GiveBetter x USA

Earthjustice

Environmental litigation, policy and public information

Research time: 6 min on GPT-6 Astra Light
  • Research — reviewed programs, finances and impact evidence.

Updated: 2026-09-14

Summary

What do they do? Earthjustice provides free environmental legal representation alongside policy, scientific and public-information work. Its portfolio includes clean air and water, toxic chemicals, energy, climate, wildlife and public lands across and beyond the United States. A partial model of additional national soot-standard implementation gives about $35 million per 10 USA QALYs, with a favorable scenario around $279,000 and zero/harm possible.

Why we’re interested in this organization:

  • A large specialist legal team can make binding public-health duties enforceable when agencies fail to act.

  • Current court records provide concrete evidence of implementation work rather than only claimed campaign victories.

  • Primary regulatory models and epidemiology connect cleaner air to clinical outcomes, allowing a numerical partial estimate.

Our main reservations:

  • Most recipient pathways remain unpriced, so the partial number is not an overall ranking.

  • Recent court victories already belong in the counterfactual; a new donor cannot claim the entire regulation.

  • Other litigators, state governments, reserves and existing gifts may replace the marginal contribution.

What do you get for your dollar? $35.4M per better life: ten additional quality-adjusted life years in USA. PM implementation health only; other impacts unestimated.

Legally effective implementation, additional emissions/exposure reductions, full-equivalent protected exposure years, adult deaths prevented and discounted lifetime QALYs. Court orders, case counts, acres and tonnes are not themselves QALYs.

1. What do they do?

Earthjustice, EIN 94-1730465, supplies legal representation without charging public-interest clients. Litigation is supported by policy and public information; work spans health, energy and climate, public lands and wildlife. The ordinary recipient scope includes all these activities, not just the clean-air case modeled below. Portfolio

The current financial report says staffing reached 600 and describes accelerated staffing growth. This indicates organizational capacity and demand, not 600 health-producing positions. Earthjustice Action is a separate 501(c)(4); the audit describes a reimbursement agreement, not consolidated inclusion of that organization's political work. Financial report Audit

2. Monitoring and information sharing

The July 17, 2026 district-court order requires EPA to promulgate final PM2.5 area designations by February 6, 2027 and retains jurisdiction. It follows June's ruling upholding the strengthened standard. The order is a real implementation milestone, but designation is not attainment or a measured reduction in deaths. Actual order June result

Earthjustice, Clean Air Task Force and Southern Environmental Law Center represented coalition groups, while state/local plaintiffs brought parallel claims. Future monitoring should distinguish designation, enforceable plans, actual controls and exposure changes; investigate which would be delayed without added legal capacity. Counsel and partners

The active MATS case challenges repeal of 2024 amendments. It does not justify credit for all health gains from the original 2012 standards. The 2026 repeal and current legal challenge are separate from already-achieved historic reductions. Challenge EPA status

3. Qualitative assessment

The PM pathway has strong evidence beyond policy outputs. Wu and colleagues analyzed 68.5 million Medicare enrollees with five approaches and found broadly consistent mortality effects. Causal interpretation still requires confounding assumptions; predicted residential exposure has measurement error. This supports a causal health mechanism, not a measured Earthjustice effect. Original study

EPA's native table provides alternative adult mortality estimates of 2,100 and 4,500 for identified controls under the revised annual standard in 2032. They must not be added. The model uses their midpoint as a judgment, then applies a transport haircut. It excludes infant and nonfatal outcomes, including asthma, to avoid case/utility overlap. Mortality occurs with a cessation lag; the QALY assumption includes that timing. RIA, Table 5-5 and methods

Habitat, climate and legal-access benefits may be important independently of USA health. They are not converted from acres, tonnes, case counts or economic damages. Litigation can also delay projects with benefits; implementation costs or energy access may harm health. No empirical estimate of those offsets was recovered, so zero and adverse scenarios remain.

