vvEPA
United States
Environmental Protection
Agency
Plan EJ 2014
*
Plan EJ 2014 is EPA's roadmap for
integrating environmental justice into
its programs and policies.
-------
This page left intentionally blank
-------
v>EPA
Man II8014
September 2011
Office of Environmental Justice
U.S. Environmental Protection Agency
Washington, D.C. 20460
-------
This page left intentionally blank
-------
A message from.
EPA Administrator Lisa P. Jackson
Dear Colleagues:
Expanding the conversation on environmentalism and working for environmental
justice are among my top priorities for our work at the U.S. Environmental Protection
Agency. All too often, low-income, minority and tribal Americans live in the shadows of
the worst pollution, facing disproportionate health impacts and greater obstacles to
economic growth in communities that cannot attract businesses and new jobs.
In 1994, President Bill Clinton issued an executive order directing all federal agencies to
participate in a governmentwide effort to address environmental justice issues. To
strengthen our efforts in anticipation of the 20th anniversary of that directive and to
ensure that the EPA is setting a standard for all other agencies, I am pleased to share
our comprehensive environmental justice strategy Plan EJ 2014.
Plan EJ 2014 builds on the solid foundation we have established at the EPA to expand
the conversation on environmentalism. Since my first days as Administrator, I have
traveled the country to meet with diverse communities and listen to their concerns.
And I am committed to making environmental justice an essential part of our decision
making.
Plan EJ 2014 offers a road map that will enable us to better integrate environmental
justice and civil rights into our programs, policies and daily work. The plan focuses on
agencywide areas critical to advancing environmental justice, including rulemaking,
permitting, compliance and enforcement, community-based programs and our work
with other federal agencies. It also establishes specific milestones to help us meet the
needs of overburdened neighborhoods through our decision making, scientific analysis
and rulemaking.
Every American deserves clean air, water and land in the places where they live, work,
play and learn. Through our implementation of Plan EJ 2014, the EPA will be leading by
example in expanding the conversation on environmentalism and working for
environmental justice - now and into the future.
I am proud to be a part of this effort and ask you to join me as we strengthen our
mission to protect the health of all Americans.
Sincerely,
Lisa P. Jackson
Lisa P. Jackson
Administrator
U.S. Environmental Protection Agency
-------
This page left intentionally blank
-------
&EPA
EXECUTIVE SUMMARY i
Cross-Agency Focus Areas i
Tools Development Areas iv
Program Initiatives vi
Civil Rights vi
Conclusion vi
1.0 INTRODUCTION 1
1.1 Achieving Environmental Justice Priorities 2
1.2 Definition of Environmental Justice 3
2.0 PLAN EJ 2014 4
2.1 Plan EJ 2014's Organizational Structure 5
2.2 Implementation Plans 6
2.3 Community Engagement and Stakeholder Outreach 6
2.4 Reporting 7
3.0 CROSS-AGENCY FOCUS AREAS 8
3.1 Incorporating Environmental Justice into Rulemaking 8
3.2 Considering Environmental Justice in Permitting 10
3.3 Advancing Environmental Justice through Compliance and Enforcement 12
3.4 Supporting Community-Based Action Programs 14
3.5 Fostering Administration-Wide Action on Environmental Justice 18
4.0 TOOLS DEVELOPMENT AREAS 21
4.1 Science 21
4.2 Law 23
4.3 Information 24
4.4 Resources 25
5.0 PROGRAM INITIATIVES 28
6.0 CIVIL RIGHTS 28
APPENDIX 29
1. Incorporating Environmental Justice into Rulemaking 33
2. Considering Environmental Justice in Permitting 41
3. Advancing Environmental Justice through Compliance and Enforcement 56
4. Supporting Community-Based Action Programs 78
5. Fostering Administration-Wide Action on Environmental Justice 91
6. Science Tools Development 107
7. Legal Tools Development 146
8. Information Tools Development 150
9. Resources Tools Development 159
ACRONYMS 181
-------
This page left intentionally blank
-------
&EPA
EXECUTIVE SUMMARY
In January 2010, Administrator Lisa P. Jackson made Expanding the
Conversation on Environmentalism and Working for Environmental Justice
an Agency priority. This priority was incorporated into the U.S.
Environmental Protection Agency's (EPA) Strategic Plan for 2011-2015. To
implement this priority, EPA developed Plan EJ 2014 as the Agency's
roadmapfor integrating environmental justice into its programs, policies,
and activities. This priority recognizes that Title VI of the Civil Rights Act
and EPA's civil rights program is a critical component in advancing
environmental justice.
Plan EJ 2014, which is meant to mark the 20th anniversary of the signing of
Executive Order 12898 on environmental justice, is EPA's overarching
strategy for advancing environmental justice. It seeks to:
Protect the environment and health in overburdened
communities.
Empower communities to take action to improve their health
and environment.
Establish partnerships with local, state, tribal, and federal
governments and organizations to achieve healthy and
sustainable communities.
In July 2010, EPA introduced Plan EJ 2014 as a concept for public comment
and initiated the development of implementation plans. This product is the
culmination of nearly a year's effort by EPA programs and regions, as well
as engagement with stakeholders, to develop nine implementation plans
with the goals, strategies, deliverables, and milestones outlined herein.
Plan EJ 2014 has three major sections: Cross-Agency Focus Areas, Tools
Development Areas, and Program Initiatives. The following summaries
outline the implementation plans for Plan EJ 2014's five cross-Agency Focus
Areas and four Tools Development Areas.
Cross-Agency Focus Areas
Incorporating Environmental Justice into Rulemaking
Goal
To more effectively protect human health and the environment for
overburdened populations by developing and implementing guidance on
incorporating environmental justice into EPA's rulemaking process.
Strategies
1. Finalize the Interim Guidance on Considering Environmental Justice
During the Development of an Action.
2. Facilitate and monitor implementation of guidance on incorporating
environmental justice into rulemaking.
3. Develop technical guidance on how to conduct environmental justice
assessments of rulemaking activities.
Plan EJ 2014: Executive Summary
-------
&EPA
Considering Environmental Justice in Permitting
Goal
To enable overburdened communities to have full and meaningful access
to the permitting process and to develop permits that address
environmental justice issues to the greatest extent practicable under
existing environmental laws.
Strategies
1. Develop tools that will enhance the ability of overburdened
communities to participate fully and meaningfully in the permitting
process.
2. Concurrent with Strategy 1, develop tools to assist permitting
authorities to meaningfully address environmental justice in permitting
decisions.
3. Implement these tools at EPA and work with others to do the same.
Advancing Environmental Justice through Compliance and
Enforcement
Goal
To fully integrate consideration of environmental justice concerns into the
planning and implementation of the Office of Enforcement and Compliance
Assurance's (OECA) program strategies, case targeting strategies, and
development of remedies in enforcement actions to benefit overburdened
communities.
Strategies
1. Advance environmental justice goals through selection and
implementation of National Enforcement Initiatives.
2. Advance environmental justice goals through targeting and
development of compliance and enforcement actions.
3. Enhance use of enforcement and compliance tools to advance
environmental justice goals in regional geographic initiatives to address
the needs of overburdened communities.
4. Seek appropriate remedies in enforcement actions to benefit
overburdened communities and address environmental justice
concerns.
5. Enhance communication with affected communities and the public
regarding environmental justice concerns and the distribution and
benefits of enforcement actions, as appropriate.
Supporting Community-Based Action Programs
Goal
To strengthen community-based programs to engage overburdened
communities and build partnerships that promote healthy, sustainable, and
green communities.
Strategies
1. Advance environmental justice principles by building strong state and
tribal partnerships through the National Environmental Performance
Plan EJ 2014: Executive Summary
-------
&EPA
Partnership System (NEPPS) and the National Program Manager (NPM)
guidance.
2. Identify scalable and replicable elements of successful Agency
community-based programs and align multiple EPA programs to more
fully address the needs of overburdened communities.
3. Promote an integrated One EPA presence to better engage
communities in the Agency's work to protect human health and the
environment.
4. Foster community-based programs modeled on the Community Action
for a Renewed Environment (CARE) principles.
5. Explore how EPA funding, policies, and programs can inform or help
decision makers to maximize benefits and minimize adverse impacts
when considering current land uses in decision making, planning, siting,
and permitting.
6. Promote equitable development opportunities for all communities.
Fostering Administration-Wide Action on Environmental Justice
Goal
To facilitate the active involvement of all federal agencies in implementing
Executive Order 12898 by minimizing and mitigating disproportionate,
negative impacts while fostering environmental, public health, and
economic benefits for overburdened communities.
Strategies
1. Assist other federal agencies in integrating environmental justice in
their programs, policies, and activities.
2. Work with other federal agencies to strengthen use of interagency
legal tools, i.e., National Environmental Policy Act and Title VI of the
Civil Rights Act of 1964.
3. Foster healthy and sustainable communities, with an emphasis on
equitable development and place-based initiatives.
4. Strengthen community access to federal agencies.
Plan EJ 2014: Executive Summary
-------
vvEPA
in
Science
Goal
To substantially support and conduct research that employs participatory
principles and integrates social and physical sciences aimed at
understanding and illuminating solutions to environmental and health
inequalities among overburdened populations and communities in the
United States. All Agency decisions will make use of the information, data,
and analytic tools produced.
Strategies
1. Apply integrated transdisciplinary and community-based participatory
research approaches with a focus on addressing multi-media,
cumulative impacts and equity in environmental health and
environmental conditions.
2. Incorporate perspectives from community-based organizations and
community leaders into EPA research agendas and engage in
collaborative partnerships with them on science and research to
address environmental justice.
3. Leverage partnerships with other federal agencies on issues of
research, policy, and action to address health disparities.
4. Build and strengthen the technical capacity of Agency scientists on
conducting research and related science activities in partnership with
impacted communities and translating research results to inform
change.
5. Build and strengthen technical capacity of community-based
organizations and community environmental justice and health leaders
to address environmental health disparities and environmental
sustainability issues.
Law
Goal
To provide legal assistance to EPA policy makers and other Agency decision
makers to advance their environmental justice objectives.
Strategy
Provide legal support to each Plan EJ 2014 cross-Agency Focus Area
workgroup.
Plan EJ 2014: Executive Summary
-------
&EPA
Information
Goal
To develop a more integrated, comprehensive, efficient, and nationally
consistent approach for collecting, maintaining, and using geospatial
information relevant to potentially overburdened communities.
Strategies
1. Develop EPA's GeoPlatform.
2. Develop a nationally consistent environmental justice screening tool.
3. Incorporate appropriate elements of the environmental justice
screening tool into the GeoPlatform.
Resources
Grants and Technical Assistance Goal
To develop an efficient and effective system for delivering financial and
technical assistance to communities to empower them to improve their
health and environment.
Strategies
1. Increase transparency and efficiency in providing community-based
grant opportunities.
