Energy Justice for All: Keeping Disadvantaged Populations Cool in a Heating World

Extreme heat is the deadliest weather phenomenon in the United States — more lethal than hurricanes, floods, and tornadoes combined. And, as extreme temperatures rise, so do American household energy bills. An alarming 16% (20.9 million) of U.S. households are behind on their energy bills and at an increased risk of utility shut-offs. 

Many households rely on electrical power systems like air conditioning (AC) to combat immediate heat effects, increasing energy demand and straining power transmission capabilities, non-reliability, and energy insecurity. Even as increasingly warmer winter months due to climate change reduce the need for heating, this indicates a future with increased energy demand for cooling. In the U.S., projected changes in cooling degree days — the metric to estimate how much cooling is needed to maintain a comfortable indoor air temperature — are expected to drive a 71% increase in household cooling demand by 2050, according to the latest annual energy outlook from the U.S. Energy Information Administration (EIA).

Increasingly excessive heat is, therefore, a financial burden for many people, particularly low-income households. This is especially the case as low-income households tend to live in less energy-efficient homes that are more expensive to cool. The inability to afford household energy needs — that is, energy insecurity — makes it a challenge to stay cool, comfortable, and healthy during periods of extreme heat. Thus, as the impacts of extreme heat and energy insecurity are not distributed evenly, it is increasingly essential for the federal government to consider equity and prioritize disadvantaged populations in its efforts to tackle these intertwined crises.

Extreme Heat Drives Energy Burdens and Utility Insecurities

Energy insecurity refers to an individual or household’s inability to adequately meet basic household energy needs, like cooling and heating. Extreme heat compounds existing energy insecurities by surging the need for AC and other electrical sources of cooling technology. Thus, as the demand for cooling during summer increases energy consumption, many households cannot afford to run their AC, leading to life-threatening living conditions. According to the latest EIA Residential Energy Consumption Survey (RECS), a striking one in five households reported reducing or forgoing necessities like food and medicine to pay an energy bill. Over 10% of households reported keeping their home at an unhealthy or unsafe temperature due to costs.

Additionally, while household access to AC has increased over the years, a significant one in eight U.S. homes on average are still lacking AC, with renters going without at a higher rate than homeowners. The lack of access to cooling may be particularly hazardous for low-income, renter, rural, or elderly households, especially for those with underlying health conditions and those living in heat islands—urban areas where temperatures are higher than surrounding rural and suburban areas.

Another critical issue is that at least three million U.S. utility customers have their power disconnected every year due to payment challenges, yet 31 states have no policy preventing energy shut-offs during excessive heat events. The states that do have policies vary widely in their cut-off points and protection policies. Across the board, low-income people are disproportionately facing disconnections and are often charged a “reconnect fee” or a deposit after a cutoff

As of 2021, 29 states had seasonal protections and 23 had temperature-based disconnection protections that prohibit utility companies from disconnecting power. Still, research from the Indiana University Energy Justice Lab shows that these do not fully prohibit disconnections, often putting the onus on customers to demonstrate eligibility for an exemption, such as medical need. Further, while 46 states, along with Washington D.C., give customers the option to set up a payment plan as an alternative to disconnection, high interest rates may be costly, and income-based repayment is rarely an option.

These cut-off policies are all set at the state level, and there is still an ongoing need to identify best practices that save lives. Policymakers can use utility regulations to protect residents from the financial burden of extreme heat events. For example, Phoenix passed a policy that went into effect in 2022 and prevents both residential energy disconnections in summer months (through October 2024) and late fees incurred during this time for residents who owe less than $300. Also, some stakeholders in Massachusetts are considering “networked geothermal energy with microdistricts” — also known as geogrids — to build the physical capability to transfer cool air through a geothermal network. This could allow different energy users to trade hot and cool air,  in order to move cool air from members who can pay for it to those who cannot.

Grid Insecurity

Extreme heat also poses a significant threat to national energy grid infrastructure by increasing the risk of power outages due to increased energy consumption. Nationwide, major power outages have increased tenfold since 1980, largely because of damages from extreme weather and aging grid infrastructure. Regions not accustomed to experiencing extreme heat and lacking the infrastructure to deal with it will now become particularly vulnerable. Disadvantaged neighborhoods in urban heat islands also face heightened risks as they more frequently lack the essential infrastructure needed to adapt to the changing climate. For example, grid infrastructure in California’s urban disadvantaged communities has been shown to be weaker and less ready to support electric appliances. 

Similarly, rural communities face unique challenges in preparing for disasters that could lead to power loss. Geographic isolation, limited resources, and older infrastructure are all factors that make power outages more frequent and long-lasting in rural areas. These factors also affect the frequency of maintenance service and speed of repairs. In addition, rural areas often have less access to emergency services and cooling centers, making power outages during extreme heat events additionally hazardous. Power outages during extreme heat events increase the risks for heat-related illnesses such as fainting, heat exhaustion, and heatstroke. And, for rural homes that rely on well water, losing power can mean losing access to water, since well systems rely on electrical pumps to bring water into the home. 

Further heightening the need for urgency to consider these especially vulnerable populations and regions, research has shown that the time to restore power after an outage is significantly longer for rural communities and in low-income communities of color. Power restoration time reflects which communities are prioritized and, as a result, which communities are neglected. 

Equity Considerations For Different Housing Types

Extreme heat and energy security cannot be addressed without considering equity, as the impacts are not distributed evenly, especially by race, income, and housing type. One example of this intersection: Black renters have faced disproportionate burdens of extreme heat and energy security, as wealth is deeply correlated with race and homeownership in the U.S. In 2021, the EPA reported that Black people are 40% more likely than non-Black people to live in areas with the highest projected increase in mortality rates due to extreme temperatures. Simultaneously, a 2020 analysis by the Brookings Institute found that Black renters had greater energy insecurity than white renters, Black homeowners, and white homeowners. Beyond the cost burden of staying cool, this energy security puts lives at greater risk of heat-related illness and death and hinders economic mobility.

