Prioritize and identify environmental justice and frontline populations and communities

100% policies should include clear language that calls out environmental justice (EJ) and sets clear targets.

Many 100% energy policies set clear goals to achieving 100%. However, some of these policies omit a critical component to meeting that target: an explicit prioritization of environmental justice. Unless environmental justice is named in the policy, attention to the needs and concerns of BIPOC and frontline communities will not be addressed in the policy.

Energy Justice Network defines environmental racism, environmental justice, and environmental equity:

“Environmental racism” is the disproportionate impact of environmental hazards on people of color. “Environmental justice” is the movement’s response to environmental racism. “Environmental equity” is not environmental justice. “Environmental equity” is the government’s response to the demands of the environmental justice movement. Government agencies, like the EPA, have been coopting the movement by redefining environmental justice as “fair treatment and meaningful involvement,” something they consistently fail to accomplish, but which also falls far short of the environmental justice vision. The environmental justice movement isn’t seeking to simply redistribute environmental harms, but to abolish them.[1]

Policy recommendations

Explicitly name environmental justice in the policy. In order to have a mandate prioritizing environmental justice and frontline communities, 100% policies should include clear language that calls out environmental justice and clear targets. For example, a carve out of 25% of all renewable energy will be sited in and benefit environmental justice communities (see definitions below). Special incentives for environmental justice and frontline communities are also needed to redress the past inequities so that they can acquire and own solar photovoltaics, energy efficiency infrastructure, or other renewable energy technologies either on their own homes or in community systems.

Create a structure to develop the methodology. The methodology to identify the target environmental justice community is essential to ensuring these communities benefit from and are prioritized in the 100% regenerative policy. Who develops the methodology is just as important as what that methodology is. For example, a Frontline Task Force or Energy Equity Working Group should be created that establishes a methodology for defining “BIPOC and frontline community” and/or “environmental justice community.”

Advocates should consider the following in the development of methodology to identify environmental justice and frontline populations and communities:

  • Different methodologies will work for different contexts (for example, urban vs. rural vs. Indigenous, or contexts that have a broad range of types of workers).
  • Attention should be paid to the differences between using geography (zip codes or census tracts) and populations (mine workers, farm workers, women, etc.) to define as frontline or environmental justice.
  • The percentages of investments should, at a minimum, align with the percentage of environmental justice/frontline areas or populations. For example, New York’s State Assembly Bill A8429 included 40% of investments to align with 40% of the total population in environmental justice communities;[2] whereas, California’s Senate Bill 535 has 25% of investments for 25% of identified environmental justice communities.[3]
  • A simple methodology for just energy and policy investment could be developed, factoring in any of the following:
    • Percentage of frontline / environmental justice / low-income populations
    • Amount of funds these populations have paid into past renewable energy programs without access (as ratepayers and taxpayers)
    • Measure of impact / proportionate benefit, societal benefit, etc.
  • Do advocates use “Frontline,” “highly impacted,” or another term to describe communities and what is the agreed upon definition? Frontline communities are typically defined as those most impacted by multiple and cumulative sources of pollution and climate impacts due to proximity to toxic factories, fossil fuel refineries, neighborhood oil drilling, freeways, and the like, often without access to clean drinking water or public investment. The inability of these communities to cope with the related health impacts can be compounded by poverty, unemployment, and lack of access to education. The following are common indicators to identify a frontline community:
    • Poverty level
    • Linguistic isolation
    • Housing burden
    • Asthma
    • Cardiovascular disease
    • Living adjacent to hazardous waste facilities
    • Air quality PM2.5
    • Drinking water contamination
    • Pesticides prevalence
  • Does the organization use “low-income” and what is the definition? BIPOC and frontline communities prefer not to use the term “low-income” as it can be degrading. However, many energy policies use “low-income” to clearly define the population for whom the policy is intended. Typically, the Area Median Income (AMI) is used to determine “low-income.” AMI is the middle income of any given area. Most federal and state housing programs set maximum incomes in order to determine eligibility to access affordable housing programs. The Department of Housing and Urban Development’s (HUD) definition of low-income has been used in energy and climate policies. HUD’s limits are based on surveys of local area AMIs. The general recommendation in various energy policies is to use 80% of AMI, meaning that any income at or below 80% of the AMI is considered low-income.
  • Do policies include low-income housing and service providers, to ensure low-income populations have access regardless of housing type? Are those policies structured to ensure low-income renters and tenants may capture benefits as well?

