From ARPA to IIJA - Fulfilling the Promise of Equity

by Brittny Saunders and Helen Chin of Communities First

At Communities First, with just months until the 2022 mid-term elections, we, like many, are reflecting on the current administration's accomplishments. Two legislative victories stand apart: the passage of the American Rescue Plan Act (ARPA) and the Infrastructure Investment and Jobs Act (IIJA).

These two massive investments — the first a broad, $1.9T package to aid pandemic and economic recovery, and the second a long-overdue $1.2T infusion of funds to build multi-modal transportation systems, broadband infrastructure, and more — represent public investments at a scale unmatched in generations. Both harken back to moments in history when the federal government made much-needed landmark investments such as through the National Housing Act, the G.I. Bill, and the Federal-Aid Highway Act.

Too often, however, these acts fell far short of their potential, excluding Americans of color from transformative opportunities and entrenching racist practices and structures. For communities of color, investments in infrastructure were weaponized, harming and isolating communities.

The 2021 legislation, however, represents a chance to break with this history by centering the needs of those most impacted communities and putting our public dollars toward community assets — classrooms, hospitals, parks, and businesses — in parts of the country that have long been deprived of investment. These two laws present a once-in-a-generation opportunity to send a powerful message about who is worthy and who belongs. To date, hundreds of billions have already flowed through ARPA programs.

At the heart of this opportunity is racial equity, or the elimination and repair of racial disparities as well as the improvement of opportunities for all through policy, practice, and structural change (1). Using federal funds to advance racial equity requires intentionality at multiple levels. This means commitments must be reflected not only in statements, orders, and language but also in the day-to-day practices of administering agencies.

ARPA provides considerable evidence of a built-in commitment to governing for racial equity. It authorizes several Department of Treasury programs to target communities that have been socially or economically disadvantaged, an important recognition of the need to repair historical harms. The Treasury Department has similarly reflected the importance of equity in the State and Local Fiscal Recovery Fund (SLFRF) rules. This Fund will send some $350B to states, cities, counties, territories, and Tribal governments over the next few years. These rules acknowledge that communities of color were vulnerable before COVID-19 and have seen particular devastation since. The Treasury has even gone beyond this to publish a blog post on the agency’s approach to centering racial equity (2) and set expectations for how equity and community engagement should shape project planning (3).

Yet, while important, stating intentions is not enough. To advance racial equity, the federal government must direct its dollars to programs and investments that truly address community needs.

In this, ARPA holds promise. Governments that were forced to downsize due to the pandemic can draw upon SLFRF dollars to rehire staff or cover administrative expenses associated with pandemic or economic recovery programs (4). The SLFRF also appears to allow for investments in public-health focused approaches to public safety that are needed to prevent crime and reduce mass incarceration (5). Dollars available under Treasury’s Capital Projects Fund can fund facilities that meet intersecting community needs by serving health, education, and employment-related functions (6). And in expanding broadband access and adoption, SLFRF has considerable potential. Not only may these dollars be used to fund broadband infrastructure, but dollars can also be leveraged as matching funds for future IIJA broadband projects (7).

Ultimately, however, the opportunities above are just that — opportunities alone. Whether ARPA and IIJA programs will make transformative progress will depend on decisions by state, local, territorial, and Tribal decision-makers, among others. To bring about these decisions, accountability at every level of government is key to ensuring ARPA and IIJA public dollars are used in alignment with community priorities. To lean into this accountability, federal agencies have a critical role to play: providing transparency about their progress, incentivizing investments that further equity, and disincentivizing those that deviate from the legislation’s intentions—like the Alabama policymakers’ use of ARPA funds for prison construction. Thus, administering agencies should use all the tools at their disposal, including reclaiming funds where appropriate (8). Furthermore, consistent, highly-visible efforts to applaud or denounce governments could encourage uses that advance equity goals. These public reminders of accountability could also remind Americans of the federal government’s commitment to investing wisely in their communities. Those of us outside the government can support the important work of informing the public and holding decision-makers accountable. Additionally, NGOs can work with the public to outline what life-changing investments should look like and then hold the Biden Administration to this vision. At Communities First, we’ve taken an initial step by reviewing the $1.9T ARPA package for the investments that communities desire most. We then identified programs that—due to either their focus on equity or general flexibility—appear particularly rich with opportunities for transformative investment in communities of color. We’ve included this analysis in our American Rescue Plan Act: Centering Equity and Impacted Communities. How we as Americans choose to put our public dollars to work makes a powerful statement about our priorities and who we believe is truly part of our national community. If we learn the lessons of our past and build from a foundation of repair, reckoning, and transformation, we can—through ARPA and IIJA—send a powerful message that Black, Latinx, Native, and Asian American communities are integral to that community. We can invest in and build a future that truly serves us all.


1 See
2 See 
4 See Final Rule at 4383.
5 See Final Rule at 4356, 4356-7.
6 See Department of Treasury, Guidance for Coronavirus Capital Projects Fund at p. 3-6, available at
7 See U.S. Department of Treasury, Final Rule State and Local Fiscal Recovery Funds at 4422, available at
8 Reclaiming funds is possible under the SLFRF program, for example. See Interim Final Rule at 26811-2,