CEQ’s Climate and Economic Justice Screening Tool Needs to Consider How Burdens Add Up
In November 2022, the White House Council on Environmental Quality (CEQ) launched a significant update to the Climate and Economic Justice Screening Tool (CEJST), a key step towards meeting the goals of the Biden Administration’s Justice40 Initiative and broader environmental justice agenda. The Justice40 Initiative aims to direct 40% of the benefits of federal climate and clean energy investments to disadvantaged communities.
Two years from its inception, the Justice40 Initiative is taking on fresh urgency as federal agencies are gearing up to target billions of dollars in investment to disadvantaged communities. Federal spending on climate and clean energy programs is expected to more than triple this decade compared to the 2010s. Sixteen federal agencies have identified over 400 programs, including those that were created or funded in the Inflation Reduction Act of 2022 and the Bipartisan Infrastructure Law of 2021, that will invest in disadvantaged communities that bear disproportionate environmental, health and socioeconomic burdens due to historic injustices and impacts of climate change.
In this regard, CEJST is a critical component to help federal agencies, other policymakers and stakeholders identify disadvantaged communities and ensure that resources are being delivered to those who need it the most.
CEJST, version 1.0, builds on a beta version that was released in early 2022 and received ample public feedback, including from WRI. CEJST identifies disadvantaged communities through eight categories of disadvantaged status including climate change, energy, health, housing, legacy pollution, transportation, water and wastewater, and workforce development. Census tracts — home to an average 4,000 residents — are identified as disadvantaged if they meet 90th percentile thresholds for indicators within any of the eight categories and are at or above the 65th percentile for low-income.
CEJST 1.0 now includes:
- Nine new indicators related to historically redlined communities, availability of greenspace and indoor plumbing, legacy pollution from abandoned mines and defense sites, projected climate risks from flooding and wildfires, transportation barriers and water pollution from underground storage tanks.
- Communities within the boundaries of Federally Recognized Tribes, including Alaska Native Villages, as disadvantaged communities.
- Communities that are completely surrounded by other disadvantaged communities and are at or above the 50th percentile for low-income as disadvantaged communities.
This article assesses how such revisions to CEJST impact the identification of disadvantaged communities, key characteristics of such communities and important considerations for federal policymakers and other stakeholders who plan to use the tool to aid such communities. Our analysis finds that CEJST 1.0, while an improvement on its beta version, still fails to account for the multidimensional burdens borne by disadvantaged communities — with communities of color bearing the heaviest cumulative burden. Here are our three major takeaways:
1. CEJST 1.0 Identifies More People Living in Disadvantaged Communities
Thirty-three percent of the U.S. population, or 109.1 million individuals, are living in disadvantaged communities as defined by CEJST 1.0, compared to 93.5 million individuals (29% of U.S. population) identified in CEJST Beta. Designating 33% of the population eligible for Justice40 funds underscores the need to ensure Justice40 exceeds its minimum goal of directing 40% of benefits to disadvantaged communities for it to meaningfully reduce inequalities.
The share of the population living in disadvantaged communities increased in almost every state. Among the 50 U.S. states and District of Columbia, Wyoming sees the most significant increase, with the share of residents in disadvantaged communities doubling to 14% of residents. Oklahoma and South Dakota also see significant increases in the share of their populations identified as living in disadvantaged communities — 90% and 69% respectively.
Over half of residents in Oklahoma, Mississippi, West Virginia, Arkansas and New Mexico live in disadvantaged communities, the highest among states. Furthermore, more than 90% of populations in American Samoa, the Northern Mariana Islands and Puerto Rico live in disadvantaged communities.
New indicators for transportation barriers, underground water storage, projected flood risk, access to greenspace and lack of indoor plumbing drive much of the overall increase in the number of communities identified as disadvantaged. Some indicators are especially relevant for particular states, as environmental impacts and exposure differ with industrial activities, historical context and locally specific factors. For example, over 50% of the population in disadvantaged communities with abandoned mine land are spread across five states (Kentucky, West Virginia, Ohio, Alabama and Pennsylvania), with West Virginia home to the highest share (46% of its population) meeting the threshold.
Other indicators are more prominent in other parts of the country. Large-scale wildfires for example, are increasingly severe and growing more so due to climate change. WRI analysis of CEJST Beta highlighted how the absence of forward-looking climate risk indicators may underestimate vulnerabilities. With the addition of new climate-risk indicators, more than 9.8 million individuals live in communities that meet the projected wildfire risk threshold, while 11.8 million individuals live in communities that meet the projected flood risk threshold. Over half of people living over these two risk thresholds are found in three states — California, Texas and Florida. Wildfire risk is also a major driver of the increase in disadvantaged populations in western regions like Wyoming, where over 62% of people in disadvantaged communities reside in places that meet the threshold.