This paradigm reflects historic, discriminatory housing policies like redlining. Such policies segregated neighborhoods, induced lower homeownership rates, and ensured underinvestment in low-income communities of color—all of these factors play a significant part in making Black residents more vulnerable to the effects of extreme heat. Further compounding this, a 2020 study of more than 100 cities across the U.S. found that 94% of formerly redlined areas are hotter than non-redlined areas; in the summer, this difference can be as high as 12.6℉. 

Nationwide, households living in manufactured homes also face disproportionate risks and impacts, with about 25% having incomes at or below the federal poverty level. At the same time, manufactured homes consume 70% more per square foot on energy than site-built homes, while using 35% less energy due to their smaller size. Notably, about 70% of all manufactured homes are located in rural areas, which on average have higher median energy burdens than metropolitan areas

Further, ​​older manufactured housing units are often in inadequate condition and do not meet building codes established after 1976. However, research has shown that the vulnerability of households living in manufactured housing units to extreme temperatures is only partially related to whether they have AC systems installed. Other key factors that residents report to drive vulnerability include AC units that do not work efficiently, are located in less-used parts of the house, or are ineffective in maintaining comfortable temperatures. These factors hamper manufactured housing residents’ ability to control their home’s thermal environment — thereby driving thermal insecurity.

Manufactured housing households facing challenges with resource access (such as exclusions from assistance programs and lack of credit access), physical health and mental limitations, care burdens, and documentation status may be at disproportionate risk. These households deal with multiple, intersecting vulnerabilities and often must engage in trade-off behavior to meet their most immediate needs, sacrificing their ability to address unsafe temperatures at home. They often take adapting to the increasingly extreme climate into their own hands, using various ways to cope with thermal insecurity, such as installing dual-pane windows, adding insulation, planting shade trees, using supplemental mobile AC units, and even leaving home to visit local air-conditioned malls.

These overlapping paradigms showcase the intrinsic interconnectedness among climate justice, climate justice, energy justice, and housing justice. Essentially, housing equity cannot be pursued without energy justice and climate justice, as the conditions for realizing each of these concepts entail the conditions for the others.  Realizing these conditions will require substantial investment and funding for climate programs to include heat governance, housing resilience, and poverty alleviation policies. 

Policy Considerations

Energy Burdens and Utility Insecurity

Update the Low Income Home Energy Assistance Program (LIHEAP)

The Low Income Home Energy Assistance Program (LIHEAP) exists to relieve energy burdens, yet was designed primarily for heating assistance. Thus, the LIHEAP formulas advantage states with historically cooler climates. To put this in perspective, some states with the highest heat risk — such as Missouri, Nevada, North Carolina, and Utah —  offer no cooling assistance funds from LIHEAP.  Despite their warm climates, Arizona, Arkansas, Florida, and Hawai’i all limit LIHEAP cooling assistance per household to less than half the available heating assistance benefit. And, since most states use their LIHEAP budgets for heating first, very little remains for cooling assistance — in some cases, cooling assistance is not offered at all. As a result, from 2001 to 2019, only 5% of national energy assistance went to cooling

For vulnerable households, the lack of cooling assistance is compounded by a lack of disconnection protections from extreme heat. Thus, with advanced forecasts, LIHEAP should also be deployed both to restore disconnected electric service and to make payments on energy bills, which may surge even higher with the increase in demand response pricing due to more extreme temperatures. The distribution of LIHEAP funds to the most vulnerable households should also be maximized. As most states do not have firm guidelines on which households to distribute LIHEAP funds to and use a modified “first-come, first-served” approach, a small number of questions specific to heat risk could be added to LIHEAP applications and used to generate a household heat vulnerability score.

Further, the LIHEAP program is massively oversubscribed, and can only service a portion of in-need families. To adapt to a hotter nation and world at large, the annual budgets for LIHEAP must increase and the allocation formulas will need to be made more “cooling”-aware and equitable for hot-weather states. The FY25 presidential budget keeps LIHEAP’s funding levels at $4.1 billion, while also proposing expanding eligible activities that will draw on available resources. Analysis from the National Energy Assistance Directors Association found that this funding level could cut off up to 1.5 million families from the program and remove program benefits like cooling. 

Reform the Public Utility Regulatory Policies Act of 1978 (PURPA) 

While PURPA prohibits electric utilities from shutting off home electricity for overdue bills when doing so would be dangerous for someone’s health, it does not have explicit protections for extreme temperatures. The federal government could consider reforms to PURPA that require utilities to have moratoriums on energy shut-offs during extreme heat seasons.

Housing Improvements

Expand Weatherization Assistance Programs

Weatherization aims to make homes more energy efficient and comfortable in various climates through actions, such as attic and wall insulation, air sealing, or adding weather stripping to doors and windows. More than half of cities have a weatherization program. The Department of Energy (DOE) Weatherization Assistance Program (WAP) funding is available for states and other entities to retrofit older homes for improved energy efficiency to power cooling technologies like AC. However, similar to LIHEAP, WAP primarily focuses on support for heating-related repairs rather than cooling. For all residential property types, weatherization audits, through WAP and LIHEAP, can be expanded to consider heat resilience and cooling efficiency of the property and then identify upgrades such as more efficient AC, building envelope improvements, cool roofs, cool walls, shade, and other infrastructure. 

Further, weatherization can be complicated when trying to help the most vulnerable populations. As some of the houses are in such poor condition that they do not qualify for weatherization, there is a need for nationwide access to pre-weatherization assistance programs. These programs address severe conditions in a home that would cause a home to be deferred from the federal WAP because the conditions would make the weatherization measures unsafe or ineffective. Pre-weatherization assistance programs are typically run by the State WAP Office or administered in partnership with another state office.  

Additionally, as the Infrastructure Investment and Jobs Act (IJA) allocated roughly $3.5 billion to WAP, states should utilize this funding to target energy-insecure neighborhoods with high rates of rental properties. Doing so will help states prioritize decreasing energy insecurity and its associated safety risks for some of the most vulnerable households.