4. What do you get for your dollar?

Audited full recipient expense is $183,685,874 for FY 2025, $165,760,409 for FY 2024 and $158,385,625 for FY 2023; the comparable mean is $169,277,303. Fiscal years end June 30. Latest expense includes $16,809,973 of donated legal and public-information services; these are retained as resources, not mistaken for cash spending. FY 2025 audit FY 2024 audit

Two annual budgets cost $367.4 million. The partial PM model produces 103.64 expected USA QALYs centrally, approximately $35.4 million per 10. The favorable joint scenario produces about 13,176 QALYs and costs about $279,000 per 10; a low-influence scenario is vastly worse. This is a partial pathway estimate, not a total recipient effectiveness claim or a guaranteed lower bound.

The model counts one conditional full-equivalent year of additional exposure protection at 2032 scale, with only a 10% incremental coalition probability, a 20% Earthjustice contribution and 50% funding additionality. It gives no new credit for the already-issued court order. Public regulators and pollution sources bear substantial implementation costs outside the recipient denominator; those resources are not free.

Model, assumptions and sensitivity

Two years of full FY 2025 audited recipient resources, including all programs, administration, fundraising and donated services. Separate c4 excluded. Regulatory agency and corporate compliance spending disclosed but not included in recipient cost.

Only domestic resident health in the EPA PM pathway is quantified, so g=1 by model scope. No overseas, territorial, biodiversity or global climate health credit is included. This is not an organization-wide USA allocation.

C=2*183685874. Y(L,start)=sum(i=0..L-1)1/1.03^(start+i). Q_USA=Q_all=D*m*q*Y*p*a*b-H. D=(2100+4500)/2=3300 central; the two EPA mortality studies are alternatives, not additive. q is discounted lifetime health per death including cessation lag to the exposure year; Y discounts exposure years to2026. Price=10*C/Q_USA when positive.

C
367371748 USD, two annual full recipient budgets (judgment). Judgment extrapolation to two years at the observed annual recipient expense: 2×FY 2025 audited expense. Two-year support horizon is judgment; donated services included. [ej-audit25]
D
3300 modeled adult deaths avoided per 2032-equivalent protected year (judgment). Midpoint of alternative EPA 2100 and 4500 estimates, not their sum or a pooled clinical estimate. Baseline assumes current 12/35 standard; identified controls for revised 9/35, not all possible attainment benefits. [ej-pm-ria]
m
0.75 clinical and exposure transport multiplier (judgment). Allows uncertain composition, adherence, changing emissions and residual confounding; .3–1 scenarios. Not an EPA parameter. [ej-pm-ria] [ej-wu]
q
5 QALYs per avoided adult death, discounted to exposure year (judgment). Composite of remaining survival, health quality, competing mortality and cessation lag. Broad 1–10 range; not EPA VSL divided by a QALY price. An older-adult dominated benefit cannot be valued as a young person's full lifespan. [ej-wu] [ej-pm-ria]
L
1 full-equivalent years of pollution protection conditional on incremental success (judgment). One year of avoided delay or equivalent retained exposure reduction; favorable 3. Does not count an indefinite standard or July 2026 victory again. [ej-pm-order]
start
6 years from 2026 to first modeled exposure year (judgment). 2032 reference-year controls; later timing tested. Native benefits are not observed 2026 outcomes. [ej-pm-ria]
r
0.03 annual health discount rate (judgment). Y discounts exposure timing. q already includes within-person lifetime and cessation-lag discounting.
p
0.1 incremental coalition probability of securing protection beyond baseline (judgment). Subjective 10-percentage-point implementation contribution, not raw court win probability. Existing binding order and legal duties sharply constrain available additional credit. [ej-pm-order] [ej-pm-role]
a
0.2 Earthjustice share of incremental coalition contribution (judgment). Counsel with important technical/client capacity, but state/local plaintiffs, CATF, SELC and other groups can substitute. .05–.5 scenarios; no equal division or sole credit. [ej-pm-role]
b
0.5 additionality of recipient support (judgment). Growth plans support capacity use, but reserve funding and replacement gifts can preserve existing commitments. .1–.8 scenarios; no measured marginal staffing-to-outcome response. [ej-finances] [ej-audit25]
g
1 USA share of this quantified domestic branch (judgment). The model intentionally includes only US resident effects in EPA domestic analysis. This is not a claim that all Earthjustice work or all global benefits are domestic. [ej-pm-ria]
H
0 domestic QALYs of adverse effects (judgment). Provisional zero, with explicit net-harm case. Energy-cost/access effects, implementation displacement and litigation downside not measured.
otherPathways
null net QALYs from all other recipient work (unknown). MATS, chemicals, water, habitat, climate, other clean-air cases and nonfatal PM effects unpriced; avoid overlaps and policy-output conversions. [ej-portfolio] [ej-mats]

