Justice40: Use of Leading Practices Would Strengthen Efforts to Guide Environmental Justice Initiative
Fast Facts
Some U.S. communities face heavy socioeconomic and environmental burdens like high rates of poverty, disease, and pollution. The Justice40 Initiative goal is for 40% of benefits from certain federal grants and programs to flow to disadvantaged communities.
The Executive Office of the President collaborated with federal agencies, nonfederal entities, and federally recognized Tribes to develop Justice40 guidance and tools, such as a tool to identify disadvantaged communities. They followed some leading practices, but can do more going forward—such as clarifying roles and responsibilities and assessing progress. Our recommendations address this.
Gowanus Canal Superfund Sediment Site, Brooklyn, NY
Highlights
What GAO Found
The Justice40 Initiative's goal is for 40 percent of the overall benefits of certain federal investments to flow to disadvantaged communities that have been historically marginalized and overburdened. To develop guidance and tools for implementing the initiative, the Executive Office of the President (EOP) took steps to collaborate with federal and nonfederal entities. EOP worked with the White House Environmental Justice Interagency Council, an advisory council, 21 Justice40 pilot programs at nine agencies, and others to develop interim guidance, a tool to identify disadvantaged communities, and a scorecard to track progress. EOP's efforts partially reflected leading practices for collaboration. For example, EOP included relevant entities in its collaboration efforts but has not clarified the roles and responsibilities of the Interagency Council.
Seven Investment Areas of the Justice40 Initiative
Additionally, over half of the Justice40 pilot programs that GAO surveyed answered that the guidance and tools in place at the time were useful. However, some programs faced challenges, such as unclear guidance. According to GAO's analysis, EOP did not systematically gather feedback on programs' experience with the guidance and tools. By more fully incorporating leading practices for collaboration, such as by systematically gathering feedback and clarifying the roles and responsibilities of the Interagency Council, EOP can better ensure that its guidance and tools provide an effective, timely, and consistent framework for Justice40 implementation.
EOP took initial steps to collect some data on agencies' Justice40 actions and published the first annual scorecard. However, EOP has not established a process for assessing implementation of the Justice40 Initiative. By incorporating key practices for effectively managing and assessing the results of federal efforts as it establishes such a process, EOP can better ensure accountability, transparency, and progress toward achieving the goal of the initiative.
Why GAO Did This Study
In February 2021, Executive Order 14008 directed federal agencies to take action to address the disproportionately high and adverse human health, environmental, climate-related, and other cumulative impacts on disadvantaged communities. As part of this effort, the executive order established the Justice40 Initiative. The initiative is led by EOP, specifically the Council on Environmental Quality (CEQ), Office of Management and Budget, and Climate Policy Office. It currently covers more than 500 federal programs at 19 agencies, which involve billions of taxpayer dollars.
GAO was asked to review implementation of the Justice40 Initiative. This report examines the extent to which (1) EOP collaborated with federal and nonfederal entities to develop guidance and tools for implementing the initiative; (2) pilot programs found EOP's guidance and tools useful; and (3) EOP established a process for assessing federal efforts to achieve the goal of the initiative.
GAO reviewed executive orders and EOP documents; interviewed EOP staff, agency officials, and nonfederal entities; analyzed survey responses from 20 of 21 Justice40 pilot programs; and compared EOP efforts with leading practices.