2. Improve delivery of technical assistance to communities.
3. Strengthen grants training for communities.
4. Improve community awareness of grant competition process.
5. Revise grant policies that are unduly restrictive.
6. Encourage legal and program offices to dialog on community-based
grant opportunities.
7. Improve timeliness of Brownfields Grant Awards.
Workforce Diversity Goal
To achieve an inclusive work environment by developing an efficient
system for the outreach and recruitment of potential employees.
Strategies
1. Increase the diverse pool of qualified applicants.
2. Operate under an integrated One EPA approach for recruitment and
outreach.
Plan EJ 2014: Executive Summary
-------
&EPA
Program Initiatives
Program Initiatives will focus on specific EPA programs. Many existing EPA
programs actively pursue environmental justice goals or produce benefits
for overburdened communities. Examples of such initiatives include:
Community Engagement Initiative (Office of Solid Waste and Emergency
Response), Urban Waters (Office of Water), National Enforcement
Initiatives (Office of Enforcement and Compliance Assurance), Air Toxics
Rules (Office of Air and Radiation), and the U.S. Mexico Border Program
(Office of International and Tribal Affairs). Over the next year, EPA will
designate at least one initiative per appropriate program for inclusion in
Plan EJ 2014. In this way, many existing EPA initiatives can be tailored to
better integrate environmental justice and produce greater benefits for
overburdened communities.
Civil Rights
One effort already under way is implementing Administrator Jackson's
priority to improve EPA's civil rights program. Complying with EPA's
statutory civil rights obligations is a critical part of our efforts to advance
environmental justice. Administrator Jackson has made improving EPA's
civil rights program a priority. As part of this effort, EPA is pursuing long
overdue, vigorous, robust, and effective implementation of Title VI of the
Civil Rights Act of 1964 and other nondiscrimination statutes. EPA is
committed to protecting people from discrimination based on race, color,
or national origin in programs or activities that receive EPA's financial
assistance.
Conclusion
Through Plan EJ 2014, EPA intends to develop a suite of tools to integrate
environmental justice and civil rights into its programs, policies, and
activities. It seeks to build stronger relationships with communities
overburdened by environmental and health hazards and build partnerships
that improve conditions in such communities. In 2014, EPA will make an
assessment of its progress in achieving the goals of Plan EJ 2014. Based on
this assessment, EPA will produce a report on the accomplishments,
lessons learned, challenges, and next steps for continuing the Agency's
efforts to make environmental justice an integral part of every decision.
Plan EJ 2014: Executive Summary
vi
-------
&EPA
1.0 INTRODUCTION
For far too long, many minority, low-income, tribal, and indigenous people
in the United States have experienced higher levels of environmental
pollution and other social and economic burdens. These overburdened
communities1 have generally viewed environmentalism and environmental
protection as a distant calling. These burdens have led to poorer health
outcomes, as well as fewer financial or advocacy opportunities to pursue
many productive activities, including "greening" their communities.
In January 2010, U.S. Environmental Protection Agency (EPA) Administrator
Lisa P. Jackson made Expanding the Conversation on Environmentalism and
Working for Environmental Justice one of EPA's priorities. The
Administrator has directed the Agency to address the needs of
overburdened communities by decreasing environmental burdens,
increasing environmental benefits, and working alongside them to build
healthy, sustainable, and green communities. This priority recognizes that
Title VI of the Civil Rights Act and EPA's civil rights program is a critical
component in advancing environmental justice. The Administrator's
priority heralds "a new era of outreach and protection for communities
historically underrepresented in EPA decision making" and calls for
"include[ing] environmental justice principles in all of our decisions."2
February 2014 will mark the 20th anniversary of the Clinton
Administration's Executive Order 12898, Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations
(EO 12898). EO 12898 calls on each federal agency to "make achieving
environmental justice part of its mission by identifying and addressing, as
appropriate, disproportionately high and adverse human health or
environmental effects of its programs, policies, and activities..."3 In
recognition of this anniversary, EPA has developed Plan EJ 2014, a
comprehensive strategy to guide the Agency in developing stronger
relationships with communities and increasing efforts to improve the
environmental conditions and public health in overburdened communities.
In July 2010, EPA introduced Plan EJ 2014 as a concept for public comment
and initiated the development of implementation plans. This product is the
culmination of nearly a year's effort by EPA programs and regions, as well
as engagement with stakeholders, to develop nine implementation plans
with the goals, strategies, deliverables, and milestones outlined herein.
1 In Plan EJ 2014, EPA uses the term "overburdened" to describe the minority, low-income, tribal, and
indigenous populations or communities in the United States that potentially experience
disproportionate environmental harms and risks as a result of greater vulnerability to environmental
hazards. This increased vulnerability may be attributable to an accumulation of both negative and lack
of positive environmental, health, economic, or social conditions within these populations or
communities.
2 Jackson, Lisa P., "Seven Priorities for EPA's Future." January 12, 2010. Available at:
http://blog.epa.gov/administrator/2010/01/12/seven-priorities-for-epas-future/.
3 Clinton, William J., Executive Order 12898, "Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations," February 11, 1994, Federal Register 59, No. 32:
7629.
Plan EJ 2014: Overview
-------
&EPA
1.1 Achieving Environmental Justice Priorities
Achieving environmental justice is an integral part of EPA's mission to
protect human health and the environment. EPA works to ensure that all
Americans are protected from significant risks to human health and the
environment where they live, learn, and work, by enforcing federal laws
protecting human health and the environment fairly and effectively and
using the best available science. EPA also works to ensure that all parts of
society have access to accurate information sufficient to effectively
participate in managing human health and environmental risks. Lastly, EPA
works to ensure that environmental protection contributes to making our
communities and ecosystems diverse, sustainable, and economically
productive. EPA has identified three overarching goals for its work on
environmental justice:
Protect the environment and health in overburdened communities.
Empower communities to take action to improve their health and
environment.
Establish partnerships with local, state, tribal, and federal governments
and organizations to achieve healthy and sustainable communities.
The Administrator's priority on environmental justice encourages EPA to
identify better ways to address the issues facing many minority, low-
income, tribal, and indigenous people regarding environmental and health
concerns. To ensure environmental justice is incorporated into all
activities, EPA has included specific language in its Fiscal Year (FY) 2011-
2015 Strategic Plan Cross-Cutting Fundamental Strategy: Working for
Environmental Justice and Children's Health: "Environmental justice and
children's health protection will be achieved when all Americans,
regardless of age, race, economic status, or ethnicity, have access to clean
water, clean air, and healthy communities."4 In addition, EPA recognizes
that complying with its statutory obligations under Title VI of the Civil
Rights Act of 1964 and other nondiscrimination laws is a critical part of
integrating environmental justice in all Agency programs, policies, and
activities.
The Agency will use a variety of approaches to meet this commitment,
including regulation, enforcement, research, outreach, community-based
programs, and partnerships to protect children and disproportionately
impacted, overburdened populations from environmental and human
health hazards. EPA anticipates that leadership in advancing
environmental justice and children's health protection will inspire and
engage a broad spectrum of partners in the public and private sector to do
the same. The activities outlined in Plan EJ 2014 support EPA's
environmental justice commitments in this Cross-Cutting Fundamental
Strategy.
4 U.S. Environmental Protection Agency, FY2011-2015 EPA Strategic Plan: Achieving Our Vision,
September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html.
Plan EJ 2014: Overview
-------
&EPA
!.- i ^finition of
EPA defines "environmental justice" as the fair treatment and meaningful
involvement of all people regardless of race, color, national origin, or
income with respect to the development, implementation, and
enforcement of environmental laws, regulations, and policies.5
Fair Treatment means that no group of people should bear a
disproportionate burden of environmental harms and risks, including those
resulting from the negative environmental consequences of industrial,
governmental, and commercial operations or programs and policies.
Meaningful Involvement means that: (1) potentially affected community
members have an appropriate opportunity to participate in decisions about
a proposed activity that will affect their environment and/or health; (2) the
public's contribution can influence the regulatory agency's decision; (3) the
concerns of all participants involved will be considered in the decision-
making process; and (4) the decision makers seek out and facilitate the
involvement of those potentially affected. In the Agency's implementation
of environmental justice, EPA has expanded the concept of fair treatment
to include not only the consideration of how burdens are distributed across
all populations, but also how benefits are distributed. For example, the
Agency's Interim Guidance on Considering Environmental Justice During the
Development of an Action encourages the evaluation of the distribution of
burdens by paying special attention to populations that have historically
borne a disproportionate share of environmental harms and risk. At the
same time, it encourages Agency staff to look at the distribution of the
positive environmental and health consequences from our activities.
EPA also recognizes that it has statutory obligations to comply with Title VI
of the Civil Rights Act of 1964 and other nondiscrimination laws. Title VI
prohibits discrimination on the basis of race, color, or national origin in all
programs or activities receiving federal financial assistance. The Supreme
Court has ruled that Title VI authorizes federal agencies, including EPA, to
adopt implementing regulations that prohibit discriminatory effects as well
as intentional discrimination. EPA has established such regulations. Title VI
allows persons to file administrative complaints with federal departments
and agencies alleging discrimination by financial assistance recipients. The
Office of Civil Rights (OCR) has the responsibility within EPA to process and
review Title VI administrative complaints.6 In the Presidential
Memorandum accompanying EO 12898, President Clinton pointed to civil
rights statutes as an important tool for achieving the goals of the
environmental justice executive order.7
5 U.S. Environmental Protection Agency, Interim Guidance on Considering Environmental Justice During
the Development of an Action. Available at:
http://www.epa.gov/compliance/ei/resources/policv/considering-ei-in-rulemaking-guide-07-2010.pdf.
6 For a description of EPA's Program to Implement Title VI of the Civil Rights Act of 1964, see:
http://www.epa.gov/civilrights/t6home.htm.
Clinton, William J., Presidential Memorandum Accompanying Executive Order 12898, "Federal Actions
to Address Environmental Justice in Minority Populations and Low-Income Populations." Available at:
http://www.epa.gov/environmentaliustice/resources/policv/clinton memo 12898.pdf.
Plan EJ 2014: Overview
-------
&EPA
2.0 PLAN EJ 2014
Plan EJ 2014 is a roadmap to help EPA integrate environmental justice into
its programs, policies, and activities. The Plan is organized into three
sections: Cross-Agency Focus Areas, Tools Development Areas, and
Program Initiatives.
Cross-Agency Focus Areas address cross-cutting issues or functions that
require work by all programs or agencies and serve to advance
environmental justice across EPA and the federal government. They require
a unified Agency approach toward policy and guidance development.
Many issues also require coordination among multiple federal agencies.
Community engagement and empowerment, with continuous input from
communities and all stakeholders, will help shape the planning and
implementation of Plan EJ 2014 initiatives.
1. Cross-Agency Focus Areas
EPA has identified five cross-Agency Focus Areas:
Incorporating Environmental Justice into Rulemaking.
Considering Environmental Justice in Permitting.
Advancing Environmental Justice through Compliance and
Enforcement.
