Robin Morris Collin
Former Senior Advisor to the Administrator for Environmental Justice, EPA; Professor Emerita, Willamette University School of Law
A cumulative impacts approach to environmental protection can lead to better policies and better outcomes. But cumulative impacts analysis is not the destination—it’s the way we get from evidence to effective action. If we want cumulative impacts to change conditions on the ground, we need to change the way we talk about them—and who we talk to
The Union of Concerned Scientists recently released Unfinished Business, a report analyzing public comments submitted to the U.S. Environmental Protection Agency on its 2024 “Interim Framework for Advancing Consideration of Cumulative Impacts.” I participated in this work and co-authored the report
One lesson from that process stands out: the conversation about cumulative impacts needs to reach beyond the communities and the professionals who have traditionally been part of it
Two constituencies, in particular, deserve much more attention: labor and public health practitioners. Workers—including unionized and blue-collar workers—experience cumulative exposures in their workplaces, homes, and communities. Public health practitioners, from policy implementers to doulas, see how those exposures translate into health consequences across a person’s life
Bringing these perspectives into the conversation is not simply about expanding the list of stakeholders. It is about expanding what we are able to see—and, ultimately, what we are able to do
Cumulative impacts helps us see the whole picture
Cumulative impacts assessment is a way to understand what is happening to people in a particular place over time by looking at multiplevironmental, health, economic, and social conditions one at a time
Members of a community may be dealing with air pollution, flooding, heavy truck traffic, inadequate green space, housing instability, displacement, and human health concerns all at the same time . A worker may encounter exposures on the job that are compounded by conditions at home and in the neighborhood where they live
Through a cumulative impacts approach, we can see these conditions together, and how they influence and compound each other
That fuller picture helps us answer an important set of questions:
What needs to be done differently? Who needs to act? And how can their actions reinforce one another?
Changing conditions rarely depends on a single agency, program, or decision. It requires a constellation of partners—regulators, community organizations, elected and Tribal officials, public health practitioners, scientists, planners, environmental and justice organizations, labor, industry, philanthropy, academics, and others—to act within their respective authorities while working toward shared outcomes
In this sense, cumulative impacts is not simply an assessment tool
It can be a roadmap for coordinated action
From a government-centered model to a constellation of partners
Much of our policy infrastructure remains government-centered. Agencies identify problems, develop programs, issue permits, enforce requirements, and allocate reons that shape people’s lives cannot be changed by government alone. Effective implementation requires a broader constellation of actors, each bringing different knowledge, authority, re
The challenge, therefore, is not simply to explain cumulative impacts to these constituencies. It is to frame this approach in language that connects with what each constituency is trying to accomplish
- For regulators, the entry point may be better decisions and better implementation of existing legal and policy mandates: Cumulative impacts gives agencies a practical way to translate existing mandates into better-informed decisions.
- For community organizers, the entry point is power, lived experience, and accountability: Cumulative impacts makes visible what communities already know—harms rarely occur one at a time.
- For community members, CI can give them a way to intervene in more specific ways. It says: Your community’s experience is evidence, and it matters.
- For elected officials, CI can help connect seemingly separate issues and make public investments and rules more strategic.
- For Tribal governments, cumulative impacts assessment can support the protection of people, places, resources, and ways of life—but the framework must be grounded in Tribal authority, knowledge, and priorities, rather than treating Tribes simply as another stakeholder.
- For scientists and technical experts, CI provides a framework for integrating quantitative, qualitative, spatial, temporal, and community-generated evidence.
- For public health practitioners, the entry point is prevention and population health: Health is shaped by exposures that accumulate across places and over time.
- For planners and local governments, CI can illuminate how land-use and infrastructure decisions interact—and help avoid adding new burdens to places already carrying disproportionate ones.
- And for industry and regulated entities, understanding cumulative conditions early can improve project planning, reduce conflict, and create a clearer basis for identifying feasible mitigation and community benefits.
Different entry points. Different language
But one shared objective: better decisions that lead to better outcomes
Without workers, nothing works
One constituency deserves particular attention: workers and organized labor
Workers see conditions in ways that may escape the notice of other decision makers. They experience exposures at work, but those exposures do not stop at the workplace gate. Working conditions interact with housing, transportation, environmental exposures, wages, scheduling, job security, and conditions in the communities where workers live
Cumulative impacts provide a framework for seeing those connections
That means asking questions such as:
- How do specific workplace exposures interact with broader environmental exposures?
- How do job quality and working conditions affect overall health and resilience?
- How will changes in energy, transportation, climate, and industrial systems affect workers as well as communities?
- Do workers have a meaningful voice in decisions about new technologies, facilities, closures, redevelopment, and environmental protections?
- When an industry changes, what happens to the workers and communities that depend on it?
This is where cumulative impacts connects directly to the idea of a just transition
We should not ask only whether an industry or facility is environmentally harmful. We should also ask: What happens to workers and communities when we change it—and who participates in designing what comes next?
Workers experience cumulative impacts, too
Protecting the environment and protecting workers are not competing goals.They are both part of building healthy communities and good jobs
Public health puts people in the picture
Public health offers another essential entry point. Environmental conditions become health conditions. Exposures accumulate across places and over time, and the consequences may appear differently across populations and across a person’s life course. A cumulative impacts approach can help public health practitioners connect those dots and identify opportunities for prevention
This matters because public policy is one of the few mechanisms we have for changing the underlying conditions that shape health at a population level. People with greater reisks—to move, purchase cleaner technologies, access better housing, or obtain specialized services. But individual strategies cannot substitute for effective public policy
Changing the conditions that produce harm requires collective action and implemented policy. And while those harms may fall most quickly and most severely on some communities, the underlying conditions ultimately affect all of us
From assessment to an integrated package of action
This is why I believe we need to shift the conversation about cumulative impacts from “What is CI?” to “How do we use CI?”
CI should not end with an assessment, a map, a report, or another layer of analysis
The real test is what happens next
Suppose an assessment identifies a community experiencing a high and disproportionate burden. The response might include:
- restrictions on new industrial sources;
- zero-emission truck corridors;
- lead abatement and asthma prevention programs;
- expansion of urban tree canopy;
- preservation of affordable housing;
- local hiring and green workforce development; and
- a community oversight board.
These actions may sit in different policy domains and may require different decision makers and show why they must be part of the same strategy
That is the opportunity. Cumulative impacts can become a bridge among environmental protection, public health, housing, infrastructure, economic development, workforce policy, and community power. It can help us move from isolated interventions to integrated strategies. And it can help us move from identifying burdens to actually changing the conditions that produce them
The next step is implementation
The future of cumulative impacts work should not be defined solely by how sophisticated our assessments become
It should be defined by whether those assessments help communities, governments, workers, Tribes, public health practitioners, and other partners make different decisions—and whether those decisions produce measurable improvements in people’s lives
That requires a broader conversation, a broader set of partners, and language that speaks to what each partner can contribute
Cumulative impacts gives us a way to see the whole picture. The challenge now is to use that picture to act