Meanwhile, analysis by the Native Lands Advocacy Project urged the inclusion of all federally recognized tribal lands as disadvantaged communities to avoid splitting populations on reservations across census tracts, and because of the “unique historic relationship between Tribes and federal government.” This has particular impact in states like Oklahoma, where 79% of the disadvantaged population in tribal areas across the U.S. are located, and where 81% of the state’s disadvantaged population lives in communities within tribal areas.
2. Persons of Color and Indigenous Populations are More Likely to Reside in Disadvantaged Communities, while the Overall Demographics of Disadvantaged Communities have Grown Whiter
CEJST Beta was met with strong criticism for excluding race as an indicator due to legal concerns. CEJST 1.0 indirectly addresses race by adding the historic underinvestment indicator, which reflects neighborhoods that were marked less suitable for investment due to the presence of non-white residents. This practice, known as redlining, began in the 1930s when the federal government’s Home Owner’s Loan Corporation drew actual red lines on maps to denote predominantly Black and immigrant neighborhoods as “hazardous,” which subsequently saw lower levels of investments and services compared to their white counterparts. Redlining was outlawed by the 1968 Fair Housing Act but its legacy endures. Today, these redlined areas have disproportionately high Black and minority populations, lower incomes and home values, less socioeconomic mobility, more air pollution, higher temperatures and worse health outcomes compared to otherwise similar areas.
This indicator, as well as data from indicators for access to greenspace and proximity to underground storage tanks, captures higher shares of minority populations. Sixty-eight to 72% of residents meeting the threshold for these indicators identify as Hispanic/Latino, Black or Native.
While the white population remains least likely to reside in a disadvantaged community, the share of this group in disadvantaged communities increases in CEJST 1.0. This is partly due to the addition of indicators that change “who” is burdened across different parts of the country.
For example, over 80% of people in communities that meet the abandoned mines threshold are white — unsurprising given over half live in a handful of predominantly white states like West Virginia, Ohio and Kentucky. Likewise, communities meeting thresholds for new indicators like transportation barriers and proximity to formerly used defense sites also tend to be white.
In contrast, a vast majority (67% to 85%) of the population in disadvantaged communities experiencing burdens related to hazardous waste and diesel particulate matter (PM 2.5) exposure, diabetes, housing burden, proximity to traffic and underground storage tanks and workforce development indicators are Hispanic/Latino, Black and Native.
Altogether, updates to CEJST shift the overall demographic composition of the population in disadvantaged communities. The white population now makes up about 40% of the population in disadvantaged communities, up from 36% in CEJST Beta, while the share of other groups decreases. However, Black, Indigenous and people of color populations are disproportionately exposed to a higher number of burdens.
3. Those Experiencing a Combination of Environmental, Socioeconomic and Health-Related Burdens are More Likely Non-White
While additional indicators have been added to the tool, CEJST 1.0 still does not incorporate a measure of cumulative burden — total harm to communities that occurs due to a combination of environmental, socioeconomic and health-related burdens. A disadvantaged community meeting multiple criteria has the same designation as a disadvantaged community meeting one criteria and does not receive any prioritization for funding. The number of indicator thresholds met by disadvantaged communities ranges from 1 to 18.
More than 7.1 million residents (7% of the population in disadvantaged communities) live in disadvantaged communities meeting 10 or more indicator thresholds. Over 4,000 individuals reside in census tracts in Ohio and Louisiana that meet the threshold for 18 indicators. On the other hand, half of disadvantaged communities — representing over 57 million people — meet the threshold of three indicators or fewer.
CEJST 1.0: Number of indicator thresholds met by disadvantaged communities
Zoom in and hover over specific locations on the map with your mouse or trackpad to see the number of indicators for each community, signifying where Justice40 investments might be needed most.
Disadvantaged communities experiencing higher cumulative burdens are more non-white than those exposed to fewer. In communities that meet the threshold for 10 indicators, 35% of residents are Hispanic/Latino, 41% are Black and 17% are white. By contrast, in disadvantaged communities meeting three indicator thresholds, 28% of residents are Hispanic/Latino, 15% are Black and 50% are white.
Cleveland, Ohio, where the Cuyahoga River fires prompted a wave of environmental justice efforts during the 1960s and the eventual passage of the Clean Water Act in 1972, offers one example. CEJST identifies 39% of Cleveland’s Cuyahoga County (more than 487,000 individuals) as residents of disadvantaged communities, meeting anywhere from 1 to 18 criteria. Communities that experienced historic underinvestment register notably higher levels of cumulative burden — an average of about 11 indicators compared to the non-redlined average of about six indicators.
This pattern highlights how years of discriminatory policies have led to much higher cumulative burdens among communities of color. To illustrate another example, U.S. highways were deliberately built through Black neighborhoods. As a result, our traffic’s air pollution disproportionately impacts these same communities, as does the asthma that results from it. While only the first step had an explicit racial motive, all of the ensuing consequences have race at the root.
