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EPA's Science Advisory Board (SAB) seeks comments on its review report of the EPA’s Draft Revised Environmental Justice Technical Guidance (EJTG), which reviews the methods and procedures described in EPA’s Draft Revised EJTG for evaluating environmental justice concerns in regulatory actions. Policy Integrity submitted comments making four key recommendations that the SAB can use to advise EPA.

In June, the Department of Energy (DOE) released draft goals for its Environmental Justice Strategic Plan and requested feedback through public comments. Executive Order 14,096 directs each federal agency to create an environmental justice strategic plan that “sets forth the agency’s vision, goals, priority actions, and metrics to address and advance environmental justice.” Our comments suggested that DOE should include objectives under their proposed goals to develop and issue agency-wide guidance on how to consider and analyze environmental justice concerns in their regulatory and policy actions. 

EPA's Science Advisory Board (SAB) sought comments on its draft peer review report on EPA’s Draft Revised Environmental Justice Technical Guidance (EJTG). This report reviews the methods and procedures described in EPA’s Draft Revised EJTG for evaluating environmental justice concerns in regulatory actions. The Institute for Policy Integrity submitted comments making three key recommendations that the SAB can use to advise EPA.

On April 30, CEQ revised its implementing regulations for the National Environmental Policy Act that undergird how federal agencies conduct environmental review of proposed projects. Consistent with federal caselaw, CEQ’s regulations emphasize the need to consider climate change and environmental justice impacts in environmental review, among other key revisions. These revisions are also consistent with suggestions that Policy Integrity has offered through our scholarship, reports, and comments on ensuring careful consideration of climate change and environmental justice in federal permitting. In addition, CEQ implemented several of Policy Integrity’s suggestions to enhance its cost-benefit analysis for this rulemaking.

In December 2023, the New York State Department of Environmental Conservation and New York State Energy Research and Development Authority released the Draft Climate Act Disadvantaged Communities Investment and Benefits Reporting Guidance for public comment. The draft guidance proposed a methodology to be used by New York State agencies, authorities, and entities to account for and report the benefits of their clean energy and energy efficiency spending accrued in disadvantaged communities and across the state overall. This information will then be used to calculate the State’s compliance with the Climate Leadership and Community Protection Act’s requirement that a minimum of 35 percent, with a goal of 40 percent, of the benefits of clean energy and energy efficiency spending accrue to disadvantaged communities. In comments, we gave suggestions on how to improve the guidance.

EPA seeks comments on the it's Draft Revised EJ Technical Guidance, which highlights technical approaches that analysts can use to evaluate environmental justice concerns in regulatory actions. The Institute for Policy Integrity's comments to the agency advocate for enhanced documentation and transparency in environmental justice assessments.

The Council on Environmental Quality (CEQ) recently published Phase One of the Environmental Justice Scorecard (Scorecard), which evaluates federal agencies' progress on advancing the Justice40 Initiative, implementing and enforcing environmental and civil rights laws, and institutionalizing environmental justice. CEQ sought public feedback on the Scorecard’s usability and potential qualitative and quantitative metrics to improve future iterations of the Scorecard. The Institute for Policy Integrity submitted comments recommending several changes to enhance transparency, accountability, and comprehensiveness.