Supporting Community-Based Action Programs.
Fostering Administration-Wide Action on Environmental Justice.
2. Tools Development Areas
Tools Development will focus on developing the methods, mechanisms,
and systems that support environmental justice analysis, technical
assistance, and community work. Plan EJ 2014 has identified four areas for
tools development:
Science.
Law.
Information.
Resources.
3. Program Initiatives
Program Initiatives will focus on specific EPA programs. EPA's programs are
designed primarily to carry out the nation's environmental protection
statutes, such as the Clean Air Act, Clean Water Act, and Resource
Conservation and Recovery Act. Certain EPA programs are organized by
media, such as air, water, and soil. Others are organized to address cross-
Agency functions, such as enforcement, research, and information. Under
Plan EJ 2014, each EPA National Program Manager (NPM) will identify
programs that benefit communities with environmental justice concerns.
Plan EJ 2014: Overview
-------
&EPA
2.1 Plan EJ 2014's Organizational Structure
EPA's programs and regions have assumed principal responsibility for
leading at least one cross-Agency Focus or Tools Development Area in Plan
EJ 2014. They have dedicated senior management and established a staff
level workgroup to carry out this responsibility. This approach ensures that
all program offices and regions bring their programmatic resources and
expertise to advancing environmental justice goals. It also develops
expertise in environmental justice throughout all Agency programs and
regions. The table below delineates each element and its respective lead
offices and regions.
PLAN EJ 2014 ELEMENT
Incorporating Environmental
Justice in Rulemaking
Considering Environmental
Justice in Permitting
Advancing Environmental
Justice through Compliance
and Enforcement
Supporting Community-
Based Programs
Fostering Administration-
Wide Action on
Environmental Justice
Science Tools Development
Legal Tools Development
Information Tools
Development
Resources Tools
Development
LEAD PROGRAM OFFICES AND
REGIONS
Office of Chemical Safety and
Pollution Prevention; Office of Policy;
Office of Research and Development;
Office of Environmental Justice;
Region 9
Office of Air and Radiation; Office of
General Counsel; Region 1
Office of Enforcement and
Compliance Assurance; Region 5
Office of Solid Waste and Emergency
Response; Regions 2, 3, 4
Office of Water; Region 6
Office of Research and Development;
Region 7
Office of General Counsel; Region 5
Office of Policy; Office of
Environmental Information; Regions
3,8,9, 10
Office of Administration and Resource
Management
This organizational structure constitutes an important step for achieving
the Agency's environmental justice program vision that all Program Offices
and Regions will integrate and address issues of environmental justice in
EPA's programs and policies as part of their day-to-day business. The
Office of Environmental Justice (OEJ) serves as the focal point for
facilitating that integration through building capacity, promoting
accountability, incorporating the community's voice, and promoting
Agency action on critical environmental justice issues.
Plan EJ 2014: Overview
-------
&EPA
2.2 Implementation Plans
Each cross-Agency Focus or Tools Development Area in Plan EJ 2014 has an
implementation plan, which is built around the following elements: goals,
strategies, activities, deliverables, and milestones. The implementation
plans will be used to track results and perform ongoing monitoring and
reporting of accomplishments. These elements are defined as follows:
Goals: The projected state of affairs or condition that the
implementation plan intends to achieve.
Strategies: Systematic action designed to achieve the stated goal.
Activities: Specific actions to implement the strategies identified.
Deliverables: Results of the activities identified, which could include
processes, products, outputs, or changes in conditions (including
environmental outcomes).
Milestones: Target dates for completion of the deliverables identified.
In addition to supporting EPA's current strategic plan, Plan EJ 2014 will
align with two other important EPA and federal government initiatives:
1. EPA's Community-Based Coordination Project is designed to improve
the effectiveness of EPA's place-based community programs by
improving management of information about EPA's programs,
community access to EPA resources, targeting EPA's resources to
communities most in need, and establishing a basis for coordinating
this work with other federal agencies.
2. The Federal Interagency Working Group on Environmental Justice (EJ
IWG) was established by EO 12898 in 1994 and reconvened in
September 2010. The EJ IWG serves as a clearing house for guidance to
and lessons learned by federal agencies on integrating environmental
justice into their programs. The EJ IWG will also coordinate the
development and implementation of interagency collaborative efforts.
2.3 Community Engagement and Stakeholder Outreach
Plan EJ 2014 also seeks to advance the Administrator's commitment to
expanding the conversation on environmentalism to groups historically
underrepresented in the environmental decision-making process. Our
goals for stakeholder engagement are as follows:
To work with champions to foster greater understanding of Plan EJ
2014's vision, priorities, and desired outcomes among all stakeholders,
inside and outside the Agency.
To obtain a broad range of stakeholder views in the development and
implementation of Plan EJ 2014.
To communicate Plan EJ 2014's vision, activities, results, and
subsequent revisions to stakeholders, partners, and other audiences in
a consistent and dynamic way.
Plan EJ 2014: Overview
-------
&EPA
To facilitate the development of partnerships with and among EPA's
stakeholders to achieve Plan EJ 2014's goals and translate them into
lasting results.
Public input played a significant role in developing the elements of Plan EJ
2014. EPA convened multiple community forums and listening sessions in
the process of developing Plan EJ 2014. It requested that the National
Environmental Justice Advisory Council (NEJAC) provide recommendations
on Plan EJ 2014. EPA, along with its federal partners, plans to continue
conducting community listening sessions and stakeholder dialogues
throughout the country. Each implementation plan workgroup is
responsible for developing and carrying out a community engagement and
stakeholder outreach plan. In addition, OCR plans to issue a Limited English
Proficiency (LEP) Order by November 2011 to ensure that all EPA programs
and activities meet federal LEP requirements.
2.4 Reporting
EPA has made a commitment to provide progress reports and update the
implementation plans. To coincide with its Strategic Plan, EPA will issue
annual reports on Plan EJ 2014 at the end of the fiscal year. Every October,
OEJ will coordinate posting of reports on Plan EJ 2014. These documents
will be available on EPA's website:
www.epa.gov/environmentaliustice/plan-ei/index.html.
For information on Plan EJ 2014 and how to get involved, please contact
Charles Lee, Deputy Associate Assistant Administrator for Environmental
Justice, 202-564-2440. Lee.Charles@epa.gov.
Plan EJ 2014: Overview
-------
&EPA
3.0 CROSS-AGENCY FOCUS AREAS
This section provides summaries of Plan EJ 2014's five cross-Agency Focus
Areas and their implementation plans. These areas involve issues related
to rulemaking, permitting, enforcement, community-based action, and
Administration-wide action.
3.1 Incorporating Environmental Justice into Rulemaking
Plan EJ 2014 calls upon EPA to develop and implement guidance to
incorporate environmental justice into the fabric of its rulemaking process.
EPA's authority to create and enforce regulations that put our nation's
environmental laws into effect is one of the Agency's most important and
powerful tools for protecting our environment and the health of our
people. EPA's regulations cover a range of environmental and public health
issues, from setting standards for clean water to controlling air pollution
from industry and other sources. EPA's regulatory authority combined with
the mandates of EO 12898 charge EPA with responsibility to ensure that, as
we develop Agency actions, we consider environmental justice issues
during the Agency's rulemaking process.
EPA achieved a significant milestone in incorporating environmental justice
into its rulemaking process by issuing the Interim Guidance on
Incorporating Environmental Justice During the Development of an Action
(Environmental Justice in Rulemaking Guidance) in July 2010. This guidance
calls upon Agency rule writers and decision makers to consider
environmental justice throughout all phases of a rule's development -
known as the Action Development Process (ADP) - from the point of its
inception through all the stages leading to promulgation and
implementation. EPA is also developing technical guidance to assist rule
writers and decision makers in determining how to analyze and incorporate
environmental justice in the Agency's rulemaking processes.
Plan EJ 2014: Overview
-------
&EPA
Implementation Plan Summary
Goal
To more effectively protect human health and the environment for
overburdened populations by developing and implementing guidance to
incorporate environmental justice into EPA's rulemaking process.
Strategies & Activities
Developing Environmental Justice Analysis for the Definition
of Solid Waste Rule
After EPA finalized the 2008 Definition of Solid Waste (DSW)
rule, the Agency committed to perform an expanded
environmental justice analysis in response to concerns raised by
citizens and other stakeholders about the rule's potential impact
on communities. The EPA developed an innovative methodology
that incorporated sound science and community engagement.
EPA began by soliciting input from the public through
roundtables, conference calls, and webinars to get their thoughts
on how to best conduct the analysis. The Agency identified
potential hazards that may pose risks to communities from the
recycling of hazardous secondary materials and the facilities that
may take advantage of the 2008 DSW rule. The facility locations
were then mapped against demographics of the surrounding
communities. EPA synthesized the information and determined
that certain population groups would be disproportionately
impacted by the increased risk of adverse impacts under the
2008 DSW rule.
EPA incorporated these considerations in the revised proposed
rule, signed June 30, 2011, to mitigate these potential adverse
impacts, as allowed under applicable authorities. In addition,
EPA has taken steps in implementing the DSW rule that also help
mitigate these impacts. These steps include closely monitoring
the facilities notifying under the rule, working with the states and
EPA Regions to ensure they have the information they need to
ensure compliance with the provisions of the rule, and making
available to the public information about the facilities that have
notified.
Strategy 1: Finalize the Interim Guidance on
Considering Environmental Justice During the
Development of an Action.
* Activity 1.1: Announce April closure of public
comment period via Environmental Justice Listserv.
Activity 1.2: Review internal and external
comments provided during the Interim Final
Guidance's implementation period.
Activity 1.3: Review documents produced by and
interview members of EPA rule writing
workgroups.
Activity 1.4: Revise and release Environmental
Justice in Rulemaking Guidance document.
Strategy 2: Facilitate and monitor implementation of
guidance on incorporating environmental justice into
rulemaking.
* Activity 2.1: Distribute model training
presentations to Agency and NPM and Region-
specific regulation development and ADP trainers.
Activity 2.2: Initiate a continuous learning effort to
identify effective practices and lessons learned
from the Agency's ongoing rulemaking efforts.
Activity 2.3: Develop and commence
implementing a monitoring scheme to assess the
extent to which the guidance is being applied, the
resources being devoted to its application, and the
effect it is having on rulemaking decisions.
Strategy 3: Develop technical guidance on how to conduct environmental
justice assessments of rulemaking activities.
* Activity 3.1: Establish a cross-Agency Environmental Justice Technical
Guidance Workgroup.
Activity 3.2: Tier the Environmental Justice Technical Guidance as a
Tier 1 Action in the Action Development Process.
Activity 3.3: Develop draft technical guidance on incorporating
environmental justice in rulemaking.
Activity 3.4: Conduct internal and external review of draft technical
guidance on incorporating environmental justice in rulemaking.
Activity 3.5: Develop and release final technical guidance on
incorporating environmental justice in rulemaking.
