Environmental Justice Indicators Assess Inequitable Burdens, State Tools Compensate

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Summary

• EJ indicators integrate social and environmental data to assess inequitable burdens.
• The 2025 rollback of EJScreen eliminated a national EJ reference point.
• State EJ tools now play a central role in identifying overburdened communities.
• Community-based metrics strengthen procedural justice and transparency.
• Chemical companies disclose EJ efforts in sustainability reports, but it remains to be seen how federal retrenchment will affect these disclosures.

Alistair Berg via Getty Images

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The Development and Implementation of EJ Indicators

Environmental justice (EJ) indicators emerge from the convergence of environmental and social dimensions. They measure impacts across environmental, demographic, epidemiological, and procedural factors. EJ frameworks are grounded in the understanding that social and environmental determinants are interconnected, reflecting broader concepts of liveability and public health. 1

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EJ indicators can be categorized into four EJ dimensions: 1. distributive justice, 2. correlational epidemiology, 3.procedural justice and restorative justice. First, distributive justice indicators identify the relationship between socioeconomic status (independent variables) and pollutant levels (dependent variables). They also address issues such as contaminated sites, noise pollution, and hydrocarbon extraction. Demographic indicators, such as age, education, gender, employment, racial characteristics, economic resources, and household income, are used to characterize disadvantage.

Correlational epidemiology indicators focus on the relationship between land use and health outcomes, measuring, for example, the proximity of industrial facilities and disease incidence. Procedural justice indicators evaluate whether regulatory processes are applied equitably, including disparities in inspection rates and enforcement actions. Restorative justice indicators assess efforts to redress unlawful or unethical environmental inequalities.

These categories collectively demonstrate that EJ metrics are not limited to pollution exposure alone but also encompass governance, participation, and corrective action.

EJScreen and State EJ Tools

The Environmental Protection Agency (EPA) created EJScreen in 2010 pursuant to executive orders directing federal agencies to collect information and assess environmental and human health risks borne by populations identified by race, national origin, or income and strengthen its commitment to environmental justice. EJScreen provided a nationally consistent dataset combining environmental and socioeconomic indicators at the census block group level.

EJScreen relied on two primary indices: a Demographic Index (percent low income and percent people of color) and a Supplemental Demographic Index incorporating additional socioeconomic factors. Environmental indicators covered air, water, and land-based risks, including particulate matter, ozone, nitrogen dioxide, traffic proximity, lead paint exposure, and proximity to hazardous waste sites. Although EJScreen was never intended as a comprehensive risk-analysis tool, it offered a standardized, publicly accessible reference point for identifying potentially overburdened communities. The EPA cautioned against using it for site-specific decisions and encouraged supplemental data sources, including community-collected metrics.

In 2025, the Trump administration revoked Executive Order 12898 and removed EJScreen and related data from public access. This action dismantled a core component of federal EJ infrastructure and sidelined the Office of Environmental Justice and External Civil Rights. Public interest groups challenged the removals in court, but EJScreen remains unavailable.

The federal withdrawal of EJScreen has complicated environmental, social, and governance (ESG) reporting. Without a nationally accepted EJ reference point, companies now operate in a fragmented data landscape. Some firms may tailor methodologies to produce favorable outcomes, while others may invest in bespoke models or partnerships with academic and community organizations. This divergence increases the risk of inconsistent reporting and greenwashing while placing disproportionate burdens on under-resourced regions and firms.

State EJ Tools as a Post-Federal Framework

With the rollback of EJScreen, state-level EJ mapping tools have become increasingly significant. These tools, originally developed to address regional environmental disparities, now fill an important data and accountability gap.

California’s CalEnviroScreen integrates dozens of environmental and demographic indicators to generate cumulative impact scores for census tracts. Its metrics include air and water pollution, pesticide exposure, traffic density, asthma rates, and linguistic isolation. CalEnviroScreen plays a statutory role in allocating cap-and-trade revenues and evaluating permitting decisions under California’s SB 535.

New Jersey’s Environmental Justice Mapping, Assessment, and Protection Tool (EJMAP) supports implementation of the state’s Environmental Justice Law, which requires cumulative impact analyses before permitting certain facilities in overburdened communities. The tool evaluates income, race, language isolation, and proximity to pollution sources to determine whether enhanced scrutiny applies.

While these state tools vary in scope, methodology, and data quality, they represent important models for EJ accountability. Their growing prominence underscores the need for harmonized EJ metrics that can support consistent ESG disclosure across jurisdictions.

Community Metrics

Integrating EJ considerations into ESG disclosure presents procedural justice challenges, particularly regarding inclusive participation and authentic outcomes. Community-Based Participatory Research (CBPR) offers a bottom-up approach in which affected communities help design indicators, gather data, and interpret results. 2

Community participation introduces transparency, local relevance, and credibility into EJ evaluations. It ensures that assessments reflect lived experiences, such as odor, noise, flooding, or health symptoms often overlooked by national datasets. Community-driven evaluations also build trust and foster ownership, making recommendations more actionable. 3

Effective participation requires addressing representation issues and investing in technical, political, and financial community capacity early in the process. This strengthens the legitimacy of EJ metrics and improves integration of community concerns into regulatory and corporate decision-making. 4

Community metrics empower residents to participate in assessment and reporting processes, addressing historical procedural injustices. By allowing communities to construct indicators and contribute to data collection, CBPR fosters transparency and reduces the risk of greenwashing.

