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:Written comments may also be submitted directly via the Disadvantaged Community Proposed Definition comment form.
- 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
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).
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.
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:
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.
Priority | Criteria | Example |
---|---|---|
High Priority | The 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 Priority | The 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 Priority | The 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.
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
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.