United States Enforcement and EPA/300-R-96-004 Environmental Protection Compliance Assurance April 1996 Agency (2201 A) Office of Environmental Justice (OEJ) 1996 Environmental Justice Implementation Plan ------- Table of Contents Implementation of EPA's Environmental Justice Strategy Background 2 EPA's Commitment 2 Environmental Justice Themes 3 Format of the Implementation Plan 4 Lead Office Acronyms 5 Mission Areas: Public Participation, Accountability, Partnerships, Outreach, and Communication With Stakeholders 6 Health and Environmental Research 12 Data Collection, Analysis, and Stakeholder Access to Public Information 14 American Indian, Alaska Native, and Indigenous Environmental Protection 19 Enforcement, Compliance Assurance, and Regulatory Review 21 ------- IMPLEMENTATION OF EPA'S ENVIRONMENTAL JUSTICE STRATEGY Background On February 11, 1994, President Clinton signed Executive Order 12898 "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations." The Executive Order required EPA and other federal agencies to develop agency-wide strategies to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects of programs, policies, and activities on minority populations and low-income populations. As a part of the strategy, each agency was to identify several specific projects that could be promptly undertaken to address particular concerns identified during the development of the proposed environmental justice strategy. Environmental justice is one of Administrator Browner's stated top priorities. Because of its importance, EPA began developing a strategy to address environmental justice concerns prior to the signing of Executive Order 12898. EPA's action document, issued in April 1995 and entitled "Environmental Justice Strategy: Executive Order 12898" (the Strategy), was the result of nearly two years of work within the Agency and with stakeholders. The Strategy not only identified specific EPA programs, polices, and activities but also listed actions EPA will take to incorporate environmental justice into its mission. EPA's Strategy was designed as "an initial step in an ongoing effort to integrate environmental justice objectives into the Agencys activities." The attached draft Implementation Plan supplements the Strategy by providing not only the timetable for undertaking revisions, as required by the Executive Order, but also identifies lead process owners and realistic measures of success. The Agency - and its stakeholders— will judge the success of its efforts by how well it carries out the Strategy and the Implementation Plan. EPA's Commitment The Agency is committed to ensuring that: 4 No segment of the population, regardless of race, color, national origin, or income, as a result of EPA's policies, programs, and activities, suffers disproportionately from adverse human health or environmental effects, and all people live in clean and sustainable communities. 4 Those who must live with environmental decisions — community residents, environmental groups, State, Tribal and local governments, businesses — must have every opportunity for public participation in the making of those decisions. An informed and involved local community is a necessary and integral part of the process to protect the environment. ------- Environmental Justice Themes The following are several themes outlined in the Environmental Justice Strategy that are components of the objectives described in this Implementation Plan: 4 The Agency is committed to ensuring active public participation of our stakeholders and to receive their input early in environmental decision-making. EPA will enhance partnerships and coordination with stakeholders, including: affected communities, Federal, Tribal, State, and local governments, environmental organizations, non-profit organizations, academic institutions (including Historically Black Colleges and Universities (HBCUs), Hispanic Serving Institutions (HSIs), and Tribal Colleges, and business and industry. EPA will use the National Environmental Justice Advisory Council (NEJAC), their public participation models, and other outreach and communication activities along with input from other stakeholders, particularly those from affected communities, early in the decision-making process. 4 Public documents and notices will be reviewed to ensure that they are concise, understandable, and accessible; published in languages other than English, in local and minority-oriented newspapers, and through electronic media, including radio and television; ensure mailing lists include the broadest possible range of stakeholder and interested parties (e.g. Tribal governments, community groups, academic institutions). 4 Each EPA Office and Region will develop a system for monitoring and evaluating program improvements resulting from the integration of environmental justice, focusing on both major environmental justice projects and routine implementation of the policy by staff. (Some Offices and Regions have already published their own plans that further describe their environmental justice activities). 4 Working with affected stakeholders, EPA will conduct research in areas where it can make the greatest contribution to environmental justice and in a manner to ensure that the Agency's environmental justice policies are based on sound science. 4 EPA will incorporate on-going training and orientation programs for its personnel on environmental justice issues. 4 All key efforts described in the Implementation Plan will respect the unique issues and concerns associated with Tribal governments, their members, and other indigenous communities. This two-year Implementation Plan does not reflect final budget decisions for FY 96 or FY 97. Actions and time lines were developed assuming FY 1995 budget information. Some adjustment may be needed to reflect final Congressional authorization. Despite current budgetary uncertainties, the Agency has a strong commitment to the integration of environmental justice into all EPA policies, programs, and activities. ------- Format of the Implementation Plan The Implementation Plan contains the same five mission areas as the April 1995 Strategy. They are: 1) Public Participation, Accountability, Partnerships, Outreach, and Communication with Stakeholders; 2) Health and Environmental Research; 3) Data Collection, Analysis, and Stakeholder Access to Public Information; 4) American Indian and Indigenous Environmental Protection; and 5) Enforcement, Compliance Assurance, and Regulatory Reviews. This Implementation Plan contains goals and objectives that track directly to the Strategy, with the additional elements of key efforts, measures of progress, lead organization, and dates of completion. Each of these components are explained below. Mission Areas: These areas demonstrate the links between Executive Order 12898, the Strategy, and this Implementation Plan. Each Mission Area contains the following: Goals: A goal is a condition that we are trying to achieve. In this Implementation Plan, the 16 goals, taken directly from the Strategy, are specific to the integration of environmental justice into the mission areas listed above. Measures of Progress: At this time, the Agency is developing a limited number of measures of progress. The purpose of these measures will be to inform the Agency and its stakeholders on how the Agency is doing under each of the 16 goal areas articulated in the Strategy and listed in this Plan. Examples of draft measures have been included in this Plan to provide a general sense of the direction EPA is moving. The measures, once finalized, will be used to evaluate the progress EPA has made toward achieving the goals outlined in this Plan. The measures will not be used to evaluate the individual key efforts. A number of the draft measures in this Plan assume the existence of "baseline" data; the starting point from which we will judge progress. At this time, such baseline data do not exist. The process of determining baseline data and for evaluating measures of progress has not yet been finalized. This process will be