Abstract
New Mexico’s Priority Climate Action Plan (2024) positions the state as a national leader in climate mitigation and energy transition under the U.S. Environmental Protection Agency’s Climate Pollution Reduction Grant framework. Yet questions remain about who truly benefits from this transition and how justice, power, and inclusion are embedded in the governance process. This article critically examines New Mexico’s climate governance through an environmental justice lens, exploring how state priorities align with equity commitments, community participation, and fair distribution of benefits and burdens. Drawing on a qualitative review of the plan, complementary policy documents, and current scholarship on just transitions, the analysis identifies both progress and persistent gaps. Although New Mexico integrates equity language and targets disadvantaged communities, implementation mechanisms remain uneven and vulnerable to political and economic influence. The article argues that realizing a just climate transition requires transparent decision-making, localized engagement, and long-term capacity building within frontline communities. By situating New Mexico’s approach within the broader U.S. discourse on environmental justice and state-led decarbonization, this review contributes to understanding how subnational climate policies can either reinforce or transform existing inequalities, offering insights for other states pursuing equitable climate action.
Keywords
INTRODUCTION
Climate change is increasingly recognized not only as an environmental challenge but also as a matter of justice. Communities that are historically marginalized, because of race, income, Indigenous status, or geography, often bear a disproportionate share of climate impacts yet are frequently excluded from decision-making processes that allocate both the risks and the benefits of climate policy. For state and local governments, embedding justice within decarbonization frameworks has become a national imperative. 1
In the United States, subnational actors, states, cities, and Tribal jurisdictions have become critical arenas for climate action. 2 Their decisions shape energy, transportation, and land-use systems, thereby influencing who benefits and who bears burdens. 3 Within these governance spaces, the question of who benefits from the transition is emerging as a core concern. For a transition to be truly just, it must go beyond technical fixes and shifting emissions trajectories; it must consider distributional outcomes (who is helped, who is harmed), procedural fairness (whose voice counts), and recognition (which actors and knowledge systems are valued). 4
In rural and Indigenous contexts, justice-oriented transitions must navigate long-standing marginalization of land-connected communities. Recent research emphasizes that effective transitions must uphold the rights, interests, and governance systems of Indigenous and rural populations rather than merely treating them as affected stakeholders. 5 Furthermore, rural households continue to face barriers to participating in clean-energy programs and equitable access to technology. 6 Such disparities underscore the importance of designing state-level policies that prioritize equity, inclusion, and place-based decision-making across New Mexico’s diverse communities.
The case of New Mexico offers a compelling laboratory for examining justice in climate governance. Its PCAP (2024) explicitly frames decarbonization as both an emissions reduction and an equity challenge. Yet implementation raises questions: Are benefits reaching frontline and disadvantaged communities? Is power over decision-making being shared? Are Indigenous, rural, and historically under-resourced communities meaningfully integrated into climate governance?
This article applies a justice-centric lens to evaluate New Mexico’s climate governance regime, situating the analysis within broader U.S. debates about just transitions and state climate action. Drawing on the plan, complementary policy documents, and recent scholarship on just-sustainability transitions, it explores how justice is conceived, operationalized, and contested in New Mexico’s climate agenda. 7 Through this review, the aim was not only to map strengths and weaknesses but also to offer practical lessons for U.S. states pursuing equitable climate transitions. Ultimately, the article argues that state-led climate governance offers a meaningful opportunity to advance justice in the United States, so long as it engages structurally with power, centers inclusion from the outset, and commits to transparent and sustained implementation.
The structure of the article is as follows: After this Introduction, the article presents the Policy Context and Analytical Framework, followed by Methods, then the Findings (including benefit distribution, power dynamics, and community inclusion). It concludes with a Discussion and Policy Recommendations.
OBJECTIVES
This review aims to critically evaluate how justice, power, and inclusion are integrated into New Mexico’s Priority Climate Action Plan (PCAP, 2024) and related state climate policies. The review is guided by three overarching objectives that reflect the intersection of environmental governance and equity implementation:
Assessment of policy alignment with justice principles:
Examine how the PCAP articulates distributional and procedural justice, including the targeting of benefits, participation processes, and burden-sharing among communities.
Evaluate power and governance structures:
Identify which institutions hold decision-making authority in New Mexico’s climate transition, how accountability is structured, and whether mechanisms exist for transparent oversight and public influence.
Analyze inclusion and recognition of indigenous and rural communities:
Determine how the plan incorporates Indigenous knowledge systems, rural needs, and community-defined priorities within state-led climate programs.
