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How prepared are US cities to implement the Justice40 Initiative?

After surveying city leaders pursuing new federal environmental justice funding, here are their challenges — and ways to overcome them.

environmental justice concept with gavel and globe

Image via Shutterstock/simon jihuan.

This article was originally published on World Resource Institute's Insights Blog. Read it here.

As hubs of talent and innovation, American cities are uniquely positioned to fight climate change and improve the health, economy and well-being of their residents. The Biden administration’s Justice40 Initiative and funding available through the Infrastructure Investment and Jobs Act (IIJA) provide rare opportunities for cities to invest in these priorities and turn big ambitions into tangible progress.

City leaders must lean into this moment and align their climate strategies with equity priorities, so they are fully equipped to receive and deliver these investments to their frontline communities through projects that center equity and drive decarbonization. But how ready are U.S. cities to do so, what challenges do they face, and what steps can they take now to prepare?

What is the Justice40 Initiative, and how is it being implemented?

Within days of taking office, President Joe Biden signed Executive Order 14008, "Tackling the Climate Crisis at Home and Abroad." The order launched the Justice40 Initiative, a whole-of-government approach to ensure federal agencies work with states and local communities to direct 40 percent of the benefits from certain federal climate and clean energy investments to marginalized, over-polluted, underserved and disadvantaged communities.

This historic commitment seeks to address environmental injustices in these communities through investments in climate change mitigation and adaptation; clean energy and energy efficiency; clean transit; affordable and sustainable housing; training and workforce development; remediation and reduction of legacy pollution and clean water and wastewater infrastructure.

In the first 6 months since the act’s passage, $110 billion has been allocated to fund more than 4,300 projects in all 50 states.

In November, Biden signed the IIJA into law. When implemented with a Justice40 Initiative approach, the law will further help confront decades of underinvestment and bring critical resources to communities that have been overburdened by legacy pollution and environmental hazards. In the first six months since the act’s passage, $110 billion has been allocated to fund more than 4,300 projects in all 50 states.

Simultaneously, the administration has been developing guidance for how the Justice40 Initiative will be implemented, and in June, EPA released which early adopter programs will integrate Justice40. These and similar Justice40 federal programs will address questions and challenges such as how to define a disadvantaged community, which programs are covered, how benefits will be distributed and how results will be delivered and measured.

What will the Justice40 Initiative require for cities applying for federal funding?

For cities applying for federal funding from the IIJA, complying with the Justice40 Initiative likely means they will need to describe in applications and funding plans how funding will flow to disadvantaged communities. To do so will require a strong understanding of community demographics, challenges and needs. Cities will need to undertake quantitative data assessments and qualitative community listening sessions in order to understand community needs and then tailor their applications accordingly.

Once funding has been awarded, recipients will be expected to measure and report how the funding was used to support disadvantaged communities. This may require new capacities to navigate data and tracking processes, as well as new tools such as CEQ’s recently released Climate and Economic Justice Screening Tool (CEJST).

What challenges do cities face in preparing to implement the Justice40 Initiative?

WRI, a partner in the Bloomberg Philanthropies’ American Cities Climate Challenge, has been working with department officials from participating cities to understand how prepared they are for upcoming federal funding opportunities, with a primary focus on how IIJA can fund equitable decarbonization projects.

In April, WRI held Justice40 Initiative discussions with seven Climate Change Challenge cities: Austin, Texas; Cincinnati; Columbus, Ohio; Seattle; Denver; Minneapolis; and Orlando. Each hour-long session sought to understand the city’s needs and approaches to integrating equity into operations, readiness to comply with the Justice40 Initiative’s guidance and ability to identify and take advantage of opportunities to raise the ambition and equity impact of its clean energy projects seeking federal funding.

Equity is a key component of the climate strategies for cities participating in the American Cities Climate Change Challenge. Each city participating in the needs assessment had incorporated equity, environmental justice, or social and racial justice in their climate action planning and/or implementation in different ways. However, the discussions revealed three common challenges cities face when it comes to applying for funding and prepping for Justice40.

Challenges facing cities in preparing for new funding

1. Finding and applying for federal funding

Access to information about federal grant opportunities was a major challenge cities cited regarding their preparedness for IIJA and Justice40 funding. In many cities, there is a lack of staff capacity for identifying opportunities or coordinating a response. Cities then run the risk of missing deadlines or learning about grants too late to conduct pre-planning activities, such as conducting an environmental impact assessment or getting community feedback on a proposal.

Additionally, while some cities have dedicated staff to locate federal opportunities, they may pass responsibility for developing applications to sustainability directors or other program staff who may not have the bandwidth or expertise needed to complete an application. All of these hurdles stop IIJA funding from reaching disadvantaged communities at the very first step.