Increase Research on Federal Protections for Vulnerable Housing Types

There is a need for a nationwide policy for secure access to cooling. While the Department of Housing and Urban Development (HUD) does not regulate manufactured home parks, it does finance the parks through Section 207 mortgages. HUD  could stipulate park owners must guarantee resident safety. This agency could also update the Manufactured Home Construction and Safety Standards to allow for AC and other cooling regulations in local building codes to apply to manufactured homes, as they do for other forms of housing, as well as require homes perform to a certain level of cooling under high heat conditions. Additionally, to support lower-cost retrofit methods for manufactured homes and other vulnerable housing types, new approaches to financing, permitting, and incentivizing building retrofits should be developed, per the Biden-Harris Administration’s Climate Resilience Game Changers Assessment.  HUD’s Green and Resilient Retrofit Program, which provides climate resilience funding to affordable housing properties, can serve as a model.

Further, as home heat-risk remains under-studied and under-addressed by hazard mitigation planning, and policy processes, there needs to be better measures of home thermal security. Without better data, homes will continue to be overlooked in state and federal climate and adaptation efforts. 

Grid Resilience and Energy Access

Prioritize access to affordable, resilient energy alternatives for energy-insecure individuals

The most long-term investment in reducing energy insecurity and climate vulnerability is ensuring the most energy insecure populations have access to alternative, renewable energy sources, such as wind and solar.  This is a core focus of the DOE Energy Futures Grant (EFG) program, which provides $27 million in financial assistance and technical assistance to local- and state-led partnership efforts for increasing access to affordable clean energy. EFG is a Justice 40 program, and required to ensure 40% of the overall benefits of its federal investments flow to disadvantaged communities. Programs like EFG can serve as a model for federal efforts to reduce energy cost burdens, while simultaneously reducing dependence on nonrenewable energy sources like oil and natural gas. 

Accelerate Energy-Efficient Infrastructure

Efficient AC technologies, such as air source heat pumps, can help make cooling more affordable. Therefore, resilient cooling strategies, like high-energy efficiency cooling systems, demand/response systems, and passive cooling interventions, need federal policy actions to rapidly scale for a warming world. For example, cool roofs, walls, and surfaces can keep buildings cool and less reliant on mechanical cooling, but are often not considered a part of weatherization audits and upgrades. District cooling, such as through networked geothermal, can keep entire neighborhoods cool while relying on little electricity. However, this is still in the demonstration project phase in the U.S. Initiatives like the DOE Affordable Home Energy Shot can bring new resilient cooling technologies into reach for millions of Americans, but only if it is given sufficient financial resources. The Environmental Protection Agency’s Energy Star program can further incentivize low-power and resilient cooling technologies if rebates are designed that take advantage of these technologies.

Finding True North: How Community Navigator Programs Can Forward Distributional Justice

State, local, and Tribal governments still face major capacity issues when it comes to accessing federal funding opportunities – even with the sheer amount of programs started since the Bipartisan Infrastructure Law (BIL) and Inflation Reduction Act (IRA) were passed. Communities need more technical assistance if implementation of those bills is going to reach its full potential, but federal agencies charged with distributing funding can’t offer the amount needed to get resources to where they need to go quickly, effectively, and equitably. 

Community navigator programs offer a potential solution. Navigators are local and regional experts with a deep understanding of the climate and clean energy challenges and opportunities in their area. These navigators can be trained in federal funding requirements, clean energy technologies, permitting processes, and more – allowing them to share that knowledge with their communities and boost capacity. 

Federal agencies like the Department of Energy (DOE) should invest in standing up these programs by collecting feedback on specific capacity needs from regional partners and attaching them to existing technical assistance funding. These programs can look different, but agencies should consider specific goals and desired outcomes, identify appropriate regional and local partners, and explore additional flexible funding opportunities to get them off the ground. 

Community navigator programs can provide much-needed capacity combined with deep place-based knowledge to create local champions with expertise in accessing federal funding – relieving agencies of technical assistance burdens and smoothing grant-writing processes for local and state partners. Agencies should quickly take advantage of these programs to implement funding more effectively. 

Challenge

BIL/IRA implementation is well under way, with countless programs being stood up at record speed by federal agencies. Of course, the sheer size of the packages means that there is still quite a bit of funding on the table at DOE that risks not being distributed effectively or equitably in the allotted time frame. While the agency is making huge strides to roll out its resources—which include state-level block grants, loan guarantee programs, and tax rebates—it has limited capacity to fully understand the unique needs of individual cities and communities and to support each location effectively in accessing funding opportunities and implementing related programs. 

Subnational actors own the burden of distributing and applying for funding. States, cities, and communities want to support distribution, but they are not equally prepared to access federal funding quickly. They lack what officials call absorptive capacity, the ability to apply for, distribute, and implement funding packages. Agencies don’t have comprehensive knowledge of barriers to implementation across the hundreds of thousands of communities and can’t provide individualized technical assistance that is needed. 

Two recent research projects identified several keys ways that cities, state governments, and technical assistance organizations need support from federal agencies:

While this research focuses on several BIL/IRA agencies, the Department of Energy in particular distributed hundreds of billions of dollars to communities over the past few years. DOE faces an additional challenge: up until 2020, the agency was mainly focused on conducting basic science research. With the advent of BIL, IRA, and the CHIPS and Science Act, it had to adjust quickly to conduct more deployment and loan guarantee activities. 

In order to meet community needs, DOE needs help – and at its core, this problem is one of talent and capacity. Since the passage of BIL, DOE has increased its hiring and bolstered its offices through the Clean Energy Corps

Yet even if DOE could hire faster and more effectively, the sheer scope of the problem outweighs any number of federal employees. Candidates need not only certain skills but also knowledge specific to each community. To fully meet the needs of the localities and individuals it aims to reach, DOE would need to develop thorough community competency for the entire country. With over 29,000 defined communities in the United States – with about half being classified as ‘low capacity’ – it’s simply impossible to hire enough people or identify and overcome the barriers each one faces in the short amount of time allotted to implementation of BIL/IRA. Government needs outside support in order to distribute funds quickly and equitably.