The review uses a qualitative, policy-focused approach informed by PRISMA transparency principles. Findings are intended to generate practical insights for U.S. subnational climate governance, providing policymakers and scholars with evidence-based recommendations for embedding environmental justice into implementation frameworks.
DATA SOURCES
This review draws upon a combination of primary policy documents, federal frameworks, and peer-reviewed literature relevant to climate governance and environmental justice in the United States, with emphasis on New Mexico between 2019 and 2025.
Primary sources include the New Mexico PCAP (2024), the Energy Transition Act Progress Report (2024), and associated executive orders, agency reports, and stakeholder engagement records published by the New Mexico Environment Department (NMED) and the Energy, Minerals, and Natural Resources Department. 8
Federal sources comprise the Climate Pollution Reduction Grant (CPRG) program materials, the Justice40 Initiative and Climate and Economic Justice Screening Tool guidance from the Council on Environmental Quality, and related technical documentation from the U.S. Environmental Protection Agency (EPA). 9
Peer-reviewed and gray literature were identified through Scopus, Web of Science, and government repositories using Preferred Reporting Items for Systematic Reviews and Meta-Analyses (PRISMA)-consistent keyword combinations (“climate justice,” “state climate governance,” “New Mexico,” “Indigenous inclusion,” and “just transition”). Searches prioritized studies published between 2023 and 2025 to ensure contemporary relevance. Reference lists of materials included were screened for additional sources, resulting in verifiable documents forming the evidence base for this analysis.
CONTEXT AND FRAMEWORK
Policy context
New Mexico’s PCAP (2024) is the state’s first integrated roadmap linking greenhouse-gas reduction with equity goals under the U.S. EPA’s CPRG program. 10 The plan targets major emission sources, transportation, power generation, and oil-and-gas operations, while pledging that at least 40% of federal climate investments benefit disadvantaged communities, consistent with the Justice40 Initiative. 11
Despite these strong commitments, implementation occurs within a challenging political economy. New Mexico remains one of the nation’s top energy producers, and fossil-fuel royalties fund a significant share of its state budget. 12 This tension between economic dependence and decarbonization ambition makes the PCAP a revealing case for evaluating how federal equity frameworks translate from design to delivery.
Analytical framework
This review applies a justice–power–inclusion lens derived from environmental justice and just transition scholarship.13,14,15
Justice assesses both distributional and procedural equity, who receives benefits or bears burdens, and whose voices shape implementation. Power examines how authority and accountability are distributed across agencies, industries, and communities. Inclusion considers recognition of Indigenous and rural knowledge systems and opportunities for shared decision-making.
This tripartite framework guided coding of documents and interpretation of results, providing a structured way to trace how climate policies articulate, institutionalize, or overlook environmental justice in practice.
RESULTS
The review identified three core dimensions of justice within New Mexico’s climate governance: Benefit distribution, power dynamics, and community inclusion. These themes reflect how equity principles are translated from planning documents into implementation processes across state agencies and partnerships.
Benefit distribution
The PCAP (2024) outlines investment priorities in transportation electrification, methane mitigation, and renewable energy deployment. However, evidence suggests that the majority of early project funding has favored urban or economically strategic regions, leaving many rural and Indigenous areas with limited direct access to clean-energy infrastructure. 16 Legislative oversight reports and stakeholder feedback show that financial and technical resources remain concentrated in counties with existing infrastructure advantages.17,18
At the same time, the plan aligns with federal expectations under the Justice40 Initiative, which requires that 40% of the benefits from federal climate investments flow to disadvantaged communities. 19 Yet multiple sources, including national and local audits, indicate that implementation gaps persist, and much of the funding does not yet meet that equity threshold.20,21
Power dynamics
Power asymmetries are evident in the governance architecture of climate policy. Decision-making remains largely centralized within state-level agencies, although community participation is often advisory or consultative rather than directive.22,23
The political economy of New Mexico complicates this further. Revenues from oil and gas production, particularly in the Permian Basin, continue to finance a substantial portion of the state budget, creating dependency tensions between short-term economic stability and long-term decarbonization goals. 24 Judicial decisions and media coverage further reveal how industry lobbying and litigation influence the scope of regulatory enforcement.25,26,27
Community inclusion
Community inclusion remains a partially realized goal. Although the PCAP (2024) highlights stakeholder engagement as a key priority, the mechanisms for meaningful participation are still developing. 28 The CPRG stakeholder engagement process has improved transparency, but representation from Tribal and rural communities remains limited. 29
Notably, university-led partnerships such as the Community-Based Water and Climate Governance Initiative at the University of New Mexico have begun to create local frameworks for participatory research and workforce development. 30 Such collaborations demonstrate practical ways to build capacity and align academic expertise with community-defined priorities.
