As expansive and even overwhelming as the Inflation Reduction Act (IRA) seems to be, it is important to remember that the IRA authorizes a number of different programs that will benefit states — programs, for example, that may come out of the Department of Energy to state energy offices, or from the Environmental Protection Agency (EPA) to state environmental agencies.
The EPA’s Climate Pollution Reduction Grants program (CPRG) is likely to be some of the first IRA funding that states will see. The CPRG will provide states with a significant springboard to reduce their carbon emissions. Before suggesting how states can make the most of this, let’s take a moment and outline the program.
What Is Clear: An Opportunity for States
The CPRG is a two-part program. Part 1 ($250 million) provides formula grants to every state. This will support states to develop a carbon reduction plan. Part 1 is on its way; the announcement and guidance will be coming out on March 1, and a Notice of Intent to Participate from states will be due March 31.
Part 2 ($4.6 billion) sets out a program of additional grants, funding for states to carry out elements of their plans and will probably roll out in early 2024. While Part 1 provides every state money for planning, Part 2 will require states to compete for funding to support the implementation of their carbon reduction programs.
For states that have yet to develop climate plans, this is an opportunity to use federal funding to explore ways to modernize your state’s economy. More specifically, this is a chance to look at the ways that your citizens, for example, manufacture products, grow crops, transport themselves, and heat and cool their homes — all sectors of your economy that produce significant carbon emissions.
In case a state doesn’t think that GHG planning is important, the CPRG provides for political subdivisions within a state, such as municipalities or local air agencies, to participate. Even where states have already developed climate action plans, these federal dollars could be very useful in updating and improving existing plans.
What Is Not Clear: Support for All Communities
While the CPRG will support states in developing carbon reduction plans, it is not clear the degree to which the program will support improving the outreach and public engagement necessary to ensure that a plan is equitable and that it will serve all communities.
This is a challenge for even successfully developed state plans. For example, in 2021, the Vermont Climate Council, spent over 10 months developing the Vermont Climate Action Plan. This was a significant undertaking by state agencies and citizens and the plan is an admirable start. However, the plan’s authors acknowledge in its preface that robust marginalized community representation was missing from the stakeholder participation:
This initial Climate Action Plan represents one of the first public processes in the State of Vermont to acknowledge and try purposefully to incorporate equity and the principles of a just transition in both its development and outcome — but we know we fell short. During our meetings and outreach, too few Vermonters had their voices lifted up to join the voices of those who have also participated in similar endeavors in the past. In our development of pathways, strategies, and actions, we faced challenges creating programs and policies organically in partnership with marginalized communities and individuals in Vermont and to envision new ways to ensure a just transition for all of us. As we continue forward, we have a strong desire to engage more Vermonters deeply and equitably in this transition, recognizing the historical and present harms and systemic injustices that are at work here in Vermont and elsewhere.
In developing its 2021 Climate Action Plan, Vermont saw first-hand that these working Vermonters did not have the time or capacity to participate and engage. This was not because they weren’t notified or encouraged to participate. People are busy earning a living. And their representatives are also challenged to participate because they work on many other pressing equity-related topics besides climate mitigation, including housing, transportation, policing, food, racism, and education. Frontline advocates generally recognize the importance of this work, but simply don’t have the bandwidth or the means to meaningfully participate.
Hearing from and consulting with marginalized communities isn’t just a matter of equitable inclusion — it’s essential to achieve the goals of climate policies, period. We need programs that are able to deliver GHG savings in all communities and to all income levels. Greater inclusion in planning will yield better, more comprehensive initiatives, in addition to more equitable program designs and benefits.
Will the EPA’s CPRG planning grants be helpful in this respect? It is not clear. The CPRG seeks to transition America to a clean energy economy that benefits all Americans, a goal that logically would incorporate the views of historically marginalized communities.
So, hopefully the EPA will recognize this need and enable states to provide direct support for community participation in CPRG-funded state planning efforts. The agency will have to make that determination.
If the EPA determines that the IRA does not allow for this, then hopefully the agency will still recognize the need and identify any other resources that it might have to help states to support this critical piece of carbon planning. The EPA may have available other funding for communities that are disproportionately impacted by air pollution and climate change. For example, there is air monitoring funding, along with environmental and climate justice block grant opportunities, that may support this work and can be stacked with CPRG funding. Finessing support for intermediaries like civic organizations or faith-based groups might also be helpful in incorporating the voices of frontline communities.
Apart from the question of the federal funding for state carbon planning, states agencies could still ask whether or not their public engagement is as thorough as it might be or whether it needs to be more welcoming to the public to be truly representative. RAP’s Public Access and Participation Plans: A Starter Kit for State Agencies is a document that outlines simple steps that state agencies can take to improve their outreach, and public participation.