Environmental Justice Implementation

Instruction Memorandum
In Reply Refer To:

In Reply Refer To:
1610 (HQ-200) P         

To:All Headquarters and Field Officials
Subject:Environmental Justice Implementation
Program Area:All Program Areas.

This Instruction Memorandum (IM) provides policy clarity for minimum requirements to elevate environmental justice at the Bureau of Land Management (BLM), with a primary focus on environmental compliance review under the National Environmental Policy Act (NEPA), including scoping, outreach, and analysis.

Administrative or Mission Related:



Working to achieve environmental justice is a whole-of-government responsibility, requiring Federal agencies to provide fair treatment and meaningful involvement to all. The BLM supports this effort.

The BLM Socioeconomics Program provides a nationally consistent approach to fulfilling the Bureau’s environmental justice responsibilities. This IM updates and formalizes best practices already in use at the BLM, and recommends methods for scoping, outreach, and analysis in environmental reviews of all proposed actions, including land use planning and individual projects. The BLM will actively fulfill its environmental justice responsibilities by following the principles and practices in Addressing Environmental Justice in NEPA Documents: Frequently Asked Questions (2022, Attachment 1). In brief:

  1. Environmental justice must be considered in environmental reviews of all proposed actions, including land use planning and individual projects.
  2. Field offices will conduct an environmental justice screening of their office’s jurisdiction to identify and inventory minority populations, low-income populations, and Tribes in their area. The screening will be conducted, at a minimum, every two years by June 30 and be documented in a report. Available screening tools are documented in Attachment 1 and on the Socioeconomics SharePoint. The first screening will be conducted by Socioeconomics Program staff. For future years, the applicable BLM State office may choose to conduct screenings on behalf of their field offices. Completed reports will be sent to the Socioeconomics Program.  
  3. The BLM will determine whether a proposed action or alternatives would adversely and disproportionately impact minority populations, low-income populations, and Tribes, and consider cumulative effects, including from reasonably foreseeable actions taken by other parties within the timeframe of the direct and indirect effects. Analysis will first consider all potential social and economic effects, beneficial and adverse, on the general population to determine if impacts on these three populations are disproportionate.
  4. The BLM will proactively provide opportunities for meaningful involvement of minority populations, low-income populations, and Tribes in BLM decision-making processes that affect their lives, livelihoods, and health. This commitment is in addition to the BLM’s responsibilities to consult with federally recognized Tribes and Alaska Native Corporations, as outlined in Department and BLM policies. The BLM will provide translation services as needed in accordance with Executive Order (EO) 13166 Improving Access to Services for Persons with Limited English Proficiency.
  5. When the Bureau develops, reviews, and assesses alternatives and potential mitigation measures as part of a land use planning process or other review under NEPA, the BLM will consider environmental justice, including, as appropriate, consideration of environmental justice issues facing minority populations, low-income populations, and Tribes living near public lands, or working with or using public land resources.

Attachment 1 explains the concepts, processes, and principles associated with environmental justice in NEPA by addressing seventeen questions. This document establishes minimum requirements while recognizing that the diversity of communities, projects, and processes requires the flexibility to adopt multiple approaches or select more sensitive or context-specific approaches. In addition to Attachment 1, best practices and tools for conducting environmental justice work are provided on the Socioeconomics SharePoint and may be referenced to ensure consistency and the use of high-quality information.


This policy is effective immediately.

Budget Impact:

No significant budget impacts are anticipated.


EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (1994) charges Federal agencies with “identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities” on low-income, minority, and tribal populations.

Manual/Handbook Sections Affected:



If you have questions, contact the Socioeconomics Program Lead Rebecca Moore, rmoore@blm.gov or (970) 226-9246 or the Environmental Justice Coordinator, Victoria Phaneuf at vphaneuf@blm.gov (720) 281-8571.


This document was collaboratively developed by the BLM Socioeconomics Program (HQ-210) in consultation with HQ-200 (Resources and Planning), HQ-400 (National Conservation Lands), HQ-300 (Energy, Minerals, and Realty Management), the Resources and Mineral Committee and the BLM Environmental Justice Working Group which includes representatives from all BLM State Offices, some Field Offices, the National Operations Center, National Training Center, and Headquarters.