Partial PM implementation central: Cost: $367.4M; USA QALYs: 103.63867676460221; all-population QALYs: 103.63867676460221. D=3300; m=0.75; q=5; L=1; p=0.1; a=0.2; b=0.5; g=1; H=0; start=6; Y=0.8374842566836542. Only domestic PM mortality branch quantified.

Strong additional implementation: Cost: $367.4M; USA QALYs: 13175.919012641092; all-population QALYs: 13175.919012641092. D=4500; m=1; q=10; L=3; p=0.3; a=0.5; b=0.8; g=1; H=0; start=6; Y=2.439985002340943. Only domestic PM mortality branch quantified.

Weak implementation additionality: Cost: $367.4M; USA QALYs: 0.02343895831924684; all-population QALYs: 0.02343895831924684. D=2100; m=0.3; q=1; L=1; p=0.01; a=0.05; b=0.1; g=1; H=0; start=10; Y=0.7440939148967249. Only domestic PM mortality branch quantified.

No further implementation benefit: Cost: $367.4M; USA QALYs: 0; all-population QALYs: 0. D=3300; m=0.75; q=5; L=1; p=0; a=0.2; b=0.5; g=1; H=0; start=6; Y=0.8374842566836542. Only domestic PM mortality branch quantified.

No benefit and illustrative policy downside: Cost: $367.4M; USA QALYs: -100; all-population QALYs: -100. D=3300; m=0.75; q=5; L=1; p=0; a=0.2; b=0.5; g=1; H=100; start=6; Y=0.8374842566836542. Only domestic PM mortality branch quantified.

Counterfactual: Current 9µg/m3 standard, June 2026 defense victory and July 2026 designation order remain in baseline. L is the extra full-equivalent exposure protection secured by future implementation work, not all protection under the rule. p is coalition incremental chance of achieving that addition, with existing statutory duties and state/local litigation continuing.

Attribution: Earthjustice is one of several important legal contributors. a=.2 subjective share of incremental coalition contribution, not share of all rule benefits. b=.5 discounts reserves, existing support, fee recovery and replacement gifts. A successful future case does not establish these values retrospectively.

Very-low-confidence partial expected-value assessment. Clinical mechanism is stronger than marginal policy attribution. The midpoint of two regulatory forecasts is judgment, not a posterior estimate; broad scenarios are not confidence intervals. Remaining recipient pathways can add benefits or harms, precluding a whole-recipient ranking from this number.

Sensitivity

  • At $367,371,748 cost, $1 million/$100 thousand per 10 requires 3673.71748/36737.1748 net USA QALYs, versus 103.63868 centrally.
  • With q=5 and other central values, the $1 million threshold requires about 35.45 times the central product of protected years and incremental contribution. One favorable parameter alone need not achieve it.
  • Using only the 2100 or 4500 mortality alternatives changes central health by 2100/3300 or 4500/3300. These are not confidence bounds; uncertainty also includes model transport and exposure changes.
  • Using the three-year mean reduces cost about 7.8%. Excluding all donated services from latest expense reduces cost 9.15%, but omits real legal resources and public-service advertising; neither adjustment solves marginal attribution.
  • A delay from 2032 to 2036 reduces benefits by 1/1.03^4. q includes post-exposure cessation lag; do not count all modeled deaths as immediate.
  • All-population harm above 103.63868 QALYs erases the central partial benefit. Zero future implementation effect gives no finite positive price.
  • A portfolio sum must de-duplicate PM effects of MATS, power-plant, permitting and ambient-standard cases before adding them. Historic successes are not new-donation yield.