Plan EJ 2014: Overview
-------
&EPA
3.2 Considering Environmental Justice in Permitting
Many federal environmental statutes rely heavily on permits to deliver the
environmental protection results that are the goal of our federal
environmental laws. These permits play a key role in providing effective
protection of public health and the environment in communities. Building
upon the Agency's efforts to incorporate environmental justice concerns in
rules, Plan EJ 2014 calls upon EPA to consider environmental justice
concerns during the permitting process. EPA will develop and implement
tools to: (1) enhance the ability of overburdened communities to
participate fully and meaningfully in the permitting process, and (2) assist
permitting authorities to meaningfully address environmental justice issues
in permitting decisions to the greatest extent practicable.
To achieve our goals, the Environmental Justice Permitting Initiative will
"identify and develop tools to support the consideration of environmental
justice during implementation of permitting programs" to reduce
"exposures for those at the greatest risk/' as stated in the FY 2011-2015
EPA Strategic Plan, Cross-Cutting Fundamental Strategy: Working for
Environmental Justice and Children's Health.8 Initially, the Agency will
focus on EPA-issued permits that provide the best current opportunities for
taking environmental justice concerns into consideration. In this way, EPA
can make short-term progress and gain valuable lessons for subsequent
efforts. In the long term, EPA will focus on permits issued pursuant to
federal environmental laws (i.e., federal, state, or tribal) that enable the
Agency to address the complex issue of cumulative impacts from exposure
to multiple sources and existing conditions.
8 U.S. Environmental Protection Agency, FY2011-2015 EPA Strategic Plan: Achieving Our Vision,
September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html.
Plan EJ 2014: Overview
10
-------
v°/EPA
Implementation Plan Summary
Goal
To enable overburdened
communities to have full and
meaningful access to the permitting
process and to develop permits that
address environmental justice issues
to the greatest extent practicable
under existing environmental laws.
Strategies
Strategy 1: Develop tools that will
enhance the ability of
overburdened communities to
participate fully and meaningfully
in the permitting process.
Strategy 2: Concurrent with
Strategy 1, develop tools and to
assist permitting authorities to
meaningfully address
environmental justice in permitting
decisions.
Strategy 3: Implement these tools
at EPA and work with others to do
the same.
Activities
For each strategy, EPA will
undertake the following activities:
Conducting Public Participation to Develop
Permitting Tools
The Environmental Justice and Permitting
Initiative Workgroup (Workgroup) is exploring
ways to enable overburdened communities to
have full and meaningful access to the
permitting process and to ensure that the
Agency develops permits that address
environmental justice issues to the greatest
extent practicable. As part of this effort, the
Workgroup is conducting extensive public
outreach to identify best practices and needed
tools, such as guidance, checklists, reports,
case studies, mapping tools, and trainings. In
June 2011, the Workgroup conducted listening
sessions for a host of stakeholder groups,
including state and local governments,
business and industry, environmental groups,
tribes, and community groups. One listening
session was conducted entirely in Spanish.
The Workgroup repeatedly heard about the
need for early and meaningful public
engagement. Its members were impressed
and inspired by the information they received
about Connecticut, Illinois, and Pennsylvania's
Enhanced/Environmental Justice Public
Participation Policies. The Workgroup is
drafting guidance to enhance the public
participation process for EPA-issued
permits and strongly encourages facilities to
host pre-application meetings with local
communities. The Workgroup's hope is that
this guidance will be used across the EPA, as
well as by other federal agencies and states in
their respective permit processes.
Activity 1: Conduct initial internal
research to begin to create a preliminary list of potential tools and finalize
the implementation plan (March-June 2011, Completed).
Activity 1.1: Conduct an initial literature review - including a review of
previous NEJAC papers, publications and other recommendations - to
identify an initial list of existing and needed tools.
Activity 1.2: Convene a cross-Agency workgroup.
Activity 1.3: Review and evaluate the permitting process for a
minimum of three federal permits with environmental justice
considerations to use as case studies to identify existing and needed
tools. The workgroup reviewed the permitting process for three
federal permits and will continue to review other permits to solicit
lessons learned and guide our next steps.
Activity 1.4: Coordinate overlapping strategies with other Plan EJ 2014
elements and consider integrating and leveraging activities between
them.
Activity 1.5: Issue the final implementation plan.
Plan EJ 2014: Overview
11
-------
&EPA
Activity 2: Solicit initial existing and recommended tools from internal and
external stakeholders.
Activity 3: Create an initial list of priority tools and corresponding
deliverables for Year 1.
Activity 4: Develop, test, and finalize priority tools for EPA-issued permits.
Activity 4.1: Develop priority tools that need to be developed, amend
existing tools, and identify those ready for potential immediate use at
EPA.
Activity 4.2: Identify opportunities to test the draft tools through on-
going permit activities.
Activity 4.3: Solicit comments both internally and externally on the
draft tools.
Activity 4.4: Incorporate comments and finalize tools.
Activity 5: Determine the best format(s) or vehicle(s) to convey and
implement the final tools (guidance, policy, rulemaking, etc.).
Activity 6: Create a more detailed timeline for FY 2012-2014 deliverables
for the workgroup.
3.3 Advancing Environmental Justice through Compliance
and Enforcement
EPA is committed to taking action to further ensure that our most
overburdened communities are given particular consideration as we
implement the Agency's enforcement and compliance program. Through
Plan EJ 2014, the Office of Enforcement and Compliance Assurance (OECA)
intends to focus and accelerate our efforts to identify, assess, and address
environmental justice concerns in these communities when developing and
implementing OECA's program strategies, civil and criminal enforcement
activities, and compliance activities. Our goal for the next three years is to
fully integrate consideration of environmental justice concerns into the
planning and implementation of OECA's program strategies, case targeting
strategies, and development of remedies in enforcement actions to benefit
these communities. We also plan to accelerate our ongoing efforts to
communicate more effectively with these communities about our
enforcement actions and program activities. Through these efforts, we
hope to further advance the Agency's environmental justice goals of fair
treatment and meaningful involvement of communities.
Plan EJ 2014 calls upon EPA to accelerate its ongoing efforts to give full
consideration to environmental justice issues when developing and
implementing its enforcement program strategies. For example, OECA
selected National Enforcement Initiatives for FY 2011-2013 that include
taking action against sewer overflows, Concentrated Animal Feeding
Operations (CAFO) that discharge manure to surface or ground waters, and
facilities that emit excessive amounts of air toxics. These types of facilities
Plan EJ 2014: Overview
12
-------
&EPA
and pollution problems often have a disproportionate impact on minority,
low-income, tribal, or indigenous communities. OECA and the regions,
working with the U.S. Department of Justice (DOJ), are also pressing for
remedies in enforcement cases that benefit communities overburdened by
illegal pollution. OECA will also make additional efforts to provide
information to overburdened communities about enforcement actions that
affect those communities, and to provide meaningful opportunities for
community input on the remedies sought in those enforcement actions.
Implementation Plan Summary
Goal
Enforcing the Clean Water Act _ , .. . . . ., , . . .
To fully integrate consideration of environmental
An EPA enforcement settlement in December 2010 requires justjce concerns into the ,anni and
that the Cleveland-area Northeast Ohio Regional Sewer District
take steps to stop the flow of untreated sewage into local implementation of OECA s program strategies, case
waterways and Lake Erie. Among other requirements, the targeting strategies, and development of remedies
District is required to take several specific steps to address in enforcement actions to benefit overburdened
concerns in overburdened communities. For example, the communities over the next three years.
District must reduce pollutant discharges much more quickly in
these areas. Strategies & Activities
In addition, several vacant lands will be transformed into green Strategy 1: Advance environmental justice goals
space and recreational areas to help capture storm water through selection and implementation of National
discharges, perhaps leading to increased property values and Enforcement Initiatives
employment opportunities. Also, the District will operate a ... ^ , .' r *, - , r- r
household hazardous waste collection center each month as a ' Activity 1.1: Selection of National Enforcement
supplemental environmental project, providing local citizens with Initiatives for FY 2011-13.
a place to properly dispose of used motor oil, paints, batteries, Activity 1.2: Implementation of National
and other items that could otherwise end up in storm water Enforcement Initiatives for FY 2011-13.
discharges. . Activity 1.3: Selection of National Enforcement
Initiatives for FY 2014-16.
Strategy 2: Advance environmental justice goals through targeting and
development of compliance and enforcement actions.
* Activity 2.1: Issue internal guidance requiring analysis and
consideration of environmental justice in EPA's compliance and
enforcement program.
Activity 2.2: Review OECA's Enforcement Response Policies to
determine whether any revisions are needed to ensure that
environmental justice concerns are addressed in case development and
resolution.
Activity 2.3: Reevaluate use of the Environmental Justice Strategic
Enforcement Assessment Tool (EJSEAT), as appropriate, in response to
recommendations of the NEJAC and conclusions of the EPA
Environmental Justice Screening Committee.
Activity 2.4: Seek opportunities to advance environmental justice goals
in implementing the Clean Water Act Action Plan.
Activity 2.5: Seek opportunities to advance environmental justice goals
in conducting the National Enforcement Strategy for Resource
Recovery and Conservation Act (RCRA) Corrective Action.
Plan EJ 2014: Overview 13
-------
&EPA
Activity 2.6: Improve compliance at federal facilities where violations
may impact overburdened communities.
Activity 2.7: Develop tools to track facilities with environmental justice
concerns and report on enforcement actions that address
environmental justice concerns.
Strategy 3: Enhance use of enforcement and compliance tools to advance
environmental justice goals in regional geographic initiatives to address
the needs of overburdened communities.
* Activity 3.1: Regions will include use of enforcement tools as part of
integrated problem-solving strategies that are focused on particular
geographic areas.
Activity 3.2: Regions will include use of compliance assistance tools as
part of integrated problem-solving strategies focused on particular
geographic areas.
Strategy 4: Seek appropriate remedies in enforcement actions to benefit
overburdened communities and address environmental justice concerns.
* Activity 4.1: Increase efforts to address environmental justice concerns
through use of injunctive relief, including mitigation, and Supplemental
Environmental Projects in civil enforcement actions, as appropriate.
Activity 4.2: Increase efforts to benefit affected communities through
use of community service and the Crime Victims' Rights Act in criminal
actions.
Activity 4.3: Look for opportunities to work with other federal
agencies, state and local governments, and the business community to
complement and leverage community benefits resulting from
enforcement activities.
Strategy 5: Enhance communication with affected communities and the
public regarding environmental justice concerns and the distribution and
benefits of enforcement actions, as appropriate.
* Activity 5.1: Provide affected communities with information about
enforcement actions and meaningful opportunities for input on
potential environmental justice concerns and remedies to be
implemented.
Activity 5.2: Improve website information and other public information
materials to explain EPA's site cleanup enforcement processes.
Activity 5.3: Enhance communication of the environmental justice
benefits of EPA's enforcement actions.
