Billions of dollars of funding from the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA) are driving forces in today’s economy focused on modernizing our national energy markets and supporting the development of new and exciting technologies. But competition for these funds is intense. An application outlining a proposed project must distinguish itself amongst the many bids seeking federal grants authorized by the IRA or IIJA.
A critical component for funding requests that fall under Justice40-covered programs is the Community Benefits Plan (CBP), a blueprint for how the project will benefit residents, businesses and organizations within the host community. The CBP typically accounts for 20% of application scoring and is vital to the success of the proposal.
Addressing Justice40 Requirements
When President Biden took office in 2021, he introduced his Justice40 Initiative, which aims to deliver a minimum of 40% of the “overall benefits” of federal funding to disadvantaged communities. For the purposes of Justice40, disadvantaged communities are Census tracts that have been identified through the White House Council on Environmental Quality’s Climate and Economic Justice Screening Tool. Many of the IIJA and IRA funding efforts are through “Justice40 covered programs” that have Justice40 objectives embedded within their goals. Therefore, when developing a CBP it is essential that Justice40 requirements are addressed by outlining the specific advantages, such as jobs, tax revenues, environmental benefits and infrastructure improvements, that a disadvantaged community can anticipate through the proposed project.
Key Elements of a Successful CBP
The CBP acts as the project’s roadmap for ensuring communities workers, and other stakeholders have opportunities for meaningful engagement.
Clear Benefits
A compelling CBP will clearly identify project benefits, such as high-quality jobs and an inclusive and diverse workforce, and how these benefits will accrue to disadvantaged communities with minimized or mitigated negative impacts. The plan should present the project’s strategy for ongoing two-way engagement to ensure participation of all stakeholders and demonstrate the project development team’s commitment to the community.
Measurable Impacts
Within the CBP, applicants should develop measurable outcomes. By measuring the impact of the project, including short-term and long-term outcomes as well as key performance indicators, the applicant can demonstrate to the agency responsible for the funding program that the project will make a meaningful and lasting difference in the region.
Targeted Needs Assessment
The application reviewer wants to see that the applicant has conducted a preliminary needs assessment of the region and has a clear understanding of the area’s needs and expectations, and how the proposed project will clearly address them. A needs assessment will encompass gathering data, such as demographic information, statistics on poverty or health and information on existing programs or services.
Mapping and Modeling
TRC’s AnalyzEJ is an ESRI-based mapping tool that incorporates custom layers designed to support Justice40 and CBP development. AnalyzEJ identifies and assesses existing community demographics and burdens, such as heavy dependency on fossil fuel employment, which can be linked to the goals of the funding opportunity. Depending on the application, economic impact modeling may also be used to estimate employment and income impacts, along with workforce capabilities and project needs.
Stakeholder Engagement
Finally, a well-written CBP will outline the steps the applicant will take to engage with stakeholders in the development process. Efforts might include partnerships with local organizations, outreach and education programs, or the development of new infrastructure. Applicants should identify potential barriers in concrete terms and present strategies to overcome them. The CBP can help alleviate concerns and doubts that some community members may have. Ultimately, the community’s involvement will build trust and support for the project among members, ensuring its success.
The importance of the CBP in the application process cannot be overstated. It is the primary tool that the funding agency uses to determine the project’s potential impact on the community. The CBP provides specific details on how the project will improve the community’s quality of life, create jobs and stimulate economic growth to achieve many of the objectives within the IRA and IIJA.
Diane Reilly, Director of Economics and Environment
Ms. Reilly has over 25 years of experience in environmental consulting as an Economist and leads TRC’s Environmental Justice CORE team. She supports TRC’s clients through socioeconomic and environmental justice analyses, helping them proactively identify challenges and navigate regulatory requirements. She works alongside other subject matter experts to provide integrated services involving technical studies, public engagement plans, agency consultation, tribal coordination, and environmental compliance strategy and support services. Ms. Reilly also specializes in economic impact analyses and evaluates socioeconomic and recreational impacts. She has extensive NEPA experience, having authored EA and EIS sections for FERC, USACE, FRA, FHWA and NPS. Contact Diane at DReilly@trccompanies.com.