Opportunity

DOE, the rest of the federal government, and the national labs are keen to provide significant technical assistance for their programs. DOE’s Office of State and Community Energy Programs has put considerable time and energy into expanding its community support efforts, including the recently stood up Office of Community Engagement and the Community Energy Fellows program. 

National labs have been engaging communities for a long time – the National Renewable Energy Laboratory (NREL) conducts trainings and information sessions, answers questions, and connects communities with regional and federal resources. Colorado and Alaska, for example, were well-positioned to take advantage of federal funding when BIL/IRA were released as a result of federal training opportunities from the NREL, DOE, and other institutions, as well as local and regional coordinated approaches to preparing. Their absorptive capacity has helped them successfully access opportunities – but only because communities, cities, and Tribal governments in those regions have spent the last decade preparing for clean energy opportunities. 

While this type of long-term technical assistance and training is necessary, there are resources available right now that are at risk of not being used if states, cities, and communities can’t develop capacity quickly. As DOE continues to flex its deployment and demonstration muscles, the agency needs to invest in community engagement and regional capacity to ensure long-term success across the country. 

A key way that DOE can help meet the needs of states and cities that are implementing funding is by standing up community navigator programs. These programs take many forms, but broadly, they leverage the expertise of individuals or organizations within a state or community that can act as guides to the barriers and opportunities within that place. 

Community navigators themselves have several benefits. They can act as a catalytic resource by delivering quality technical assistance where federal agencies may not have capacity. In DOE’s case, this could help communities understand funding opportunities and requirements, identify appropriate funding opportunities, explore new clean energy technologies that might meet the needs of the community, and actually complete applications for funding quickly and accurately. They understand regional assets and available capital and have strong existing relationships. Further, community navigators can help build networks – connecting community-based organizations, start-ups, and subnational government agencies based on focus areas. 

The DOE and other agencies with BIL/IRA mandates should design programs to leverage these navigators in order to better support state and local organizations with implementation. Programs that leverage community navigators will increase the efficiency of federal technical assistance resources, stretching them further, and will help build capacity within subnational organizations to sustain climate and clean energy initiatives longer term.

These programs can target a range of issues. In the past, they have been used to support access to individual benefits, but expanding their scope could lead to broader results for communities. Training community organizations, and by extension individuals, on how to engage with federal funding and assess capital, development, and infrastructure improvement opportunities in their own regions can help federal agencies take a more holistic approach to implementation and supporting communities. Applying for funding takes work, and navigators can help – but they can also support the rollout of proposed programs once funding is awarded and ensure the projects are seen through their life cycles. For example, understanding broader federal guidance on funding opportunities like the Office of Management and Budget’s proposed revisions to the Uniform Grants Guidance can give navigators and communities additional tools for monitoring and evaluation and administrative capacity. 

Benefits of these programs aren’t limited to funding opportunities and program implementation – they can help smooth permitting processes as well. Navigators can act as ready-made champions for and experts on clean energy technologies and potential community concerns. In some communities, distrust of clean energy sources, companies, and government officials can slow permitting, especially for emerging technologies that are subject to misinformation or lack of wider recognition. Supporting community champions that understand the technologies, can advocate on their behalf, and can facilitate relationship building between developers and community members can reduce opposition to clean energy projects. 

Further, community navigator programs could help alleviate cost-recovery concerns from permitting teams. Permitting staff within agencies understand that communities need support, especially in the pre-application period, but in the interest of being good stewards of taxpayer dollars they are often reluctant to invest in applications that may not turn into projects. 

Overall, these programs have major potential for expanding the technical assistance resources of federal agencies and the capacity of state and local governments and community-based organizations. Federal agencies with a BIL/IRA mandate should design and stand up these programs alongside the rollout of funding opportunities.

Plan of Action

With the Biden Administration’s focus on community engagement and climate and energy justice, agencies have a window of opportunity in which to expand these programs. In order to effectively expand community navigator programs, offices should: 

Build community navigator programs into existing technical assistance budgets.

Offices at agencies and subcomponents with BIL/IRA funding like the Department of Energy, the Bureau of Ocean Energy Management, the Bureau of Land Management (BLM), and the Environmental Protection Agency (EPA) have expanded their technical assistance programs alongside introducing new initiatives from that same funding. Community navigator programs are primarily models for providing technical assistance – and can use programmatic funding. Offices should assess funding capabilities and explore flexible funding mechanisms like the ones below. 

Some existing programs are attached to large block grant funding, like DOE’s Community Energy Programs attached to the Energy Efficiency and Conservation Block Grant Program. This is a useful practice as the funding source has broad goals and is relatively large and regionally nonspecific.

Collect feedback from regional partners on specific challenges and capacity needs to appropriately tailor community navigator programs. 

Before setting up a program, offices should convene local and regional partners to assess major challenges in communities and better design a program. Feedback collection can take the form of journey mapping, listening sessions, convenings, or other structures. These meetings should rely on partners’ expertise and understanding of the opportunities specific to their communities.

For example, if there’s sufficient capacity for grant-writing but a lack of expertise in specific clean energy technologies that a region is interested in, that would inform the goals, curricula, and partners of a particular program. It also would help determine where the program should sit: if it’s targeted at developing clean energy expertise in order to overcome permitting hurdles, it might fit better at the BLM or be a good candidate for a partnership between a DOE office and BLM. 

Partner with other federal agencies to develop more holistic programs. 

The goals of these programs often speak to the mission of several agencies – for example, the goal of just and equitable technical assistance has already led to the Environmental Justice Thriving Communities Technical Assistance Centers program, a collaboration between EPA and DOE. By combining resources, agencies and offices can even further expand the capacity of a region and increase accessibility to more federal funding opportunities. 