Race is absent from CEJST as an indicator despite its role as the most consistent predictor of environmental burden, but its impact is still visible in the pattern of cumulative burden disadvantaged communities experience. Addressing cumulative impacts is, therefore, a key part of advancing environmental justice. While screening tools can help identify disadvantaged communities, policymakers will need to account for the multidimensionality of the challenges they face in order to effectively prioritize and support them.
Key Considerations to Make CEJST 1.0 More Effective
CEJST 1.0 is not meant to be a static tool and is expected to go through improvements in future iterations. Below we offer potential improvements and suggestions to enable more effective use of the tool by different stakeholders.
- Direct agencies to consider cumulative burden when allocating funding now, and update CEJST to measure it. A screening tool whose explicit purpose is to target federal funding to disadvantaged communities most in need of those resources should not be treating each community as equal in levels of need. Justice40 programs should target communities with high cumulative burden, which are more likely to be communities of color, for the earliest and most investment. Agencies working to address a specific dimension of disadvantage — whether housing, energy, health or transportation — should weigh whether a community is subject to additional burdens outside their jurisdiction when designing programs and considering funding applications. Communities subject to particularly high levels of burden should receive proactive outreach, more time to complete applications for federal funding, waived cost-share requirements and additional support that increases their capacity to plan for, apply for and steward federal monies. Further, across the eight categories of burden included in CEJST 1.0, the workforce development, housing and health categories identify the most people of color compared to other categories. This highlights that spending through Justice40 programs to address inequities in these three categories will tend to benefit people of color. Lastly, methods of incorporating assessments of cumulative burden into environmental justice screening tools exist— from simply adding up the indicators meeting thresholds, to applying agency-specific weights to certain indicators, to adopting a composite indexing or scoring method as has been done by CalEnviroScreen. CEQ should review which method is most appropriate and update CEJST to incorporate it, rather than leaving it to federal agencies to choose how they might want to prioritize funding amongst disadvantaged communities.
- Identify severely burdened communities as disadvantaged even if they do not meet the low-income indicator. A census tract qualifies as a disadvantaged community only when they meet the threshold for one or more indicators across the eight categories and meets the low-income threshold (except for workforce, which uses high school education as a qualifying socio-economic indicator). Our analysis reveals that there are more than 2,700 census tracts where approximately 10 million people meet the threshold for five or more indicators but do not qualify as a disadvantaged community because they do not meet the low-income criteria. Of this, 3.8 million people live in majority non-white census tracts. The low-income indicator can be set such that it is easier to meet for census tracts with severe environmental, health and economic burden and more difficult to meet for those with fewer burdens. This could be achieved by waiving the low-income criteria for communities meeting the threshold for a certain number of indicators or lowering the threshold (currently set at the 65th percentile) as communities’ environmental, health and economic burdens increase.
- Continue to iterate upon and improve the tool. CEJST 1.0 already includes new data that makes it more robust than CEJST Beta. CEQ has said the tool will be updated “at least annually,” and these updates should include not simply fresh data but improved methods for measuring indicators and the addition of new relevant ones. The National Academies’ Committee on Utilizing Advanced Environmental Health and Geospatial Data and Technologies to Inform Investment, which has been tasked with identifying gaps in data availability and quality and suggesting improvements, can be an important resource. Furthermore, it will be important for CEQ to dispel confusion about how federal agencies will use CEJST to target funding to disadvantaged communities and how various subnational actors should use CEJST to identify disadvantaged communities when applying for federal funding. The latest guidance to federal agencies notes that they “may use their own data and metrics to prioritize certain communities within the set of disadvantaged communities identified by the CEJST.” While this is an important step, additional clarifications are needed, including around how federal agencies are using and/or modifying CEJST to help with their decision making, whether subnational actors can use state-specific screening tools if they have them instead of CEJST, or whether they can substitute local data for measuring an indicator included in CEJST 1.0 if they have more granular and richer data to capture state-specific characteristics.
- Implement a framework for monitoring and evaluation to ensure that benefits are really flowing to disadvantaged communities. The success of Justice40 depends on its implementation. At a minimum, federal agencies should assess their progress in meeting the goals of Justice40 by tracking both the amount and the share of federal funding that is flowing to disadvantaged communities. Furthermore, given that the goal of Justice40 is to deliver at least 40% of the overall benefits from certain federal investments to disadvantaged communities, there is a need to identify what is meant by those benefits (i.e., pollutants and carbon emissions reduced, number of jobs created) and require federal agencies to track those metrics for Justice40 investments. The forthcoming Environmental Justice Scorecard from CEQ is meant to assess progress being made by the federal government on its EJ efforts. Until its release, however, there is uncertainty around how federal agencies are tracking impact and benefits.