Recommendations
GAO is making 15 recommendations, including that the EOP entities leading the initiative incorporate leading practices for collaboration into their Justice40 efforts. EOP neither agreed nor disagreed, but CEQ stated that it anticipates taking steps to implement our recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Council on Environmental Quality | 1. The Chair of CEQ, jointly with the Assistant to the President and National Climate Advisor of CPO and the Director of OMB, should work with the Interagency Council to clarify and document the roles and responsibilities of the Interagency Council in updating and developing new guidance and tools for implementing the Justice40 Initiative. (Recommendation 1) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Management and Budget | 2. The Director of OMB, jointly with the Chair of CEQ and the Assistant to the President and National Climate Advisor of CPO, should work with the Interagency Council to clarify and document the roles and responsibilities of the Interagency Council in updating and developing new guidance and tools for implementing the Justice40 Initiative. (Recommendation 2) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Domestic Climate Policy | 3. The Assistant to the President and National Climate Advisor of CPO, jointly with the Chair of CEQ and the Director of OMB, should work with the Interagency Council to clarify and document the roles and responsibilities of the Interagency Council in updating and developing new guidance and tools for implementing the Justice40 Initiative. (Recommendation 3) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Council on Environmental Quality | 4. The Chair of CEQ, jointly with the Assistant to the President and National Climate Advisor of CPO and the Director of OMB, should work with WHEJAC members and WHEJAC administrative officials to assess WHEJAC's communication needs with EOP, and then, as appropriate, develop methods for meeting those needs. (Recommendation 4) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Management and Budget | 5. The Director of OMB, jointly with the Chair of CEQ and the Assistant to the President and National Climate Advisor of CPO, should work with WHEJAC members and WHEJAC administrative officials to assess WHEJAC's communication needs with EOP, and then, as appropriate, develop methods for meeting those needs. (Recommendation 5) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
|
| Office of Domestic Climate Policy | 6. The Assistant to the President and National Climate Advisor of CPO, jointly with the Chair of CEQ and the Director of OMB, should work with WHEJAC members and WHEJAC administrative officials to assess WHEJAC's communication needs with EOP, and then, as appropriate, develop methods for meeting those needs. (Recommendation 6) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Council on Environmental Quality | 7. The Chair of CEQ, jointly with the Assistant to the President and National Climate Advisor of CPO and the Director of OMB, should work with the Interagency Council to identify and leverage resources available through the Interagency Council to update and develop new guidance and tools for implementing the Justice40 Initiative. (Recommendation 7) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Management and Budget | 8. The Director of OMB, jointly with the Chair of CEQ and the Assistant to the President and National Climate Advisor of CPO, should work with the Interagency Council to identify and leverage resources available through the Interagency Council to update and develop new guidance and tools for implementing the Justice40 Initiative. (Recommendation 8) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Domestic Climate Policy | 9. The Assistant to the President and National Climate Advisor of CPO, jointly with the Chair of CEQ and the Director of OMB, should work with the Interagency Council to identify and leverage resources available through the Interagency Council to update and develop new guidance and tools for implementing the Justice40 Initiative. (Recommendation 9) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Council on Environmental Quality | 10. The Chair of CEQ, jointly with the Assistant to the President and National Climate Advisor of CPO and the Director of OMB, should establish and document a formal approach for systematically gathering feedback from agencies and their covered programs about the adequacy of EOP's guidance and tools for implementing the Justice40 Initiative. (Recommendation 10) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Management and Budget | 11. The Director of OMB, jointly with the Chair of CEQ and the Assistant to the President and National Climate Advisor of CPO, should establish and document a formal approach for systematically gathering feedback from agencies and their covered programs about the adequacy of EOP's guidance and tools for implementing the Justice40 Initiative. (Recommendation 11) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Domestic Climate Policy | 12. The Assistant to the President and National Climate Advisor of CPO, jointly with the Chair of CEQ and the Director of OMB, should establish and document a formal approach for systematically gathering feedback from agencies and their covered programs about the adequacy of EOP's guidance and tools for implementing the Justice40 Initiative. (Recommendation 12) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Council on Environmental Quality | 13. The Chair of CEQ, jointly with the Director of OMB, and the Assistant to the President and National Climate Advisor of CPO, should establish and document a process for assessing progress toward achieving the goal of the Justice40 Initiative that incorporates key practices for evidence-building and performance-management activities. (Recommendation 13) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Management and Budget | 14. The Director of OMB, jointly with the Chair of CEQ and the Assistant to the President and National Climate Advisor of CPO, should establish and document a process for assessing progress toward achieving the goal of the Justice40 Initiative that incorporates key practices for evidence-building and performance-management activities. (Recommendation 14) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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| Office of Domestic Climate Policy | 15. The Assistant to the President and National Climate Advisor of CPO, jointly with the Chair of CEQ and the Director of OMB, should establish and document a process for assessing progress toward achieving the goal of the Justice40 Initiative that incorporates key practices for evidence-building and performance-management activities. (Recommendation 15) |
In written comments reproduced in our report, CEQ stated that it anticipates taking steps in the coming months to implement our recommendations on leading practices. We will update the status of this recommendation when we receive additional information from the agencies.
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