ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING

This guidance document, produced by the Environmental Justice Leadership Forum on Climate Change, provides a framework for state agencies to incorporate equity and environmental justice (EJ) into the planning and implementation of the U.S. Environmental Protection Agency's (EPA) 2015 Clean Power Plan (CPP). It emphasizes the need for meaningful community engagement, the use of EJ analyses to prevent disparate impacts, and the prioritization of public health and a 'just transition' for workers and overburdened communities.

• The EPA's Clean Power Plan requires state regulators to meet carbon dioxide emission levels while demonstrating meaningful engagement with stakeholders, including low-income communities, communities of color, indigenous populations, and people living near power plants. States must describe this engagement and evaluate the plan's effects on vulnerable communities to ensure all benefit from the rule.
• The document advocates for 'high impact' engagement over 'low impact' efforts. High impact engagement involves visible decision-makers, EJ stakeholders driving the process, and results that lead to tangible environmental and health improvements. In contrast, low impact engagement is characterized by one-way conversations and standard public hearings that do not facilitate genuine learning or community context.
• The guidance strongly recommends that states conduct an Environmental Justice (EJ) analysis to identify vulnerable communities and minimize unintentional disparate impacts. Such an analysis should identify affected populations, determine demographics, and evaluate the potential impact of various compliance options.
• The Environmental Justice Leadership Forum expresses significant concern regarding carbon trading (cap-and-trade) and the Clean Energy Incentive Program (CEIP). They argue that trading allows power plants to avoid on-site pollution reductions, which denies nearby communities health benefits and may increase localized emissions of co-pollutants like ozone and particulate matter.
• To avoid the risks of carbon trading, the guidance suggests states consider alternative strategies such as source reductions (the 'cap' without trading) or implementing a carbon tax. It references the Climate Protection and Justice Act as a potential model, which includes a carbon pollution fee and a rebate program for eligible residents.
• The document emphasizes a 'Just Transition' to ensure that the shift from fossil fuels to clean energy does not leave workers and communities behind. This includes providing job training, economic stimulus, and infrastructure funding to make low-income communities 'energy efficiency ready.'
• The guidance highlights severe health disparities linked to pollution, noting that African American and Hispanic children have higher rates of asthma than national averages. It argues that climate change-induced increases in ozone will exacerbate these respiratory ailments and lead to increased hospitalizations.
• The document identifies specific tools for EJ analysis, including the EPA's EJSCREEN and California's CalEnviroScreen. However, it criticizes CalEnviroScreen for removing data on race and ethnicity, arguing that such data is essential for a proper environmental justice analysis and compliance with Title VI of the Civil Rights Act.

APA

Environmental and Energy Study Institute (2016). ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING. https://www.eesi.org/files/EJ-State-Guidance-Final-v5-jan-15-2016.pdf

Chicago

Environmental and Energy Study Institute. ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING. 2016. https://www.eesi.org/files/EJ-State-Guidance-Final-v5-jan-15-2016.pdf.

Wikipedia

{{cite report |author=Environmental and Energy Study Institute |title=ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING |date=January 2016 |url=https://www.eesi.org/files/EJ-State-Guidance-Final-v5-jan-15-2016.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{environmentalandenergystudyinstitute2016environmental, author = {{Environmental and Energy Study Institute}}, title = {{ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING}}, institution = {Environmental and Energy Study Institute}, year = {2016}, month = jan, url = {https://www.eesi.org/files/EJ-State-Guidance-Final-v5-jan-15-2016.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }