HUD’s 2024-2028 Environmental Justice Strategic Plan Frequently Asked Questions
What is the driver for the development of HUD’s 2024-2028 EJ Strategic Plan?

Executive Order (EO) 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, advances the Federal government’s efforts to deliver real, measurable progress on environmental justice (EJ). EO 14096 charges Federal agencies to exercise leadership and immediately strengthen their efforts to address environmental injustice. The order makes clear that the pursuit of environmental justice is a duty of all executive branch agencies and that agencies should be taking actions now to incorporate this charge into their missions.

Environmental Justice Strategic Plans are due to be submitted to the Chair of the Council on Environmental Quality (CEQ) and made available to the public online no later than 18 months after the signing of EO 14096 and every 4 years thereafter. Two years after publishing an Environmental Justice Strategic Plan, each agency must also publish an Environmental Justice Assessment that evaluates the effectiveness of that strategic plan, including the agency’s progress in implementing the plan, barriers to implementation, and steps to address those barriers.

Will the 2024-2028 HUD Environmental Justice Strategic Plan build upon previous EJ efforts of the Department?

Yes. CEQ guidance to Federal departments and agencies for updating or developing their Environmental Justice Strategic Plans states that an agency may incorporate pre-existing content from another strategic plan. This approach seeks to help an agency expand and update any existing environmental justice strategic planning efforts, while also reducing redundancy and streamlining reporting obligations, as directed by EO 14096, Section 9.

Is this the first effort by the Department to develop an Environmental Justice Strategic Plan?

No. HUD’s original EJ Strategy, developed in 1995, focused on four program areas: empowerment, zones/enterprise communities; childhood lead poisoning; brownfields redevelopment; and farmworkers and colonias. HUD has made significant progress since its inaugural strategy was published, perhaps most notably in the area of environmental health with the success of lead poisoning prevention under the leadership of the Office of Lead Hazard Control and Healthy Homes (OLHCHH).

HUD published its 2012-2015 EJ Strategic Plan in April 2012, following the execution of an August 2011 memorandum of understanding (MOU) between 17 Federal agencies, which recommitted each agency to E.O. 12898. The MOU also committed each agency to publish EJ Strategic Plan updates along with annual implementation reports. In HUD’s 2012–2015 EJ Strategic Plan, the Department focused on integration of EJ into agency-wide initiatives, program operations, and interagency efforts. Comments received by HUD staff at regional listening sessions organized by the Interagency Working Group on Environmental Justice (EJ IWG), input from HUD staff and stakeholders, and discussions with EJ IWG representatives informed the development of that strategic. HUD drafted a 2016-2020 EJ Strategic Plan, but it was never published publicly.   

How will implementation of the Department’s EJ Strategic Plan improve public health and the environment for low-income and minority communities?

E.O. 12898 directs federal agencies to identify and address disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations, to promote enforcement of all health and environmental statutes in areas with concentrations of minority populations and low-income populations, and to ensure greater public participation.  E.O. 14096 directs federal departments and agencies to identify, analyze, and address disproportionate and adverse human health and environmental effects (including risks) and hazards of Federal activities, including those related to climate change and cumulative impacts of environmental and other burdens on communities with environmental justice concerns. The goals identified for HUD’s 2024-2028 Environmental Justice Strategic Plan are reflective of E.O. 12898 and E.O. 14096 and will assist in working towards advancing environmental justice across the Department’s programs, policies, and activities to identify and address disproportionate environmental and human health impacts faced by low- income populations and communities of color.

For example, HUD has identified actions for addressing lead (Pb) exposure for low-income families living in HUD-assisted housing. The Department also continues to work across the federal government and specifically with the U.S. Environmental Protection Agency (EPA) to identify ways to leverage HUD’s relationships with stakeholders from the public and private sectors to maximize the impact of every dollar invested in lead (Pb), health, and safety activities. HUD also has developed a departmentwide radon testing and mitigation policy that will better help protect low-income, minority, and overburdened communities.