DISCUSSION
Interpretation of findings
New Mexico’s PCAP (2024) demonstrates a forward-looking integration of climate and justice priorities, aligning state ambitions with federal frameworks such as the CPRG and Justice40.31,32,33 This reflects a growing national trend where states act as laboratories for environmental justice policy. 34 Yet, as this review shows, justice in design does not guarantee justice in delivery.
The PCAP introduces equity mandates, but implementation remains constrained by capacity, economic dependence on oil and gas, and evolving federal funding conditions.35,36,37 Agency coordination has improved, particularly through new methane enforcement and rule-making authority,38,39 but community participation remains uneven. Engagement mechanisms are documented, yet Indigenous and rural partners still face challenges in moving from consultation to shared decision authority. 40
However, expanding participation beyond already-privileged stakeholders requires more than formal engagement opportunities. Public comment periods, advisory councils, and stakeholder workshops often attract participants with greater institutional familiarity, technical expertise, or time flexibility. Without targeted outreach, financial compensation for community participation, language accessibility, and sustained technical assistance for under-resourced communities, engagement processes may unintentionally reproduce existing inequalities. 41 Experiences from states such as California and New York illustrate that equity-centered participation models, supported by funded community liaison programs, technical assistance grants, and structured advisory bodies, can broaden representation when participation is treated as an investment rather than a procedural requirement.42,43 These examples underscore that inclusive climate governance is not self-executing; it must be intentionally financed, facilitated, and institutionally protected.
This tension between policy ambition and institutional power defines the state’s climate transition. Power, as seen through Avelino’s concept of transformative governance, must redistribute both authority and accountability. 44 Without structural mechanisms for transparency and cogovernance, the equity language risks becoming procedural rather than transformative.
A further challenge concerns the influence of incumbent fossil-fuel industries within state governance structures. In resource-dependent states, concentrated economic power can shape regulatory priorities, delay enforcement through litigation, and influence legislative outcomes. 45 Political science research on subnational climate policy identifies these dynamics as forms of regulatory capture and policy conflict, where industry coalitions mobilize to slow or reshape environmental standards. 46 Community participation alone is insufficient to counterbalance such asymmetries in influence. Strengthening independent oversight mechanisms, protecting agency rule-making authority, mandating public disclosure of lobbying activities, and ensuring transparent monitoring systems are essential safeguards against concentrated industrial leverage. 47 Without institutional checks on incumbent power, transition frameworks risk remaining aspirational rather than transformative.
New Mexico’s experience also underscores a broader pattern within U.S. subnational governance: federal frameworks can stimulate justice innovations, but states must build durable administrative and fiscal capacity to sustain them.48,49 The temporary cancellation of several federal climate and environmental justice grants in 2025 exposed vulnerabilities in state programs reliant on federal continuity.50,51,52 Strengthening internal funding and codifying reporting systems are thus essential steps toward resilience.
Policy and practice recommendations
The review identifies several practical and time-bound actions through which New Mexico, and other states, can institutionalize environmental justice within climate governance:
Immediate (≤12 months): Establish justice metrics and dashboards.
Develop a Climate Justice Metrics Framework under the Environment Department (NMED) to track funding distribution, project locations, and participation outcomes in near real time.36,53 Public dashboards strengthen transparency and accountability.
Short term (1–2 years): Create a climate equity fund.
Establish a dedicated Climate Equity Fund, financed by a small royalty surcharge and matched federal grants, to buffer against federal program volatility.44–46 This fund should guarantee continuity for frontline and Tribal projects during fiscal uncertainty.
Medium term (2–4 years): Advance cogovernance with indigenous and rural communities. Formalize cogovernance agreements between state agencies and Tribal governments through memoranda of understanding granting joint oversight over implementation and benefit tracking.40,54
Comparative experiences demonstrate that cogovernance arrangements are most effective when they are embedded in statutory authority, clearly defined oversight roles, and stable funding commitments. In Washington State, the Climate Commitment Act established an Environmental Justice Council with formal advisory authority regarding investment priorities and implementation oversight, integrating justice considerations into administrative decision-making structures. 55 Similarly, British Columbia’s implementation of the Declaration on the Rights of Indigenous Peoples Act has enabled negotiated decision-making agreements between the provincial government and First Nations, shifting engagement from consultation toward structured shared governance in defined policy areas. 56 Peer-reviewed research on just transitions further indicates that durable cogovernance depends on transparent reporting requirements, enforceable agreements, and fiscal guarantees rather than informal stakeholder inclusion alone. 57 These examples suggest that for New Mexico, advancing beyond consultative engagement will require legally codified mechanisms that redistribute oversight authority and institutionalize accountability within climate governance.
