Between January 2020 and March 2023, U.S. electronic cigarette sales grew 43%, from 15.6 million devices per month to 22.4 million devices. During this time frame, the portion of sales comprising disposable devices grew from 4 million to 11.9 million per month. The impact upon the environment has been largely overlooked by policymakers.

This Article calls on the Council on Environmental Quality (CEQ) to issue guidance clarifying that concurrent decommissioning is a “connected action” under the National Environmental Policy Act for relocation, managed retreat, and protect-in-place projects aimed at replacing infrastructure in environmentally threatened Alaska Native communities.