further discussed and refined with the benefit of the Agency's Environmental Justice Policy Work Group and stakeholder input. The National Environmental Justice Advisory Council (NEJAC) will initially serve as our stakeholder group during the development of measures and for eventual surveying (as outlined in some of the Plan's measures). The Office of Environmental Justice (OEJ) will be the principal lead for evaluating the measures of progress (for the goals) outlined in this Plan. The leads designated for each key effort in the Plan will measure the success of their own activities and report to OEJ their progress in completing the key efforts. A number of regional and program offices have already developed their own, more detailed, plans that include processes for measuring progress. As the Agency moves toward a greater reliance on environmental results or administrative outcome-type measures, the types of measures contained in this Plan will change. Measures that indicate better environmental ------- quality in a specific geographic community, or that reflect intended outcomes of greater and/or enhanced participation (did the involvement of stakeholder's result in a change?) may become the measures of choice. Key Efforts: Key efforts are specific program activities that support the completion of the objectives and goals. Specific criteria for key efforts included in this Implementation Plan are: 1) Funding - The program activities and projects listed under key efforts must already be funded and committed to by senior management at the EPA. 2) Completion within two years - Key efforts, or discrete phases of on-going efforts, must be completed by second quarter FY 97 due to reporting requirements and budget considerations. 3) Broad representation of Agency activities - Selected projects must represent the range, not necessarily the depth, of regional and programmatic activities in each of the goal areas. Dates of Completion: Self-explanatory. Leads: Although many key efforts represent inter-Agency or inter- Office collaborations, each key effort has a designated program or regional lead. Lead Office Acronyms OAR Office of Air and Radiation OARM Office of Administration and Resources Managment OCEPA Office of Communication, Education, and Public Affairs OCR Office of Civil Rights OECA Office of Enforcement and Compliance Assurance OEJ Office of Environmental Justice OGC Office of General Counsel OIA Office of International Activities OPPE Office of Policy, Planning, and Evaluation OPPTS Office of Prevention, Pesticides, and Toxic Substances ORD Office of Research and Development OSWER Office of Solid Waste and Emergency Response OW Office of Water Reg EPA Region ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Goal (1) Outreach and Partnerships - To ensure their active public participation and to provide input early in environmental decision-making, EPA will enhance partnerships and coordination with stakeholders, including: affected communities, Federal, Tribal, State, and local governments, environmental organizations, non-profit organizations, academic institutions (including Historically Black Colleges and Universities (HBCUs), Hispanic Serving Institutions (HSIs), and Tribal Colleges), and business and industry. Measure of Progress: (Draft) 50% of stakeholders surveyed indicate that the Agency's level of effort to ensure active public participation and early in-put has improved. Objectives EPA will use the National Environmental Justice Advisory Council (NEJAC) along with input from other stakeholders, particularly those from affected communities, early in the decision-making process. EPA will utilize public participation models, such as the one created by NEJAC, in its partnerships, and outreach and communication activities. EPA will work to improve environmental education, training opportunities and partnerships with academic institutions, including HBCUs, HSIs, and Tribal Colleges. EPA will improve communication, education, and outreach on environmental justice issues among all stakeholders. EPA will ensure that public documents and notices related to human health or the environment are concise, understandable to the community involved, and are made readily accessible to the public. Whenever possible and appropriate, EPA will publish public notices for EPA public meetings in languages other than English, in local and minority- oriented newspapers, and through electronic media, including radio and television. EPA will identify a network of translators to assist in conducting public meetings. Key Efforts a. Develop the "NEJAC public participation model and checklist" to provide a comprehensive, easy to follow guide on how to enhance participation of stakeholders in the decision making process. Finalize, test model in a pilot, distribute, review its use by the program offices and regions, and conduct a customer service review to check effectiveness. b. Develop an accessible data base of stakeholders in coordination with all EPA offices. Identify stakeholders, develop master list and sub- lists, and distribute lists for validation and use. c. Continue annual funding for environmental education grants that improve teaching skills; educate the public about human health problems from environmental pollution; enhance State, local, and Tribal government agency programs; promote environmental careers; and provide education for communities and the general public. d. Review, by the "Steering Committee," of established guidance to ensure that public documents and notice related to the environment are understandable to the affected community and are made readily accessible to the public. Additionally, environmental justice components will be added to established training for public documents development. e. Develop a national relocation policy to describe more fully the criteria for when to conduct permanent relocations or temporary relocations as part of remedial activities under Superfund. OERR is jointly planning with the NEJAC a roundtable to acquire community comment from various sites around the Nation, has identified a relocation pilot in one Region, and is working closely with several Regions on their ongoing relocation efforts. *Community roundtable - May 1996; Initiate Relocation Pilot - June '96; Draft National Policy - June '97. Completion Date 3/97 Lead OEJ 3/96 9/96 OEJ OCEPA ongoing OPPE OSWER ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Objectives (contd.) EPA will ensure mailing lists include Tribal governments and organizations, environmental justice organizations, and other interested stakeholders including schools, civic associations, local business and industry associations, and religious institutions as appropriate. EPA will exchange information and expertise with affected stakeholders. EPA will work to ensure that future legislation will incorporate techniques to improve public participation. Key Efforts f. Implement EPA's Brownfields Economic Redevelopment Initiative to empower States, communities, and other stakeholders in joint efforts to prevent, assess, safely clean up, and sustainably use "brownfields," where opportunities for expansion or redevelopment are complicated by real or perceived environmental contamination. EPA plans to complete awards of 50 Brownfields pilot cooperative agreements to States, cities, towns, counties, and Tribes to test redevelopment models, direct special efforts toward removing regulatory barriers (without sacrificing protectiveness), and facilitate coordinated public and private efforts at the Federal, State, and local levels. In February 1996, EPA hosted its first Brownfields Pilots National Workshop in Washington, DC to bring together key stakeholders to identify and leverage opportunities for building on the environmental assessment, cleanup, and redevelopment efforts of the Brownfields pilots. g. Prepare specific demographic information for regional Superfund sites. Information will be provided to site managers and will include but not be limited to information on income levels, race and