2. Connecting existing plans with upcoming funding opportunities

As cities anticipate IIJA and Justice40 funding, they expressed concerns over aligning existing programming with the upcoming unknown grant criteria. With some climate plans and actions well into the implementation stage, cities want to avoid creating any new planning processes or programs to secure an IIJA grant.

Other challenges include getting community buy-in for projects and having a process for evaluating the costs and benefits of different funding opportunities to determine which to pursue. Cities will be better able to respond to grants if requirements are flexible enough for existing plans and programs to match federal funding opportunities.

3. Maximizing the impact of federal funding and making sure that it goes to communities who need it most 

Lastly, cities need support ensuring that federal funding is delivered to their frontline, marginalized and over-polluted communities. Most cities interviewed had done some level of data assessment to understand community demographics, such as a comprehensive planning exercise.

Many said they weren’t sure they had the "right" data to measure equity and prepare for Justice40, despite the number of equity screening tools and indicators currently available. In other words, there may be a mismatch in the kind of data cities have readily available versus what they’ll need to fit Justice40 requirements and guidelines. This mismatch could make it challenging to ensure funding goes to the communities who need it most.

What can cities do now to prepare for implementing Justice40?

As the federal administration rolls out Justice40 guidance, cities would be well-served to undertake the following steps to prepare:

1. Understand which communities within a city can be considered disadvantaged

Many tools exist to help cities understand community demographics and disparities. The White House Council on Environmental Quality has developed the beta version of a Climate and Economic Justice Screening Tool specifically to help cities, states and community-based organizations to do this analysis.

Cities can also learn from each other. Earlier this year, Cincinnati published a Climate Equity Indicators Report with 52 indicators paired with climate risk exposure for each neighborhood in the city. The report is intended to "serve as the foundation of a broad range of decision-making and action to provide redress to the inequities it details," including driving the development of the 2023 Green Cincinnati Plan.

2. Create a plan to guide equitable infrastructure development

If a city does not already have an equitable climate plan in place, it should consider developing one to prioritize actions and projects that could receive federal funding. The Austin City Council adopted the Austin Climate Equity Plan in 2021 following a community engagement process with input from more than 200 residents, including from members of the new Community Climate Ambassadors program. The city used an equity tool ⁠— based on the Government Alliance on Race and Equity (GARE)’s approach ⁠— to evaluate each of the plan’s 74 strategies to account for outcomes related to health, affordability, accessibility, community capacity, cultural preservation, accountability and a just transition to green jobs.

In Minneapolis, city staff are updating their 2013 Climate Action Plan, which is being informed by environmental justice organizations and residents from low-income and Black, Indigenous and people of color (BIPOC) communities. The new Climate Equity Plan is to be completed in 2023.

3. Assess whether existing plans are aligned with upcoming federal funding opportunities

Cities shouldn’t start from scratch if a plan with community buy-in already exists. Orlando recently published its Future-Ready City Master Plan. Aligned with other citywide planning strategies, it is Orlando’s roadmap "to advance and embrace new opportunities to help address community challenges" toward equitable resilience.

To help operationalize this and other plans, Orlando held a federal funding alignment workshop in the spring, which brought together city staff, other jurisdictions in the region and federal employees. Attendees learned about each other’s plans, prioritizing equitable climate projects for the region, aligning them with upcoming federal funding opportunities and discussing how to collaborate going forward.

4. Learn from other cities that are already directing funding specifically for climate and energy projects within disadvantaged communities 

Some cities have been taking a similar approach to the Justice40 Initiative even prior to its announcement. In 2021, the Denver Office of Climate Action, Sustainability and Resiliency published a five-year investment strategy for their annual $40 million Climate Protection Fund. At least 50 percent of the funding will be directed "toward projects that directly benefit people of color and Indigenous people, low-income households, people living with chronic health conditions, children, older adults and others most impacted by climate change."

In Minneapolis, the city uses Environmental Justice and Green Zones — citywide geographic designations based on data on demographics, environmental inequities, institutional racism and underinvestment — to prioritize environmental and clean energy projects through programs such as the city’s Green Cost Share program. This program was partially funded by federal dollars from the American Rescue Plan Act of 2021.

Now is the time for city leaders to take the necessary steps to better position their cities to secure upcoming funding for equitable decarbonization projects.

Local leaders can be a driving force in addressing environmental injustices in frontline communities. Now is the time for city leaders to take the necessary steps to better position their cities to secure upcoming funding for equitable decarbonization projects. 

In June, the Biden administration released the inaugural list of more than 200 programs covered under the Justice40 Initiative for Department of the Interior, Environmental Protection Agency, Health and Human Services and the Department of Agriculture. We can expect this list of programs to grow with each new announcement of coverage under the Justice40 Initiative.

While the level of preparedness to secure these resources varies from city to city, there is still work to do to prepare for these and future opportunities.

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