Unresolved inputs

  • Prospective unfunded staffing/case plan and counterfactual use of reserves, fee recoveries and replacement donations.
  • Case-specific incremental implementation probability, affected exposure years and Earthjustice contribution beyond state and other counsel.
  • Updated emissions/compliance baseline under current policy, actual state plans, controls and corresponding clinical outcomes.
  • Mortality age/cause distribution and remaining quality-adjusted survival, including cessation lag, to replace q.
  • Net health effects of other recipient pathways, geographic attribution, overlaps and possible policy/energy-access harms.

5. Funding and previous grants

The audit reports $56,995,368 of financial assets available for general expenditure within one year and a $201,282,311 board-designated reserve. The latter can be redesignated and is distinct from donor-restricted endowment assets. Those reserves support long-term legal obligations, but they also make complete next-dollar additionality implausible without a specific work plan. Liquidity and reserve notes

FY 2025 revenue was $207,196,608 and net assets rose $23,510,734. Court-awarded fees and costs contributed $5,787,062; these can recycle resources after successful cases, but are not assured. The marginal funding question is whether support expands otherwise-unfunded legal work or mainly replenishes reserves. The staffing-growth statement is promising capacity evidence, not a quantified funding gap. Current plans

Annual expenses

Organization-level spending, including programs, administration and fundraising. The research list averages three comparable, consecutive full fiscal years when available.

  • FY 2023: $158.4M; Earthjustice, EIN 94-1730465, 12-month period, US GAAP accrual audited full recipient expense including donated services; June 30 fiscal year. Source
  • FY 2024: $165.8M; Earthjustice, EIN 94-1730465, 12-month period, US GAAP accrual audited full recipient expense including donated services; June 30 fiscal year. Source
  • FY 2025: $183.7M; Earthjustice, EIN 94-1730465, 12-month period, US GAAP accrual audited full recipient expense including donated services; June 30 fiscal year. Source

6. Sources

  1. FY2025 and FY2024 audited financial statements. BPM LLP / Earthjustice. Published: 2025-12-02; retrieved: 2026-09-14.
  2. FY2024 and FY2023 audited financial statements. BPM LLP / Earthjustice. Published: 2024-10-31; retrieved: 2026-09-14.
  3. Current financial report and staffing plans. Earthjustice. Published: not stated; retrieved: 2026-09-14.
  4. Current litigation portfolio. Earthjustice. Published: not stated; retrieved: 2026-09-14.
  5. Current outcomes and historical cases. Earthjustice. Published: not stated; retrieved: 2026-09-14.
  6. Order compelling PM area designations. US District Court, Northern District of California. Published: 2026-07-17; retrieved: 2026-09-14.
  7. PM implementation litigation and counsel roles. Earthjustice and partner coalition. Published: 2026-07-20; retrieved: 2026-09-14.
  8. D.C. Circuit upholds 2024 standard. Earthjustice and partner coalition. Published: 2026-06-26; retrieved: 2026-09-14.
  9. 2024 PM NAAQS final regulatory impact analysis, native health outcomes. US Environmental Protection Agency. Published: not stated; retrieved: 2026-09-14.
  10. Current PM NAAQS. US Environmental Protection Agency. Published: not stated; retrieved: 2026-09-14.
  11. Long-term PM exposure and elderly mortality. Wu et al. / Science Advances. Published: 2020-07-17; retrieved: 2026-09-14.
  12. Challenge to repeal of 2024 MATS amendments. Earthjustice and litigation coalition. Published: 2026-03-30; retrieved: 2026-09-14.
  13. Current mercury and air toxics standards, including 2026 repeal. US Environmental Protection Agency. Published: not stated; retrieved: 2026-09-14.