nationality, number of non-English speaking residents, and what languages are spoken. With this information on demographics around each Superfund site, site managers will be able to better target communication activities and improve efforts to get residents involved. h. Work with other Federal agencies, the private sector, municipal government, and community groups on a variety of projects (e.g., creation of an eco-industrial park, energy efficiency retrofits for the public school system) that are designed to improve environmental quality while providing jobs and economic opportunity in poor and minority neighborhoods. This effort will be accomplished through the Vice President's Community Empowerment Board and many of the 105 Empowerment Zone and Enterprise Communities. Completion Date 12/96 Lead OSWER 9/96 Reg 10 ongoing OPPE ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Goal (2) Technical Assistance -EPA will examine its current technical assistance programs for minority communities and low-income communities. Measure of Progress: (Draft) 15 % of Agency grants awarded to minority communities and low-income communities that are exposed to disproportionately high and adverse human health or environmental effects. Objective EPA will administer appropriate grant programs for and promote technical assistance to partners particularly small business, community-based organizations, and Tribal governments. EPA will exchange information and expertise with affected stakeholders. Key Efforts a. Work with community groups through a grant to address the environmental health issues in the Nogales, AZ area (predominantly low income Latino communities). The project will provide environmental health workshops, a quarterly bilingual newsletter, informational hotline, monthly lupus screening clinics, and provide outreach and case management services. Work with individual community members to encourage their leadership skills and share information with friends and neighbors. b. Provide $350,000 to the Rural Community Assistance Program to help improve or establish basic wastewater and water supply services in twenty four rural, minority communities around the country. c. Initiate a small grants program as part of Border XXI, the next phase of binational environmental planning between the U.S. and Mexico. The program will address environmental issues along the border by strengthening local capacity at the community level. For example, a grant was awarded to develop a cross-border planning mechanism to enhance long-range environmental protection of the natural resources on Kumeyaay reservation lands and to develop a water quality control plan. The grant project also involves cooperation among the Kumeyaay sister Tribes in Baja California. d. Continue the Office of Environmental Justice Small Grants Program and other similar Agency programs to provide assistance to community-based/grassroots organizations and Tribal governments that are working on local solutions to local environmental problems. e. Continue the Office of Environmental Justice Community/ University Partnership (CUP) Grants Program to encourage collaborative projects that provide technical assistance to community organizations. f. Continue the 'Open Airways for Schools' program, which focuses on developing asthma management skills for students, helping parents and teachers create more supportive environments for asthmatic children, and developing activities to reduce indoor pollutants. This partnership between EPA, the American Lung Association, and Zeta Phi Beta sorority will impact millions of urban, poor households with asthmatic children. Completion Date ongoing Lead Reg 9 6/97 11/96 OW OIA ongoing OEJ ongoing ongoing OEJ OAR ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Goal (3) Training - EPA will encourage State, Tribal, and local governments to work with the Federal government to achieve environmental justice goals through training and other coordinated activities. Measure of Progress: (Draft) 60% of EPA's training programs/materials for internal and external use, where appropriate, include discussion of environmental justice issues over the next two years. Objectives EPA will incorporate an ongoing orientation and training program for its personnel on environmental justice issues, including those related to public participation, Tribal relations, health research, and data gathering. The development of training programs will include input from stakeholders, including grassroots organizations. The training will be tailored to the needs of the Office or Region. Training kits may include: generic information on environmental justice, examples of model initiatives and projects, and public participation guidelines. EPA will offer training assistance to other Federal agencies and Tribal, State, and local officials on environmental justice issues. EPA will sponsor environmental justice seminars or workshops to focus on media-specific environmental justice activities and case examples Key Efforts a. Sponsor an EJ Symposium with the Maryland Dept. of the Environment, City of Baltimore, International City/County Mgt. Assoc., and several colleges and community organizations in Baltimore, MD at Morgan State University on October 21/22, 1995. The "Baltimore Symposium on Urban Environmental Justice Research and Education" created an opportunity for scientists, educators; Federal, State and local government representatives, and community leaders to discuss past and ongoing urban environmental justice research and future research needs of the Baltimore community. b. Work with the Lake Pontchartrain Basin Foundation (LPBF) on education and outreach activities in the Basin regarding watershed protection and lake restoration. Young children in minority communities have limited opportunity to learn about, visit or enjoy the Lake. The Foundation and the U.S. Fish and Wildlife Service co- sponsor a nature camp for youth from New Orleans inner-city areas. The event allows children to participate in environmental and educational activities focusing on the Lake. Other activities include: working with teachers in developing curriculum about the basin's environmental issues; field trips for students to the canal pumping stations and to the Lake; and field trips to New Orleans' area nature centers. c. Coordinate with the Denver Federal Executive Board to organize meetings, conferences, and/or training sessions with other Federal agencies in the Denver metropolitan area to provide coordination and improve awareness of EJ efforts. Topics for the meetings will include: (1) education on environmentaljustice issues for staff; (2) coordination of EJ research and identification of future needs; and (3) a conference on coordinating EJ activities in Indian country. d. Continue the Radon Education and Outreach program which provides targeted inner city communities with education about the risks from exposure to radon. Provide training for the mitigation of those risks by the community members themselves. Completion Date complete Lead Reg 3 ongoing Ree6 2/97 Reg 8 ongoing OAR ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Goal (4) Management Accountability - EPA will strengthen management accountability for environmental justice activities. Measure of Progress: (Draft) EPA will be able to report quantitatively and qualitatively environmental justice-related actions and outcomes it has achieved since implementation. Objectives EPA will reorganize to strengthen leadership and management of environmental justice activities in the Agency. EPA will develop a system for monitoring and evaluating program improvements resulting from the integration of environmental justice. Each Office or Region will develop a feedback mechanism for tracking environmental justice activities across the Office or Region, focusing on both major environmental justice projects and routine implementation of the policy by staff. Key Efforts a. Develop a regional internal tracking system for program support activities provided by the E J core. The system will track