As businesses and organizations apply for federal funding opportunities, the Justice40 (J40) Initiative has created a series of new considerations and metrics for applicants to integrate into funding applications and project planning or development. This initiative, designed to prioritize projects impacting underserved communities, helps ensure that federal investments leave no one behind.
The White House notes that an initiative “of this magnitude has never been made before”. It’s essential that the goals of the J40 Initiative are met to ensure more equitable government investment nationwide. However, the implementation of such monumental goals can create unintended challenges and obstacles for applicants, if unprepared. In order to better anticipate these challenges, let’s take a closer look at the initiative itself.
What does Justice40 do, exactly?
Simply put, the Justice40 (J40) Initiative requires that 40% of the benefits of identified federal investments are directed to “disadvantaged communities that are marginalized, underserved, and overburdened by pollution” (The White House, n.d.). This initiative applies to a wide range of projects and federal agencies — in fact, hundreds of funding programs are now subject to J40 design and tracking. If a federal agency’s program is determined to be a “covered program”, potential applicants must consider how their project will serve disadvantaged communities and identify metrics for tracking that 40% of the project’s benefits flow to these areas.
To support the implementation of this initiative, several tools to identify disadvantaged communities have been developed, the first and broadest of which is the Climate and Economic Justice Screening Tool (CEJST). While other federal agencies, such as the U.S. Department of Energy and U.S. Department of Transportation, have also created tools that are specifically tailored to their covered programs, starting in Fall 2023, the CEJST will likely be the required tool that applicants must use for determining disadvantage community location, in addition to any more specific tools their federal agency may require.
Justice40 in practice
Because the initiative is so new, there are many questions about how to integrate J40 into a project, as well as how to evaluate and convey J40 compliance in a funding application. Although these challenges and solutions are nuanced depending on the administering federal agency, an applicant’s project, or both, common throughlines include:
Defining what makes a community “disadvantaged”.
While at the center of the J40 Initiative, defining what makes a community disadvantaged can be challenging. Tools such as the CEJST have been developed to assist in this definition and identification process. However, other criteria for determining community need may vary by federal agency, covered program, and project.
Determining and measuring how benefits “flow to disadvantaged communities”.
The ultimate goal of J40 is for “40 percent of the overall benefits” of federal funds to flow to disadvantaged communities. This purposeful phrasing emphasizes benefits over something more concrete, such as solely financial investment. This leaves room for more questions than answers — namely, how does an applicant define what it means for benefits to flow to a particular community, and how should these benefits be measured and assessed? Because there is no clearly defined methodology for every community and every program, it’s essential for applicants to clearly explain their methodology in applications.
More requirements demand more time and resources.
The J40 Initiative adds more requirements for applicants as they pursue federal funding, which often results in increased time and/or resource needs for completing an application. J40 also adds to the needs of back-end reporting once funds are awarded. Making time for these processes may be especially difficult for applicants from underserved and under-resourced communities — the very areas that J40 is designed to support.
Justice40 consulting to help navigate the unknown
Although the Justice 40 (J40) Initiative is relatively new, there is help for businesses, organizations, and government agencies looking to pursue funding from a J40 covered program. These consultants and experts can often support you at every stage of the process through a variety of activities, helping you navigate familiar federal funding applications that may be entwined with unfamiliar J40 requirements.
Here at Milepost, our Government Sector Team can be one of these sources of support. What sets our in-house team apart?
From for-profit companies to local and state government agencies, our team has supported various organizations by developing Justice40 (J40) plans, integrating them into a defined project, and applying for federal funding opportunities to bring their project to fruition. We have supported organizations across every step of the process, helping to apply, build, and measure J40 covered programs. Our work has included but is not limited to:
• Facilitation of discussions surrounding J40 and Diversity, Equity, Inclusion, and Accessibility (DEIA)
• J40 plan development, demographics analysis, and Disadvantaged Community identification
• Collaboration with project partners and stakeholder identification
We've been in your shoes
Our team supports clients by building on our collectively rich knowledge and experience implementing and administering state and federally-funded programs in our recent past. Pooling our experiences, we have supported efforts and built connections across federal agencies and state departments, including the U.S. Department of Transportation (DOT), the U.S. Department of Energy (DOE), and the U.S. Environmental Protection Agency (EPA). Our extensive, firsthand knowledge in navigating federally and state-funded programs makes us the logical partner to provide guidance and support for your program.
The Milepost difference
When you partner with Milepost, you not only tap into our J40 expertise, but you also benefit from our deep roster of talented professionals and embedded team of writers, designers, and creatives, with experience in management consulting and program strategy and development. At our core, we value the meaningful change a J40 covered program can mean for communities nationwide. Let us help you proactively navigate any potential J40 obstacles in funding applications or program development, enabling your organization to bring meaningful investment to everyone in your community.
Use the links below to learn more about the Justice40 Initiative.
- The Council on Environmental Quality “Climate and Economic Justice Screening Tool”
- The White House Justice40 webpage
- The U.S. Department of Energy “Energy Justice Mapping Tool”
This article was written with contributions from Susan Steffenhagen and Matt Cooke.