A good example of offices collaborating on these programs is below, with the Arctic Energy Ambassadors, funded by the Office of State and Community Energy Programs (SCEP) and the Arctic Energy Office. 

Roadmap for Success

There are several initial considerations for building out a program, including solidifying the program’s goals, ensuring available funding sources and mechanisms, and identifying regional and local partners to ensure it is sustainable and effective. Community navigator programs should: 

Identify a need and outline clear goals for the program. 

Offices should clearly understand the goals of a program. This should go without saying, but given the inconsistency in needs, capacity, and readiness across different communities, it’s key to develop a program that has defined what success looks like for the participants and region. For example, community navigator programs could specifically work to help a region navigate permitting processes; develop several projects of a singular clean energy technology; or understand how to apply for federal grants effectively. Just one of those goals could underpin an entire program. 

Ideally, community navigator programs would offer a more holistic approach – working with regional organizations or training participants who understand the challenges and opportunities within their region to identify and assess federal funding opportunities and work together to develop projects from start to finish. But agencies just setting up programs should start with a more directed approach and seek to understand what would be most helpful for an area. 

Source and secure available funding, including considerations for flexible mechanisms.

There are a number of available models using different funding and structural mechanisms. Part of the benefit of these programs is that they don’t rely solely on hiring new technical assistance staff, and offices can use programmatic funds more flexibly to work with partners. Rather than hiring staff to work directly for an agency, offices can work with local and regional organizations to administer programs, train other individuals and organizations, and augment local and community capacity. 

Further, offices should aim to work across the agency and identify opportunities to pool resources. The IRA provided a significant amount of funding for technical assistance across the agency – for example, the State Energy Program funding at SCEP, the Energy Improvements in Rural and Remote Areas funding at the Office of Clean Energy Demonstrations (OCED), and the Environmental Justice Thriving Communities Technical Assistance Centers program from a Department of Transportation/Department of Energy partnership could all be used to fund these programs or award funding to organizations that could administer programs. 

Community navigator programs could also be good candidates for entities like FESI, the DOE’s newly authorized Foundation for Energy Security and Innovation. Although FESI must be set up by DOE, once formally established it becomes a 501(c)(3) organization and can combine congressionally appropriated funding with philanthropic or private investments, making it a more flexible tool for collaborative projects. FESI is a good tool for the partnerships described above – it could hold funding from various sources and support partners overseeing programs while convening with their federal counterparts. 

Finally, DOE is also exploring the expanded use of Partnership Intermediary Agreements (PIAs), public-private partnership tools that are explicitly targeted at nontraditional partners. As the DOE continues to announce and distribute BIL/IRA funds, these agreements could be used to administer community navigator programs.

Build relationships and partner with appropriate local and regional stakeholders.

Funding shouldn’t be the only consideration. Agency offices need to ensure they identify appropriate local and regional partners, both for administration and funding. Partners should be their own form of community navigators – they should understand the region’s clean energy ecosystem and the unique needs of the communities within. In different places, the reach and existence of these partners may vary – not every locality will have a dedicated nonprofit or institution supporting clean energy development, environmental justice, or workforce, for example. In those cases, there could be regional or county-level partners that have broader scope and more capacity and would be more effective federal partners. Partner organizations should not only understand community needs but have a baseline level of experience in working with the federal government in order to effectively function as the link between the two entities. Finding the right balance of community understanding and experience with federal funding is key. 

This is not foolproof. NREL’s ‘Community to Clean Energy (C2C) Peer Learning Cohorts’ can help local champions share challenges and best practices across states and communities and are useful tools for enhancing local capacity. But this program faces similar challenges as other technical assistance programs: participants engage with federal institutions that provide training and technical expertise that may not directly speak to local experience. It may be more effective to train a local or regional organization with a deeper understanding of the specific challenges and opportunities of a place and greater immediate buy-in from the community. It’s challenging for NREL as well to identify the best candidates in communities across the country without that in-depth knowledge of a region. 

Additional federal technical assistance support is sorely needed if BIL/IRA funds are to be distributed equitably and quickly. Federal agencies are moving faster than ever before but don’t have the capacity to assess state and local needs. Developing models for state and local partners can help agencies get funding out the door and where it needs to go to support communities moving towards a clean energy transition.

Case Study: DOE’s Arctic Energy Ambassadors 

DOE’s Arctic Energy Office (AEO) has been training state level champions for years but recently introduced the Arctic Energy Ambassadors program, using community navigators to expand clean energy project development. 

The program, announced in late October 2023, will support regional champions of clean energy with training and resources to help expand their impact in their communities and across Alaska. The ambassadors’ ultimate goal is clean energy project development: helping local practitioners access federal resources, identify appropriate funding opportunities, and address their communities’ specific clean energy challenges. 

The Arctic Energy Office is leading the program with help from several federal and subnational organizations. DOE’s Office of State and Community Engagement and Office of Energy Efficiency and Renewable Energy are also providing funding. 

On the ground, the Denali Commission will oversee distribution of funding, and the Alaska Municipal League will administer the program. The combination of comparative advantages is what will hopefully make this program successful. The Denali Commission, in addition to receiving congressionally appropriated funding, can receive funds from other nonfederal sources in service of its mission. This could help the Commission sustain the ambassadors over the longer term and use funds more flexibly. The Commission also has closer relationships with state-level and Tribal governments and can provide insight into regional clean energy needs. 

The Alaska Municipal League (AML) brings additional value as a partner; its role in supporting local governments across Alaska gives it a strong sense of community strengths and needs. AML will recruit, assess, and identify the 12 ambassadors and coordinate program logistics and travel for programming. Identifying the right candidates for the program requires in-depth knowledge of Alaskan communities, including more rural and remote ones. 

