in or adjacent to the area of the major source when applying for or renewing a permit, which considers the following indicators:
• Community demographics and locations of community exposure points such as schools, day care centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers;
• Air quality and the potential effect on that air quality of emissions of air pollutants (including pollutants listed under section 108 or 112) from the major source, including in combination with existing sources of pollutants;
• Potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the major source, including in combination with existing sources of pollutants; and
• public health and any potential effects on public health from the major source.		No specific thresholds mentioned.
No specific threshold calculations mentioned.
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U.S. Congress Proposed LegislationLegislation2021, IntroducedS.2630 - Environmental Justice Act of 2021
To require Federal agencies to address environmental justice, to require consideration of cumulative impacts in certain permitting decisions, and for other purposes. Reintroduces the S.2239 Environmental Justice Act of 2019.		Requires consideration of cumulative impacts in permitting decisions, enhanced reporting and participation, codifies the existing National Environmental Justice Advisory Council (NEJAC) and EJ Grant programs (Since these grant programs and NEJAC have never been Congressionally authorized, they are susceptible to being discontinued by future Administrations)Cumulative impacts means any exposure, public health or environmental risk, or other effect occurring in a specific geographical area, including from an emission or release, including environmental pollution released either routinely, accidentally; or otherwise; and from any source, whether single or multiple; and as assessed based on the combined past, present, and reasonably foreseeable emissions and discharges affecting the geographical area; and evaluated taking into account sensitive populations and socioeconomic factors, where applicable.Includes language to amend the Federal Water Pollution Control Act and the Clean Air Act, section 501 of the Clean Air Act (42 U.S.C. 7661), to include submission of a CI analysis for each census tract or Tribal census tract located in or adjacent to the area of the major source when applying for or renewing a permit, which considers the following indicators:
• Community demographics and locations of community exposure points such as schools, day care centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers;
• Air quality and the potential effect on that air quality of emissions of air pollutants (including pollutants listed under section 108 or 112) from the major source, including in combination with existing sources of pollutants;
• Potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the major source, including in combination with existing sources of pollutants; and
• public health and any potential effects on public health from the major source.		No specific thresholds mentioned.
No specific threshold calculations mentioned.
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Senate and House of Representatives of the United States of America in CongressLegislation2020, Not re-introducedH.R.8271 - Environmental Justice Legacy Pollution Cleanup Act of 2020

To provide supplemental appropriations for the cleanup of legacy pollution, including National Priority List sites, certain abandoned coal mining sites, and formerly used defense sites, to replace lead drinking water service lines, to provide grants under certain programs, and to amend the Clean Air Act to prohibit the issuance of new major source air pollution permits in overburdened communities, and for other purposes.		Amend the Clean Air Act to prohibit the issuance of new major source air pollution permits in overburdened communities. Supplemental appropriations were made available by the Treasury for The Department of Interior, Environmental Protection Agency, Department of Housing and Urban Development, Corps of Engineers, Department of Agriculture, and Indian Health Services which include environmental cleanup and remediation of threats to public health including remedial actions, capitalization grants, reduction projects, brownfields projects, and other grants and waivers .Cumulative Impacts are discussed within the framework of their impact on overburdened communities using Section 501 of the Clean Air Act (42 U.S.C. 7661) Suggests language to amend Clean Air Act so that 'no permit shall be granted by a permitting authority for a proposed major source that would be located in an overburdened census tract'. Overburdened census tract identified within the National Air Toxics Assessment published by the Administrator. Overburdened census tract = A greater than 100 in 1,000,000 total cancer risk; or has been determined to have an annual mean concentration of PM2.5 of greater than 8 micrograms per cubic meter, as determined over the most recent 3-year period for which data are available.No specific threshold calculations mentioned.
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U.S. Environmental Protection Agency
Tool/Methodology
2022EJScreen 2.0
(does not include a cumulative score)		Limited because its indicators only provide proxies for actual exposure or risk. Also, EJSCREEN does not include all environmental issues nor does it identify EJ communities. EJScreen 2.0 is not a CI tool. While it includes 12 environmental justice indexes and 1 demographic index, these indexes are not constructed by combining multiple environmental indicators. Despite these limitations, we include it here because it allows us to see various environmental and demographic indicators at a high spatial resolution.11 EJ indexes reflecting 12 environmental indicators. Each EJ index is a combination of environmental and demographic data. Socioeconomic indicators: % people of color, % low-income, unemployment, % in linguistic isolation, % less than high school education, % under age 5, % over age 64, demographic index. Environmental indicators: PM2.5, ozone (level in air), diesel PM (level in air), air toxics respiratory hazard index, traffic proximity and volume, lead paint (% pre-1960 housing), Superfund proximity, Risk Management Plan (RMP) facility proximity, hazardous waste proximity, underground storage tanks (UST) and leaking UST, wastewater discharges indicator. Climate indicators: wildfire hazard potential, drought, coastal flood hazard, estimated 100-year floodplains, sea level rise. Health indicators: low life expectancy, heart disease, asthma. Critical service gaps: broadband gaps, food desert, medically underserved. See map description for more details. No specific thresholds mentioned.EJ Index =

