The Department of Energy’s (DOE) effort to deploy large-scale carbon removal includes important first steps toward a more equitable CDR industry. Community benefit plans (CBPs) are required for all Bipartisan Infrastructure Law and Inflation Reduction Act funding opportunity announcements and loan applications, a move towards codifying community engagement alongside historic clean energy investments. 

DOE characterizes CBPs as intentionally flexible to generate the best approaches from applicants. Four DOE policy priorities guide how developers should collaborate with communities throughout a project’s lifecycle: community engagement, high-quality jobs, diversity, equity, inclusion, and accessibility (DEIA), and progress towards Justice40.  

DOE’s policy priorities help provide structure to a community benefits plan, but more specificity in each section is needed to meaningfully improve community engagement and drive just outcomes. CBPs should include information about how a project will be community-driven, safeguard public health, generate economic benefits, and advance the existing priorities and needs of host communities. 

Using DOE’s policy priorities as a framework, we’ve created recommendations for project developers as they construct their community benefits plans. Community benefits plans are only impactful if they are implemented and enforced. That’s why we’ve provided additional recommendations to DOE on how CBPs can live up to their potential. 

Building an impactful CBP 

Community engagement 

A successful community engagement section should be tailored to the unique characteristics of a community and incorporate proactive, impartial, honest, and long-term two-way engagement touchpoints between communities and project developers to build trust, ensure procedural justice, and enable community self-determination. Engagement plans should be a means to co-create projects with communities rather than simply check a box or convince communities to accept the project. 

There should be detailed, dedicated efforts to identify and build rapport with disadvantaged communities, environmental justice groups, and equity-focused community-based organizations. This should include honesty about where progress is slow and should address when or why opposition is building. These sections should also include efforts to help organizations build internal capacity and reduce barriers for these groups to engage in the project. For the creation of legally enforceable agreements, engagement efforts should clearly identify how the community defines benefits, particularly for disadvantaged stakeholder groups. 

High-quality jobs 

A jobs section in a CBP should focus on the quality of jobs, not just the quantity. It should include commitments to work with local labor groups and workforces to expand union memberships and build labor strength, or establish unionization options for workers if they don’t already exist. A form of a legally binding agreement, whether a community benefits agreement or a project labor agreement, should be included to ensure labor benefits match the needs of a community’s workforce. Important additions also include ambitious local hiring commitments, a pipeline of workforce and educational development opportunities, workforce safety, family-sustaining wages, and a robust range of benefits. 

Diversity, equity, inclusion, and accessibility 

Any DEIA plans should overlap with the activities of other sections and should continue to evolve based on community input throughout the project’s lifecycle. For any DEIA efforts to be successful, there should be pathways of buy-in for all the people who have roles and responsibilities for enacting it. The DEIA plans should clearly articulate how those conversations are happening, the knowledge gaps that exist and how to rectify them, and any economic opportunities created from the project and how to access them. There should also be accessible information about the milestones, roles, and responsibilities of a community benefits plan, and who is executing it, as well as public mechanisms for tracking progress and measures of success. 

Justice40 

Justice40 is a federal environmental justice goal that directs 40% of benefits from climate investments to flow to disadvantaged communities that have been impacted by environmental injustice. Strong plans in this category should include a clear identification of what the anticipated project benefits are and who are the disadvantaged communities that will receive them. These anticipated benefits should be quantifiable, measurable, and trackable. Project developers should clearly identify the anticipated benefits and how they expect those benefits to flow to communities. Additionally, there should be a thorough discussion of any cumulative environmental or health impacts of a project, and who is responsible for monitoring those impacts. 

Our recommendations to the Department of Energy

CBPs have the potential to be powerful tools for communities to influence, co-create, greenlight, and reject DOE projects –– granting them self-determination, a core principle of justice. Communities are asking for improved transparency from DOE, including that CBPs are made publicly available, and there are clearly defined processes that govern how community feedback is incorporated at key decision points. DOE should revisit community benefit plans as a core pillar of DOE programs and implement some changes to help CBPs to achieve their full potential:

  1. Expand the timeline and recruitment process for project merit reviews to ensure members of host communities have a direct role in reviewing project applications and decision points.
  2. Extend the timelines on future FOAs so project developers can meaningfully build community relationships and co-develop robust CBPs.
  3. Conduct more frequent, focused engagement activities to build the capacity of communities to understand, develop, implement, and sustain their own approaches to carbon removal.
  4. Move away from the current unenforceable language in CBPs and towards clearly defined requirements of developers.

DOE and carbon removal developers have the opportunity to set standards for community engagement on clean energy projects — if they operate in tandem. Developers must provide robust and specific detail within the four priority policy areas identified above while DOE commits to making CBPs publicly available, increasing transparency and accountability. Taken together, these efforts could ensure CBPs fulfill their role in supporting an equitable and responsible scale up of carbon removal.

Edited by Ana Little-SañaImage by Sincerely Media.