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5 Ways to Optimize IRA Grants’ Contribution to Environmental Justice
December 19, 2022
Watching the most recent meeting of Environmental Protection Agency’s (EPA) National Environmental Justice Advisory Committee (NEJAC) in Puerto Rico was, as so many NEJAC meetings are, both inspiring and infuriating: I am inspired by the experience and dedication of the NEJAC members and the endurance and resourcefulness of the communities and the community-based organization that are doing so much with so little. I also am infuriated by the problems they and the public commenters must manage. As a nation we can and must do better to address and solve environmental justice issues.
The Inflation Reduction Act Provides a Path Forward
The Inflation Reduction Act (IRA) is not only a huge government investment in reducing U.S. climate emissions, it is also an enormous investment in environmental justice. The IRA establishes the Environment and Justice and Climate Grant Program (ECJ Grants) totaling $3 billion with $2.8 billion for grants and $200 million specifically set aside for technical support to low-income and disadvantaged communities. The ECJ Grants alone will increase the amount of money that the Office of Environmental Justice and External Civil Rights will have to provide to communities from prior presidential administrations by a factor of 60.
The money will fund significant emission reductions, but it can do much more than that. If spent correctly, the funds can build increased social capital, providing local jobs and economic assets for communities that have historically received little if any government investment. This provides a great opportunity to make gains towards EPA’s environmental justice goals.
Guiding the Money to Where it’s Needed Most
One of the NEJAC sessions focused on the Environmental and Climate Justice Grant Program, which will have over $2 billion in grant funding to distribute. But just because money is available does not mean that it will benefit those who need it most. The program must be carefully designed to ensure that money won’t be skimmed or misdirected away from the people who need it most. Based on the discussion and a later question and answer session, it appears that EPA is aware of the problem and being thoughtful about crafting solutions and getting the right input.
Five Potential Solutions
Based on what I heard at NEJAC, the following is a list of potential actions to help ensure low-income and disadvantaged communities receive the funds intended for them:
1.Set scoring rules which favor less money being spent on overhead. Ideally, the amount applicants are taking for overhead versus applying directly to solutions should be considered in grant decisions. Local and tribal governments and universities may bring a lot to the table, but they are not the reason these programs exist, communities and the environment are. Although there are limits to EPA’s authority to limit overhead charges, grant scoring systems could give bonus points to grants with lower overhead costs.
2.Community-based organizations must have the lead role in determining where money goes. Part of a potential grantee’s plan should include how decisions are made in the partnership. Partnership agreements need to be part of a grant application, and technical assistance needs to show community-based organizations how to set up a partnership where they are in charge.
3.Limit “nepotism.” I am talking about a different kind of nepotism. In the past NEJAC shared examples of large institutions sending former employees to set up new non-profits that magically get most of the money from those institutions. Grantees should have plans in place to ensure that all forms of nepotism are prevented.
4.No money for brand new community-based organizations. The IRA is a huge pile of money and large piles of money sometimes attract people who are only looking out for themselves. Longer records of authentic community representation should be rewarded. While there undoubtedly will be new groups created by people with the purest of intentions, the risks are simply too great.
5.Reporting requirements for community-based organizations should be simplified so smaller groups can still get funding. EPA could develop a simple process for groups to report the results of their work. Complicated reporting requirements can make it difficult for the smaller groups to apply and win funds, and also can inadvertently serve as an exclusionary tool that ensures the large groups that have traditionally received funding continue to do so.
These rules or other innovative ideas are needed to ensure that not only the environment but the communities that need the most help receive the investments that they have long been denied. We must change the way the game is played if we want a different score at the end.