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:
- Federal agencies reported tangible progress on half of the WHEJAC’s Justice40 recommendations, such as reducing exposure to lead and investing in the LIHEAP program to lower home energy bills.
- While this progress is commendable, it is important to note that agency-reported progress does not always match the lived reality of stakeholders. There is an opportunity and a need for the WHEJAC and federal agencies to co-develop strategies for tracking Justice40 implementation that incorporate multiple perspectives (e.g., from government officials, impacted communities, local leaders, and independent experts).
- Agencies struggled to implement a quarter of the recommendations due to barriers such as lack of statutory authority, lack of resourcing, or lack of clarity on what particular actions would constitute implementation. The WHEJAC should consider revisiting and revising these recommendations to improve actionability.
- There are clear pathways for the White House Environmental Justice Interagency Council (IAC), working with CEQ, to facilitate near-term progress on a number of the WHEJAC’s recommendations that have gone largely unfulfilled to date. In parallel, there are a number of high-interest topic areas—including clean transit and transportation, urban forestry and urban greening, and varied aspects of climate mitigation and resiliency—for which the WHEJAC should consider building out additional recommendation.
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:
- Section 1 (Summary of agency-reported progress) describes how we evaluated agency-reported progress on the WHEJAC’s Justice40 recommendations. We found that agencies detailed tangible progress for about half (50%) and did not illustrate tangible progress for about a quarter (24%) of the recommendations. Implementation status could not be assessed for the remainder. The assessment supplement maps each recommendation to its corresponding agency response(s) and to its corresponding quantitative and qualitative evaluations from FAS.
- Section 2 (Improving existing recommendations) identifies Justice40 recommendations that could not be fully implemented because of (i) a lack of statutory authority, (ii) inappropriate assignment of the recommendation to a particular agency or agencies, (iii) lack of resources, and/or (iv) vague language. This section also provides suggestions for how the WHEJAC may wish to revisit and/or strengthen the recommendations in question.
- Section 3 (Prioritizing progress on unfulfilled recommendations) highlights Justice40 recommendations which the IAC may wish to consider as priorities for future progress. FAS selected these recommendations based on holistic evaluation of (i) recommendation feasibility, (ii) indicated agency willingness to pursue additional responsive action, and (iii) whether there is a clear role for the IAC to play in facilitating implementation.
- Section 4 (Building out additional recommendations) identifies high-interest topics for which the WHEJAC provided few or no recommendations. As it continues its work, the WHEJAC may wish to consider building out additional recommendations for agency action related to these topics. These topics include:
- Clean energy beyond solar power
- Clean transit and transportation
- Urban forestry and urban greening
- Drinking-water pollutants beyond lead
- Ensuring environmental justice for migrant and seasonal workers
- Varied aspects of climate mitigation and resiliency
- Linguistic isolation
- Section 5 (Implementation highlights) draws attention to Justice40 recommendations where FAS identified particularly notable progress on implementation. These highlights are both independently commendable and indicate areas with momentum that the WHEJAC and IAC can leverage for follow-on work.
Read the full assessment:
- Assessment of progress on the White House Environmental Justice Advisory Council (WHEJAC)’s Justice40 recommendations
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