How will the Department’s EJ Strategic Plan consider the disproportionate impacts that result from climate change on low-income and minority communities?  

E.O. 14096 directs federal departments and agencies to identify, analyze, and address disproportionate and adverse human health and environmental effects (including risks) and hazards of Federal activities, including those related to climate change and other burdens on communities with environmental justice concerns. Under the Department’s 2021 Climate Action Plan, HUD has committed to a variety of actions to empower communities to achieve climate resilience, facilitate economic opportunities, and eliminate health risks caused by environmental injustices, which is reflected within the priority actions of the Department’s 2024-2028 Environmental Justice Strategic Plan. HUD has established environmental justice as a budget priority, ensuring that both HUD staff and its external stakeholders are aware of the significance of avoiding and reversing environmental inequities. 

The Climate and Environmental Justice Working Group (CEJWG) is an internal HUD working group that is focused on the long-term integration of climate and environmental justice into the Department’s programs to better achieve HUD’s mission – both through implementation of the Department’s Climate Action Plan and through raising awareness around HUD’s climate efforts. As a part of the CEJWG, HUD will strive to maximize investments in low-income communities, communities of color, and other disadvantaged and historically underserved communities in an effort to minimize the impact of a changing climate.

Will the public have an opportunity to review and provide feedback on the Department’s draft EJ Strategic Plan?

E.O. 14096 directs federal departments and agencies to provide opportunities for the meaningful engagement of persons and communities with environmental justice concerns who are potentially affected by Federal activities. This includes providing timely opportunities for members of the public to share information or concerns and participate in decision-making processes, as well as fully considering public input provided during public engagement.

HUD will hold three public engagement listening sessions to discuss the goals, objectives, and desired outcomes of its 2024-2028 Environmental Justice Strategic Plan. These public listening sessions are scheduled for Tuesday, April 30th (Tribes, Tribally Designated Housing Entities and Tribal Housing Authorities), Wednesday, May 1st (General Public), and Thursday, May 2nd (General Public) 2024.

Will the Department engage with Tribal and indigenous organizations and communities during the development of the EJ Strategic Plan?

E.O. 14096 directs Federal departments and agencies to continue to engage in consultation on Federal activities that have Tribal implications and potentially affect human health or the environment, pursuant to Executive Order 13175 of November 6, 2000 (Consultation and Coordination With Indian Tribal Governments), the Presidential Memorandum of January 26, 2021 (Tribal Consultation and Strengthening Nation-to-Nation Relationships), and the Presidential Memorandum of November 30, 2022 (Uniform Standards for Tribal Consultation), and fulfill obligations established pursuant to Executive Order 13007 of May 24, 1996 (Indian Sacred Sites). As a part of HUD’s public engagement on the development of its 2024-2028 Environmental Justice Strategic Plan, the Department will hold one listening session specifically engaging Tribal organizations. The Department will also continue to seek advice and recommendations from the Tribal Intergovernmental Advisory Committee (TIAC), which was formed November 2022. The purpose of the committee is to allow Tribal leaders a forum to provide input on Departmental policies – especially before policies are adopted and implemented. The goal of the committee is to ensure Tribal leaders have a voice on all HUD policy matters that will have substantial effects on their Tribal communities.

How will the Department engage with other Federal agencies during the development of the EJ Strategic Plan?

HUD has identified priority actions within its 2024-2028 Environmental Justice Strategic Plan that align with meeting the directive under E.O. 14096 for a Whole-of-Government Approach for advancing environmental justice. These actions include working across the Federal government for lead hazard reduction, addressing climate change through greenhouse gas reduction, and improving communication between HUD properties and Superfund sites where there is an identified potential health concern for HUD housing residents. Also, the Department continues to engage with the White House Environmental Justice Interagency Council Peer Learning Community on Environmental Justice Strategic Planning hosted by CEQ. The Peer Learning Community was created to support the development of department and agency strategic plans while cultivating an open exchange of ideas, leveraging agency expertise, and gaining peer feedback on strategic planning.  CEQ recommends interagency collaboration particularly when there is an overlapping interest in a particular geographic area and/or when a partnership can advance key aspects of each agency’s mission.