The discontinuation of EJScreen has heightened the importance of community-generated data. In the absence of a federal baseline, CBPR frameworks offer a democratic, place-based model for identifying inequities and guiding ESG disclosures. Community metrics now function not only as substitutes for federal tools, but also as more responsive instruments for EJ accountability.

Public–Private–Community Partnerships

The integration of EJ metrics into ESG frameworks requires public–private–community partnerships. These collaborations pool regulatory authority, technical expertise, and local knowledge to develop robust data systems that monitor environmental conditions, track compliance, and sustain enforcement.

The state plays a key role in facilitating EJ solutions, while ESG can operate as a temporary remedy for the lack of mandatory environmental regulations and unequal distribution of environmental harms. Public and private governance must work together to address environmental degradation and inequitable treatment of EJ communities.

One challenge is the reliance on upstream climate and environmental data controlled by public institutions. Selective disclosure and proprietary models can exacerbate information inequality and greenwashing. Public–private partnerships can help develop accessible, standardized tools that democratize environmental data.

Community capacity-building remains central to EJ strategies. Effective programs emphasize collaborations, technical assistance, and CBPR to empower communities and produce tangible results. 5

The EPA has promoted Community-Based Public-Private Partnerships (CBP3s) to support green infrastructure investments. These partnerships offer cost-efficient alternatives to traditional infrastructure models while delivering local economic and social benefits.

Despite these opportunities, tensions persist. EJ groups often distrust government and corporate actors due to historical exploitation. Many view these institutions as adversaries rather than allies. 6 Overcoming this mistrust requires transparency, accountability, and sustained engagement grounded in mutual respect.

Corporate EJ Disclosure in Sustainability Reports

Even after the federal rollback of EJScreen , some companies continue to disclose EJ efforts in sustainability reports. These disclosures are often motivated by consumer expectations, investor preferences, reputational risk management, and heightened scrutiny of permitting decisions in overburdened communities.

Corporate sustainability reports typically use frameworks such as the International Sustainability Standards Board (ISSB), the Sustainability Accounting Standards Board (SASB) which now part of the ISSB, and The Global Reporting Initiative (GRI). EJ criteria may be disclosed under material topics like Community Relations, Human Rights, or Local Community Engagement.

The chemical sector provides a useful case study due to its historical links to environmental justice concerns. 7 After surveying more than 142 sustainability reports, only four reports explicitly referenced “environmental justice.”

In 2023 Chemours reported completing EJ evaluations of U.S. manufacturing sites using EPA’s EJScreen tool. Its sustainability reports described identifying seven sites for targeted community engagement and developing communication plans based on EJ data. EJ was incorporated under SASB’s Community Relations category but not linked to GRI disclosures. Chemours tied environmental and social justice to land stewardship through the donation or sale of former sites to support local economic development.

Eastman Chemical disclosed using EPA and White House Council on Environmental Quality mapping tools to assess community burdens related to climate, health, housing, and legacy pollution. EJ was incorporated under GRI’s “Operations with local community engagement” framework. However, Eastman has released limited follow-up information on how these tools informed concrete actions, and the company faced EPA enforcement actions for environmental violations in 2023.

Dow Chemical adopted a more integrated approach, embedding EJ into its governance, climate, and community impact disclosures. Dow established an EJ Steering Team, conducted site-level assessments using EJScreen and the Climate and Economic Justice Screening Tool, and developed dashboards and community engagement plans across its U.S. sites. EJ was explicitly cross-referenced across multiple GRI disclosure categories.

DuPont illustrates the fragility of EJ commitments. In 2023, the company referenced EJ as a “core value” without identifying tools or methodologies. By 2024, DuPont elevated EJ to a material topic, created an Environmental Justice Team, and completed 21 site assessments using federal and state screening tools. In 2025, however, amid federal rollbacks of environmental justice programs, DuPont’s public sustainability disclosures no longer emphasized EJ progress.

These examples show that some companies have disclosed environmental justice and the use of EJtools. However, the absence of standardized federal guidance raises concerns about consistency, verification, and long-term commitment. It remains to be seen how corporate EJ disclosures will evolve as political and regulatory landscapes shift.

Community-based approaches strengthen procedural justice, improve data accuracy, and empower frontline communities. Public–private–community partnerships offer pathways for sustainable, inclusive governance. Meanwhile, corporate EJ disclosures reflect both the growing importance of EJ and the fragility of voluntary commitments.

The dismantling of EJScreen has reshaped the environmental justice landscape. In its absence, state EJ tools, community metrics, and collaborative partnerships now serve as the primary mechanisms for identifying inequities and guiding ESG disclosures.

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Endnotes

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Author

Barbara Ballan

Barbara Ballan is an assistant professor of law at Florida International University....

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Author

Barbara Ballan

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Committees

This content was produced by:

• Environmental, Social, Governance, and Sustainability Committee
• In-House Counsel Committee

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