For its own part, the AEO will provide the content and technical expertise for the program. DOE continues to host an incredible wealth of subject matter knowledge on cutting-edge clean energy technologies, and its leadership in this area combined with the local understanding and administration by AML and Denali Commission will help the Arctic Energy Ambassadors succeed in the years to come. 

In all, strong local and regional partners, diverse funding sources and flexible mechanisms for delivering it, and clear goals for community navigator programs are key for successful administration. The Arctic Energy Ambassadors represents one model that other agencies can look to for success. 

Case study: SCEP’s Community Energy Fellows Program

DOE’s State and Community Energy Programs office has been working tirelessly to implement BIL and IRA, and last year as part of those efforts it introduced the Community Energy Fellows Program (CEFP). 

This program aims to support local and Tribal governments with their projects funded by the Energy Efficiency and Conservation Block Grants. CEFP matches midcareer energy professionals with host organizations to provide support and technical assistance on projects as well as learn more about how clean energy development happens. 

Because the program has a much broader scope than the Arctic Energy Fellows, it solicits and assesses host institutions as well as Fellows. This allows SCEP to more effectively match the two based on issue areas, expertise, and specific skillsets. This structure allows for multiple community navigators – the host institution understands the needs of its community and the Fellow brings expertise in federal programs and clean energy development. Both parties gain from the fellowship. 

In addition, SCEP has added another resource: Clean Energy Coaches, who provide another layer of expertise to the host institution and the Fellow. These coaches will help develop the Fellows’ skills as they work to support the host institution and community. 

Some of the awards are already being rolled out, with a second call for host institutions and Fellows out now. Communities in southern Maine participating in the program are optimistic about the support that navigators will provide – and their project leads have a keen sense of the challenges in their communities. 

As the program continues to grow, it can provide a great opportunity for other agencies and offices to learn from its success.

Assessing Agency-Reported Progress on the Justice40 Initiative

Question: What do family game nights and federal government initiatives have in common?

Answer: They’re both much easier to successfully start than to successfully finish.

Coordinating multiple stakeholders—each with their unique interests and perspectives—around a common goal is simply difficult. At FAS, we have yet to figure out how to best tackle family game nights. But we have found that for complex federal initiatives involving many agencies, taking the time to step back and assess progress to date often paves the way for continued future success. We also recognize that unless specifically tasked and resourced, Executive Branch agencies and offices generally lack capacity to do this on their own.

That’s why today, FAS is releasing an independent assessment of agency-reported progress on the Administration’s Justice40 Initiative—a landmark whole-of-government effort to ensure that 40% of the overall benefits of certain federal investments flow to disadvantaged communities that are marginalized, underserved, and overburdened by pollution.

The complete assessment is freely available here. A supplemental spreadsheet to the assessment is available here.

The assessment focuses on the 175 Justice40 recommendations issued by the White House Environmental Justice Advisory Council (WHEJAC) in May 2021. Key takeaways include:

Additional background and insights from the assessment are provided below. 

The WHEJAC and the Justice40 Initiative

President Biden launched the Justice40 Initiative within days of taking office in January 2021. Executive Order (E.O.) 14008, which created the Initiative, also established the first-ever White House Environmental Justice Advisory Council (WHEJAC). The WHEJAC comprises two dozen experts in environmental justice, climate change, disaster preparedness, racial inequity, and related fields. 

The WHEJAC’s mission is to provide advice and recommendations to the Chair of the Council on Environmental Quality (CEQ) and the White House Environmental Justice Interagency Council (IAC) “on how to increase the Federal Government’s efforts to address current and historic environmental injustice.” The WHEJAC’s first suite of recommendations, released in May 2021, included 175 specifically focused on the Justice40 Initiative. In May 2022, CEQ delivered a required report to Congress that included responses from the federal agencies named in each of these.

Assessing agency-reported progress on Justice40

To inform the WHEJAC’s future efforts, and to support ongoing implementation of the Justice40 Initiative, we at FAS conducted an independent assessment of the WHEJAC’s Justice40 recommendations and CEQ’s corresponding report. We emphasize that this assessment was scoped to elucidate key insights and trends from agency-reported progress on Justice40, and did not include independent verification of agency responses. The assessment includes five sections:

Read the full assessment:

Establishing the AYA Research Institute: Increasing Data Capacity and Community Engagement for Environmental-Justice Tools

Summary

Environmental justice (EJ) is a priority issue for the Biden Administration, yet the federal government lacks capacity to collect and maintain data needed to adequately identify and respond to environmental-justice (EJ) issues. EJ tools meant to resolve EJ issues — especially the Environmental Protection Agency (EPA)’s EJSCREEN tool — are gaining national recognition. But knowledge gaps and a dearth of EJ-trained scientists are preventing EJSCREEN from reaching its full potential. To address these issues, the Administration should allocate a portion of the EPA’s Justice40 funding to create the “AYA Research Institute”, a think tank under EPA’s jurisdiction. Derived from the Adinkra symbol, AYA means “resourcefulness and defiance against oppression.” The AYA Research Institute will functionally address EJSCREEN’s limitations as well as increase federal capacity to identify and effectively resolve existing and future EJ issues.

Challenge and Opportunity

Approximately 200,000 people in the United States die every year of pollution-related causes. These deaths are concentrated in underresourced, vulnerable, and/or minority communities. The EPA created the Office of Environmental Justice (OEJ) in 1992 to address systematic disparities in environmental outcomes among different communities. The primary tool that OEJ relies on to consider and address EJ concerns is EJSCREEN. EJSCREEN integrates a variety of environmental and demographic data into a layered map that identifies communities disproportionately impacted by environmental harms. This tool is available for public use and is the primary screening mechanism for many initiatives at state and local levels. Unfortunately, EJSCREEN has three major limitations:

  1. Missing indicators. EJSCREEN omits crucial environmental indicators such as drinking-water quality and indoor air quality. OEJ states that these crucial indicators are not included due to a lack of resources available to collect underlying data at the appropriate quality, spatial range, and resolution. 
  2. Small areas are less accurate. There is considerable uncertainty in EJSCREEN environmental and demographic estimates at the census block group (CBG) level. This is because (i) EJSCREEN’s assessments of environmental indicators can rely on data collected at scales less granular than CBG, and (ii) some of EJSCREEN’s demographic estimates are derived from surveys (as opposed to census data) and are therefore less consistent.
  3. Deficiencies in a single dataset can propagate across EJSCREEN analyses. Environmental indicators and health outcomes are inherently interconnected. This means that subpar data on certain indicators — such as emissions levels, ambient pollutant levels in air, individual exposure, and pollutant toxicity — can compromise the reliability of EJSCREEN results on multiple fronts. 