How will the Department consider the current Administration’s Justice40 Initiative?

As part of meeting the mission of the Department and in support of the Biden-Harris Administration’s agenda to advance environmental justice, HUD has identified programs included in the Administration’s Justice40 Initiative. These programs align with President Biden’s “Whole-of-Government” approach to deliver 40 percent of the overall benefits of climate, clean energy, affordable and sustainable housing, clean water, and other investments to disadvantaged communities that are marginalized, underserved, and overburdened by pollution.

During fall 2022, CEQ requested an Environmental Justice Scorecard from each agency, in response to the White House Environmental Justice Action Council’s request for more transparency when it comes to federal activity on environmental justice. The draft framework for the Environmental Justice Scorecard will assess the efforts that Federal agencies are taking toward:

  1. Reducing burdens and harms in communities,
  2. Delivering benefits to communities, and
  3. Centering justice in decision making.

The Scorecard will assess the progress Federal agencies are making to advance environmental justice, including through the Justice40 Initiative. As part of the Administration’s agenda to advance environmental justice and deliver 40% of the overall benefits of federal programs, HUD has identified the departmental programs and metrics to track progress of the priority action for its Justice40 initiative.

How will the Department improve and/or refine its EJ Strategic Plan over the span of its implementation?

CEQ guidance to federal departments and agencies for updating or developing their Environmental Justice Strategic Plans states that no later than 2 years after the submission of an Environmental Justice Strategic Plan that each agency shall submit to the Chair of CEQ, and make available to the public, an Environmental Justice Assessment that evaluates, based on guidance provided by the Chair of CEQ under section 9 of this order, the effectiveness of the agency’s Environmental Justice Strategic Plan. The Environmental Justice Assessment shall include an evaluation of:

  • The agency’s progress in implementing its Environmental Justice Strategic Plan;
  • Any barriers to implementing the agency’s Environmental Justice Strategic Plan; and
  • Steps taken to address any barriers identified.

An agency’s completion of an Environmental Justice Strategic Plan and Environmental Justice Assessment shall satisfy the requirements of section 1-103 of Executive Order 12898. The Environmental Justice Scorecard established under section 223(d) of Executive Order 14008 states that departments and agencies also shall address agency progress toward achieving the goals outlined in E.O. 14096.

How will progress of implementation of the EJ Strategic Plan be measured?

CEQ guidance to Federal departments and agencies for updating or developing their Environmental Justice Strategic Plans states that for each goal or objective, the agency should identify specific metrics that can be used to gauge progress and success. CEQ states that metrics should ideally include a measurable, quantitative component, which can be supplemented by qualitative information that provides context. Where possible, the agency should strive to develop metrics that are outcome-oriented and assess progress (e.g., reduced pollution, increased environmental restoration, improved public health, etc.), rather than rely only on output measures (e.g., number of staff, grants or services provided, etc.).

HUD’s 2024-2028 EJ Strategy includes goals, objectives, and priority actions that will provide further integration of environmental justice and the requirements of E.O. 12898 into Department programs while also working to fully implement E.O. 14096. Meeting the goals of HUD’s Environmental Justice Strategic Plan through implementing the objectives and priority actions will serve to fortify HUD’s support for equitable community development for all people while establishing continuity with the Department’s 2022-2026 Strategic Plan.

HUD has identified a set of metrics that directly align with the Department’s 2022-2026 Strategic Plan that are measurable and outcome oriented. For certain priority actions that HUD is unable to clearly linked to specific metrics within the Department’s 2022-2026 Strategic Plan, the Department has offered an explanation as to how that priority action supports the environmental justice goals and objectives, as well as how the Department will measure the progress of those actions and their efforts towards meeting the goals and objectives of HUD’s 2024-2028 Environmental Justice Strategic Plan.

 

 

Content current as of April 15, 2024