Disadvantaged Community Definition and Guidance

Public Comment Period on Disadvantaged Community Definition

The Lake Champlain Basin Program is currently seeking public comments on the definition of “disadvantaged community” described on this page. The LCBP has scheduled a series of meetings to solicit feedback and will accept public comments online through June 9, 2023. The meetings will be directed toward specific audiences, but all meetings are open to any interested party:
  • Watershed groups and previous LCBP funding recipients: May 23rd at 10 a.m. (Register here)
  • Groups serving or representing the interests of disadvantaged community members: May 24th at 3 p.m. (Register here)
  • Municipal representatives: May 31st at 10 a.m. (Register here)
  • Community members or any interested party (in person, pre-registration appreciated but not required)
    • June 6th at 6 p.m. – O’Brien Community Center, 32 Malletts Bay Ave, Winooski, VT 05404
    • June 7th at 6 p.m. – Plattsburgh Public Library, 19 Oak St. Plattsburgh, NY 12901
Written comments may also be submitted directly via the Disadvantaged Community Proposed Definition comment form.

The Lake Champlain Basin Program is committed to advancing diversity, equity, and inclusion across our work. In response to the U.S. federal Justice40 Initiative and corresponding Environmental Protection Agency (EPA) guidance, LCBP has developed a definition of ‘disadvantaged community’ to guide funding decisions. LCBP has set a goal that 40% of funds distributed through our grant programs will support projects that benefit disadvantaged audiences, occur in communities identified as disadvantaged, or have demonstrable benefits to disadvantaged communities.

The criteria included in LCBP’s definition of a disadvantaged community will be an additional consideration for funding projects that meet the objectives of LCBP’s management plan Opportunities for Action: an Evolving Plan for the Future of the Lake Champlain Basin.

Questions relating to LCBP’s disadvantaged community definition can be directed to Mae Kate Campbell, LCBP Associate Scientist (mkcampbell@lcbp.org).

LCBP Interim Definition of Disadvantaged Community

For LCBP funding purposes, a community is considered disadvantaged if it meets any one or more of the following criteria:

Criteria Threshold 
High School Degree Non-Attainment ≥ 15% of the population age 25+ has an education level less than a high-school diploma 
Housing Cost Burden The ratio of monthly gross rent + utilities to monthly household income (renters) or the percentage of household income that goes towards mortgage payments, real estate taxes, insurance, utilities, and fuels (owners) is ≥ 35% 
Lack of Access to Complete Plumbing Facilities The % of households who lack complete plumbing facilities (hot and cold running water and a bathtub or shower) is ≥ 5% 
Linguistic isolation/limited English proficiency The percentage of households in which no one over the age of 14 speaks English “very well” is ≥ 1% 
Median household income The percentage of households earning less than 80% of the area median income is ≥ 50% 
National School Lunch Program Eligibility The number of students eligible for the National School Lunch Program is ≥ 50% 
Poverty Rate The percentage of households whose annual income is <200% of the federal poverty limit is ≥ 40% 
Estimated Prevalence of Cancer The estimated prevalence of all-cause cancer (excluding skin cancer) among adults 18 and older is greater than for 66.66% of U.S. census tracts (2020) 
Prevalence of Mobile/Manufactured Homes The percentage of houses that are mobile/manufactured homes is ≥ 15% 
Unemployment Rate The percentage of the population in the workforce who are unemployed is ≥ 7.5% 
Presence of Tribal Lands or Sites of Cultural Importance (State or Federally recognized Tribes) Any project that will occur on tribal lands or sites of cultural importance with tribal support 
Self-identification Any project than can demonstrate direct benefit to a disadvantaged community, regardless of geographic location 

LCBP’s disadvantaged community mapping tool is available here.

 

Technical documentation describing the sources and application of the datasets used in LCBP’s definition and map is available here.

Determining If a Project Meets LCBP's Disadvantaged Community Definition

Proposed projects that meet the objectives of Opportunities for Action will be identified as meeting LCBP’s disadvantaged community definition if any one or more of the following criteria are met: 

  1. The project will be implemented in a census block that is identified as disadvantaged per LCBP’s mapping tool; 
  1. The project will benefit groups identified as disadvantaged per the criteria included in LCBP’s definition (regardless of location); 

    Examples: A project to develop educational resources or signage in different languages to benefit limited English proficiency populations, a project to assist low-income homeowners with installing best-management practices on their property, a riparian restoration project that takes place at a mobile/manufactured home park, an educational program that targets students at schools with high National School Lunch Program eligibility, a workforce development or training program that targets adults who have not attained a high-school degree 
  1. The project will not be implemented in a census block that is identified as disadvantaged, but would benefit a nearby disadvantaged community; 

    Examples: A land conservation project that would increase recreational access opportunities to nearby disadvantaged communities, an educational project implemented at a school that serves students from nearby disadvantaged communities 
  1. Self-identification 

    LCBP recognizes that the datasets used in our definition and related mapping tool may not capture all factors that can contribute to a community being disadvantaged. We encourage grant applicants to include a justification of how their project will benefit disadvantaged communities, including any accompanying data where possible. 

How this Definition Will be Used in the Proposal Evaluation Process

Any project that is determined to meet the criteria outlined in LCBP’s disadvantaged community definition will be given additional weight in the proposal evaluation process. LCBP will use a tiered system to evaluate how much additional weight a proposal will be given according to the guidelines below. Projects that demonstrate a direct benefit to populations identified as disadvantaged (not just to a geographic area identified as disadvantaged) and demonstrate meaningful involvement with disadvantaged communities will be more competitive in the proposal evaluation process. 

