The Equitable and Just National Climate Forum (EJNCF) strongly supports the creation of an Environmental Justice (EJ) Scorecard to evaluate federal government performance on achieving environmental justice. On January 2021, President Biden signed the Executive Order 14008 on Tackling the Climate Crisis at Home and Abroad, which directed the White House Council on Environmental Quality (CEQ) to create a historic tool that would be the first government-wide assessment on environmental justice. The EJNCF submitted recommendations to the White House Council on designing the EJ Scorecard. A summary of those recommendations are below.
Center racial equity and utilize race as an indicator to report on federal agency performance on environmental justice (EJ).
Federal programs should account for whether the programs are addressing the disparate access to critical services and disparate burdens in communities of color. We recommend that the EJ Scorecard use data on race to identify racial inequality in accessing federal programs as well as account for federal program impacts according to race.
Support transparency, accountability and establish milestones to target at each agency.
We realize that each federal agency may use agency specific methods for assessing progress toward shared environmental justice goals. We recommend that through the EJ Scorecard, agencies and CEQ make accessible to the public for review the different methodologies agencies may use to assess progress and measure benefits. We recommend that the EJ Scorecard also assess progress made on interagency collaboration on environmental justice (such as interagency model projects on environmental justice).
Measure progress in reducing burdens and harms.
- Measure progress towards reducing burdens by utilizing data captured in the Climate and Economic Justice Screening Tool. The Climate and Economic Justice Screening Tool can be a useful tool in establishing a baseline for reporting on progress the federal government is making in addressing burdens and harms.
- Measure federal government performance on protecting civil rights in EJ communities. EJ Scorecard must include an evaluation metric on the performance of all federal agencies to enforce civil rights protections in environmental justice communities. Areas to consider under this evaluation metric should include environmental programs, transportation planning and projects, housing and community developments, and health services that receive federal funds.
- Develop federal program criteria to reduce community displacement and other harms. Federal agencies must help ensure that program funds do not lead to the displacement of the community members they were intended to benefit. The scorecard should measure the extent to which agencies require funding applicants to take steps to avoid gentrification.
Measure progress in delivering benefits.
- Measure progress towards delivering a holistic range of benefits. The scorecard category should focus on measuring benefits beyond reducing burdens and harms, for example, quality jobs created, job training, new and resilient infrastructure and affordable housing, etc.
- Measure direct and indirect investments in EJ communities. The scorecard should measure direct investments in defined frontline geographies; direct investments in people; indirect and direct investment in community and external direct investments. In addition, the scorecard should track the amount and percentage of direct investments in the Justice40 categories that are delivered to disadvantaged communities.
Measure progress in incorporating justice in agency decision making.
- Measure how meaningful public engagement guides federal decision making. The scorecard should measure if and how public engagement influences agency decision making. In addition, the scorecard should include measures that assess agency efforts to improve the quality of public engagement on the design of programs to advance environmental justice priorities.
- Measure how environmental and climate justice goals and criteria guide federal funding decisions. The scorecard should capture the extent to which agencies have strengthened their funding criteria to ensure federal investments advance environmental and climate justice goals and benefit disadvantaged communities, including by reducing local air and water pollution, soil contamination, and greenhouse gas emissions; reducing health and climate change risks; and building climate-resilient infrastructure and housing.
- Measure agency hiring of environmental justice experts and staff expansions to provide technical and capacity building assistance to ensure disadvantaged communities can access federal funding. The scorecard should measure the extent to which federal agencies have expanded their field offices and hired new staff to raise awareness of federal program funding opportunities. The scorecard should also measure the number of environmental justice experts agencies have hired across their departments and programs to help meet environmental justice goals.
- Evaluate whether agency professional culture encourages and incentivizes staff to reflect, share and act on lessons learned, including lessons learned from mistakes. Agencies should develop “processes for incorporating iterative and bidirectional feedback with communities and other stakeholders for the sake of crafting sustainable and socially equitable solutions that avoid repeating and that redress the impact of past mistakes.”
- Federal agency decision making should include increased community impact, agency and power. Often community participation in public institutions exists in the form of rubber stamp advisory boards with limited influence on decisions being made. In the long term, centering justice in federal agencies should result in delegating at least part of the decision making authority to advisory boards and community groups that agencies are consulting with.