These limitations must be addressed to unlock the full potential of EJSCREEN as a tool for informing research and policy. More robust, accurate, and comprehensive environmental and demographic data are needed to power EJSCREEN. Community-driven initiatives are a powerful but underutilized way to source such data. Yet limited time, funding, rapport, and knowledge tend to discourage scientists from engaging in community-based research collaborations. In addition, effectively operationalizing data-based EJ initiatives at a national scale requires the involvement of specialists trained at the intersection of EJ and science, technology, engineering, and math (STEM). Unfortunately, relatively poor compensation discourages scientists from pursuing EJ work — and scientists who work on other topics but have interest in EJ can rarely commit the time needed to sustain long-term collaborations with EJ organizations. It is time to augment the federal government’s past and existing EJ work with redoubled investment in community-based data and training.

Plan of Action

EPA should dedicate $20 million of its Justice40 funding to establish the AYA Research Institute: an in-house think tank designed to functionally address EJSCREEN’s limitations as well as increase federal capacity to identify and effectively resolve existing and future EJ issues. The word AYA is the formal name for the Adinkra symbol meaning “resourcefulness and defiance against oppression” — concepts that define the fight for environmental justice.

The Research Institute will comprise three arms. The first arm will increase federal EJ data capacity through an expert advisory group tasked with providing and updating recommendations to inform federal collection and use of EJ data. The advisory group will focus specifically on (i) reviewing and recommending updates to environmental and demographic indicators included in EJSCREEN, and (ii) identifying opportunities for community-based initiatives that could help close key gaps in the data upon which EJSCREEN relies.

The second arm will help grow the pipeline of EJ-focused scientists through a three-year fellowship program supporting doctoral students in applied research projects that exclusively address EJ issues in U.S. municipalities and counties identified as frontline communities. The program will be three years long so that participants are able to conduct much-needed longitudinal studies that are rare in the EJ space. To be eligible, doctoral students will need to (i) demonstrate how their projects will help strengthen EJSCREEN and/or leverage EJSCREEN insights, and (ii) present a clear plan for interacting with and considering recommendations from local EJ grassroots organization(s). Selected students will be matched with grassroots EJ organizations distributed across five U.S. geographic regions (Northeast, Southeast, Midwest, Southwest, and West) for mentorship and implementation support. The fellowship will support participants in achieving their academic goals while also providing them with experience working with community-based data, building community-engagement and science-communication skills, and learning how to scale science policymaking from local to federal systems. As such, the fellowship will help grow the pipeline of STEM talent knowledgeable about and committed to working on EJ issues in the United States.

The third arm will embed EJ expertise into federal decision making by sponsoring a permanent suite of very dominant resident staff, supported by “visitors” (i.e., the doctoral fellows), to produce policy recommendations, studies, surveys, qualitative analyses, and quantitative analyses centered around EJ. This model will rely on the resident staff to maintain strong relationships with federal government and extragovernmental partners and to ensure continuity across projects, while the fellows provide ancillary support as appropriate based on their skills/interest and Institute needs. The fellowship will act as a screening tool for hiring future members of the resident staff.

Taken together, these arms of the AYA Research Institute will help advance Justice40’s goal of improving training and workforce development, as well as the Biden Administration’s goal of better preparing the United States to adapt and respond to the impacts of climate change. The AYA Research Institute can be launched with $10 million: $4 million to establish the fellowship program with an initial cohort of 10 doctoral students (receiving stipends commensurate with typical doctoral stipends at U.S. universities), and $6 million to cover administrative expenses and staff expert salaries. Additional funding will be needed to maintain the Institute if it proves successful after launch. Funding for the Institute could come from Justice40 funds allocated to EPA. Alternatively, EPA’s fiscal year (FY) 2022 budget for science and technology clearly states a goal of prioritizing EJ — funds from this budget could hence be allocated towards the Institute using existing authority. Finally, EPA’s FY 2022 budget for environmental programs and management dedicates approximately $6 million to EJSCREEN — a portion of these funds could be reallocated to the Institute as well.

Conclusion

The Biden-Harris Administration is making unprecedented investments in environmental justice. The AYA Research Institute is designed to be a force multiplier for those investments. Federally sponsored EJ efforts involve multiple programs and management tools that directly rely on the usability and accuracy of EJSCREEN. The AYA Research Institute will increase federal data capacity and help resolve the largest gaps in the data upon which EJSCREEN depends in order to increase the tool’s effectiveness. The Institute will also advance data-driven environmental-justice efforts more broadly by (i) growing the pipeline of EJ-focused researchers experienced in working with data, and (ii) embedding EJ expertise into federal decision making. In sum, the AYA Research Institute will strengthen the federal government’s capacity to strategically and meaningfully advance EJ nationwide. 

Frequently Asked Questions
How does this proposal align with grassroots EJ efforts?

Many grassroots EJ efforts are focused on working with scientists to better collect and use data to understand the scope of environmental injustices. The AYA Research Institute would allocate in-kind support to advance such efforts and would help ensure that data collected through community-based initiatives is used as appropriate to strengthen federal decision-making tools like EJSCREEN.

How does this proposal align with the Climate and Economic Justice Screening Tool (CEJST) recently announced by the Biden administration?