“Meaningful Involvement” means that: (1) potentially affected community residents have an appropriate opportunity to participate in decisions about a proposed activity that will affect their environment and/or health; (2) the public’s contribution can influence the decision-making process; (3) the concerns of all participants involved will be considered in the decision-making process; and (4) the decision-makers seek out and facilitate the involvement of those potentially affected. 

PriorityCriteria Example 
High PriorityThe project will benefit a disadvantaged community that meets multiple criteria included in LCBP’s definition AND demonstrates meaningful involvement from the selected community   A water-quality workforce development program in a community with high unemployment and high school degree non-attainment; a project to address flooding at a mobile home park in a census block with a high poverty rate 
Medium PriorityThe project will benefit a disadvantaged community that meets one criterion included in LCBP’s definition AND demonstrates meaningful involvement from the selected community   A project to assist low-income homeowners with installing best-management practices on their property in a census block with high poverty rates 
The project will take place in a disadvantaged community meeting multiple criteria, but the work proposed does not demonstrate meaningful involvement from the selected community   A dam removal project in a community with high lack of access to indoor plumbing and high National School Lunch Program eligibility 
Low PriorityThe project will take place in a disadvantaged community that meets one criterion, but the work proposed does not demonstrate meaningful involvement from the selected community   A streambank stabilization project in a census block with high linguistic isolation 

 

LCBP staff, in coordination with confidential external peer reviewers selected for each grant category, will evaluate the degree to which a project meets the criteria outlined in LCBP’s definition of disadvantaged community. Please refer to a specific Request For Proposals (RFP) for more information on how disadvantaged community criteria will be considered in that grant category’s evaluation process.

Frequently Asked Questions

  1. What if my proposed project will not benefit disadvantaged communities? 

    Proposed projects are not required to have demonstrable benefits to disadvantaged communities. If your proposed project does not meet the definition, it will not receive additional weight in the proposal evaluation process, but may still be competitive if the project strongly aligns with the criteria identified for that grant program. 
  1. What if the location of my proposed project has not yet been determined? 

    Projects that do not have an implementation location finalized at the time of proposal submission can still qualify as meeting the criteria in LCBP’s disadvantaged community definition if the applicant can provide information on how disadvantaged communities will be prioritized in the location selection process once the grant work begins. However, proposals that do identify benefits to disadvantaged communities at the proposal stage may be more competitive. 
  1. What if my proposed project will take place across multiple census block groups, some of which are identified as disadvantaged but others are not? 

    Projects that will occur in multiple locations, some of which are identified as disadvantaged, will receive additional weight in the proposal evaluation process proportional to the degree to which the project will take place in or benefit disadvantaged communities.  
  1. What if my proposed project will not take place at a physical location (ex. developing a video, website, or lesson plans)? 

    Projects that will not take place at a physical location can still qualify as meeting the criteria outlined in LCBP’s definition of disadvantaged community if they can demonstrate how the project will benefit a disadvantaged audience (for example, videos will be developed in multiple languages to benefit limited English proficiency populations, lesson plans will be used at schools with high National School Lunch Program eligibility).  
  1. What if my proposed project will take place in Canada? 

    Projects located in Canada are not eligible for funding under RFPs that are currently open. We will provide additional information on this topic when applicable.  
  1. Why are you using the term “disadvantaged community”? 

    LCBP is using the term “disadvantaged community” to remain consistent with federal guidance associated with implementing the Justice40 Initiative. Applicants are welcome to use alternate terms, such as “marginalized”, “underserved”, or “impacted” community if preferable. 

Development of the Definition

LCBP reviewed relevant federal and state agency definitions of ‘disadvantaged’ or ‘environmental justice’ communities to identify datasets commonly included in these definitions1. LCBP selected a suite of criteria to be included in our definition, following EPA guidance and consideration of commonly used datasets that align with LCBP’s mission. A public comment period on the proposed criteria was held in November-December 2022. 

Following review of public comments received, the Lake Champlain Steering Committee approved an interim disadvantaged community definition in December 2022. LCBP then developed a mapping tool to assist with identifying the locations of disadvantaged communities per LCBP’s definition.

With the mapping tool available, LCBP is planning to open a second public comment period involving direct outreach to communities identified as disadvantaged and groups working with these communities in Spring 2023. The Lake Champlain Steering Committee will revisit LCBP’s definition following the second public comment period. The Lake Champlain Steering Committee intends to review this definition annually.

1Definitions reviewed include: Agency for Toxic Substances and Disease Registry’s Environmental Justice Indicator, The Center for Disease Control and Agency for Toxic Substances and Disease Registry’s Social Vulnerability Index, The Council on Environmental Quality’s Climate and Economic Justice Screening Tool, EPA’s Environmental Justice Screening and Mapping Tool, The New York State Climate Justice Working Group’s draft Disadvantaged Communities Criteria, Québec Ministry of Municipal Affairs and Housing Economic Vitality Index, Vermont Act No. 154. An act relating to environmental justice in Vermont 

Environmental Quality Impacts

LCBP recognizes that communities can be impacted by factors that are not solely related to socioeconomic indicators. In addition to the socioeconomic criteria that are used in LCBP’s definition of disadvantaged community, proposals should clearly demonstrate how the proposed project will address or improve environmental quality concerns across the intended project area, and how these concerns align with LCBP’s mission and management goals identified within Opportunities for Action. The degree to which a community is impacted by any one or more of these environmental quality indicators will be weighed to help prioritize projects within underserved communities.

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