Analysis of FEMA Equity Action Plan: Recommendations for Climate Justice

Just Solutions Collective is announcing the publication of the “Analysis of FEMA Equity Plan: Recommendations for Climate Justice” brief. In this brief we cover what is in FEMA’s Equity Plan, whether the plan will achieve equity for BIPOC and frontline communities, and we identify recommendations for advocates.


Since the publications of Equity Action Plans from multiple federal agencies in April 2022 in response to the Biden’s Executive Order 13985, many environmental justice and climate justice advocates are asking: what is next? How will federal agencies implement the plan and to what extent do the plans outline equitable actions? Key to environmental and climate justice issues is the Federal Emergency Management Agency (FEMA), whose mission is to help people before, during, and after Presidents declare emergencies or disasters.

In the brief, I review FEMA’s Equity Action Plan, with six criteria in mind. Whether the Equity Plan clearly: (1) identifies BIPOC and Frontline communities as a priority, (2) outlines specific equity actions in their recommendations, (3) provides relevant and measurable equity metrics, (4) communicates outreach plan to underserved groups, (5) proposes accountability to underserved groups, and (6) structures internal or inter-agency accountability.

What is in FEMA’s Equity Plan?

FEMA’s Equity Action Plan includes what FEMA calls “an initial equity analysis” of six programs in the agency: Public Assistance (PA), Individual Assistance (IA), Hazard Mitigation Assistance (HMA), Nonprofit Security Grant Program (NSGP), National Flood Insurance Program (NFIP), and the Office of the Chief Component Procurement Officer (OCCPO). Each program submitted 1.5 to 3 pages of documentation outlining four considerations: (1) Barriers to Equitable Outcomes, (2) Actions and Intended Impact on Barriers, (3) Tracking Progress, and (4) Accountability.

Overall Findings

In general, each FEMA program varies in their level of understanding and commitment around equity. For example, the IA and HMA programs had more relevant equity actions and more robust proposed outreach to frontline communities than the PA and NSGP programs. The PA, IA, and HMA programs included strong institutional accountability, however none of the programs had strong accountability measures to frontline communities. In terms of relevant equity metrics, the PA and NSGP programs had none, while the IA program had some relevant but weak equity metrics. The HMA program was the only one that outlined two relevant equity metrics. For a breakdown of what each program is and more details on their equity assessment, read the full brief here.


FEMA’s Equity Plan alone will not achieve equity for BIPOC-Frontline Communities. It is comprised of equity assessments from six different FEMA programs with varying abilities to enact their outlined recommendations. Thus, the Equity Plan is more like preliminary equity findings rather than an actionable plan that can be implemented without further legislation. There are three main barriers in the Equity Plan: (1) few relevant equity metrics to measure progress, (2) lack of accountability to frontline and BIPOC communities, and (3) impediments to act of proposed actions in some cases due to statutory limits and needs for further reform.

However, the Equity Plan is a great compliment to FEMA’s 2022-2026 Strategic Plan, which outlines equity as one of its three strategic points. The Strategic Plan is also created for FEMA as an organization rather than by specific programs and could have a bigger impact. Just Solutions Collective will publish a deeper equity analysis for FEMA’s Strategic Plan as well.

Although FEMA is prioritizing equity and moving in the right direction there is still need for further work, because of the three overarching barriers mentioned above and the overall variability of each program’s understanding of equity. Climate and environmental advocates should push for more accessible mechanisms for meaningful engagement of and accountability to BIPOC and frontline communities in the consideration, implementation, and evaluation of such equity actions and plans. Advocates should also continue to push for legislative reforms across federal agencies and programs. As outlined in the brief, some existing statutes actually limit direct implementation of equity actions identified in the Equity Plan. Advocates should also follow and inform the development of equity outcomes in these plans which have long term implications for how eligibility is determined, funding distributed, and programs and policies implemented. Finally, as they stand, the Equity Plans are not codified in statute which can be reversed by the next president and limits the ability of advocates to prevail in a court challenge when agencies are not fulfilling the executive order. Read the full brief for more details on policy recommendations.