However, experiences elsewhere also demonstrate the limits of advisory structures without binding authority. For example, some environmental justice advisory bodies in U.S. states have faced criticism for lacking formal decision-making power or guaranteed funding, resulting in limited influence over final policy outcomes.
58
Research on subnational climate conflict similarly finds that when equity bodies operate without statutory authority or enforceable mandates, industry coalitions and executive agencies often retain decisive control over implementation.
59
These shortcomings highlight that symbolic consultation mechanisms are insufficient unless accompanied by legally defined oversight powers and fiscal protections.
Medium term (2–5 years): Guarantee rural access to clean energy infrastructure.
Apply rural equity scoring to EV charging, efficiency upgrades, and renewable projects, ensuring at least 20% of new investments target rural and Tribal areas.35,60
Long term (≥5 years): Codify equity and accountability in law.
Enact a Climate Accountability and Equity Act mandating annual justice reporting, independent audits, and public data access. 61 This would institutionalize transparency beyond administrative cycles.
Across all timelines, sustained investment in workforce development, through partnerships with universities and Tribal colleges, is critical to embed equity into the next generation of technical and planning expertise.48
These measures form a sequenced roadmap: Immediate visibility through metrics, midterm power-sharing through cogovernance, and long-term continuity through legislation. Together, they can transform New Mexico’s climate governance from compliance-oriented to community-driven, turning equity from a policy statement into a measurable public good.
LIMITATIONS AND CONCLUSION
Limitations
This study is a policy review, not an empirical evaluation; its insights rely on publicly available documents, federal program guidance, and secondary literature. Although this ensures transparency and verifiability, it also limits the capacity to measure on-the-ground outcomes of equity initiatives still in progress.62,63,64 Because the PCAP (2024) is at an early implementation stage, the justice impacts observed are anticipatory, reflecting potential trajectories rather than realized performance.
Another limitation is the dynamic federal context. The recent suspension of several climate and environmental justice grants introduces uncertainties that may alter state capacities in ways not fully predictable at the time of writing.65,66,67 Despite these constraints, triangulating official policy sources, peer-reviewed studies, and agency data provides a credible basis for interpreting how justice, power, and inclusion are currently embedded in New Mexico’s climate governance.
Conclusion
New Mexico stands at a defining moment in U.S. climate governance. The PCAP (2024) places equity at the center of decarbonization, a significant milestone in state-level policy. Yet justice in design must now become justice in delivery. The analysis shows that although frameworks such as Justice40 and CPRG offer strong scaffolds, sustained transformation depends on three deeper shifts: Measuring outcomes, sharing authority, and securing continuity.
If New Mexico institutionalizes justice metrics, builds genuine cogovernance with Indigenous and rural communities, and stabilizes funding through a Climate Equity Fund, it could redefine what a “just transition” means in practice. The state’s choices in the next 5 years will demonstrate whether subnational climate governance can move beyond compliance toward inclusive, accountable, and durable justice.
More broadly, this review invites U.S. policymakers, scholars, and practitioners to view decarbonization not only as a technical challenge but also as a democratic opportunity, the chance to align climate ambition with fairness, dignity, and shared prosperity. The promise of a just transition will be fulfilled only when those most affected by the old energy economy help design and benefit from the new one.
Footnotes
ACKNOWLEDGMENTS
The author acknowledges the guidance of Dr. Lani Tsinnajinnie, Associate Professor, University of New Mexico, for scholarly mentorship and appreciates the insights shared by community members and local leadership in the Chapters of the Navajo Nation, whose experiences continue to shape the author’s understanding of equitable climate governance.
AUTHOR DISCLOSURE STATEMENT
The author declares no competing financial interests.
FUNDING INFORMATION
This research received no specific grant from any funding agency in the public, commercial, or not-for-profit sectors.
Supplemental Material
Supplementary Material
Please find the following supplemental material available below.
For Open Access articles published under a Creative Commons License, all supplemental material carries the same license as the article it is associated with.
For non-Open Access articles published, all supplemental material carries a non-exclusive license, and permission requests for re-use of supplemental material or any part of supplemental material shall be sent directly to the copyright owner as specified in the copyright notice associated with the article.