3.4 Supporting Community-Based Action Programs
The Agency has learned that communities must be the driver for local
solutions. However, far too many communities lack the capacity to truly
affect environmental conditions. As a result, many low-income, minority,
tribal, and indigenous communities continue to live in the shadows of the
worst pollution and face some of the harshest impacts. Consequently, EPA
has implemented numerous programs to support community
empowerment and provide benefits that range from basic educational and
Plan EJ 2014: Overview
14
-------
&EPA
leadership development to comprehensive approaches. These include
financial assistance programs such as Environmental Justice, Community
Action for a Renewed Environment (CARE), Brownfields Area-Wide
Planning, Lead, and Tribal grants, as well as community-based programs
such as EPA's Local Climate and Energy, Childhood Asthma, Sustainable
Communities and Smart Growth, Urban Waters, Superfund, and
Brownfields programs.
EPA's ten regions play a leading role in implementing these programs.
Plan EJ 2014 builds upon an Agency effort to improve the effectiveness of
EPA's community-based programs through better information access,
coordination, and leveraging. EPA will build upon and leverage Agency
efforts to promote greater coordination in the use of programs and tools
that support community empowerment. Through these efforts, EPA will
make the Agency's resources more accessible to underserved communities,
while achieving greater internal efficiency through feedback and better
understanding of how to implement community-based programs. This
approach will result in environmental, health, and economic improvements
in such communities.
Plan EJ 2014: Overview
15
-------
&EPA
Implementation Plan Summary
Goal
To strengthen community-based programs to engage overburdened
communities and build partnerships that promote healthy, sustainable, and
green communities.
Strategies & Activities
Promoting Area-Wide Strategies for Brownfields
Redevelopment and Community Revitalization
EPA is piloting an area-wide planning approach to brownfields in
23 communities nationwide, recognizing that revitalization of the
area surrounding a brownfield is just as critical to the successful
reuse of the property as site assessment, cleanup, and
redevelopment. Each community will receive up to $175K in
grants and technical assistance. The pilot program will help
further community-based partnership efforts within underserved
or economically disadvantaged neighborhoods by confronting
local environmental and public health challenges related to
brownfields, while creating a planning framework to advance
economic development and job creation.
As one example, the Ironbound Community Corporation in
Newark, New Jersey, is building upon existing revitalization and
redevelopment efforts to develop an area-wide plan to create
sustainable recreational and mixed-use development in an area
with 100 brownfields. This community is home to over 50,000
residents and contains the remnants of a once vibrant economy,
anchored by a large brewery that closed in the 1970s, leaving
behind contaminated sites and deteriorating infrastructure. The
area is economically distressed with the poverty rate as high as
55 percent.
Strategy 1: Advance environmental justice
principles by building strong state and tribal
partnerships through the National Environmental
Performance Partnership System (NEPPS) and
National Program Manager (NPM) guidance.
* Activity 1: Create a workgroup to provide
recommendations that mutually support
community involvement, resource/data sharing,
monitoring/tracking, and training within
programs implemented through performance
partnership agreements, tribal agreements, and
work plans guided by NEPPS and NPM
documents.
Activity 2: Develop language for environmental
justice principles including Title VI guidance (as
appropriate with all Agency grants) for inclusion
in the FY 2013 NEPPS and FY 2012 NPM
guidance through collaboration and discussions
with Office of Congressional and
Intergovernmental Affairs (OCIR), Office of Civil
Rights (OCR), Regional Offices and States.
Strategy 2: Identify scalable and replicable elements of successful Agency
community-based programs and align multiple EPA programs to more
fully address the needs of overburdened communities.
* Activity 3: Review Agency and key outside community-based
programs, and existing evaluations of select Agency programs, to
identify scalable and replicable program elements which encourage
place-based solutions to environmental justice issues, strengthen and
promote partnerships, and support healthy and sustainable
communities.
Activity 4: Make recommendations on how EPA can align its
community-based work, particularly in EPA's regions to more fully
address the needs of overburdened communities.
Plan EJ 2014: Overview
16
-------
&EPA
Strategy 3: Promote an integrated One EPA presence to better engage
communities in the Agency's work to protect human health and the
environment.
* Activity 5: Target three approaches to promote an integrated One EPA
presence where EPA will find the best solution by working in a
consistent and unified way.
Strategy 4: Foster community-based programs modeled on the
Community Action for a Renewed Environment (CARE) principles.
* Activity 6: Develop a community-based partners (CBP) program to
create opportunities in undeserved and overburdened neighborhoods
for collaborating with private industry, foundations, and other
institutions to implement the CARE model.
Activity 7: Develop a CBP program that caters to grassroots or
emerging community groups with little to no organizational and/or
technical capacity.
Activity 8: Identify technical assistance resources, program staff, and
regional staff available to aid overburdened communities with issues
related to their areas of expertise.
Strategy 5: Explore how EPA funding, policies and programs can inform
or help local decision makers to maximize benefits and minimize adverse
impacts from land use decision making, planning and siting.
* Activity 9: Establish a workgroup and seek stakeholder feedback to
explore ways the Agency's work intersects with land use decision
making, planning, and siting.
Strategy 6: Promote equitable development opportunities for all
communities.
* Activity 10: Promote equitable development opportunities.
Plan EJ 2014: Overview
17
-------
&EPA
3.5 Fostering Administration-Wide Action on Environmental
Justice
Everyone in America deserves to live, learn, and work in a healthy and
sustainable community. EPA seeks to facilitate the active involvement of
all federal agencies in ensuring healthy, sustainable and green
communities, as well as equitable development, for all people. To better
achieve this goal, EPA is leading the Administration's effort to fully
implement EO 12898. As each agency reinvigorates its effort to make
environmental justice part of its mission, EPA will focus on helping each
agency participate in a coordinated approach that acknowledges the
disproportionately high and adverse human health and environmental
impacts on overburdened communities, while providing access to the
environmental, public health, and economic benefits that Agency programs
provide. A coordinated and holistic approach is essential to ensuring that
we address the full scope of adverse human health and environmental
effects in overburdened communities, legacy pollution problems rooted in
historical discrimination, and cumulative impacts; and ensure that all
communities participate in, and benefit from, the transition to a clean
energy economy.
EO 12898 also called for the establishment of an Interagency Working
Group on Environmental Justice (EJ IWG), which is chaired by the EPA
Administrator. EPA worked the White House Council on Environmental
Quality (CEQ) to reconvene the IWG in September 2010. In addition, EPA
has a number of federal partnerships established and initiatives underway
that support a holistic approach to addressing the environmental, social,
and economic burdens that impact communities. For example, EPA, the
U.S. Department of Housing and Urban Development, and the U.S.
Department of Transportation joined together to form the Partnership for
Sustainable Communities, an unprecedented agreement to coordinate
federal housing, transportation, and environmental investments; protect
public health and the environment; promote equitable development; and
help address the challenges of climate change. All federal agencies are
responsible for considering environmental justice issues in National
Environmental Policy Act (NEPA) environmental impact assessments and
enforcing Title VI of the Civil Rights Act.
r i a M a
Plan EJ 2014: Overview
18
-------
v°/EPA
Implementation Plan Summary
Goal
To facilitate the active involvement of all federal agencies in implementing
EO 12898 by minimizing and mitigating disproportionate negative impacts
while fostering environmental, public health, and economic benefits for
overburdened communities.
Strategies & Activities
Strategy 1: Assist other federal
agencies to integrate
environmental justice in their
missions, programs, policies, and
activities.
* Activity 1.1: Chair and convene
EJ IWG Principal, Deputy, and
Senior Staff meetings.
Activity 1.2: Chair, assist, and
oversee each agency's effort to
update or develop its
environmental justice strategy.
Activity 1.3: Lead the effort to
organize regional events.
Activity 1.4: Develop and
provide tools that help
environmental justice and other
stakeholders identify federal
information and resources.
Activity 1.5: Convene a group of
senior attorneys from across the
federal government to promote
the integration of environmental
justice into their agencies'
actions.
HUD-DOT-EPA Interagency Partnership for
Sustainable Communities
The Partnership for Sustainable Communities
is supporting an Environmental Justice
Showcase Communities project in Jacksonville,
Florida. This EPA program convenes federal
agencies, state and local government entities,
non-governmental organizations, and other
stakeholders to help underserved communities
shape their neighborhoods' futures with
comprehensive, locally appropriate solutions.
The agencies and stakeholders will support the
local partners as they establish a community
health center on a cleaned-up brownfield site
close to parks, community gardens, and other
amenities. The area has several Superfund and
brownfield sites and high rates of heart
disease, cancer, diabetes, asthma, and infant
mortality. The health center will work in
partnership with historically black colleges and
universities to provide training for health care
jobs and offer educational programs on healthy
living. The lessons learned through this and
other Environmental Justice Showcase
Communities pilots will help the Partnership
better use its resources to help underserved
communities build more sustainable
neighborhoods with better access to
opportunities; improved services and amenities;
and healthier places to live, work, and play.
Strategy 2: Work with other federal agencies to strengthen use of
interagency legal tools, i.e., National Environmental Policy Act (NEPA)
and Title VI of the Civil Rights Act of 1964.
National Environmental Policy Act
Activity 2.1: Articulate a consistent message about the need to
incorporate environmental justice into NEPA implementation.
Activity 2.2: Enable federal NEPA practitioners to enhance
consideration and execution of environmental justice requirements in
NEPA implementation.
Plan EJ 2014: Overview
19
-------
&EPA
Title VI of the Civil Rights Act of 1964
Activity 2.3: Consult with DOJ to strengthen the use of Title VI of the
Civil Rights Act of 1964 by reevaluating the approach for analyzing Title
VI complaints.
Activity 2.4: Collaborate with DOJ and within EPA, to develop
compliance strategies and actions to address non-compliance.
Strategy 3: Foster healthy and sustainable communities, with an
emphasis on equitable development and place-based initiatives.
* Activity 3.1: Recommend ways to enhance federal interagency
coordination in support of healthy and sustainable communities as well
as equitable development, in areas such as:
o Green Jobs and Clean Energy.
o Healthy and Sustainable Communities.
o Climate Change and Adaptation.
o Goods Movement.
Strategy 4: Strengthen community access to federal agencies.
* Activity 4.1: Conduct community needs inventory pilot.
Activity 4.2: Identify targeted training for communities.
Activity 4.3: Review results of Federal Partners Meeting.
Activity 4.4: Coordinate with Agency community-based coordination
efforts.
Plan EJ 2014: Overview
20
-------
v°/EPA
This section provides summaries of Plan EJ 2014's Tools Development
Areas and their implementation plans. These areas involve issues related
to science, law, information, and resources.
4-1
Building Scientific Capacity Among Tribal
Environmental Professionals
EPA has a long history of supporting capacity building
among tribal environmental professionals, primarily through
its partnership with the Institute for Tribal Environmental
Professionals (ITEP) at Northern Arizona University. The
Office of Air and Radiation (OAR) has supported this
project for over 15 years. Consistent with our trust
responsibility to tribes, OAR works with Tribes to increase
their capability to address their environmental concerns.