Policies should clearly identify the desired impacts or goals of BIPOC and frontline communities to be achieved by the policy, such as energy burden reduction targets, bill savings targets, job creation, job training, ownership, entrepreneurship and economic opportunities, minority and women business enterprise opportunities, etc.

  • An example of outlining the desired impact is the Solar for All Program in Washington DC. This program aims “to bring solar energy to 100,000 low- to moderate-income families, whether homeowners or renters living in multi-family buildings. All are expected to see a 50-percent savings on their electricity bills over 15 years.”[4]

Advocates should ensure that energy is affordable for BIPOC and frontline households. Advocates may reference the Low-Income Affordability Data Tool[5] for guidance. Research recommends using an affordability standard of 6% of gross household income based on the idea that a household can afford to spend about 30% of income on shelter costs and that about 20% of shelter costs are used for energy bills.[6] It is essential to have similar energy affordability provisions early in the process of the renewable energy transition to insulate low-income households from price increases and from any special costs or charges associated with the energy transition.

Set up robust accountability and accounting measures. 100% regenerative policies should set up an Environmental Justice (or Climate Justice) Board or Accountability Board comprised of frontline communities that can guide the process, ensure methodologies are adopted, and hold policy-makers accountable. This board can set processes and structures in place for the accounting of investments and disinvestments in energy programs that impact environmental justice and frontline communities.


Denver Housing Authority’s (DHA) new community solar array: In 2017, DHA partnered with GRID Alternatives Colorado and Namaste Solar to develop and install a 2 megawatt DC community solar project. The project’s output will benefit DHA housing as well as other Low-income Housing Tax Credit and Public Housing Buildings in the Denver metro region–properties housing over 700 residents in total. Residents will save an estimated 15 to 20% on their average monthly utility bills.[7]

Examples of methodologies and tools used in policy to identify environmental justice and frontline populations and communities:

  • “EJSCREEN” is a national environmental justice mapping and screening tool that provides the EPA with a nationally consistent dataset and approach for combining environmental and demographic indicators.[8]
  • In California, the Office of Environmental Health Hazard Assessment defined “disadvantaged community” using their CalEnviroScreen model. “CalEnviroScreen is a mapping tool that helps identify California communities that are most affected by many sources of pollution, and where people are often especially vulnerable to pollution’s effects. CalEnviroScreen uses environmental, health, and socioeconomic information to produce scores for every census tract in the state. The scores are mapped so that different communities can be compared. An area with a high score is one that experiences a much higher pollution burden than areas with low scores. CalEnviroScreen ranks communities based on data that are available from state and federal government sources.”[9]


  1. Environmental Justice / Environmental Racism.” Energy Justice Network. Accessed 24 Jul. 2019.
  2. Assembly Passes Climate Leadership And Community Protection Act.” New York State Assembly, 20 Jun. 2019. Accessed 24 Jul. 2019.
  3. SB 535 Disadvantaged Communities.” Office of Environmental Health Hazard Assessment, 2017. Accessed 24 Jul. 2019.
  4. Solar for All? Removing Financial Obstacles to Green Energy.” Changing Climate, 7 May 2019. Accessed 24 Jul. 2019.
  5. Low-Income Energy Affordability Tool.” Office of Energy Efficiency and Renewable Energy.
  6. Home Energy Affordability Gap.” Fisher, Sheehan & Colton Public Finance and General Economics, 2019. Accessed 27 Jul. 2019.
  7. DHA’s Community Solar Project Keeps Housing Affordable.” Low-Income Solar Policy Guide. Accessed 24 Jul. 2019.
  8. What is EJScreen?Environmental Protection Agency. Accessed 24 Jul. 2019.
  9. CalEnviroScreen 3.0.” Office of Environmental Health Hazard Assessment, Jun. 2018. Accessed 24 Jul. 2019.