WE ACT Addresses Inequity for BIPOC Communities in Justice40 Initiative Memo

(Photo: Climate justice banner hangs across the building. Credit: Canva Pro Stock.)

In a memo to the White House Council on Environmental Quality (CEQ), WE ACT for Environmental Justice called out a racially disproportionate increase in communities added to the 1.0 version of the Climate and Economic Justice Screening Tool (CEJST). The screening tool, a searchable geospatial map of U.S. states and territories, will help federal agencies identify disadvantaged communities that are marginalized and overburdened by pollution.

This information is crucial to fulfilling the promise of the Justice40 Initiative, a commitment to environmental justice made by the Biden administration. According to the EPA, the definition of environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the environment. In particular, fair treatment requires that no group of people should bear a disproportionate share of the negative environmental consequences of commercial or governmental actions.

The Justice40 initiative was founded to ensure fair treatment, requiring that at least 40% of certain federal investments mandated by the Biden administration’s Executive Order 14008 would flow to disadvantaged communities. The investments will focus on clean energy and energy efficiency; clean transit; affordable and sustainable housing; training and workforce development; the remediation and reduction of legacy pollution; and the development of critical clean water infrastructure. In addition, all Justice40 programs must meaningfully involve community members in determining the program’s benefits.

The mapping tool (CEJST) is meant to be an unbiased source of the disadvantaged communities most in need of the Justice40 programs. Yet some advocacy groups, such as the Conservation Law Foundation (CLF), argue that the tool skews the data by failing to factor in race.

“By adjusting the tool’s methodology, we’re not getting an accurate picture of impacts that harm Black, Latino, and Indigenous populations,” said Dana Johnson, WE ACT Senior Director of Strategy and Federal Policy. “If the cumulative impact is not considered, they are diluting the potential financial benefit to the communities that desperately need the funds. We urge the CEQ to expand its methodology so that communities intentionally harmed by systematic racism and redlining can receive the maximum benefit.”

CEQ actually released a beta version of the CEJST in early 2022 and asked for feedback from federal agencies, Tribal Nations, state and local governments, the White House Environmental Justice Advisory Council, environmental justice stakeholders, and the public. Early on, WE ACT provided feedback on the methodology to avoid the negative impact of removing race from the calculations. Despite these efforts, the revised methodology reduced eligible Latino people by as much as 2.83% and eligible Black people by 1.77%. Meanwhile, the number of white people who would benefit from the Justice40 Initiative increased by 10.7 million.

(Photo: Table shows racially disproportionate increase in communities added to the 1.0 version of CEJST. Credit: Screenshot from WE ACT Interested Parties Memo, February 2023.)

It is well-researched that BIPOC communities are more likely to endure the results of environmental injustice – often called environmental racism. WE ACT and Green Latinos partnered in 2021 on a quantitative survey which demonstrated that 64% of the Black and Latinx respondents agreed that they personally experience the effects of climate change. Additionally, a 2021 study by the EPA found that exposure to air pollution is higher for people of color, regardless of their region or income.

“The inequities we report are a result of systemic racism: Over time, people of color and pollution have been pushed together, not just in a few cases but for nearly all types of emissions,” explained Julian Marshall, co-author of the EPA report.

Two of WE ACT’s key recommendations in the recent memo included the adequate inclusion of redlining and cumulative impacts. Redlining, a discriminatory practice which prevented applicants from predominantly Black neighborhoods from receiving government loans, is addressed in version 1.0 of the CEJST. Yet other thresholds in place counteract their influence, so that 1155 redlined tracts were not selected as disadvantaged communities by the CEJST after all.

WE ACT started in 1988 when three community leaders in West Harlem noticed environmental racism in their neighborhood. The member-based organization is now dedicated to ensuring that people of color and low-income residents can participate meaningfully in creating fair environmental policies and practices.