The Department of Housing and Urban Development’s Climate Action Plan, Reviewed
President Biden’s January 2021 Executive Order 14008 (Tackling the Climate Crisis at Home and Abroad) spurred the Department of Housing and Urban Development (HUD) to lay out their own Climate Action Plan in November of 2021. The goal of this plan is to ‘address climate threats and environmental injustice’.1 In addition, the 2018 National Climate Assessment from the U.S. Global Change Research Program (USGCRP) emphasized HUD’s essential role in mitigation and adaptation in the face of climate change.2
Environmental Justice in the Climate Action Plan
HUD’s Climate Action Plan acknowledges the historical inequalities and environmental injustices; an essential first step. The use of words and phrases such as “environmental justice”, “underserved” and “vulnerable communities”, and specific recognition of injustice for “communities of color” and “tribal communities” indicate HUD’s attention to environmental and housing injustice.3 However, it is essential that the actions outlined in the document actually embody this recognition and work to correct it.
In a statement, HUD describes environmental justice as “ensuring equal protection from environmental and health hazards and providing equal and meaningful opportunity to participate in the decision-making process to achieve a healthy environment.”’4 It is important to analyze HUD’s Climate Action Plan with this definition in mind.
Goals of the Climate Action Plan
HUD’s Climate Action Plan provides timelines for specific achievements and actions within their overarching goals of 1.) increasing climate resilience, 2.) reducing greenhouse gas (GHG) emissions, and 3.) pursuing environmental justice.5
Under these overarching goals are six to eight broad actions, including;
- Collecting data and analyzing climate risk, resilience, GHG emissions,
- Enabling recovery from climate disasters,
- Increasing resilience,
- Fostering climate justice in frontline communities.
Within each action item, HUD includes sub-actions, along with the committee responsible, implementation method, and timeline. Examples of specific actions are:
- Providing technical assistance to support sustainable, net zero building reflective of tribal cultures and supports job creation (under 3.1 promote climate justice in tribal communities),
- Publishing an Equitable Decarbonization Roadmap establishing a path for HUD’s portfolio to meet the Nation’s climate commitments equitably (under 2.3 publish actionable analysis on greenhouse gas emissions reduction),
- Updating Community Development Building Grant Disaster Recovery and Mitigation (CDBG-DR and CDBG-MIT) requirements to promote resilience and environmental justice.
Actions and Progress
The table below provides a visual representation of a few specific actions included in HUD’s Climate Action Plan; it is by no means a comprehensive list. The actions included in the table are the most measurable at this time because of their timelines outlined in the plan and the publicity of the actions themselves. Additionally, these actions are most relevant in terms of Just Solutions’ goal of centering frontline communities in environmental justice policy. Most of the actions analyzed in the table are specific programs HUD has or plans to implement. A majority of the actions in the Climate Action Plan are logistical and analytical to better assess the feasibility of these programs.
In analyzing HUD’s progress, the table below highlights in red an overdue deadline or unfinished project, yellow represents an ongoing timeline and progress, green indicates an upcoming deadline or finished (launched) project.
|Increasing Climate Resilience||Collect data and map risk, including implementing vulnerability assessments for multifamily properties||Ongoing||Collecting climate risk data continues to be a priority.⁶ Public data on multi-family property vulnerability assessments is not available.|
|Update CDBG-DR Grant Requirements to Promote Resilience and Environmental Justice||Universal notice March 2023||Updated CDBG grant requirements as of June 2022. April 2023 notice for urban county qualification: does not highlight resilience or environmental justice, focuses on grant applications. Criticisms of CDBG grant requirements and oversight will be discussed below.|
|Enable a Sustainable Recovery for Puerto Rico and the U.S. Virgin Islands||Ongoing||HUD’s support of Puerto Rico and the U.S. Virgin Islands primarily involves grant money but also other resources such as a disaster response toolkit created in partnership with Enterprise.|
|Provide Climate Resilience and Environmental Justice Training||Ongoing||According to a 2022 progress update, these training will begin once “relevant regulations” are updated.⁷ There is Environmental Review training available.|
|Reducing greenhouse gas emissions||Publish an Equitable Decarbonization Roadmap||March 2023||Delayed publication of the Equitable Decarbonization Roadmap. Reiterated goal during COP27.⁸|
|Publish utility data dashboards for Public Housing Agencies and HUD||June 2023||Done.|
|Implement Small Rural Frozen Rolling Base Program||December 2023||Launched 2022.|
|Create the Green and Resilient Retrofit Program||Ongoing||Launched August 2022.|
|Implement the Public Housing Rapid Return Utility Conservation program||December 2024||Not finished. Funding for this project was requested in HUD’s 2023 budget.|
|Launch Better Climate Challenge with DOE||December 2023||Done.|
|Continue Choice Neighborhoods Implementation grants||Ongoing||Continuing to invest in historically disadvantaged neighborhoods. A summary of 2022 grant recipients is available here.|
|Target resources for Indian Housing Block Grant-assisted housing energy efficiency.||Ongoing||Difficult to identify the extent of resources directed towards Indian Housing Block grantees. Resources available include the Tribal Climate Resilience Annual Awards Program, ONAP Environmental Resources, and general Climate Resilience resources. Funding is available and continually requested in HUD’s budget.|
|Pursuing environmental justice||Update HUD’s National Environmental Policy Act (NEPA) Policies||Ongoing||Developed a training series for NEPA policies. HUD’s publically available NEPA policies and resources are updated as of November 2021.|
|Publish guidance on incorporating the Social Vulnerability Index into Consolidated Plan development and grantee priority setting||December 2022||Published July 2023.|
|Citizen Participation and Engagement Toolkit for CDBG-DR and CDBG-MIT grantees||September 2022||Done.|
It is important to recognize HUD’s progress in meeting their goals and accomplishing action items from the 2021 Climate Action Plan. However, it is also essential to analyze the impacts of HUD’s programs and the success of their implementation. This is why HUD has also placed importance on collecting data in their Climate Action Plan and organizational goals.11
A Review of Community Development Block Grants (CDBG)
In the Climate Action Plan, HUD’s Community Development Block Grants are mentioned a multitude of times. It is one of HUD’s best-funded programs and provides the backbone of financial support for many of their action items. It exemplifies, in the Climate Action Plan, their past and continuing success by having “driven innovation and elevated the national conversation on resilient recovery”.