activities by site and note the type of involvement by EJ staff, the time frame, and the outcome of such involvement. This system will provide both a current record of ongoing EJ involvement as well as a historical record of past EJ involvement and the outcome. b. Develop a monitoring and evaluation program for tracking project commitments and measuring successes as part of the Implementation Plan for the EJ Strategy. c. Encourage Superfund contractors to promote environmental justice through the development of Environmental Justice award-fee criteria for the award-fee plans of all new Response Action Contracts (RACs). The RACs are the long-term remedial clean-up contracts placed in the regions to support the Superfund program. The Environmental Justice award-fee criteria provide monetary incentives for contractors to demonstrate a commitment to environmental justice throughout contract performance. d. Produce the "OSWER Environmental Justice Action Agenda" and "Waste Programs Environmental Justice Accomplishments Report" through partnership with EPA regional offices and NEJAC. These publications track program accomplishments and ensure management accountability on environmental justice issues within the solid waste and emergency response programs. * Agenda/Report - 5/95; Accountability - ongoing Completion Date 7/96 Lead Reg 3/96 complete OEJ OSWER /OARM OSWER 10 ------- Mission Area: PUBLIC PARTICIPATION, ACCOUNTABILITY, PARTNERSHIPS, OUTREACH, AND COMMUNICATION WITH STAKEHOLDERS Goal (5) Public Participation in Facility Siting and Permitting - A major priority for the Office of Solid Waste and Emergency Response (OSWER) is to address the siting and permitting of hazardous waste facilities that might have a disproportionately high and adverse human health or environmental effect on minority or low-income communities. Measure of Progress: (Draft) 30% of stakeholders surveyed indicate that the Agency's level of effort to ensure active public participation and early in-put has improved. Objectives EPA will improve public participation in siting and permitting decisions. Resolution of these issues is expected to focus on at least two major avenues: 1) early and ongoing public participation in permitting and siting decisions, and, 2) active participation in the Agency-wide effort to develop methodologies for defining cumulative risk from multiple sources. Key Efforts a. Provide avenues for earlier and more meaningful stakeholder input into the RCRA permitting process. Promulgate the "RCRA Expanded Public Participation Rule" (12/95) to provide earlier opportunities for public involvement and expands public access to information. Revise the "RCRA Public Involvement Manual" to meet the needs of permitting agencies, facilities, and the public. b. Improve all EPA permitting processes through the Permits Improvement Team and the Enhanced Public Participation Task Force. Develop an "easy reference" guidance for public participation activities. Generate recommendations for more meaningful public participation. Explore a pilot project on the use of comprehensive Community Involvement Plans (CIPs) at selected facilities. Completion Date 6/96 Lead OSWER 9/96 OSWER /Reg 2 11 ------- Mission Area: HEALTH AND ENVIRONMENTAL RESEARCH Goal: (1) Research Partnerships - Working with affected stakeholders. Measure of Progress: (Draft) 20% of Agency research plans and/or processes where appropriate that are developed with affected stakeholders. Objectives An early EPA priority will be to explore the dimensions of community-led research and to better integrate this model into EPA's research strategy. EPA will explore through pilot projects the resources and strategies necessary to help train community people to be effective collaborators in the research process. This training will include such things as decision-making processes, research design, questionnaire construction, data collection, and data analysis. EPA will work with minority communities and low-income communities under study to incorporate, to the extent practicable, their concerns and comments in EPA research design, data analysis, implementation, and information dissemination. EPA will work with the scientific community to improve health assessments and risk assessments and incorporate environmental justice including socioeconomic issues into its policies and guidance. EPA will support environmental justice research through (1) competitive grants to researchers examining environmental justice questions and, (2) exchange programs between EPA and non- governmental groups with a shared research agenda. EPA will expand interagency and other intergovernmental partnerships to ensure a coordinated research strategy and the ability to target cross-disciplinary projects in affected communities. Key Efforts a. Present diverse community concerns and bring together community, government, and academia to address the environmental and health issues raised by individuals and neighborhood groups in the South/Southwest Philadelphia study. Johns Hopkins University School of Public Health is characterizing the state of the environment and the health of the population in the study area. The local academic community formed a Science Advisory Board to address the direction of the study and future courses of action. Community representatives will communicate from and relate findings to the neighborhoods. A team of representatives from the city, State, and Federal governments has been formed to address issues that may be quickly resolved through joint intervention. b. Implement two pilot EJ community assessments in West Oakland and Watsonville, California. The pilot assessments are comprehensive, community-based projects where EPA will work in conjunction with other agencies and community groups to identify and address significant environmental concerns in specific "EJ communities" in the Region. The pilot projects will serve to test the implementation phases of the EJ Assessment Project. c. Coordinate activities and capabilities within EPA and with other Federal and State environmental and health agencies to identify and address environmental health issues along the U.S.-Mexico border. This includes surveillance/monitoring, registry development, exposure/health studies, risk assessment, education, training and communication. This research effort is a model of partnership to generate better data for decision making by the community. Projects underway and future projects include a transboundary air pollution project, a FDA market basket survey, a Border-wide health and environmental survey, a surveillance evaluation system, and a study of cumulative exposure/cumulative risk from pesticides. Completion Date 2/97 Lead Reg 3 12/96 Reg 9 ongoing ORD 12 ------- Mission Area: HEALTH AND ENVIRONMENTAL RESEARCH Goal: (2) Sound Science - Working with affected stakeholders, EPA will conduct research in areas where it can make the greatest contribution to environmental justice and in a manner to ensure that the Agency's environmental justice policies are based on sound science. Measure of Progress: (Draft) The percentage of Agency EJ Key Efforts supported by and evaluated positively for good scientific methods in peer review. Objectives EPA, in coordination with other Federal agencies, will: collect, analyze, and maintain information on fish and/or wildlife subsistence consumption patterns, conduct research, develop methodologies, collect data, and publish guidance on the human health risks and effects associated with the consumption of pollutant-bearing fish, and wildlife. EPA will communicate the risks of those consumption patterns and work to integrate differential consumption patterns of natural resources and exposure patterns into the Agency's regulations, guidance, policies, and other activities. EPA will continue to develop human exposure data and will address exposure in at least three main areas: methods development, model development, and monitoring data. EPA will assess major pollution sources of high environmental risks in communities and