Last week, Smart Growth America submitted comments on the design of the Environmental and Climate Justice Block Grant Program (ECJ Program), created under the Inflation Reduction Act, on the types of projects EPA could prioritize, requirements that should be applied to ensure projects are community-driven, and different types of technical assistance that could support the ECJ Program’s eligible applicants. This letter does not seek to comment on all aspects of the ECJ Program; SGA has also participated in other sign-on letters covering a broader array of sub-topics relevant to program design and administration.
Smart Growth America believes that the ECJ program has the opportunity to support historically underserved communities by providing financial assistance via grants and technical assistance to community-based organizations to combat the impacts of climate change. Ideally, these investments can be paired with other types of support which address the housing affordability crisis and the long-term impact of discriminatory land use policies. In designing the ECJ Program, SGA and partner organizations recommend the following:
- Recognize that climate impacts have been compounded by racist land use, housing, and lending policies
- Seek to pair investment from the ECJ Program with proactive anti-displacement initiatives
- Design the program to be inclusive of small-scale and multi-family housing providers:
- Support community-driven climate projects, which are prepared for increasingly frequent and intense climate events
- Include types of projects which address environmental health and climate adaptation alongside energy efficiency and mitigation
- Provide flexibility and recognize the needs and constraints of community-based organizations
- Design program TA to incorporate lessons learned on models for long-term partnerships
- Identify synergies with resources from other federal agencies
Climate change presents an urgent, existential threat to our communities, and those who are most vulnerable in our society today are disproportionately affected. Smart growth is an important strategy for reducing emissions and enhancing preparedness for future climate impacts.
We thank the EPA for the opportunity to share our perspective on the design of the ECJ Grant Programs. SGA believes that climate resilience and adaptation—better preparing for the impacts of climate change such as extreme heat, sea level rise, wildfires, and drought—requires land use strategies that enhance standards for future development and prioritize those who are most vulnerable, supporting communities who are in harm’s way. Thus, the ECJ Grant Programs present a vital resource and opportunity for impact to advance climate adaptation and mitigation in communities historically marginalized by land use and transportation policy and infrastructure investments.
This letter was also prepared with input from staff from partner organizations including the American Society of Adaptation Professionals (ASAP), the Florida Brownfields Association, the Partnership from Southern Equity (PSE), the Union of Concerned Scientists, and the National Brownfields Coalition’s Environmental Justice Committee.