(The Environmental Indicator)
X (Demographic Index for Block Group – Demographic Index for US)
X (Population count for Block Group)
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U.S. House of Representatives Legislation2022, IntroducedH.R 6548 Justice in Power Plant Permitting Act
To establish new renewable energy Federal purchase requirements, support the equitable transition to clean energy power generation, and require cumulative impact assessments for fossil fuel-fired power plant permitting, and for other purposes.		•Requires a Cumulative Impacts Analysis for any permit or renewal of a permit for a fossil fuel-fired power plant that is, or is proposed to be, a major source of air pollution, or is within one mile of another fossil fuel-fired power plant or major source of air pollution. "A permitting authority shall not grant a permit or renewal unless the cumulative impacts analysis under paragraph (1) indicates a reasonable certainty that the permit or renewal will result in no harm to the health of the general population, or to any potentially exposed or susceptible subpopulation, including environmental justice communities, of a census block group or Tribal census block group .”.

•Eligibility requirements for governments to receive 'Just Energy Transition' funds include: projects that (1) supported by residents of impacted EJ communities. (2) does not rely on fuels or technologies that create environmental harm, including greenhouse gas emissions, or contribute to health burdens on environmental justice communities and impacted communities; and (3) results in a quantifiable improvement to the health and well-being of residents of impacted EJ communities and other impacted communities as measured by the Advisory Council. Programs supported by residents of EJ communities that 'result in a quantifiable improvement to the health and well-being of residents of environmental justice communities and other impacted communities, as measured by the Advisory Committee' are the second eligibility category. These can include programs that (1) apportion funds to individuals who face or are expected to face burdensome energy costs and (2) support ratepayer advocacy or intervenor compensation opportunities to lower energy costs and reduce pollution faced by residents of impacted environmental justice communities and other impacted communities.		Cumulative impacts means any exposure to a public health, environmental, or climate risk, or other effect occurring in a specific geographical area, including from an emission, discharge, or release, including (i) environmental pollution released—(I) routinely, accidentally, or otherwise; and (II) from any source, whether single or multiple; and (ii) as assessed based on the combined past, present, and reasonably foreseeable emissions and discharges affecting the geographical area; and evaluated taking into account sensitive populations and other factors that may heighten vulnerability to environmental pollution and associated health risks, including socioeconomic characteristics.CI Analysis should consider:
(1) community demographics and locations of community exposure points, including schools, day care centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers;
(2) air quality and any potential effects on that air quality of emissions of air pollutants from the fossil fuel-fired power plant proposed to be permitted, including in combination with existing sources of pollutants
(3) the potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the fossil fuel-fired power plant proposed to be permitted, including in combination with existing sources of pollutants;
(4) public health and any potential effects on public health from the emissions of pollutants from the fossil fuel-fired power plant proposed to be permitted, including in combination with existing sources of pollutants;
(5) the potential adverse impacts on health and well-being of residents of impacted environmental justice communities and populations with heightened vulnerability to pollution and associated health risks, which may be due to socioeconomic characteristics including housing insecurity, barriers to receive quality healthcare or afford health insurance, energy cost burdens that limit use of heat and air conditioning, long-term impacts of siting polluting sources in environmental justice communities, and public disinvestment and redlining;
(6) the potential effects of any proposed action on environmental justice communities, including if the action causes or exacerbates a disproportionate or inequitable burden on the environmental justice community, and
(7) shall be based on an analysis of data that accurately describes the potential cumulative impacts of the proposed action, and may include a supplemental qualitative analysis.		No specific thresholds mentioned.
No specific threshold calculations mentioned.
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U.S. EPA Report2022, draftCumulative Impacts: Recommendations for ORD Research
White paper to inform the EPA Office of Research and Development's (ORD) FY23-26 Strategic Research Action Plans. The Cumulative Impacts Scoping Workgroup was tasked to more fully understand how to grow ORD’s existing cumulative impact research across the six National Research Program Partners’ needs in the context of ORD’s FY23-FY26 research planning process. The Workgroup synthesized in this report inputs from multiple engagement events with ORD partners both internal and external to the Agency to identify research gaps and barriers to conducting and translating the research, which formed the basis for the Workgroup’s recommendations. 		Provides definitions, research gaps and barriers to implementing cumulative impact research at EPA, and recommendations for advancing cumulative impact research going forward within ORD’s FY23-26 Strategic Research Action Plan. Cumulative Impacts refers to the total burden – positive, neutral, or negative – from chemical and
non-chemical stressors and their interactions that affect the health, well-being, and quality of life of an individual, community, or population at a given point in time or over a period of time. Cumulative impacts include contemporary exposures in various environments where individuals spend time and past exposures that have lingering effects. Total burden encompasses direct health effects and indirect effects to people through impacts on resources and the environment that affect human health and well-being. Cumulative impacts provide context for characterizing the potential state of vulnerability or resilience of the community, i.e., their ability to withstand or recover from additional exposures under consideration.