support pollution prevention with research, as needed, to reduce risk from those sources. EPA will evaluate the current state of knowledge in exposure and cumulative risk fields, and then identify data gaps and research needs. In particular, research needs to include diverse exposed populations in epidemiological and clinical studies, especially those population segments at high exposure. EPA's risk characterization guidance will help communicate risks by characterizing the most important findings and conclusions. Risk characterization includes the strengths, weaknesses, and assumptions of the risk data and analysis and a comparison to other risks. EPA will work to ensure that future legislation will be responsive to environmental justice health research and data needs Key Efforts a. Fund a community group to work with Asian and Pacific Islander community groups in the San Francisco Bay Area to complete Phase I of a Fish Consumption Study that will determine accurate exposure data. Phase I will concentrate on designing a scientifically sound study based on community determined goals and objectives and to develop a model of the process that involves early community input. b. Evaluate exposures to over 150 toxic pollutants across multiple exposure pathways for the entire continental U.S. The goal of the Cumulative Exposure project is to measure the distribution of environmental exposure at the National level across demographic groups and locations. The analysis will draw on a mixture of monitoring data, and modeling for three major routes of exposure: inhalation, ingestion of drinking water and ingestion of food. Each three routes will be evaluated separately, the all three will be integrated to estimate a national distribution of multi-pathway cumulative exposure. c. Maintain and make available for public access a national database on fish consumption advisories so that people can determine whether a particular waterbody has any advisories in place (*Complete). Provide States with guidance and technical tools to improve their ability to develop fish consumption advisories and communicate any potential health risks associated with those advisories to the public (* 7/96). d. Contribute to the integration of environmental justice and cumulative risk into EPA activities through the "Environmental Justice and Cumulative Risk Study." The study examines two questions: 1) to what extent have environmental justice studies incorporated cumulative risk; and 2) to what extent have cumulative risk studies incorporated environmental justice? The study examines the variety of cumulative risk studies to identify the gaps in our knowledge in order to determine future research venues. Completion Date 12/96 Lead Reg 9 3/97 OPPE OW 6/96 OPPE 13 ------- Mission Area: DATA COLLECTION, ANALYSIS, AND STAKEHOLDER ACCESS TO PUBLIC INFORMATION Goal: (1) Addressing Data Gaps - EPA will conduct an inventory of Agency's major data systems to identify uses, limitations, and gaps. Measure of Progress: (Draft) 25% of Agency's major data systems will be inventoried to identify uses, limitations, gaps, and areas for integration. Objectives EPA will work to fill data gaps including those related to pollution prevention in affected communities and those identified by affected communities through interactive needs assessments. EPA will examine, and expand, as appropriate, its databases to identify major facilities or sites, including Federal and non-Federal facilities or sites (covered by the Executive Order), that could pose a substantial environmental, human health, or economic effect on the surrounding populations. EPA will coordinate with public health departments and other Federal agencies to improve environmental health and exposure databases. EPA, in partnership with affected stakeholders, will: - identify methods of combining data and performing analysis for geographical and exposure information, and will publish guidance on how to use these methods to address environmental justice. - increase the accuracy of its locational data for major facilities or sites of potential toxic releases and environmental quality monitoring points in affected communities Key Efforts a. Implement ground water protection programs through the use of community volunteers. Senior Retired Volunteer Program (RSVP) members conducted the contaminant source inventory for the Well Head Protection Program (WHP). This project gained national and international attention and the effective use of volunteers to implement ground water protection programs is now common practice in several States. The Discovery Channel featured the current University of Texas at El Paso's intergenerational AmeriCorps® project using students and RSVP members to expand WHP activities in the Border area. b. Work with the Maryland Department of the Environment (MDE), which is serving as the lead agency, on a fish consumption survey in the Baltimore Harbor area. Sojourner-Douglass College, a private non- profit minority college, was identified to perform public outreach services including: the collection of additional survey information from fishermen on fishing patterns; the responses/attitudes towards the current fish advisory; and to measure the success of previous outreach efforts aimed at those fishing in the harbor. Completion Date ongoing Lead Reg 6 12/96 Reg 3 14 ------- Mission Area: DATA COLLECTION, ANALYSIS, AND STAKEHOLDER ACCESS TO PUBLIC INFORMATION Goal (2) Improving Quality and Reducing Burdens of Data Reporting - In partnership with affected stakeholders. Measure of Progress: (Draft) 50 % of affected stakeholders indicate improved accessibility and usability of EPA's major data systems. Objectives EPA, in coordination with other Federal agencies and State, Tribal, and local governments, will work to create effective reporting mechanisms, including electronic reporting, to minimize cumbersome or duplicative reporting requirements and to improve accuracy. EPA will develop key identifiers, assist citizen reporting of key data elements, and facilitate analysis of human health and environmental data. Key Efforts a. Establish a policy for legally accepting reports through Electronic Data Interchange (EDI) and establish EDI production system for accepting the Agency's Discharge Monitoring Report. b. Work with stakeholders to identify the data and technical requirements for establishing and implementing a standard facility ID for the regulated community. Pilot a central system to compare and manage a standard facility ID. A standard facility ID will enhance data integrity and facilitate public access to information about facilities in their communities. Completion Date 5/96 2/97 Lead OARM OARM 15 ------- Mission Area: DATA COLLECTION, ANALYSIS, AND STAKEHOLDER ACCESS TO PUBLIC INFORMATION Goal (3) Data Integration and Analysis - In partnership with affected communities and stakeholders. Measure of Progress: (Draft) 40% of Agency's major data systems will be inventoried to identify uses, limitations, gaps, and areas for integration. Objectives EPA will promote the use of Geographical Information Systems (GIS) to enhance identification of disproportionately affected communities. EPA will integrate the Agency's information resource management process linking environmental priorities, data needs, and resource investments. EPA will collect, analyze, and disseminate data that will compare environmental and human health risks to populations identified by race, national origin, or income. Key Efforts a. Collect and analyze available studies that attempt to sub-divide the population for factors associated with exposure to environmental contaminants. The report, "Exposure Factors of Specific Demographic and Ethnic Subpopulations," provides useful data for the exposure and risk assessors determining hazards to toxic substances among various U.S. Subpopulations. The information supports exposure scenarios that are specific to age, region, gender, behavior, culture, and socio- economical status. The follow-up effort, "Estimating Exposures for Susceptible