As states and other regional entities prepare climate action plans under the U.S. Environmental Protection Agency’s Climate Pollution Reduction Grant (CPRG) program, they face important strategic choices about how to decarbonize and about the legal mechanisms for accomplishing a clean energy transition. To help states meet the CPRG program goals, which require advancing environmental justice and analyzing the environmental justice impacts of chosen strategies, this report draws lessons on incorporating environmental justice voices and goals from California’s most recent scoping plan update, its 2022 Scoping Plan for Achieving Carbon Neutrality (the 2022 Plan or the Plan).
We describe the planning process and review the way environmental justice principles were — and were not — integrated into the final scoping plan. We then assess the degree to which the decision-making process facilitated or impeded integrating environmental justice, as well as the strengths and weaknesses of California’s public participation processes, including the role of the state’s dedicated Environmental Justice Advisory Committee (EJAC). Based on the assessment, we provide recommendations to guide states currently preparing climate action plans, due to EPA in 2025, as well as California’s next planning round.
The Center will also host a webinar on this report on October 17, 2024, 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.
Decision-making Structures to Help Agencies Integrate Environmental Justice
Certain legal parameters and approaches would help agencies integrate environmental justice into their climate action plans, including the following:
- Include strong environmental justice commitments.
To achieve a clean energy transition in a way that maximizes benefits and minimizes harms, climate action efforts should include strong and explicit environmental justice commitments. California’s AB 32 and executive orders helped shape environmental justice principles in the 2022 Plan. EPA’s Comprehensive Climate Action Plan (CCAP) program has articulated environmental justice priorities that should shape grant recipients’ plans.
- Begin the planning process with climate policy deliberations, using modeling as a way to confirm that the policies will achieve desired goals, rather than modeling abstract parameters at the outset.
California’s process began by focusing on “scenario inputs” — abstract technological shifts (such as a certain overall percentage of renewable energy, a certain number of heat pump sales) — without considering the legal or policy strategies that would be used to achieve these shifts. Most implementation strategies were not debated until after the scenario was locked in. We recommend deliberating about the best strategies at the outset. Scenario modeling should come later in the process, to assess the strategies’ implications and confirm that they will meet required targets.
- Vest planning responsibility in a multi-agency council.
In California, legislation vested responsibility for drafting the scoping plan in a single agency, the California Air Resources Board (CARB). However, climate action planning spans multiple agencies with jurisdiction over multiple sectors. And frontline communities face multiple overlapping concerns that require a holistic approach. Although CARB convened teams and workgroups across agencies, a multi-agency council could potentially facilitate more comprehensive cross-jurisdictional strategies. A multi-agency council would be consistent with EPA’s CPRG Guidance, which instructs lead planning agencies to involve multiple agencies in their efforts.
- Develop specific policy frameworks coupled with implementation timelines and agency responsibilities.
The planning process should recommend the critical policy mechanisms for achieving carbon reduction goals, like regulations, incentives, market mechanisms, or some combination of the above. Some degree of specificity about recommended policy mechanisms is necessary to evaluate the distribution of the policies’ costs and benefits, including their environmental justice impacts. And without information on how policies would impact environmental justice communities, community members seeking to participate in the state’s planning will not have the benefit of the information that matters most to them, undermining public participation.
Moreover, if policy discussions are deferred to the later “implementation” stage, then the discussions will take place in siloed and fragmented agency proceedings. That would hamper the ability to develop integrated approaches. If key decisions are devolved to many different agencies, then advocacy groups and communities would not have sufficient resources to engage in the plethora of proceedings, hampering public participation.
This recommendation is consistent with EPA’s CPRG Guidance, which requires planning entities to identify environmental justice impacts, identify key implementing agencies and schedules, as well as requiring agencies to indicate if they need additional authority to undertake the planned actions. Planners cannot include these components unless they have outlined specific policy mechanisms.
Recommendations to Enhance Participatory Mechanisms
Drawing from the successes and weaknesses of California’s participatory mechanisms, we offer several recommendations to inform state climate action planning efforts, including:
- Develop an effective environmental justice advisory board structure and provide adequate resources.
Permanent environmental justice advisory bodies enhance climate action planning and subsequent implementation. A permanent advisory body can develop institutional knowledge and expertise and can contribute to the plan’s development, as well as its implementation. An advisory body requires funding to be effective. That includes compensation for members, as payment for the expertise they offer, as well as funding for technical assistance.
- Give the environmental justice advisory body a strong role in climate plan development.
The advisory body should advise on all phases of climate planning, including establishing the planning process itself, developing criteria, and working with climate modelers. In addition, there should be a structured process that enables direct collaboration and dialogue between the advisory committee and the agency staff drafting the climate action plan. Full transparency would also facilitate environmental justice engagement. California’s EJAC was frustrated by their lack of access to data used by the climate modelers and their lack of access to the draft climate plan text until the draft plan was officially released.
- Facilitate meaningful public participation and community engagement.
Community input is essential to incorporating the lived experience of environmental justice communities. Regional meetings in frontline communities, hosted by trusted convenors during non-working hours and in the populations’ own languages, would enhance community engagement. Providing food, childcare, and compensation for the participants’ time and expertise would facilitate effective participation. Agency staff and experts the agency is relying on should also be present to answer questions and engage in dialogue, enhancing communication.
- Begin the planning process with priority and strategy deliberations rather than scenario modeling.
Beginning the planning process with deliberations about guiding principles, priorities, and potential strategies, rather than abstract scenario inputs, would facilitate meaningful public participation. California’s initial focus on abstract and technical scenario inputs did not facilitate debate about the principles that should guide the state’s priority-setting and strategy development, hampering meaningful public participation.
- Develop policy frameworks that allow the public to ascertain likely impacts.
California’s reluctance to include planned policy mechanisms in its scoping plan limited the state’s ability to accurately assess environmental and economic impacts. For marginalized communities, information on how a climate plan will affect them — how it will distribute co-pollutant and other transition benefits — is critical. Without information on the issues that matter to them, they will not find participation opportunities meaningful. Specifying planned policy approaches would help meet CPRG requirements, which require grant recipients to include an analysis of the climate plan’s benefits in general and, more specifically, an analysis of impacts in disadvantaged and low-income communities.
A clean energy transition presents significant opportunities and risks for frontline communities. Thoughtful planning processes can facilitate the integration of environmental justice principles and strategies and enhance meaningful public participation. Insights drawn from California’s most recent scoping plan process can inform jurisdictions new to comprehensive climate planning, helping them learn from California’s successes and avoid its shortcomings.
Read the full report
Read the related blog post
Register for the October 17 webinar
Visit our California climate justice project page