OAR supports the training and educational efforts of ITEP
in the areas of air quality and climate change impacts and
adaptation planning, as well as the work of the Tribal Air
Monitoring Support (TAMS) Center, which builds and
strengthens the technical capacity of tribal staff. The
TAMS Center cross-trains tribal air professionals on air
monitoring, indoor air quality, radon and asthma. EPA is
building on this model to develop an Environmental Justice
Community Learning Center.
Under Plan EJ 2014, EPA has committed to building a
strong scientific foundation for supporting
environmental justice and conducting
disproportionate impact analysis, particularly
methods to appropriately characterize and assess
cumulative impacts. These efforts will help to ensure
that EPA brings the best science to decision making
around environmental justice issues. The science and
research activities described in Plan EJ 2014 build
upon discussions and recommendations from EPA's
Science of Disproportionate Impacts Analysis
Symposium (March 17-19, 2010) and an
Environmental Justice Regulatory Analysis Technical
Workshop (June 9-10, 2010). The March 2010
Symposium was the principal event for the Agency to
identify science needs for environmental justice and
stimulate innovative research to meet those needs.
Implementation Plan Summary
Goal
To substantially support and conduct research that employs participatory
principles and integrates social and physical sciences aimed at
understanding and illuminating solutions to environmental and health
inequalities among overburdened populations and communities in the
United States.
Strategies & Activities
Strategy 1: Apply integrated transdisciplinary and community-based
participatory research approaches with a focus on addressing multi-
media, cumulative impacts, and equity in environmental health and
environmental conditions.
* Activity 1.1: Establish an Integrated Transdisciplinary Office of
Research and Development (ORD) Research Program on Environment
and Community Health, including the Sustainable and Healthy
Communities Research Program.
Activity 1.2: Develop technical guidance, analytic methods, tools and
data to advance the integration of environmental justice in EPA
decision making.
Plan EJ 2014: Overview
21
-------
&EPA
Strategy 2: Incorporate perspectives from community-based
organizations and community leaders into EPA research agendas and
engage in collaborative partnerships on science and research to address
environmental justice.
* Activity 2.1: Establish a Community Engagement Initiative.
Activity 2.2: Re-engage with the NEJAC.
Activity 2.3: Support Community-Based Participatory Research (CBPR).
Strategy 3: Leverage partnerships with other federal agencies on issues
of research, policy and action to address environmental and health
disparities.
* Activity 3.1: Join the Federal Collaboration on Health Disparities.
Activity 3.2: Engage with President's Task Force on Environmental
Health Risks and Safety Risks to Children.
Strategy 4: Build and strengthen the technical capacity of Agency
scientists on conducting research and related science activities in
partnership with impacted communities and translating research results
to inform change.
Activity 4.1: Provide training to EPA scientists on CBPR.
Activity 4.2: Build social science capacity within ORD.
Activity 4.3: Develop Environmental Justice Risk
Management Training for the Office of Pesticide Programs
(OPP).
Strategy 5: Build and strengthen technical capacity of community-based
organizations and community environmental justice and health leaders to
address environmental health disparities and environmental
sustainability issues.
* Activity 5.1: Build community capacity to address asthma disparities.
Activity 5.2: Build tribal community capacity to monitor air quality.
Activity 5.3: Increase citizen participation in science and decisions.
Activity 5.4: Establish Centers of Excellence on Environment and
Health Disparities.
Activity 5.5: Build diverse environmental workforce and enhance the
capacities of Minority Academic Institutions (MAI) to engage in
scientific research and workforce training.
Plan EJ 2014: Overview
22
-------
&EPA
The Office of General Counsel (OGC) is working with the programs and
regions to identify opportunities to utilize EPA's statutory authorities to
advance environmental justice. Our vision is that the Agency will use law
as a tool to advance environmental justice. OGC's advice will help EPA to
implement forward-leaning environmental justice policies with acceptable
legal risk and to identify new opportunities to promote their environmental
justice policy objectives.
Implementation Plan Summary
Using the National Environmental Policy Act to
Address Environmental Justice
The National Environmental Policy Act (NEPA) is an important tool
that can be used to advance the goals of environmental justice. A
1994 Executive Order requires that all federal agencies identify and
address disproportionately high and adverse human health or
environmental impacts on minority, low-income and tribal
populations. In April 2011, the Assistant Administrator of the EPA's
Office of Enforcement and Compliance Assurance reemphasized
those requirements in a memo urging EPA offices across the country
to enhance efforts to consider environmental justice in fulfilling their
NEPA responsibilities.
EPA is required to review all Environmental Impact Statements (EIS)
drafted by federal agencies and to make those reviews public, as
mandated under Section 309 of the Clean Air Act. This review
responsibility puts the EPA in a unique position to monitor how well
Federal agencies comply with the Executive Order. Furthermore, the
Presidential memo that transmitted the Executive Order states that
the EPA, "shall ensure that the involved agency has fully analyzed
environmental effects on minority communities and low-income
communities, including human health, social, and economic effects."
Goal
To provide legal assistance to EPA policy makers
and other Agency decision makers to advance
their environmental justice objectives and
achieve the Agency's vision of using the law as a
tool to advance environmental justice.
Strategy
OGC will accomplish its goal of providing legal
assistance to EPA policy makers and other
Agency decision makers to advance their
environmental justice objectives by providing
legal support to each cross-Agency Focus Area
workgroup. OGC's activities will promote a
sound legal framework for the tools and
programs developed by the five focus area
workgroups. OGC will conduct this activity
contemporaneously with the work of the five
cross-Agency Focus Areas.
Activities
Activity 1: Counseling attorneys will serve as workgroup members for
each cross-Agency Focus Area; these attorneys are drawn from OGC
and the Offices of Regional Counsel (ORC).
Activity 2: Regional Counsels and OGC Associate General Counsels will
convene regularly to identify legal issues and develop advice in support
of the five focus areas.
Activity 3: The EPA's General Counsel will provide active oversight,
direction, and decision making on all aspects of this initiative, in
consultation with EPA's Senior Leadership.
Activity 4: OGC will convene a group of senior attorneys from across
the federal government to promote the integration of environmental
justice into their agencies' actions.
Plan EJ 2014: Overview
23
-------
Tools to Identify Overburdened Populations
During the BP Oil Spill Response
The dynamic nature of the BP oil spill has been a
challenge for a range of communities along the Gulf -
from hotel operators to fishermen to local community
leaders. During cleanup activities, EPA and other
agencies used a variety of Geographic Information
Systems (GIS) tools to collect information, including
EJView and GeoPlatform.gov/gulfresponse. EPA
developed EJView, a public mapping tool, to get a
snapshot of environmental, health, and other social
factors that were affecting local communities.
GeoPlatform.gov/gulfresponse, an online tool developed
by the National Oceanic and Atmospheric Administration,
EPA, the U.S. Coast Guard, and the U.S. Department of
Interior, was used to gather close to real time information
about the response effort. These tools were used to
identify locations of overburdened communities in
comparison to areas of waste disposal, pinpoint locations
where oil had reached the shore, and identify locations of
community centers where people could get assistance.
4,3
EPA's programs and regions have developed a variety of internal screening
tools and other Geographic Information System (GIS) applications to
enhance environmental justice analysis and decision making to better meet
our responsibilities to protect public health under EO 12898. These
applications have played an important role as the Agency worked to
integrate environmental justice into its programs, policies and activities.
Under Plan EJ 2014, EPA is focused in an Agency-wide effort to develop a
nationally consistent environmental justice screening tool. In addition, EPA
is developing a suite of tools, data and services known as EPA's
GeoPlatform that will help coordinate and consolidate mapping activities,
applications, and data across the Agency. The GeoPlatform will support a
wide variety of uses across the Agency, including components of the
nationally consistent environmental justice
screening tool, and other data and applications that
may be of interest to environmental justice
stakeholders.
Implementation Plan Summary
Goal
To develop a more integrated, comprehensive,
efficient, and nationally consistent approach for
collecting, maintaining, and using geospatial
information relevant to overburdened
communities. EPA will accomplish this by: (1)
developing a common Agency-wide mapping
platform -the GeoPlatform, (2) creating a
nationally consistent environmental justice
screening tool, and (3) incorporating appropriate
elements of the screening tool into the
GeoPlatform.
Strategies & Activities
Strategy 1: Develop EPA's GeoPlatform.
* Activity 1: Develop prototype of the EPA Environmental Analyst for
review.
Activity 2: Develop production release of the EPA Environmental
Analyst.
Activity 3: Develop production release of the EPA GeoPlatform
(including initial data services) for use by Environmental Analyst and
other GeoPlatform components.
Plan EJ 2014: Overview
24
-------
&EPA
Strategy 2: Develop a nationally consistent environmental justice
screening tool.
* Activity 1: Hold regular staff workgroup and project steering
committee meetings.
Activity 2: Develop a set of options to present to Senior Agency
Officials.
Activity 3: Create a working prototype of screening tool.
Activity 4: Update the NEJAC on progress.
Activity 5: Obtain peer review and public comment on a prototype
tool.
Activity 6: Revise the tool based on comments.
Strategy 3: Incorporate appropriate elements of the screening tool into
the GeoPlatform.
* Activity 1: Review screening tool data, methods, and requirements to
determine which portions may be appropriate to include in the
GeoPlatform.
Activity 2: Incorporate appropriate elements of the prototype
screening tool into the GeoPlatform.
Activity 3: Revise GeoPlatform elements of the tool to be consistent
with changes made to the prototype tool in response to peer review
and public comments on screening tool.
4.4 Resources
Under Plan EJ 2014, the Office of Administration and Resource
Management (OARM) focuses on two components: (1) grants and technical
assistance to support community-based programs, and (2) workforce
diversity. With respect to grants and technical assistance, OARM seeks to
develop an efficient and effective system for delivering financial and
technical assistance to communities to empower them to improve their
health and environment. OARM's efforts advance the Administrator's
priority of Expanding the Conversation on Environmentalism and Working
for Environmental Justice by establishing a new paradigm for the delivery
of EPA assistance to minority, low-income, tribal, and indigenous peoples
to promote equitable development and create healthy and sustainable
neighborhoods. It also responds to the cross-Agency Focus Area under
Plan EJ 2014 of Supporting Community-Based Action Programs. With
respect to workforce diversity, OARM seeks to achieve an inclusive work
environment by developing an efficient system for the outreach and
recruitment of potential employees. When EPA recruits and
retains an inclusive workforce one that looks like the America it
serves and individual differences are respected, appreciated, and
valued, diversity becomes an organizational strength that contributes to
achieving results.
Plan EJ 2014: Overview
25
-------
&EPA
Implementation Plan Summary
Grants and Technical Assistance Goal
To develop an efficient and effective system for delivering financial and
technical assistance to communities to empower them to improve their
health and environment.