Populations," will recommend values for actual exposures and will supplement the factors document will additional data and sources. It will also provide an index of data. b. Support an examination of environmental justice issues by the Organization for Economic Cooperation and Development (OECD) as part of a report on U.S. environmental performance. This report describes environmental justice issues relating to water supply, sanitation and waste management in the U.S. The report is being distributed to environmental stakeholders in this country and 70 countries worldwide. c. Develop the electronic capability to locate Tribal boundaries using geographical data. This application, used in conjunction with other data sources, improves EPA's ability to assess water quality conditions and problems on Native American lands. d. Explore the use of TRI and other data bases as tools to help protect the ground water resource in poor/minority communities. Pilots studies are ongoing in Vicksburg, MS and Alcorn State University, MS. e. Utilize Geographic Information System (GIS) mapping to identify low-income communities and communities of color where existing and potential sources of environmental hazard and risk are numerous; identify potential options for addressing the most significant environmental problems in these communities; and begin to address the problems in these communities through EPA action and through the involvement of other agencies with jurisdiction. Initial mapping completed. Completion Date 12/96 Lead ORD 4/96 OIA complete OW 3/97 12/96 Reg 4 Reg 9 16 ------- Mission Area DATA COLLECTION, ANALYSIS, AND STAKEHOLDER ACCESS TO PUBLIC INFORMATION Goal (4) Improving Public Access - In partnership with affected stakeholders Measure of Progress: (Draft) 30% of affected stakeholders indicate improved accessibility and usability of EPA's major data systems. Objectives EPA will work to provide, as appropriate and practicable, direct stakeholder and user involvement in the design, implementation, and evaluation of its information systems. EPA information systems, as appropriate and practicable, will allow two-way communication between the Agency and community information users. EPA will produce educational materials to assist the public in their effective use of EPA data. EPA will make available to the public, information it collects on populations surrounding major facilities or sites. Key Efforts a. Continue efforts to support the Lead Clearinghouse/Hotline which: collects, evaluates, and disseminates information on lead poisoning to the public; provides the public with information to make informed choices on lead exposure reduction measures or know where to seek more information; and uses multilingual ads, PSAs, technical information, and lead abatement training centers to educate the public. b. Develop LandView, a personal computer-based, geographic analysis and reference system, which combines five EPA databases, Census economic and demographic data, and Tiger files (street address, waterways, and similar data) in a map and table form. The system is usable by communities for identifying the location of sources of potential environmental risk. c. Establish an Internet Homepage to provide the public with information on multiple water-related issues and activities. A comment box allows for two-way communication, providing users with the opportunity to send as well as receive information. d. Develop the Ozone Education Program in the Baltimore region where ground- level ozone has been increasing due to the rise in automobile travel miles. The Program incorporates an ozone pollution, computer-generated map, which has been broadcast overWJZ-TV (Channel 13) in Baltimore since August 7, 1995. The map is an effective means of educating the public regarding air pollution by providing an accessible, understandable representation of real-time ozone pollution levels through daily television weather reports. e. Acquire key spatial hydro logic, critical habitat, wetland, and soils data to support analysis with GIS. Provide INTERNET access to EPA spatial data. Completion Date ongoing Lead OPPTS 3/95 OSWER complete OW complete Ree3 7/96 OARM 17 ------- Mission Area: DATA COLLECTION, ANALYSIS, AND STAKEHOLDER ACCESS TO PUBLIC INFORMATION Goal (4) Improving Public Access (contd.) Key Efforts f. Conduct a case study of the precedent setting Lorain County Pesticide Removal Site in Lorain and Elyria, OH to capture "lessons learned" in addressing environmental justice issues and use this site as a model for how environmental justice issues can been addressed. This case, which involved the cleanup of over 200 homes and the relocation of over 200 families in a predominantly minority and low-income community, addresses some of the key concerns related to environmental justice, namely, communication/public outreach, access/relocation, legal, human health, risk, social, and economic issues. Completion Date 3/96 Lead Reg 5 18 ------- Mission Area: AMERICAN INDIAN, ALASKA NATIVE, AND INDIGENOUS ENVIRONMENTAL PROTECTION Goal: EPA will work with Federally-recognized Tribal governments, Tribal and indigenous organizations, affected native populations, the Tribal Operations Committee, and the National Environmental Justice Advisory Council to integrate the provisions of the Executive Order into EPA's environmental policies, programs, and activities. Measure of Progress: (Draft) Given a baseline of the last three years, a 10% increase in the number of Tribal governments with developed and delegated environmental programs. Objectives EPA will continue to work with other Federal agencies and Federally-recognized Tribes to effectively protect and improve Tribal health and environmental conditions. These activities will include: providing outreach, education, training, and technical, financial and legal assistance to develop, implement, and maintain comprehensive Tribal environmental programs, which will undertake the remediation of environmental hazards and the development and implementation of Tribal environmental codes and Tribal-EPA Agreements to address Tribal needs, program delegations, and direct Federal implementation. EPA will implement its programs both for American Indians and indigenous communities, recognizing the government-to- government relationship, the Federal Trust responsibility, Tribal sovereignty, treaty-protected rights, other tenets of Federal Indian law, and particular historical and cultural needs of Tribes and indigenous populations. To ensure consistency, the Office of Environmental Justice, the Environmental Justice Coordinators, the American Indian Environmental Office, the Office of Enforcement and Compliance Assurance, and the Indian Coordinators will work closely to coordinate activities. Key Efforts a. Develop guidance to encourage Tribes to monitor, assess, and report on water quality conditions as part of the National Water Quality Inventory. This information will help document water quality conditions and identify improvements needed to achieve Tribal goals, including unique cultural water resource uses. Support training workshops with the Native American Water Association (NAWA) to improve Tribal ability to operate and maintain drinking water systems. b. Provide grant assistance to Tribes within the Missouri River Basin who are helping the Corp of Engineers revise the Missouri River Master Water Control Manual. MNI SOSE (Intertribal Water Rights Coalition) is assisting Missouri River Basin Tribes to enhance their protection, management, Tribal information systems, and sustainable development of natural and water resources. The project aims to strengthen cooperation between Federal, Tribal, State, and local natural resource agencies in the areas of Tribal involvement in water rights impacts, mitigation of conflicts, resource management and planning, environmental protection strategies, and training for Tribal leaders and natural resource staff. c. Directly assist Tribes, with a grant to the University of Wisconsin-Stevens Point, to strengthen their infrastructure