Examples of Burdens and Avoidance Strategies

This page lists examples of avoidance strategies that correspond to the types of burdens listed in the Supplemental Guidance to Avoid Substantial Burdens or Harms to Priority Populations.

Many of these examples are compiled from strategies that administering agencies have implemented or strategies that have been suggested through community engagement. Some of these strategies can be implemented immediately while others may require training, research, or external support. Administering agencies can use this table after identifying potential burdens to help generate ideas for developing strategies to avoid the identified burdens in program design and project selection.


Types of Burdens	Burden Examples	Avoidance Strategies
Physical Health	Exposure to air, water, soil, odor, sound, or light pollution	Restrict project eligibility criteria to only fund zero-emission equipment Use green infrastructure Limit and monitor emissions Require project buffer zones Increase project application scores for sustainable building practices, such as obtaining LEED certification
Mental Health	Undermined sense of self-determination and overall quality of life due to exclusion from local decision-making and reduced access to essential needs and services	Co-create projects with communities Involve local leadership Invest in cultural humility training Provide trauma-informed engagement Require the inclusion of local Tribes in decision-making processes when performing work near sites of Tribal cultural significance Prioritize follow-up with community members, community organizations and Tribes; highlight where and how community or Tribal feedback was incorporated, including feedback that the program hopes to incorporate in the future Employ liaisons from the community or Tribe near/in the project area that can explain the project to concerned community members and communicate concerns to the grantee team
Mental Health	Instability, confusion, or frustration from lack of coordination and transparency on timelines or processes	Use transparent communication processes Provide clear timelines Respond to community feedback Document responses and how they informed program or project changes
Public Safety	Reduced access to healthcare facilities or inaccessible engagement venues	Require that project plans minimize public transportation, traffic, and emergency route disruptions Require ADA-compliant, accessible engagement venues Provide mobile services or transport for engagement events
Public Safety	Insufficient lighting or lack of pedestrian-safe infrastructure	Invest in lighting and pedestrian-safe routes Improve traffic control Conduct safety audits
Public Safety	Tensions within communities from increased surveillance or police presence	Use community-led safety models Reduce reliance on police where appropriate Invest in bias mitigation training
Public Safety	Safety risks caused by a heightened presence of nontribal members in and around land under the control of Native American Tribes	Engage Tribal governments early Invest in Tribal consultation training Recognize, respect and defer to Tribal sovereignty Establish accountability and dispute resolution protocols alongside neighboring Tribes
Physical Environment	Increased flooding, erosion, groundwater depletion, or wildfire vulnerability from development	Use permeable surfaces Require hydrologic and erosion control plans Utilize water reclamation and recycling systems, or other water conservation measures Invest in fire prevention measures
Ecosystem	Habitat loss, habitat fragmentation, reduced biodiversity, or introduction of invasive species	Conduct ecological assessments Avoid sensitive habitats Invest in habitat restoration and connectivity
Ecosystem	Harm to culturally significant species to Native American Tribes	Collaborate with Indigenous and local communities on species protection and management plans
Cost	Increased costs of housing, energy, or transportation	Provide cost-free energy efficiency and renewable energy services for low-income households Invest in energy storage and resilience projects Prioritize transit service and vehicle charging infrastructure for low-income communities Invest in free or reduced-fare transit
Workforce	Reduced access to local jobs and business opportunities or exacerbation of existing workforce injustices and wage disparities	Require local hiring Provide workforce training and apprenticeships Increase project application scores for demonstrated support of local small businesses Incorporate prevailing wage requirements
Resource	Administrative, financial, or planning challenges that strain time, resources, and cash flow	Simplify application processes Use phased application processes that limit early requirements and request detailed information only from selected applicants Provide technical assistance Clearly communicate how data will be used and reduce unnecessary reporting requirements Use advance payment options Ensure timelines are transparent and predictable
Resource	Diversion of resources away from sustainable solutions due to reliance on short-term or temporary projects	Provide pathways to secure long-term funding Integrate State climate goals into program design decisions Explicitly exclude funding for projects that undermine climate action and climate justice Increase project application scores for inclusion of community advisory committees
Social	Displacement from neighborhoods, ancestral lands, or social networks and/or gentrification of long-established communities	Protect culturally significant areas Prioritize community cohesion in planning Require that applicants submit an anti-displacement strategy and community benefits agreement
Social	Culturally incompatible public processes	Extend comment periods for required processes, such as Tribal Council Review Respect and accommodate culturally grounded forms of expression, such as storytelling, collective dialogue, and oral traditions Adopt engagement approaches beyond standardized formats
Social	Difficulty engaging or getting funding to under-resourced communities	Use data mapping tools and racial equity tools to determine the distribution of project impacts and benefits Target outreach to underserved communities Include equity advisors in program allocation decisions
Social	Language, logistical, or financial barriers that limit equitable participation and access	Provide materials in multiple languages Use plain language (avoid technical jargon) Use trusted community messengers for outreach Provide evening meetings and facilitate participation of families, including children
Social	Insensitivity to historical injustices or exclusion	Address historical harms openly Include historical context in planning Increase project application scores for reparative projects

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