Criticisms of HUD’s CDBG exemplify the need to investigate the success of HUD’s programs in order to deliver effective support to disadvantaged communities. In 2021, the Government Accountability Office analyzed HUD’s commitment to reaching the most vulnerable communities with these grants and found that they were not analyzing sufficient data to fully assess the reach of these grants for vulnerable populations. GAO’s research found that vulnerable populations faced a number of barriers to accessing CDBG-DR assistance such as language barriers, transportation, and program requirements. HUD accepted GAO’s feedback but as of March 2022 cites staffing and infrastructure limit collecting and publishing more data.12
In February of 2023, the National Community Reinvestment Coalition (NCRC) published a letter from environmental justice advocates to HUD with regards to equity in CDBG-Disaster Recovery (DR) funds.13 This letter contained criticisms and recommendations regarding the equitable distribution of HUD’s CDBG-DR funds. Advocates argue that HUD must provide more specific direction for equitable allocation and critical analysis of fund allocation proposals’ adherence to equity in distribution.14
“The disproportionate exclusion of [low-income communities of color] from the recovery process, due to the skewed designation of funds by geography or by income, displacement pressures, and the failure to prioritize or target the most critical and pressing needs, has presented a grave civil and human rights issue in many places.”15
One action item within the Climate Action Plan specifically addressing some concerns mentioned by the GAO and NCRC is the creation of a Citizen Participation and Engagement Toolkit for CDBG-DR and CDBG-MIT grantees. According to HUD, the toolkit will “help to ensure whole community recovery and resilience by providing information and resources to help grantees bring in the ‘whole’ community to the conversation, specifically historically disadvantaged populations and protected classes”.16
The completed toolkit addresses some concerns, such as language barrier (available in Spanish). Yet the toolkit does not ensure that HUD is holding grant recipients accountable for equitable allocation; as of now, they are simply providing guidance.
A Note on the Equitable Decarbonization Roadmap
The Equitable Decarbonization Roadmap is essential to communicate HUD’s plan to utilize funds and programs mentioned in the Climate Action Plan. The delay of the Roadmap leaves the public and HUD lacking clarity and direction on the next steps for new programs, as well as commitment to continue the goals outlined in the Climate Action Plan. HUD must publish this plan to show their commitment to environmental justice and continue the momentum of the Climate Action Plan.
There is a lack of media coverage and attention by non-governmental organizations of HUD’s Climate Action Plan, which could indicate this is simply a structured plan rather than direct outcomes . Many environmental justice organizations have focused on analyzing actions resulting from this plan rather than the plan itself, such as the Green and Resilient Retrofit Program (GRRP).17
Since the release of HUD’s Climate Action Plan, there is one brief update on progress on prioritized climate actions. It reiterates HUD’s values in terms of environmental justice, and reports on the progress of eight action items.18
The Climate Action Plan can be a beneficial resource for environmental justice organizations looking for resources regarding housing and climate change – nearly all of HUD’s current climate mitigation grant programs are mentioned within this document, and the plan also provides an understanding of background actions and logistical collaborations that HUD is initiating, including data collection, inter- and intra- organization collaborations, organization of resources, assessment of risks, benefits, feasibility, and capacity for new projects, and much more.
In addition, environmental justice organizations that may be focused on specific issues within housing and climate could use the Climate Action Plan to pinpoint what actions HUD is taking, and then offer more pointed input.
It is clear in the Climate Action Plan that HUD is not only focused on the intersection of housing and climate, but also on implementing policies and programs that specifically benefit ‘low-income communities, communities of color, and other disadvantaged and historically underserved communities.’19 This in itself is a hopeful message for Environmental Justice organizations. However, the work ahead is significant.