to manage environmental problems on Tribal lands. This effort will be accomplished by providing information to Tribes on environmental issues, assisting in training and technical assistance, and providing mechanisms for inter- governmental cooperatives. The project will create a sustainable development model and host an Inter-tribal environmental justice forum to address the unique problems of the different Tribes and produce education materials. d. Develop, with BIA, the "Healing the Earth" American Indian Environmental Dialogue to enhance consultation between government officials and Tribal and indigenous environmental leaders on environmental definitions, goals, and program directions. The project featured a Washington conference/dialogue with several panels on American Indian/Alaska Native environmental issues, especially the spiritual/religious/cultural aspects. The proceedings were videotaped and are being incorporated into training programs. Completion Date complete Lead OW 12/96 OW ongoing OEJ/ Reg 5 12/96 OW 19 ------- Mission Area: AMERICAN INDIAN, ALASKA NATIVE, AND INDIGENOUS ENVIRONMENTAL PROTECTION Objectives (contd.) Human health and environmental research and other activities involving Tribal and indigenous environments and communities will take into account the cultural use of natural resources. These activities will seek contributions from Tribal governments and indigenous people in order to incorporate their traditional understandings of, and relationships to, the environment. EPA will work with other Federal agencies, Federally-recognized Tribal governments, and environmental justice advocates to develop appropriate guidance for addressing indigenous grassroots environmental justice issues and encourage public participation processes for environmental protection activities. EPA will work with Tribal governments and indigenous populations to protect and sustain Tribal and indigenous health, environments, and resources. Key Efforts e. Research and analyze basic spatial/temporal information on military installations and activities in the past 50-60 years and show the basic spatial relationship between them and Alaska native villages and Tribes. This project has four objectives: 1) develop an extensive spatial/temporal data base including; subsistence land use patterns, demographics (e.g. population centers, ethnicity), and descriptions of past and present military installations; 2) develop maps that represent the data; 3) analyze the spatial/temporal and demographic information; and 4) develop a summary of information and recommendation(s). The results should serve as the basis for future research on health problems in Alaska. f. Promote and foster active involvement and participation by Tribes in technical training sessions on the water quality criteria and standards programs. These programs represent the basic underpinnings of all water quality protection efforts and a thorough understanding of their features is critical if they are to be adopted and effectively applied on Tribal lands. g. Award a cooperative agreement (* 12/95) to the Native American organization, Americans for Indian Opportunity, to establish a Tribal association to advise OSWER on waste issues pertinent to Tribal lands, and to provide outreach and technical assistance to Tribal governments on the subject of Brownfields redevelopment. Completion Date 7/96 Lead Reg 10 ongoing OW *ongoing OSWER 20 ------- Mission Area: ENFORCEMENT, COMPLIANCE ASSURANCE, AND REGULATORY REVIEW Goal (1) Strategic Enforcement of Environmental Statutes - EPA will incorporate environmental justice concerns into its program for ensuring compliance with Federal environmental requirements at both private and Federal facilities. The Agency will review and revise as needed significant policy and guidance documents to address environmental justice issues. A major feature of this approach will be to ensure that EPA's enforcement and compliance assurance activities include a focus on minority communities and low-income communities which suffer from disproportionately high and adverse human health or environmental effects. EPA will use, as appropriate, the full range of tools available to it to correct noncompliance in such communities. EPA will ensure that Memoranda of Agreement between Headquarters and Regional offices reflect environmental justice activities and will include environmental justice as a specific component of program reviews. Measure of Progress: (Draft) 20% of enforcement cases and/or compliance activities that are initiated or completed involve minority communities and/or low-income communities. Objectives EPA will include in its enforcement efforts identification of communities and populations, such as low-income urban and rural populations which suffer from disproportionately high and adverse human health or environmental effects. EPA will work to ensure that inspection and enforcement actions are sufficient to address those effects. EPA's focused efforts will use the most current demographic information (using Geographic Information System mapping techniques), Toxics Release Inventory data, media specific and multi- media data, community reports, and relevant health statistics. Key Efforts a. Work with the Technical Enforcement Program and the Case Screening Committee to assure incorporation of EJ considerations into the full range of Region 8 enforcement activities. The activities included are: 1) development of an implementable mechanism for staff and managers to include EJ considerations in priority setting for sector, media, inspections and other enforcement activities; 2) a guidance document for staff and managers on incorporating EJ considerations into negotiations and settlement activities; and 3) participating in case screening activities to insure EJ considerations are met. *Priority setting mechanism-April 1996; Guidance document- June 1996; Case screening - twice a month b. Issue grants to the Texas Office of the Attorney General Strike Force and the New Mexico Attorney General's Office in support of enforcement actions being taken by the Attorneys General against colonias developers who are in violation of State laws, as related to infrastructure in Texas colonias. c. Establish the Commission for Environmental Cooperation (CEC), which includes as one of its three major components a Joint Public Advisory Committee (JPAC). JPAC includes members of State and provincial governments as well as members of Native American Tribes, business, academia, and NGOs. EPA has also established a Government Advisory Committee (GAC) and a National Advisory Committee (NAC) to provide guidance from U.S. communities. The GAC consists of members of State, local, and Tribal governments. The NAC consists of businesses, NGO,s and the public at large. The CEC prepares reports requested by the public, and responds to allegations by members of the public that a government is not effectively enforcing its own environmental laws (the Article 14 process). The CEC's guidelines for the Article 14 process, prepared with extensive public input, allow a resident of any of the three countries (U.S., Mexico, Canada) to make a submission; the resulting information is then made public. d. Continue to implement the new Supplemental Environmental Projects Policy (SEP) to identify and develop SEP Projects which address environmental justice concerns, as appropriate in each case. Implement the new Supplemental Environmental Projects Policy (SEP) to identify and develop SEP Projects which address environmental justice concerns. Completion Date Lead Ree8 ongoing Ree6 ongoing OIA ongoing OECA 21 ------- Mission Area: ENFORCEMENT, COMPLIANCE ASSURANCE, AND REGULATORY REVIEW Objectives (contd.) EPA will customize its enforcement and compliance assurance program for affected communities to reflect the needs of the community and the particular compliance problems in that community. EPA will also use technical support and assistance as a supplement to traditional enforcement as appropriate. EPA will actively encourage the