Strategies & Activities
Strategy 1: Increase transparency and efficiency in providing
community-based grant opportunities.
Community Action for a Renewed Environment
Grant Program
The Community Action for a Renewed Environment
(CARE) program is a competitive grant program that
provides on-the-ground support and funding to help
revitalize and improve the health of communities in
sustainable ways. Through CARE, various local
organizations, including non-profits, businesses, schools
and governments, create partnerships that create and
implement consensus-based local solutions to reduce
releases of pollutants and minimize people's exposure
to them. Through CARE, community leaders develop
expertise in sustaining partnerships and addressing
environmental issues, providing a strong basis for
continued future action as other environmental threats
emerge in the community. Since 2005, CARE has
provided over $14.5 million in financial assistance to 80
communities in 39 states and territories. CARE offers
two levels of financial assistance, up to $100,000 for
Level I and up to $300,000 for Level II grants.
* Activity 1.1: Draft recommendations for improving
community group access to EPA grant programs to be
presented to Executive Management Committee (EMC).
. Activitv 1.2: Solicit informal feedback from communities
. CARE p workshops)
v '6v 6 K ''
. Activity 1.3: Conduct outreach to Regions and NPMs via
conference calls and sharing of drafts.
Strategy 2: Improve delivery of technical assistance to
communities.
Develop Technical Assistance Center
Draft preliminary options to be presented
Activitv 2.1
approach.
Activity 2.2
to tne EMC
Activjtv23: obtajn senjor management guidance on
- ' - b b
initial concepts before obtaining informal feedback from
communities.
Activitv 2.4: Conduct outreach to Regions and NPMs via
conference calls and sharing of drafts.
Strategy 3: Strengthen grants training for communities.
* Activitv 3.1: Create umbrella, basic on-line grants training for
communities, environmental justice-specific on-line training, and
program-specific training (e.g., CARE, Urban Waters).
Activitv 3.2: Develop training modules.
Activitv 3.3: Obtain informal community feedback as modules
developed.
Activitv 3.4: Conduct outreach to the EPA grants management
community by providing opportunities for review of draft training
scripts.
Strategy 4: Improve community awareness of grant competition
process.
* Activitv 4.1: Develop and implement appropriate grant competition
tools (e.g., listservs, webinars).
Activitv 4.2: Obtain informal community input through
Regional/Headquarter websites.
Activitv 4.3: Work with region and NPMs to develop and implement
tools.
Plan EJ 2014: Overview
26
-------
Strategy 5: Revise grant policies that are unduly restrictive.
* Activity 5.1: Revise Delegation 1-86 and indirect cost rate policies for
environmental justice grants.
Activity 5.2: Establish simplified Indirect Cost Rate (ICR) policy.
Activity 5.3: Obtain informal community feedback once draft ICR policy
developed.
Activity 5.4: Conduct outreach to regions and NPMs by providing
opportunity to comment on draft policy issuance.
Activity 5.5: Explore simplification of other policies.
Strategy 6: Encourage Office of General Counsel/Office of Regional
Counsel/Program Office dialogue on community-based grant
opportunities.
* Activity 6.1: Conduct periodic OGC/ORC/Office of Environmental
Justice (OEJ) meetings and OGC guidance on scope of community-
based grant authorities.
Activity 6.2: Obtain OGC legal guidance on scope of grant authorities.
Activity 6.3: Coordinate discussions with larger OGC effort on existing
legal authorities.
Strategy 7: Improve timeliness ofBrownfields Grant Awards.
* Activity 7.1: Draft recommendations for consistent Brownfields award
times.
Workforce Diversity Goal
To achieve an inclusive work environment by developing an efficient
system for the outreach and recruitment of potential employees.
Strategies
Strategy 1: Increase the diverse pool of qualified applicants.
Strategy 2: Operate under a One EPA approach for recruitment and
outreach.
Activities
Activity 1: Design an efficient Agency-wide outreach strategy.
Activity 2: Develop effective marketing materials and strategy.
Activity 3: Develop a National Conference Toolkit.
Activity 4: Develop a National Outreach Calendar.
Plan EJ 2014: Overview 27
-------
&EPA
5.0 PROGRAM INITIATIVES
As indicated earlier, there are many programs at EPA that actively pursue
environmental justice goals or produce benefits for overburdened
communities. Examples of such initiatives include: Community
Engagement Initiative (Office of Solid Waste and Emergency Response),
Urban Waters (Office of Water), National Enforcement Initiatives (OECA),
Air Toxics Rules (OAR), and the U.S. Mexico Border Program (Office of
International and Tribal Affairs). Over the next year, EPA will designate at
least one initiative per appropriate program for inclusion in Plan EJ 2014.
In this way, many existing EPA initiatives can be tailored to better integrate
environmental justice into their programs and produce greater benefits for
overburdened communities. The identified initiatives may include those
developed to implement the Administrator's other priorities.
6.0 CIVIL RIGHTS
One effort already under way is implementing Administrator Jackson's
priority to improve EPA's civil rights program. Complying with EPA's
statutory civil rights obligations is a critical part of our efforts to advance
environmental justice. Administrator Jackson has made improving EPA's
civil rights program a priority. As part of this effort, EPA is pursuing long
overdue, vigorous, robust, and effective implementation of Title VI of the
Civil Rights Act of 1964 and other nondiscrimination statutes. EPA is
committed to protecting people from discrimination based on race, color,
or national origin in programs or activities that receive EPA's financial
assistance. In June 2011, the Administrator convened a workgroup of
senior management to assess OCR and EPA's overarching civil right
program. The workgroup is charged with making recommendations to
advance civil rights. The workgroup will look at revamping the civil rights
office, pursuing effective and timely responses to complaints, and
developing proactive compliance guidance and strategies. As the
recommendations are adopted, the agency will develop implementation
plans, take public comment and finalize the plans as part of EPA's annual
work plans under Plan EJ 2014.
7.0 CONCLUSION
Plan EJ 2014 is EPA's roadmap for integrating environmental justice and
civil rights into its programs, policies, and activities. Through Plan EJ 2014,
EPA intends to develop a suite of tools to advance such integration. It
seeks to build stronger relationships with communities overburdened by
environmental and health hazards and build partnerships that improve
conditions in such communities. In 2014, EPA will make an assessment of
its progress in achieving the goals of Plan EJ 2014. Based on this
assessment, EPA will produce a report on the accomplishments, lessons
learned, challenges, and next steps for continuing the Agency's efforts to
make environmental justice an integral part of every decision.
Plan EJ 2014: Overview
28
-------
&EPA
APPENDIX
Plan EJ 2014 Implementation Plans
Plan EJ 2014: Acronyms
29
-------
This page left blank intentionally
-------
&EPA
September 2011
Led by
Office of Chemical Safety and Pollution Prevention,
Office of Policy, Office of Research and Development,
Office of Environmental Justice, and Region 9
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans
33
-------
&EPA
Goals At-A-G lance
To more effectively
protect human health and
the environment for
overburdened populations
by developing and
implementing guidance on
incorporating
environmental justice into
EPA's rulemaking
process.
1.0 INTRODUCTION
Dirty air, polluted water, and contaminated land have significant effects on
the health and economic possibilities of the people who live in
overburdened communities. Administrator Jackson has called on the U.S.
Environmental Protection Agency (EPA) to develop policies that have a
measurable effect on the health and environment of overburdened
populations and communities. The Interim Guidance on Considering
Environmental Justice During the Development of an Action (Environmental
Justice in Rulemaking Guidance) and the associated development of
technical guidance for rulemaking activities, (Environmental Justice
Technical Guidance), are important tools for answering that call.
1.1 Goals
The goal of this implementation plan is to more effectively protect human
health and the environment for overburdened populations by developing
and implementing guidance for incorporating environmental justice into
EPA's rulemaking process. Specifically, this implementation plan will:
Elevate the interim Environmental Justice in Rulemaking on the
procedural aspects of environmental justice in rulemaking to final
status.
Establish and commence mechanisms to facilitate and monitor
implementation by National Program Managers (NPMs) and regional
offices of the Environmental Justice in Rulemaking Guidance to
maximize its effectiveness. NPMs lead the major EPA offices that are
responsible for developing regulations protecting air, water, land, and
ensuring chemical safety. EPA's regional offices also develop some
lower tier regulations and, therefore, also need to implement the
guidance.
Develop technical guidance on how to conduct environmental justice
assessments of rulemaking activities within analytical and decision-
making frameworks used by EPA to support regulatory development
(e.g., exposure assessment, benefit-cost analysis).
Successful implementation of this plan will significantly advance the
Agency's commitment to the goals of environmental justice in EPA's
rulemaking work to protect human health and the environment.
Issuing the Environmental Justice in Rulemaking Guidance as an interim
final document in July 2010 represented a historic accomplishment,
conveying EPA's commitment to consider environmental justice concerns in
the rulemaking process for the first time in EPA's history. It represents one
of the Agency's most important and publically visible endeavors. The
Environmental Justice in Rulemaking Guidance provides specific, detailed
instructions for steps that should be taken procedurally to fulfill this
commitment through EPA's rule writing process, formally known as the
Action Development Process (ADP). It provides information to rule writers
on when during the ADP to consider environmental justice, as well as the
Plan EJ 2014: Appendix, Implementation Plans
34
-------
&EPA
types of questions to ask. It outlines multiple steps that every EPA program
office can take to incorporate the needs of overburdened populations and
communities into its decision making, scientific analysis, and rule
development. Complementary to the Environmental Justice in Rulemaking
Guidance is the Environmental Justice Technical Guidance. This guidance
will provide technical direction to EPA analysts to aid them in incorporating
environmental justice into the development of risk assessment, economic
analysis, and other scientific input and policy choices during the
development of a rule.
1.2
Distinct organizational structures are being employed under each goal of
this implementation plan:
Leadership for finalizing the Environmental Justice in Rulemaking
Guidance is being provided by the Office of Chemical Safety and
Pollution Prevention (OCSPP), which has reconvened the Agency-wide
Environmental Justice in Rulemaking Workgroup and its Process
Guidance Subgroup. The final guidance documents developed by the
workgroup, and associated issues requiring senior management
attention, are raised first with the Principals for this effort - the Deputy
Assistant Administrators (DAAs) or Deputy Regional Administrators
(DRAs) for OCSPP, Office of Policy (OP), Office of Enforcement and
Compliance Assurance (OECA), Region 9; and the Associate Assistant
Administrator for Environmental Justice - and then elevated to the
Environmental Justice Committee (EJC) and the Executive Management
Council (EMC) prior to being presented to the Administrator for final
approval.
An Executive Steering Committee (ESC) comprised of senior executives
from OCSPP, OP, OECA, the Office of Environmental Justice (OEJ), the
Office of Research and Development (ORD), the Office of Air and
Radiation (OAR), the Office of Water (OW), the Office of Solid Waste
and Emergency Response (OSWER), and Region 9; along with the
Associate Assistant Administrator for Environmental Justice, will
oversee the implementation, facilitation, and monitoring efforts.
