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Comments to CEQ on Phase One of the Environmental Justice Scorecard

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:

  • CEQ should disclose the process through which it solicits information to develop the Scorecard;
  • The Scorecard should add a metric that assesses whether agencies articulate how their work affects environmental justice communities on their websites; 
  • The Scorecard should include new metrics that assess the environmental justice outcomes of agency actions and agencies’ year-to-year progress; 
  • The Scorecard should show all reporting categories for each agency, even when those metrics are not applicable to an agency’s work or an agency did not report any information;
  • The Scorecard should note why information on certain reporting categories are omitted for individual agencies, where applicable; and
  • The Scorecard should provide more a more comprehensive review of:
    • Justice40 covered programs and associated funding and benefits
    • Environmental and civil rights protections
    • Centering environmental justice in decisionmaking
    • Institutionalizing environmental justice 

These suggested changes could provide environmental justice stakeholders with a comprehensive view of agencies’ progress, which would better equip them to ensure agencies fulfill their environmental justice commitments.