Uranium mining legacies across the Colorado Plateau have left Indigenous communities living, working, and carrying out ceremonial and spiritual practices  amid long‑lived contamination. However, these harms remain systematically underrepresented in federal cleanup priorities. The U.S. Environmental Protection Agency’s (EPA) Hazard Ranking System (HRS), which governs listing under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), relies heavily on quantifiable exposure pathways and population metrics, while providing limited space to account for cumulative, intergenerational, and culturally specific risks on Indigenous lands. In uranium‑impacted landscapes where subsistence use, ceremonial practice, and close ties to land and water shape daily life, this narrow scoring framework effectively discounts ongoing hazards.

This project, drawn from my law review research, critiques the current HRS structure as applied to uranium‑contaminated Indigenous lands on the Colorado Plateau and highlights how data gaps in bioaccumulation and food‑web pathways depress site scores. The analysis combines statutory and regulatory interpretation with review of site documentation and available environmental data to show how missing or sparse information on uranium uptake in plants, livestock, and wildlife creates an illusion of lower risk, even where community testimony and local knowledge indicate pervasive contamination. In this context, “data gaps” are not neutral; they become structural barriers to listing and remediation.

I propose a set of modifications to the HRS that would better reflect Indigenous exposure pathways and cultural significance, while remaining grounded in CERCLA’s existing authority. These include incorporating Indigenous spatial and subsistence use data, elevating pathways likely to be affected by bioaccumulation even when formal datasets are thin and explicitly recognizing the role of sacred and ceremonial sites in risk characterization. For the “Mining Legacies and Environmental Remediation in the Southwest” session, this presentation will translate these legal‑policy arguments into concrete implications for geoscientists and agency scientists. It is aimed in part at colleagues in agencies such as USGS and EPA, who are uniquely positioned to generate the bioaccumulation and ecosystem‑level data needed to align CERCLA implementation with both environmental justice and long‑term ecological health on the Colorado Plateau.