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  • Overview
  • Recommendations
  • 1. Improve identification methodology
  • 2. Meaningfully engage communities
  • 3. Revise funding structure
  • 4. Build community capacity
  • 5. Refine implementation guidance
  • 6. Create accountability mechanisms
  • 7. Enhance government coordination
  • 8. Expand Justice40’s reach
  • Resources
  • Acknowledgments
  • Research Report Positioning Justice40 for Success
    A Policy and Practice Playbook
    Samantha Fu, Anna Shipp


    Note: This publication was updated on November 29, 2022. Under recommendation 3, the concept of funding was added to the second sub-recommendation: “Allocate appropriate time and funding for planning and community engagement.”

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    The Justice40 Initiative

    Created through President Biden’s Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” Justice40 is an initiative of the federal government that aims to deliver 40 percent of the benefits of certain federal investments to communities identified as “disadvantaged” based on factors such as exposure to pollution and other environmental hazards, vulnerability to the impacts of climate change, and levels of socioeconomic distress.1 Justice40 applies to federal programs that make covered investments (including grants, loans, and direct payments) in the following seven areas: climate change, clean energy and energy efficiency, clean transportation, affordable and sustainable housing, remediation and reduction of legacy pollution, critical clean water and waste infrastructure, and training and workforce development related to any of the preceding areas.

    The White House states that the Justice40 Initiative “seeks to address the intersectionality of underinvestment, environmental injustice, and the climate crisis.” These efforts to concurrently elevate equity, climate action, and economic health as core principles guiding the federal government’s work represent an unprecedented acknowledgement of the increasingly evident interdependence of these major issues, and mark a fundamental change in how the federal government works to address ongoing and historical economic, racial, and environmental injustices as well as the climate crisis. Advocates see in Justice40 a historic opportunity to generate transformative change in marginalized, overburdened, and underserved communities. However, they also caution that achieving Justice40's ambitious goals hinges on how the initiative is implemented.

    Justice40 Timeline

    Justice40 timeline graphic

    Positioning Justice40 for Success

    The Urban Institute’s Equity in Place project, which is part of the Shared Prosperity Partnership, seeks to support the ability of the Justice40 Initiative to meet its goals and deliver benefits to communities carrying the greatest environmental, public health, and economic burdens. Our work began in early 2022 with a scan of the initiative’s official guidance and supplemental reports to build an understanding of Justice40’s framework, vision, and goals. We then conducted scoping interviews with representatives from the US Environmental Protection Agency (EPA), the Pennsylvania Department of Environmental Protection, the Urban Waters Federal Partnership, and nonprofit organizations across the country engaged in policy, capacity-building, and technical-assistance work with some of the communities that Justice40 intends to benefit. We also attended virtual public meetings hosted by the White House Environmental Justice Advisory Council.

    Following the scoping interviews, which were conducted in the first half of 2022, we held two convenings with leaders from many of the nonprofit environmental justice organizations we interviewed, as well as a few others. The first convening focused on validating and refining our synthesis of insights gathered from the interviews; the second focused on understanding leaders’ visions for Justice40 and on articulating the principles and specific actions that, in their view, were needed to make the vision a reality.

    The nonprofit leaders we spoke with expressed optimism in the paradigm shift undergirding the Justice40 framework, and consistently indicated their belief that Justice40 offers a promising opportunity to pursue new and different federal investments that better meet community needs, reduce and repair harms, and otherwise address the legacy of investments that have perpetuated—and continue to perpetuate—racial and environmental injustice. They also expressed substantive concerns about the ability of the initiative to deliver benefits for the communities they serve. We synthesized their viewpoints into five themes, cutting across both the opportunities the initiative presents and the challenges that may stymie its success, in an initial framing paper, Advancing Equity, Climate Action, and Economic Health in Communities: Challenges and Opportunities for the Justice40 Initiative, published in October 2022. A summary of each theme is reproduced below.

    1. Identifying, engaging, and prioritizing communities. Improvements in how communities are identified, engaged, and prioritized would enable Justice40 to simultaneously advance equity, climate action, and economic health.
    2. Program design and funding structure. Changes to program design and funding structure could help make Justice40 funding more accessible to the “disadvantaged” communities it is intended to benefit.
    3. Defining and measuring benefits. A clear definition of “benefits” and how they are measured would help align Justice40’s intent with its impact and support meaningful evaluation of investment outcomes against Justice40’s goals.
    4. Oversight and accountability. A robust, transparent, and equitable accountability structure would help ensure that Justice40 investments at all levels of government deliver the promised benefits to “disadvantaged” communities.
    5. Whole-of-government approach. Increased coordination and collaboration, both horizontally between federal agencies and vertically between federal, state, and local governments could help expand Justice40’s impact and scope.

    In this playbook, we turn to the second objective of our work: providing recommendations to federal policymakers and agencies on ways to ensure the successful implementation of Justice40. Following the release of the framing paper, we conducted a series of calls with federal agencies involved in Justice40’s implementation, including the Council on Environmental Quality (CEQ), the Department of Housing and Urban Development, and the Economic Development Administration, to preview our findings and learn about their ongoing work. The recommendations that follow are grounded in the realities of this ongoing work and informed by the knowledge, actions, and aspirations of the more than 30 national, regional, and local nongovernmental stakeholders with whom we spoke.

    Questions and Feedback

    For questions or feedback about these recommendations, including proposed additions, please reach out to our team at [email protected].




    1 We use the term “disadvantaged” to describe the communities referenced throughout this playbook because it is the term used by the federal government in its initial announcement of Justice40 and all subsequent guidance and communication. However, we recognize that such deficit-based language carries negative connotations and can result in stigma of the very groups that the initiative is aiming to serve. We encourage the federal government and its partners to consider using more positive terms to identify communities to be prioritized for Justice40 investments, such as “priority” communities, and to otherwise consult members of the communities in question on their preferred language, with the recognition that there may not be a single term that resonates with all of the communities that Justice40 intends to serve.