2023 Grant Writing Post-Mortem: The Rise of DEIA and Department of Energy Community Benefit Plans

As 2023 has stumbled to a close, a grant writing post-mortem is in order.

Having written grant proposals since dinosaurs walked the earth (mid-70s, but close enough), the process remains relatively the same, except now we use computers instead of a legal pad* and the Internet instead of endless trips to the library. So, like the Talking Heads song Once in a Lifetime, it’s the “same as it ever was.” This is because very little has changed in how human services are delivered, how capital projects get built, etc.—outreach and case planning are still conducted in the same ways and site control and a building permit are still needed for construction. So, we develop project concepts in much the same way as I learned decades ago and the proposals look about the same when printed. But, 2023 introduced a new obsession with all things Diversity, Equity, Inclusion, and Accessibility (DEIA): virtually every federal RFP we see these days requires some form of DEIA discussion, often quite extensive, in the project narrative, no matter the program purpose or target population. This may include President Biden’s Justice40 Initiative, which is nominally about environmental justice but is used as DEIA shorthand in some RFPs.

Writing about DEIA concepts in proposals, however, is not new, as these are just different words for old themes. In the late ’70s, I was the Grants Coordinator for the City of Lynwood in LA County, which had transitioned from almost 100% white pre-Watts Rebellion in 1965 to almost 100% African American by the time I got there. I quickly learned that threading in variations on what was then usually called institutional racism (e.g, the “400 years of oppression causes all problems” argument) was a winner and I larded it into every proposal I wrote for Lynwood, and later for the City of Inglewood, another mostly African American community, where I was Redevelopment Manager in the ’80s.

Since S + A started business over 30 years ago, we’ve continued to use similar arguments in needs assessments, modified for such other target populations as Hispanics, LGBTQ, etc. It doesn’t matter much who the population is because, like college professors and reporters, most grant reviewers are Democrats/progressives. They are steeped in the oppressor/victim construct and we write to their expectations, since our job is to get our clients funded. It’s fairly easy to manipulate data to support this gestalt. Case in point: some years ago we wrote a funded $2M California state grant proposal for an affluent city in Orange County to build a new youth center. The RFP was aimed at funding facilities for low-income, at-risk youth of color, but this was an upper-middle-class, mostly white city. What to do? Since Mission Viejo had a small but rapidly growing Asian population, we were able to carefully manipulate/obfuscate** census data, other data, and anecdotes to create the illusion of need, which is all that a needs assessment actually is.

Since DEIA is now ubiquitous, we must often go through some narrative contortions to apply the concept, particularly if the project concept or target area have little, if anything, to do with this issue. For example, we write many proposals for clients in rural Appalachia, which is very low-income but almost 100% white. So, the needs assessments discuss applying DEIA to imaginary residents, since everyone knows that DEIA is usually not applied to poor white folks, just like the violent protests across America following the recent horrific attack on Israel show that intersectionality is rarely applied to Jewish folks, no matter what other characteristics beyond religious affinity they may have. Still, this slight-of-hand writing should not be hard for an experienced grant writer.

Due to the avalanche of funds from the Bipartisan Infrastructure Law (BIL) and similar appropriation bills, we wrote many Department of Energy (DOE) proposals in 2023. The DEIA obsession is evident in DOE FOAs (DOE-speak for RFP), which not only require that DEIA be addressed in project narratives, but also require that long-winded Community Benefits Plans (CBPs) be attached. We recently completed a DOE proposal—the FOA was 90 single-spaced pages, including about 15 pages devoted to the complex CBP instructions, but the project narrative response was limited to nine single-spaced pages, while the CBP had no page limit. This creates a classic “tail wagging the dog”*** writing challenge.

Newsflash to DOE: no matter what the proposal topic, all CBPs will be relatively the same because the “solutions” are all about the same. This is very similar to many HUD proposals we used to write. Up until a few years ago, these required an attachment similar to CBPs: a discussion of how the project related to Section 3 of the Housing and Community Development Act of 1968: “The Section 3 program requires that recipients of certain HUD financial assistance, to the greatest extent possible, provide training, employment, contracting and other economic opportunities to low- and very low-income persons, especially recipients of government assistance for housing, and to businesses that provide economic opportunities to low- and very low-income persons.” CBPs are just Section 3 Plans by another name with a soupçon of DEIA. All Section 3 Plans read more or less the same, as do CBPs, and I could convert a HUD Section 3 Plan we wrote 20 years ago into a DOE CBP fairly quickly. I don’t think anyone actually read a Section 3 Plan and doubt if anyone will read a CBP. Also, these would be very hard to enforce, as the goals, objectives, and activities are very nebulous and few federal agencies still conduct program audits.

Since most of our DOE clients are for-profits, including some Fortune 500 companies, they are unfamiliar with the grant-seeking process and terrified of the CBP requirement. When we scope the proposal project concept, we talk them off the ledge and draft their CBP as part of the assignment. The fun part is that not a single DOE client seems to care about the CBP, except that they know they must submit one to get funded. When drafting a CBP, we usually get the company’s DEIA statement/policies to incorporate. Second fun fact: these also read about the same, which means they’re likely boilerplate, written by the army of DEIA consultants that have emerged. From a grant-writing perspective, DEIA discussions and CBPs are just friction in the system. This should be obvious, since discrimination has been banned by federal, state, and local laws since 1965, and Affirmative Action has existed since the Nixon administration. But, the Golden Rule in grant writing is that the people with the gold make the rules, so the need to incorporate DEIA will continue until Congress replaces it with a similar requirement.

* I got so good at writing proposals by 1979 that I was able to dictate them to my secretary who knew shorthand (Millennials and Gen Z can google “shorthand”).
** While S + A is a master of data manipulation and obfuscation, we never intentionally include any untruths or fabrications in our proposals and neither should you.
*** The 1997 movie, “Wag the Dog” is worth watching.