The Future Energy Jobs Act (FEJA) mandates that at least 25 percent of the Illinois Solar for All Program’s incentives be allocated to projects located within environmental justice communities. On January 17, Elevate Energy and the Illinois Power Agency (IPA) held a stakeholder engagement session to address how the program will address these environmental justice obligations. While qualification for Solar for All depends on household income—not on being situated within an environmental justice community—this 25 percent threshold will give proposed projects in environmental justice communities an advantage when the Program Administrator selects approved projects and awards incentives under Solar for All.
Broadly speaking, environmental justice refers to eliminating and avoiding the disproportionate impacts caused by environmental pollution on communities with significant socioeconomic burdens. Environmental justice communities struggle to receive equal environmental protections under the law and are more susceptible to the negative health impacts of pollution.
The Solar for All Program aims to address existing disproportionate impacts, in part, by broadening and diversifying participation in the development of renewable energy. It does so through specialized incentives, workforce training opportunities, and grassroots education campaigns aimed at low-income communities, communities of color, and other often underserved communities. Specifically addressing low-income and environmental justice communities should be considered a best practice in designing and implementing new community solar and other clean energy programs.
Designating Environmental Justice Communities
Elevate has proposed a dual-pronged process for designating environmental justice communities. First, Elevate devised an analytical process to categorize Illinois communities based on exposure to pollutants, proximity to environmental harms, and various socioeconomic factors. This process, which depends on EPA’s EJSCREEN tool and the California Office of Environmental Health Hazard Assessment’s CalEnviroScreen tool, will calculate an “EJ Score” for each census block group in Illinois. Census block groups with the highest 25 percent of EJ Scores—indicating the highest levels of environmental and socioeconomic burden—will be designated as environmental justice communities. Additional details about this process are available on the Solar for All website. A portion of the communities with the highest EJ Scores in Elevate’s initial analysis are depicted in green below. The blue lines correspond to more familiar neighborhood boundaries to provide geographic reference points.
Recognizing the shortcomings of a purely statistical approach and the fact that environmental burdens come in varied and often unpredictable forms, Elevate also proposed a self-designation process for communities that do not automatically qualify. Representatives of those communities can submit proposals that provide Elevate with qualitative and quantitative data to justify why they should qualify as environmental justice communities. This self-designation process will occur on a rolling basis and allow the “community designator” submitting a proposal to define their community’s geographic boundaries as they see fit. Further, “community designator” is not strictly defined – that role may be filled by a community organization, a local government representative, a community resident, etc. See the complete Self-Designation Proposal.
Proposals will be evaluated by an “Environmental Justice Community Self-Designation Committee …. comprised of 5-8 members, including representatives from the Program Administration team and additional Environmental Justice expert(s).” Some characteristics that might justify self-designation as an environmental justice community are listed below.
Elevate will also design and make available a suite of tools to facilitate understanding an employment of environmental justice community designations. For example, one tool will allow users to input an address and determine whether that address falls within a designated environmental justice community.
In moving forward with designing and implementing the processes through which communities receive the environmental justice designation, it is imperative that the Program Administrator consider the broad and long-standing obstacles that disadvantaged communities face toward participation in this and other political and regulatory processes. These obstacles include language, technical, and access barriers, among others. Elevate should maximize flexibility in designating environmental justice communities to eliminate undue obstacles and maximize opportunities for these communities’ genuine participation in Solar for All.