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A Review of Renew America’s Schools Investments: What Does It Mean to Meet J40 Goals When Barriers Persist for Disadvantaged Communities?

Authorized through the Infrastructure and Investment Jobs Act (IIJA), Renew America’s Schools1 is a Justice40 (J40) Initiative covered program that provides up to $500 million in funding to K-12 public school facilities across the country for infrastructure and energy upgrades, with a focus on high-need schools. Program objectives include improving the health and safety of the school environment and realizing energy cost savings. Following the first round of funding released under this program, we assess how this program is meeting the objectives of J40, which commits 40 percent of the benefits from specified federal investments to disadvantaged communities (DACs) that have experienced underinvestment and have been overburdened by pollution. 

If the criteria for meeting J40 goals is the amount of money spent, then one might also say that Round 1 results of the Renew America’s Schools program met that goal, as described below. DACs did receive the majority of funding. However, our analysis finds that 63 percent of grantees whose schools were located fully in DACs received only 57 percent of total funding. Of six awards made in excess of $14 million, two were made to grantees representing DACs. The other four went to a mix of DAC and mostly non-DAC areas which together received 34 percent of Round 1 funding. 

Public School Infrastructure Needs

The need for public school facility improvements is great. The 2021 Infrastructure Report Card for Schools prepared by the American Society of Civil Engineers rated the country’s school infrastructure a  D+, finding that 53 percent of public school districts are in need of multiple facility improvements, including HVAC systems. The 2021 State of Our Schools Report reported that the annual underinvestment in U.S. pre-kindergarten to 12th grade public school facilities is $85 billion. The report also pointed to the racial and economic disparities in the condition of school facilities. Nationally, high poverty districts received 37 percent less funding for facility improvements than low poverty districts. Similarly, a 2012-13 study found that, in schools where 75 percent or more of students receive free or reduced price lunch, about a third of permanent buildings and nearly half of portable buildings were rated fair or poor. In schools where 50 percent or more of students were children of color, about one-quarter of permanent school buildings rated fair or poor. Schools with large Black, Indigenous, and People of Color (BIPOC) populations were also significantly more likely to have portable buildings, impermanent facilities that too often become permanent.  

Renew America’s Schools Round 1 Process and Results

To begin to address these needs, the first round of funding for Renew America’s Schools was launched in 2022 as a competitive grant program, Successful proposals were announced in June 2023. Although the Department of Energy (DOE) had planned to allocate $80 million in the first round, the overwhelming response prompted DOE to increase funding to nearly $178 million. Over 1,000 concept papers with requests totaling almost $5.5 billion were submitted. Of the 24 projects funded, 88 percent included HVAC improvements. Other priorities included lighting and upgrades to the building envelope. With limited funding available, DOE capped grant awards at $15 million in Round 1. Round 1 grant amounts ranged from $774,915 to $14,999,000. Eleven grants (46 percent) were made to recipients in rural areas. Several of these grantees serve Tribal communities. 

In awarding funds, DOE reports that it is prioritizing proposals that demonstrate public school renovation, repair, and improvement needs in “disadvantaged communities,” rural areas, and areas where a high percentage2 of students are eligible for a free or reduced price lunch. Those proposals that not only meet these objectives but that also leverage private sector investment through energy-related performance contracting are most competitive. At least two-thirds of the successful grantees in Round 1 had such partnerships in place, according to information provided about each grantee by the Renew America’s Schools program. 

Continuing Administrative Barriers 

The results of Round 1 point to a number of challenges related to the funding process. The amount of available funding is meager given demonstrated needs. An onerous application process includes the recruitment of private sector partners and cost share requirements. A statutory cap of 5 percent on operation and maintenance training for energy efficiency and renewable energy improvements means that some prospective grantees that wish to train their own staff to operate and maintain the improvements may have insufficient resources to do so. Others may face barriers in identifying contractors in their areas to provide affordable operation and maintenance services.  

In launching a second round of funding in late March 2024, DOE announced significant programmatic changes intended to reduce the application’s administrative burden. The program is now being run as a prize. Concept papers will not be required. Eligibility is restricted to those applications that include a minimum of 10 schools or school buildings, although applicants can partner with other school districts to meet that threshold. Up to 23 projects will be funded, with a total allocation of about $180 million. Funds will be disbursed in three phases:

  • In Phase 1, the successful recipients will be chosen, based on the same criteria as in Round 1, but with a heavy emphasis on the ability to leverage private funding and/or tax credits. Successful Phase 1 applications will be awarded $300,000, regardless of how many schools are included in their proposal.
  • In Phase 2, recipients will enter into cooperative agreements with DOE and conduct energy audits, strategic planning, and design. Projects involving 10-14 schools will receive $500,000. Those with 15-19 schools will receive $750,000, and those with 20 or more schools will receive $1 million. Funds awarded in Phase 1 can fund Phase 2 work, along with a 5 percent cost share. Funds will be disbursed in Phases 2 and 3 on a reimbursement basis.
  • Phase 3 is an implementation phase. In this phase, recipients with 10-14 schools will receive $7 million. Those with 15-19 schools will get $10.5 million, and those with 20 or more schools will receive $14 million. In Phase 3, the cost share increases to 25 percent. 