Cumulative Impact Assessment is the process of accounting for cumulative impacts in the context of problem identification and decision-making. It requires consideration and characterization of total exposures to both chemical and non-chemical stressors, as well as the interactions of those stressors, over time across the affected population. Cumulative impact assessment explores how stressors from the built, natural, and social environments affect people, potentially causing or exacerbating adverse outcomes. It also accounts for health-mitigating factors or solutions aimed at improving health and well-being. The posited elements of a cumulative impact assessment include: community role throughout the assessment, and in particular, identifying problems and potential intervention decision points to improve community health and well-being; combined impacts across multiple chemical and non-chemical stressors; multiple sources of stressors from the built, natural, and social environments; multiple exposure pathways across media; community vulnerability; past exposures, especially during vulnerable ages or life stages; individual variability and behaviors; health and well- being benefits/mitigating factors; and evaluation of potential interventions that reduce cumulative impacts and improve community health and well-being		Recommendations of factors to consider/indicator categories for Cumulative Impact Assessment:
a. Combine quantitative and qualitative data on stressors to inform a cumulative impact assessment.
b. Characterize the cumulative impacts of multiple decisions at once (e.g., permitting multiple facilities in an area).
c. Develop and combine stressors/indicators for one or more health and well-being outcomes that provide relative or absolute measures of exposure or impact.
d. Standardize (in absolute and relative ways) identification and characterization of disproportionately impacted and overburdened communities.
e. Use biomarker identification for exposures to multiple chemical or non-chemical stressors.
f. Integrate multiple streams of data, including data from community and citizen science and traditional ecological knowledge.
g. Characterize health inequities within and across communities and at varying spatial scales.
h. Characterize health-benefiting assets of a community, such as measuring the benefits of green space.
i. Identify and account for historical stressor exposures in cumulative impact assessments.
j. Evaluate the cumulative impacts/benefits of various types of interventions		No specific thresholds mentioned.
No specific threshold calculations mentioned in report. Yet, the following is mentioned regarding methodologies: The Health and Environmental Risk Assessment (HERA) Research Program has predominantly focused on single chemical assessments and a smaller number of assessments of chemical mixtures. HERA assessments of chemical mixtures such as dioxins, total petroleum hydrocarbons, and polycyclic aromatic hydrocarbons have advanced the application of chemical mixture approaches, including application of toxicity equivalence factors, relative potency factors, and hazard indexes (EPA, 1993, 2009, 2010). As the need for evaluating multimedia exposures that incorporate chemical and non- chemical stressor interactions has increased, the HERA program has focused research on cumulative risk assessment methods and practice (Genres et al., 2016).
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Office of the President of the United StatesExecutive Order2023, issuedExecutive Order (EO) 14096 of 2023, Revitalizing Our Nation's Commitment to Environmental Justice for All

The Executive Order embeds cumulative impacts into how it defines environmental justice, as follows: "'Environmental justice' means the just treatment and meaningful involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision-making and other Federal activities that affect human health and the environment so that people (i) are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers..." (Sec. 2)		The EO establishes a "government-wide approach to environmental justice". This approach explicitly includes addressing cumulative impacts, as set out in Section 3: "Each agency shall, as appropriate and consistent with applicable law,

(i) identify, analyze, and address disproportionate and adverse human health and environmental effects (including risks) and hazards of Federal activities, including those related to climate change and cumulative impacts of environmental and other burdens on communities with environmental justice concerns;

(ii) evaluate relevant legal authorities and, as available and appropriate, take steps to address disproportionate and adverse human health and environmental effects (including risks) and hazards unrelated to Federal activities, including those related to climate change and cumulative impacts of environmental and other burdens on communities with environmental justice concerns; ....

(vi) evaluate relevant legal authorities and, where available and appropriate, consider adopting or requiring measures to avoid, minimize, or mitigate disproportionate and adverse human health and environmental effects (including risks) and hazards of Federal activities on communities with environmental justice concerns, to the maximum extent practicable, and to address any contribution of such Federal activities to adverse effects — including cumulative impacts of environmental and other burdens — already experienced by such communities..."

In addition, the EO states that environmental reviews under the National Environmental Policy Act (NEPA) should "analyze direct, indirect, and cumulative effects of Federal actions on communities with environmental justice concerns." (Sec. 3.ix.A)		There is no explicit definition of "cumulative impact" in the EO, however in Section 1, which describes the EO's purpose, there is some language from which a definition can be deduced: "Communities with environmental justice concerns experience disproportionate and adverse human health or environmental burdens. These burdens arise from a number of causes, including inequitable access to clean water, clean air, natural places, and resources for other basic human health and environmental needs; the concentration of pollution, hazardous waste, and toxic exposures; and underinvestment in affordable housing that is safe and healthy and in basic infrastructure and services to support such housing, including safe drinking water and effective sewage management. The cumulative impacts of exposure to those types of burdens and other stressors, including those related to climate change and the environment, further disadvantage communities with environmental justice concerns."

Similarly, in Section 5 which discusses the need for an EJ Science, Data, and Research Plan, it states that the plan should yield recommendations to agencies on "analyzing cumulative impacts (including risks) from multiple sources, pollutants or chemicals, and exposure pathways, and accounting for non-chemical stressors and current and anticipated climate change." (Sec. 5.iii.F.6)		N/AN/AN/A
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