use of creative approaches to settlement of enforcement actions, particularly where violations have been identified in communities disproportionately impacted by environmental problems (traditionally, many enforcement actions have been resolved by assessing cash penalties and imposing "end of pipe" solutions). Specifically, Regions and States will be encouraged to obtain Supplemental Environmental Projects (SEPS) which promote pollution prevention, remedy environmental damage, and collect adequate monetary fines. The goal of the projects will be to reduce long-term exposures within the affected community. EPA will work with academic institutions, including HBCUs, HSIs, and Tribal Colleges, and other local environmental justice groups to develop an educational program that provides affected communities with information on environmental protection, such as statutory and regulatory matters; citizen rights under Federal and State environmental statutes; whistle-blower protection for employees; the interpretation of data on performance available to the public; and the regulator's role in ensuring compliance. Key Efforts e. Enhance enforcement of EPA Worker Protection Standards through (1) protecting workers from adverse effects by enforcing the labeling requirements for use, application, and protective action and (2) working with applicators, farmers, and State agencies to ensure compliance with Worker Protection Standards. f. Include environmental justice factors in EPA compliance and enforcement agreements with States. Develop a list of State-EPA authorities and encourage and support State pilot projects in environmental justice. g. Provide GIS technical assistance to Clark/Atlanta University (CAU) and Xavier University (XU) in New Orleans. CAU will be developing workshops and conducting surveys in five Superfund locations and XU will be conducting outreach and workshops at two military locations in Biloxi, MS. h. Organize a conference with public interest attorneys in partnership with Illinois Institute of Technology - Kent School of Law. The purpose of this conference will be to stimulate dialogue on how environmental justice and citizen input can be taken into account in the enforcement process. i. In the South Bronx, New York City: 1) address community environmental justice concerns (*4/96 - a public meeting) ; 2) improve compliance rates through increased enforcement presence (*5/96 - field activities: interviewing citizens, inspections, etc.); 3) promote voluntary pollution prevention; 4) develop a program to help the public and industry to access information and comply with existing and new regulations; 5) increase public participation in selecting alternative compliance measures (e.g., supplemental environmental projects); and 6) establish partnerships between State and local governments (*3/96 - draft strategy). Completion Date 12/96 Lead OECA 12/96 ongoing OECA Reg 4 9/96 Reg 5 * ongoing Reg 2 22 ------- Mission Area ENFORCEMENT, COMPLIANCE ASSURANCE, AND REGULATORY REVIEW Goal (2) National Environmental Policy Act (NEPA) and Clean Air Act (CAA) Section 309 Responsibilities -Under the authority of NEPA and Sec. 309 of the CAA, EPA will, consistent with regulations and guidelines issued by the President's Council on Environmental Quality, routinely review the environmental effects of major Federal actions significantly affecting the quality of the human environment. For such actions, EPA reviewers will focus on the spatial distribution of human health, social, and economic effects to ensure that agency decision makers are aware of the extent to which those impacts fall disproportionately on covered communities. Measure of Progress: (Draft) Number of major Federal actions reviewed under the authority of NEPA and Section 309 of the CAA that had included consideration of spatial distribution of human health, social, and economic effects. Objectives EPA will aid Federal officials in their review of Federal actions as it relates to carrying out its responsibilities under NEPA and CAA Sec. 309. EPA will consider holding workshops and seminars with Sec. 309 reviewers and NEPA coordinators to further explore environmental justice impact analysis methods. Key Efforts a. Provide training for other regional staff to further explore environmental justice impact analysis methods in EIS reviews. In addition, this training will be made to Tribal groups, other Federal agencies, and grassroots organizations. Completion Date 12/96 Lead Reg 8 23 ------- Mission Area ENFORCEMENT, COMPLIANCE ASSURANCE, AND REGULATORY REVIEW Goal (3) Non-discrimination - EPA will work to ensure non- discrimination in the development and implementation of environmental protection programs. Measure of Progress: (Draft) Reduce complaint processing time by 10%. Objectives EPA will improve its implementation of requirements of Title VI of the Civil Rights Act of 1964 (Title VI) by issuing guidance, and conducting oversight for State and local recipients of EPA funding. EPA will develop guidance on the requirements of Title VI for carrying out Federally-authorized State permitting programs under the Clean Air Act, Clean Water Act, and the Resource Conservation and Recovery Act. EPA will work to develop case referral guidance, training materials on environmental justice and Title VI, and materials on Title VI compliance EPA will develop guidance on non-discrimination responsibilities of the Agency under the Executive Order. Key Efforts a. Develop a data and information collection instrument, through an external compliance pilot project with the Grants Administration Division and the Office of Water, to assess whether recipients of EPA financial assistance are in compliance with Title VI and the other external civil rights statutes. b. Develop, issue, and implement guidance, in consultation with program offices, on the requirements of Title VI for carrying out Federally- authorized State permitting programs. Completion Date 9/96 Lead OCR pending OCR/ OECA 24 ------- Mission Area: ENFORCEMENT, COMPLIANCE ASSURANCE, AND REGULATORY REVIEW Goal (4) Regulatory Review - EPA will work to ensure that environmental justice is incorporated into the Agency's regulatory process. Measure of Progress: (Draft) 10% of the Agency's regulatory packages that identify and address environmental justice concerns. Objectives EPA will complete its Regulatory Impact Analysis Guidance. This will provide the Agency guidance on ways to incorporate environmental justice into its regulatory development process. A cross-Agency work group on grants and environmental justice will examine options for incorporating environmental justice into EPA's grant programs to adequately reach minority populations and low-income populations and make recommendations to the Steering Committee on implementation. EPA will work with other Federal agencies and State, Tribal, and local governments to address environmental problems involving jurisdictional disputes or gaps in environmental laws. EPA will work to address cross-border pollution. Key Efforts a. Work with the Enforcement and Compliance Task Force of the Interagency Working Group to identify gaps or weaknesses in environmental statutes and develop recommendations for addressing those gaps and weaknesses. b. Simplify the administrative demands of applying for and administering a TAG, since the management of Superfund Technical Assistance Grants (TAGs) entails much administrative burden on behalf of a community group that lacks extensive resources. TAG application materials were simplified and reduced (9/94). Proposed regulations for modifying the TAG process are planned for Federal Register publication to get public comment. c. Continue to develop work plans under New England's Urban Enforcement Initiative to target enforcement and compliance assistance efforts in minority and low-income communities. Workplans include risk based priority setting, on-site compliance assistance in urban environments, and multi-media inspections. Completion Date pending Lead OGC 9/96 OSWER ongoing Regl 25 ------- |