Incorporating Environmental Justice in State Climate Planning, with Lessons from California

Around the country, in blue states and red, policymakers are engaging in climate action planning, guided by a far-seeing Inflation Reduction Act funding program — the Carbon Pollution Reduction Grant (CPRG) program — which has devoted $250 million to state, metropolitan, and Tribal planning efforts. A new report from the Center for Progressive Reform, Environmental Justice in State Climate Planning: Learning from California, offers critical insights to help policymakers and advocates working on these plans translate climate goals into action and advance environmental justice.

Co-authored by Alice Kaswan, a law professor at the University of San Francisco and a CPR Member Scholar, and by Senior Policy Analyst Catalina Gonzalez, the report provides an in-depth assessment of the role of environmental justice in California’s 2022 Scoping Plan. The report draws on interviews with dozens of advocates and decision-makers across the state to identify best practices to follow as well as pitfalls to avoid, and offers specific recommendations for centering environmental justice in decision-making structures and participatory mechanisms.

The Center will also host a webinar on these issues on October 17 at 1 p.m. Eastern/10 a.m. Pacific, featuring Kaswan, Gonzalez, Chanell Fletcher of the California Air Resources Board, and Dr. Catherine Garoupa of the Central Valley Air Quality Coalition and the CARB Environmental Justice Advisory Committee for the 2022 Scoping Plan.

A Climate Action Planning Moment

Over the next year, 45 states—and multiple Metropolitan Statistical Areas, Tribes, and territories—will develop Comprehensive Climate Action Plans (CCAPs), due December 1, 2025. Phase 1 of the CPRG’s support for state and local planning began with Priority Climate Action Plans (PCAPs) submitted to EPA in March 2024, which required states and other participants to identify relatively immediate and higher-priority action items.

These upcoming CCAPs will require a more substantial planning effort than last year’s PCAPs. As explained in the program guidance, they must include jurisdiction-wide greenhouse gas (GHG) emissions projections, GHG reduction targets, and quantified GHG reduction measures. CCAPs must also analyze expected benefits in general and for low-income and disadvantaged communities more specifically.

Our report, grounded in California’s experience, provides insights to help planners at all jurisdictional levels integrate environmental justice principles and strategies into their plans. Equally important, the report provides concrete suggestions for fostering meaningful participation by the public at large and by communities that have historically had little influence in state planning exercises.

How California’s Climate Planning Can Inform Planning Across the Country

Pursuant to California’s landmark climate law, AB 32, California began preparing climate action “scoping plans” in 2008 and has updated its plans every five years, incorporating new legislative and policy developments each time. AB 32 included environmental justice goals, including the goal of designing climate measures that would also reduce pollution in areas failing to meet air quality standards. The legislation also required CARB to constitute a dedicated Environmental Justice Advisory Committee (EJAC) to advise CARB on the development of each of its scoping plans.

California approved its most recent climate action scoping plan in December 2022, a plan that provides sector-specific goals for technological shifts and greenhouse gas reductions. The plan was the first to sketch the transitions needed to meet the state’s 2045 climate neutrality target.

Meanwhile, California is participating in EPA’s CPRG program and preparing a CCAP that builds on its 2022 scoping plan, and held a kickoff webinar on its draft CCAP on October 8.

Recommendations for Climate Action Planners

The CPRG planning process provides an opportunity for states and metropolitan areas to chart a clean energy transition path that helps achieve environmental and economic benefits and minimizes potential harms. To set these plans up for success, we recommend that climate plans:

• Include strong environmental justice principles and clear commitments that provide a guidepost for the plan’s more specific elements. California benefited from strong state laws and executive orders establishing environmental justice principles.

• Begin the planning process with inclusive discussions about policy pathways for reducing emissions. California began its public process with abstract and technical “scenario modeling” that was hard to unpack and that did not focus on how technological shifts would impact frontline communities, frustrating the EJAC and other public participants.

• Identify specific policy mechanisms to achieve hoped-for transitions. California’s scoping plan identified goals, and listed a wide array of “suggested strategies,” but did not recommend particular strategies, like regulations, or funding, or market incentives. Consequently, it did not reveal the degree to which the state’s ultimate policy choices would meet environmental justice principles. And the lack of specific policy choices impeded the ability to analyze on-the-ground benefits and costs. The EJAC and others thus lacked the information they cared about, and were not given an array of policy choices that would have enabled them to offer the kind of input they hoped to provide.

• Vest planning responsibility within a multiagency council. California law vested responsibility for drafting the scoping plan in a single agency, CARB. Although CARB worked with other agencies in developing the plan, a multi-agency council would facilitate interagency coordination and the development of holistic solutions.

To meaningfully engage the public and environmental justice communities, we recommend that jurisdictions:

• Constitute a permanent and adequately funded environmental justice advisory body. Although California’s EJAC did not always have the resources it needed or sufficiently structured interaction with the agency, it provided a critical vehicle for synthesizing environmental justice views. That role is particularly necessary given marginalized communities’ lack of resources and the challenges that grassroots community members face in accessing state-level proceedings.

• Ensure meaningful community participation early in the planning process and in deliberations about priorities, especially with marginalized communities, by reaching them through trusted partners in accessible locations and by providing compensation for their time and expertise.

The report is part of our project on Climate Justice in California, focused on increasing transparency and sharing lessons on climate governance and decision-making structures from California more broadly. Other resources include an index of the state climate laws and statutes, agency structures, and climate justice funding programs, as well as an in-depth analysis of California’s extensive efforts to fund a clean energy transition.

Join us on Thursday, October 17, at 1 p.m. Eastern/10 a.m. Pacific for our webinar on Environmental Justice in State and Local Climate Planning.