EJSCREEN and CEJST are meant to be used in tandem. As the White House explains, “EJSCREEN and CEJST complement each other — the former provides a tool to screen for potential disproportionate environmental burdens and harms at the community level, while the latter defines and maps disadvantaged communities for the purpose of informing how Federal agencies guide the benefits of certain programs, including through the Justice40 Initiative.” As such, improvements to EJSCREEN will inevitably strengthen deployment of CEJST.

Has a think tank ever been embedded in a federal government agency before?

Yes. Examples include the U.S. Army War College Strategic Studies Institute and the Asian-Pacific Center for Security Studies. Both entities have been successful and serve as primary research facilities.

What criteria would the AYA Research Institute use to evaluate doctoral students who apply to its fellowship program?

To be eligible for the fellowship program, applicants must have completed one year of their doctoral program and be current students in a STEM department. Fellows must propose a research project that would help strengthen EJSCREEN and/or leverage EJSCREEN insights to address a particular EJ issue. Fellows must also clearly demonstrate how they would work with community-based organizations on their proposed projects. Priority would be given to candidates proposing the types of longitudinal studies that are rare but badly needed in the EJ space. To ensure that fellows are well equipped to perform deep community engagement, additional selection criteria for the AYA Research Institute fellowship program could draw from the criteria presented in the rubric for the Harvard Climate Advocacy Fellowship.

What can be done to avoid politicizing the AYA Research Institute, and to ensure the Institute’s longevity across administrations?

A key step will be grounding the Institute in the expertise of salaried, career staff. This will offset potential politicization of research outputs.

What is the existing data the EJSCREEN is using?

EJSCREEN 2.0 is largely using data from the 2020 U.S. Census Bureau’s American Community Survey, as well as many other sources (e.g., the Department of Transportation (DOT) National Transportation Atlas Database, the Community Multiscale Air Quality (CMAQ) modeling system, etc.) The EJSCREEN Technical Document explicates the existing data sources that EJSCREEN relies on.

7. What are the demographic and environmental indicators of interest included in EJSCREEN?

The demographic indicators are: people of color, low income, unemployment rate, linguistic isolation, less than high school education, under age 5 and over age 64. The environmental indicators are: particulate matter 2.5, ozone, diesel particulate matter, air toxics cancer risk, air toxics respiratory hazard index, traffic proximity and volume, lead paint, Superfund proximity, risk management plan facility proximity, hazardous waste proximity, underground storage tanks and leaking UST, and wastewater discharge.

Senators press the nominee to lead the Environmental Protection Agency on the administration’s plans for promoting environmental justice

Environmental justice is a priority for the Biden administration, with the president advocating for the use of a whole-of-government approach based on the latest science to improve environmental conditions in low-income communities and communities of color. When pressed to expand on the administration’s vision during Wednesday’s Senate Environment and Public Works Committee hearing, Michael Regan, the president’s nominee for Administrator of the Environmental Protection Agency (EPA), offered an initial slate of actions the administration will take to work toward environmental justice.

Effects of pollution on underserved communities

Ensuring environmental justice means that no one bears a “disproportionate share of the negative environmental consequences resulting from industrial, governmental, and commercial operations or policies.” Historically, pollution-emitting facilities have often been constructed in low-income or minority communities. In 2018, the EPA National Center for Environmental Assessment released a study which found that people who lived in poverty were exposed to more damaging particulate matter 2.5 micrometers or smaller (PM 2.5) in the air than more affluent communities. Researchers in the academic community have published similar results. PM 2.5 exposure has been found to contribute to asthma, low birth weights, high blood pressure, and a variety of other health conditions. Because of this, low-income and minority communities have likely experienced an inordinate amount of PM 2.5-related health impacts.

Several recent incidents have brought greater attention to environmental justice issues, particularly the Flint, Michigan water crisis, in which thousands of children were exposed to highly toxic lead in the water supply, and “Cancer Alley” in Louisiana, where residents have been slowly poisoned by the emissions from nearby chemical plants. During the hearing, Senator Cory Booker (D-NJ) noted that a person’s skin color is one of the strongest indicators that they will live in a polluted environment. Senators Jeff Merkley (D-OR)Ed Markey (D-MA), and Tammy Duckworth (D-IL) echoed this sentiment, calling on Mr. Regan to explain the administration’s plan for improving the environmental living conditions of low-income and minority communities.

The Biden administration and environmental justice

Mr. Regan acknowledged the Senators’ concerns and laid out his initial steps for incorporating environmental justice issues into the EPA’s future work. These steps include:

Mr. Regan has had extensive experience with environmental justice issues during his time as the Secretary of North Carolina’s Department of Environmental Quality. As secretary, he formed the state’s first Environmental Justice and Equity Board, which brought together a diverse set of stakeholders to help the state government issue consistent, equitable policies regarding environmental health issues. Mr. Regan also spearheaded a multi-billion dollar settlement with Duke Energy to clean up several large coal ash ponds which were contaminating the water supply and the air, the most costly coal ash cleanup project in the country. During his nomination hearing, Mr. Regan assured the Committee that he will draw on his experience in North Carolina to lead the EPA during this new administration.

Environmental justice now a top federal priority

Environmental justice has quickly become a leading priority for both the White House and Congress as the Biden administration ramps up. It is likely that Congress will hold more hearings on this issue featuring numerous experts from the private and public sectors. We will be tracking this issue closely and encourage the CSPI community to get involved by sending in your questions and ideas to future Calls to Action.

A Carbon Tax to Combat Climate Change and Support Low-Income Households

Summary

Putting a price on carbon is fundamental to achieving U.S. climate goals for 2050. Many options for carbon price-setting exist, and in this policy brief we propose a tax-and-dividend approach that mitigates the challenging impacts that carbon policies have on poor and suburban/rural communities, particularly those in Middle America. Such a plan will be a net gain for low-income households, in contrast to other proposed climate change policies which will adversely affect the poor. Furthermore, it has been shown that even a modest carbon tax can have large benefits in terms of cost-effectiveness.

For that reason, we propose the following: