1. Improve the methodology used to identify “disadvantaged” communities
Revise the Climate and Economic Justice Screening Tool to account for race and current and projected climate impacts, and to more effectively prioritize communities with cumulative burdens.
The Climate and Economic Justice Screening Tool was created to help federal agencies identify “disadvantaged” communities to prioritize for Justice40 investments. As many of the responses to the CEQ’s request for information on the tool noted, the present version of the Climate and Economic Justice Screening Tool (which is still in beta) does not account for race or current or projected climate impacts. But race is one of the strongest predictors of exposure to environmental hazards, and prioritizing frontline communities is key to achieving Justice40’s environmental justice and climate goals. The tool’s binary determination of “disadvantage” also limits its ability to prioritize communities dealing with multiple burdens, including exposure to environmental hazards, public health burdens, and economic hardships, and may result in communities with comparatively fewer burdens receiving funding ahead of communities with comparatively higher burdens.
To ensure that limited federal resources are channeled to communities of color, frontline communities, and communities bearing large cumulative burdens, the Climate and Economic Justice Screening Tool should be revised for the next iteration to include race and climate impacts—both current and projected—including vulnerability to extreme weather events, flooding, drought, and wildfires. The next iteration should also assess cumulative burdens and score communities based on these burdens to allow for more effective prioritization. The federal government can look to well-established state tools, such as California’s CalEnviroScreen, for examples of how to implement such a scoring method.
Establish a fair and expedited process for communities to petition their designations.
The administration has noted that once final implementation guidance for the Justice40 Initiative is issued, the Climate and Economic Justice Screening Tool’s methodology for identifying “disadvantaged” communities will be used by all federal agencies. Although this can be an important means of enforcing consistency across federal agencies, the tool is currently unable to capture the full range of environmental, climate, economic, and health burdens that communities across the country face at the level of granularity needed. This challenge exists for several reasons, including because the relevant data does not exist, because the data is not captured for all communities nationwide, or because the burdens are difficult to quantify. This is especially true for rural and tribal communities, who face significant environmental burdens that may not be captured in datasets available at a national level.
As the EPA acknowledges regarding its own tool, EJScreen, “a screening tool cannot capture all the relevant issues that should be considered” and “should be supplemented with additional information and local knowledge wherever appropriate.” To ensure that communities that are disproportionately burdened are not inadvertently left behind because of data gaps, the administration should direct federal agencies to provide opportunities for communities who believe they are incorrectly classified to petition their designations. The administration should also establish a fair and expedited process to evaluate these petitions to ensure that decisions are made in a consistent manner across agencies.