Billions of dollars and more than 30 EJ screening tools - How are Justice40 opportunities rolling out? Let’s find out!
EPIC is launching new research with Beech Hill Research and Climate XChange to analyze how states are mobilizing toward Justice40 and EJ goals in Infrastructure and IRA funding. In Phase 1, we’re following the state workflow to consider and involve priority communities.
Read below for more about the project, and what you can expect from us in the coming months!
Two years after EO 14008 and Justice40 and “hundreds of Federal programs, representing billions of dollars in annual investment…are being reimagined and transformed to maximize benefits to disadvantaged communities”.
Whether you call it a “swirl” or “flood” or “deluge” or “once-in-a-generation” funding, we’re mobilized. Federal agencies have incorporated Equity and Environmental Justice into new and existing federal programs. Consultants and lawyers are interpreting them. State and local agencies are monitoring funding opportunities, planning and screening projects, and writing grant applications. Environmental Justice advocates and nonprofits are working feverishly to bridge the gaps between communities and funding opportunities. My email, LinkedIn, news feeds and Slack channels are awash in new guides, webinars, charts, maps/tools, and news about Infrastructure and IRA opportunities.
It’s great, it’s happening! How do we know it’s working?
While one test is whether 40% of the benefits of investments in J40 covered programs serve priority communities, quantitative indicators won’t come for a while. Yes, we need immediate action to track the flow of funds geographically, and set up dashboards showing where projects/funding is awarded…a topic for another post!
Priority Communities:
Historically underinvested in, underserved, marginalized, overburdened and disadvantaged communities.
These terms are often used interchangably to describe people and places. We use priority communities.
So, what do we have today to see how things are working?
I came to know Jessie Mahr and EPIC through the US Digital Services (USDS) Open Source group, which formed in February 2021 and held open monthly meetings with anyone interested to talk about environmental justice data and mapping. We found common interest in the development, data quality and validity of CEJST, and after its launch, we are all curious if and how it’s being used. While it’s officially designed to guide federal investments, it is available for state and local governments, nonprofits and communities to see information about burdens that communities experience.
In parallel with CEJST, some federal agencies developed their own tailored DAC screening tools – e.g., DOT Equitable Transportation Index; DOE Disadvantaged Communities; CDC Environmental Justice Index; FEMA National Risk Index and at least 30 states and localities have their own EJ or DAC criteria and maps. Many program guidelines issued in 2022 allow multiple methods to identify priority communities, including federal screening tools or other criteria…a “choose your own adventure”, giving discretion to applicants. On January 27, 2023, CEQ issued updated guidance for federal agencies transition to CEJST for programs without pre-existing statutory definitions (such as, for example, Drinking Water State Revolving Funds).
There are more than 140 Justice40 covered programs, including new and established programs, formula funding, competitive and discretionary grants. Guidelines for identifying, considering and involving priority communities are encoded in legislation, program/funding notices, and equity action plans. We can see what’s written but how does that translate in implementation? This led us to wonder:
Given all of the guidelines, maps/tools and resources available, what are decision-makers actually using? What are questions or gaps?
Over the next few months, I am partnering with EPIC and Climate XChange to learn from state agency staff – who administer J40 covered programs – about how they are navigating federal guidelines, what resources they are using, what’s working and what they need. We’re starting with state agency staff because they play a key role in planning and allocating formula funds, and facilitating local projects.
Phase 1 focus on state agency perspective:
12 exploratory interviews
Open workshop to groundtruth findings across other states/programs
Co-develop priorities and potential actions
This isn’t a test of whether state administrators are doing it “right” - but rather, how the ecosystem of guidance, resources, maps/tools, technical assistance, capacity-building, etc is effectively supporting state action. With a passenger seat view of what staff are experiencing we can learn:
What’s working - Things to scale, expand or replicate
Barriers they see - Things that federal agencies, partners, nonprofits and others can address.
…toward considering, involving and prioritizing communities in the distribution of hundreds of billions of dollars.
How did we get here?
These questions first sprung from the narrow question of whether state and local agencies are using screening tools and maps like the Climate and Economic Justice Screening Tool (CEJST) or others to identify priority communities. Identifying specific communities is just one part of the puzzle, so we broadened the interviews.
This spring, we will invite program managers to show/tell us what they’re working on – the guidelines/deadlines they are facing; how they are juggling the equity and EJ goals/intent with other constraints; what they see as questions, challenges or gaps to fulfilling the promise of J40. Through our work with states and feedback from the EJ community, advocates, nonprofits and technical assistance providers we’re heard many challenges, and qualitative research will be a chance to ground-truth this within the context of specific federal funding opportunities that state administrators influence.
What can we learn from what’s working (or not) among states to prioritize if/where…
additional or outside capacity/assistance is needed?
data/technology or other resources are needed?
federal action or guidance is needed?
What are we doing?
In Phase 1 of this research we’re facilitating 75-90 minute exploratory interviews focusing on 3-4 programs in 3-4 states – including at least two EPA programs and one DOT program:
EPA Drinking Water State Revolving Fund including Lead Service Line Replacement
EPA Clean Water State Revolving Funds such as Nonpoint Source Pollution (NPS 319)
DOT resilience programs such as PROTECT
(TBD) Air quality program such as EPA Carbon Reduction Pollution Grants, DOT Carbon Reduction Program or CMAQ
You may see emails from us or partners to connect with state program staff writing plans for these programs. Thank you to all of our partners thus far who have offered to make connections!
We’d like to offer financial compensation for people’s time and effort to speak with us, though this is not feasible for state employees. In return, we can share any resources or contacts we know of that might address questions that arose in the call. And, following all 12 interviews we will host an open workshop among research participants and partners to share key themes, groundtruth them (is what we heard in 12 interviews consistent with what you’re hearing/experiencing?), and together, prioritize actions or resources that could support state administrators.
…and with answers…more questions!
Undoubtedly these open-ended and exploratory discussions will point toward other questions, groups or stakeholders. We see state-focused interviews as Phase 1 of a multi-perspective research on the path to Justice40, and look forward to the ideas and questions that participants and partners will raise!