While the administrative burden associated with the application process may be reduced, the barriers to participation in the program remain. The fixed amount of funding in each phase may disadvantage recipients in areas where construction costs and professional services are more expensive. Those applicants with limited ability to leverage private financing, particularly given the cost shares in Round 2, may be less competitive. Other potential barriers include the continued statutory cap of 5 percent for operation and maintenance training for energy efficiency and renewable energy improvements and the programmatic requirement that at least 10 schools be identified. Some Round 2 applicants may have difficulty generating the up-front funding or accessing financing for improvements that will then be reimbursed by DOE in Phases 2 and 3. DOE will be holding two virtual office hours to provide technical assistance to applicants. In order to more effectively reach low-resourced areas, Just Solutions recommends that the number of such sessions be increased and that low-resourced applicants be prioritized for assistance. 

What Does It Mean to Meet J40 Goals?

Round 1 results also raise questions about what it means to meet J40 goals, what the administrative expectations are for covered programs, and, in the case of the stated objective of Renew America’s Schools, what it means to prioritize high-need communities. In announcing the results of Round 1, DOE stated that J40 goals were exceeded, based on the number of schools receiving funding that are located in disadvantaged communities. Those grantees representing schools located in DACs3 generally also demonstrate a high level of need, based on Renew America’s Schools program review criteria: 

  • Nine (60 percent) of these grantees’ recipient schools have majority BIPOC student populations.4 
  • All but two of these grantees’ funded schools are located in DACs that also meet the threshold for “low income.” 5
  • Schools receiving funding in nine of the grantee school districts have free and reduced price lunch eligibility rates that exceed 50 percent.6 
  • Ten (67 percent) grantees serve completely or predominantly rural areas.7

However, despite the program’s stated prioritization of “high-need school communities,” including DACs, the consideration given to such communities was a relatively small part of proposal scoring. The needs assessment – the degree to which the proposal identified facilities requiring improvements that are located in a rural area or disadvantaged community or having a high percentage of free and reduced price lunch eligibility – accounted for only 20 percent of the final score. An equal weight was applied to the innovation criteria – the degree to which the project was innovative, scalable, and leveraged private funding. If directing resources to areas of high need – whether based on DAC status, free and reduced lunch eligibility, or a rural community – is a priority – and if a program is to be considered a J40 covered program, one might expect the evaluation criteria to be weighted more in that direction.

Despite such a small portion of consideration going to an assessment of need, DACs did receive the majority of funding. However, as shown below, the amount of funding provided to DACs and the mix of DACs and non-DAC areas was not proportional. In addition, of the six awards made in excess of $14 million, two were made to grantees representing a DAC. The others8 went to a mix of DAC and mostly non-DAC areas which together received a total of $59,908,198, or 34 percent, of Round 1 funding.

Although DOE stated that high-need school communities were prioritized, this did not exclude other applicants. For example, a consortium of 20 school districts, which included DAC and non-DAC areas, included two school districts that have no DAC census tracts in their district while two others have one each. Only three of the 20 districts have majority BIPOC school populations, and the family poverty rate in half of the participating districts is less than 10 percent. In another case, a grantee received funding for a public charter school that has been constructed within the last few years. The school’s student population is non-DAC, non-low income, majority white, and with a very low percentage of free and reduced price lunch-eligible students


The results of Round 1 of Renew America’s Schools program raise questions about what it means to provide “overall benefit” to disadvantaged communities under J40 and the expectations of J40 covered programs. If J40 goals are considered to be met solely by the number of grants made or the percentage of funds directed to such communities, many of the barriers frontline communities face in accessing resources will likely continue. If overall benefit for covered programs under J40 instead involves a restructuring of the way federal resources are distributed to improve the community capacity and well-being of disadvantaged communities, then programmatic and administrative barriers in programs like Renew America’s Schools that limit access for under-resourced communities must be resolved.

  1. The Renew America’s Schools program is authorized under Section 40541 of the Infrastructure Investment and Jobs Act. ↩︎
  2. “High percentage” is undefined in both the legislation and in DOE 2022 Q&A documents. It is considered within the context of the proposal. ↩︎
  3. These grantees are located in Alaska, Arkansas, California, Connecticut, Idaho, Indiana, Minnesota, Mississippi, Montana, Oklahoma, Oregon, South Dakota, Tennessee, Utah, and Virginia. In this analysis, a proposal by Bridgeport (CT) Public Schools is included in this group, despite the fact that the two schools that are receiving the grant funds are unknown. Thirty-three of the 39 census tracts in Bridgeport are considered disadvantaged communities, and the district has a family poverty rate of 30 percent. It is assumed that the two schools selected will be in one of the DAC census tracts. ↩︎
  4. National Center for Education Statistics (NCES) data for school year 2022-2023 were consulted to obtain information about the racial composition of the student population at each school, free and reduced price lunch eligibility, and school district family poverty rates. ↩︎
  5. DAC census tracts are identified through use of the Climate and Environmental Justice Screening Tool (CEJST). The CEJST also identifies low-income communities, where the adjusted percentage of individuals with incomes below 200 percent FPL is at or above the 65th percentile are considered low income. (Poverty rates are adjusted to exclude those enrolled in higher education.) ↩︎
  6. The free and reduced price lunch data for Bridgeport Public Schools is not included, as the two schools that are receiving funding are unknown ↩︎
  7. The Round 1 results announcement from the Office of State and Community Energy Programs included a description of the grant proposals, including the number of schools or buildings involved, the amount of the award, and, in many cases, the specific names of the schools to be improved. In those cases where schools were not identified, a search for news clippings related to the awards was conducted, which in several cases led to the identification of the schools involved. Demographic information about the schools was drawn from National Center for Education Statistics data and data drawn from the Energy Justice Mapping Tool for Schools. ↩︎
  8.  These grantees are located in Alabama, Illinois, Kentucky, and Texas. ↩︎