Those efforts are expected to continue after the guidance documents
are finalized to promote continuous learning and improvement and to
ensure effective implementation.
1 The Environmental Justice Technical Guidance is being developed as a
Tier 1 action under the ADP by an Agency-wide workgroup chaired by
OP, OEJ, and ORD. As a Tier 1 action, the Administrator or her
designee is the decision maker at each stage of the ADP.9 This
workgroup is a subcommittee of the Environmental Justice in
Rulemaking Workgroup.
9 EPA's regulatory development process utilizes a system of "tiering" to prioritize actions in terms of
their potential for large and multimedia effects and ensures early involvement of key Agency personnel.
Each regulatory action is assigned one of three tiers. Tier 1 denotes the Administrator's Priority
Actions, which are the few top actions that demand ongoing involvement of the Administrator and
extensive involvement of Assistant Administrators and Regional Administrators across the Agency.
Plan EJ 2014: Appendix, Implementation Plans 35
-------
v°/EPA
,:"
Strategies to achieve the goals of this plan are specific to each goal:
Strategy 1: Finalize the Interim Guidance on Considering Environmental
Justice During the Development of an Action.
* Assess internal and external comments provided on the interim
Environmental Justice in Rulemaking Guidance through Agency
websites.
Evaluate documents produced by rule-writing workgroups since the
Interim Guidance was released to assess the extent to which the
guidance is being addressed and its effect on EPA's rulemaking
decisions.
Interview members of rule-writing workgroups, their supervisors, and
their senior managers to assess the clarity and usefulness of the
guidance and the burdens associated with its implementation; and
obtain suggestions for improvement.
Revise the Environmental Justice in Rulemaking Guidance for
presentation to and approval by the EMC, its EJC, and the
Administrator.
Strategy 2: Facilitate and monitor implementation of guidance on
incorporating environmental justice in rulemaking.
* Work with the National Program Managers (NPM) and regions, which
are primarily responsible for incorporating environmental justice in
their own rulemaking efforts.
Provide training to rule-writing teams, their managers, and decision
makers.
Initiate a continuous learning effort to identify effective practices and
lessons learned from the NPMs' ongoing rulemaking efforts.
Develop and commence implementing a monitoring scheme to assess
the extent to which the guidance is being applied, the resources being
devoted to its application, and the effect it is having on rulemaking
decisions.
Strategy 3: Develop technical guidance on how to conduct
environmental justice assessments of rulemaking activities.
* Develop draft technical guidance through an Agency-wide ADP
workgroup.
Establish and conduct a peer consultation on the Draft Environmental
Justice Technical Guidance with a special panel of EPA's Science
Advisory Board (SAB).
Plan EJ 2014: Appendix, Implementation Plans 36
-------
&EPA
Execute an outreach strategy to obtain internal and external comments
on the Draft Environmental Justice Technical Guidance.
Incorporate SAB, EPA, and external comments in developing the Final
Environmental Justice Technical Guidance for approval by the
Administrator.
2.2
The following activities are intended to carry out the strategies identified
for this implementation plan.
Strategy 1: Finalize the Interim Guidance on Considering Environmental
Justice During the Development of an Action.
* Activity 1.1: Announce April closure of public comment period via the
Environmental Justice listserv.
o Time Frame: Completed in April 2011.
Activity 1.2: Review internal and external comments provided during
the implementation period when the guidance is in interim status.
o Time Frame: July 2011.
Activity 1.3: Review documents produced by and interview members
of the EPA rule-writing workgroups.
o Time Frame: October 2011.
Activity 1.4: Revise and release Final Environmental Justice Rulemaking
Guidance document.
o Time Frame:
>^ Draft to OCSPP, OP, and OAR Principals by end of
October 2011.
>^ Draft to EJC by mid-November 2011.
>^ Draft to ESC by end of November 2011.
S Draft to Administrator by mid-December 2011.
S Release by end of December 2011.
Strategy 2: Facilitate and monitor implementation of guidance on
incorporating environmental justice into rulemaking.
* Activity 2.1: Distribute model training presentations to Agency, NPM,
and region-specific regulation development and ADP trainers.
o Time Frame: June 2011.
Activity 2.2: Initiate a continuous learning effort to identify effective
practices and lessons learned from the Agency's ongoing rulemaking
efforts.
o Time Frame: September 2011.
Activity 2.3: Develop and commence implementing a monitoring
scheme to assess the extent to which the guidance is being applied, the
resources being devoted to its application, and the effect it is having on
rulemaking decisions.
o Time Frame: December 2011.
Plan EJ 2014: Appendix, Implementation Plans 37
-------
&EPA
Strategy 3: Develop technical guidance on how to conduct
environmental justice assessments ofrulemaking activities.
* Activity 3.1: Establish a cross-Agency Environmental Justice Technical
Guidance Workgroup.
o Time Frame: Completed in February 2010.
Activity 3.2: Tier the Environmental Justice Technical Guidance as a
Tier 1 Action in the ADP.
o Time Frame: Completed in November 2010.
Activity 3.3: Develop draft technical guidance on incorporating
environmental justice in rulemaking.
o Time Frame: FY 2012.
Activity 3.4: Conduct internal and external review of draft technical
guidance on incorporating environmental justice in rulemaking.
o Time Frame: FY 2012/2013.
Activity 3.5: Develop and release final technical guidance on
incorporating environmental justice in rulemaking.
o Time Frame: FY 2013.
i ' i and
The following items constitute key community engagement and
stakeholder outreach activities for this implementation plan.
Consultations at regularly scheduled National Environmental Justice
Advisory Council meetings and conference calls.
Solicitation of internal and external comments on draft guidance
documents via established websites.
Engagement of state, tribal, and local governments through consortia
and direct contact, to the extent possible.
Coordination with outreach activities of other Plan EJ 2014 initiatives.
Technical briefings and consultation with a special panel of the EPA
Science Advisory Board.
Consultations at regularly scheduled Children's Health Protection
Advisory Committee (CHPAC) meetings.
Consultations at regularly scheduled technical conferences and
meetings.
Interim final and draft guidance documents will be revised as part of a
process of elevating them to final status and may be subsequently revised
based on experience and lessons learned during implementation.
Plan EJ 2014: Appendix, Implementation Plans 38
-------
&EPA
3.0 DELIVERABLES
1 ACTIVITIES
Develop Final
Environmental Justice
in Rulemaking
Guidance.
Facilitate and monitor
implementation of the
Environmental Justice
in Rulemaking
Guidance.
Develop Draft and Final
Environmental Justice
Technical Guidance.
DELIVERABLES MILESTONES
Report on Summarizing
Internal and External
Comments, Rule-Writing
Documentation Assessment,
and Experiences of EPA
Rule-Writers in Implementing
Interim Final Guidance.
* Draft Final Guidance on
Considering Environmental
Justice During the
Development of an Action.
* Final Guidance on
Considering Environmental
Justice During the
Development of an Action.
* Distribute model training
presentations to Agency,
NPM, and regional regulation
development and ADP
trainers.
Initiate a continuous learning
effort to identify effective
practices and lessons learned
from the Agency's ongoing
rulemaking efforts.
Develop and commence
implementing a monitoring
scheme to assess the extent
to which the guidance is
being applied, the resources
being devoted to its
application, and the effect it is
having on rulemaking
decisions.
Draft Final Technical
Guidance on Considering
Environmental Justice During
the Development of an
Action.
* October
2011
November
2011
December
2011
June 2011
October
2011
December
2011
FY2013
Plan EJ 2014: Appendix, Implementation Plans
39
-------
v°/EPA
The milestones established in Section 3.0 above are the performance
measures which will be used to track progress in implementing this plan.
These milestones may be augmented by more detailed interim milestones
as they are established. Implementation of the guidance documents to be
developed under this plan may support development of future outcome
and activity measures.
Reporting on progress in implementing this plan will take place on an
ongoing basis when its scheduled deliverables are completed. Annual
progress reports will be provided and updates to this implementation plan
will be made at that time. For information, please contact Mike Burns,
202-564-8273, Burns.Mike@epa.gov: or Kelly Maguire, 202-566-2273,
Maguire.Kelly@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 40
-------
&EPA
September 2011
Led by
Office of Air and Radiation, Office of General Counsel,
and Region 1
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans 41
-------
&EPA
Goals At-A-G lance
To enable overburdened
communities to have full
and meaningful access to
the permitting process
and to develop permits
that address
environmental justice
issues to the greatest
extent practicable under
existing environmental
laws.
1.0 INTRODUCTION
The intent of Plan EJ 2014: Considering Environmental Justice in Permitting
(Environmental Justice Permitting Initiative) is to ensure that
environmental justice concerns are given as full consideration as possible in
the decision to issue a permit and the terms of the permits issued under
existing federal environmental laws. It contemplates a focus on both U.S.
Environmental Protection Agency (EPA)-issued permits, as well as permits
issued pursuant to existing federal environmental laws (i.e., federal, state,
local, or tribal). The Environmental Justice Permitting Initiative seeks to
identify the best current opportunities for taking environmental justice
concerns into consideration and to enable EPA to address the complex
issue of cumulative impacts from exposure to multiple sources and existing
conditions that are critical to the effective consideration of environmental
justice in permitting.
The proposed activities outlined in this implementation plan rely heavily on
the advice and recommendations presented by the National Environmental
Justice Advisory Council (NEJAC) from both their most recent response to
EPA's permitting charge and numerous relevant prior NEJAC reports. EPA
recognizes that there has been a considerable amount of work -
particularly on the NEJAC's part - advocating for earlier and more effective
public participation in the permitting process, but that these practices have
not been widely adopted. We also recognize that although environmental
justice can be incorporated into the permitting process in a variety of ways,
there are significant challenges - particularly related to cumulative/multi-
media impacts. We therefore seek to truly create a culture within EPA -
and among other federal, state, local, and tribal permitting agencies - in
which engaging on issues of environmental justice more readily translates
into greater protections for overburdened communities.
EPA's implementation plan merely describes our process for the
Environmental Justice Permitting Initiative, with a focus on activities for
2011 and early 2012. Our proposed deliverables for this time period are a
cohesive suite of tools for EPA-issued permits (for example, EPA guidance
on enhanced early public participation) along with a public database of
many other tools to serve as a resource for EPA, other federal agencies,
states, local government, tribal governments, facilities, non-profit
organizations, and communities. This larger database of tools will also
serve as a starting point for our 2012-2014 activities. We are defining
"tools" broadly to include not only guidance, but also best practices,
templates, reports, checklists, case studies, mapping and screening tools,
protocols, trainings, sample language, and other resources.
Appendix A of this document contains our initial draft list of potential tools,
but the list is neither prescriptive nor exhaustive. Over the next few years,
we may decide not to develop some of these potential tools; similarly, we
may decide to add new potential tools to the list as we continue to gather
Plan EJ 2014: Appendix, Implementation Plans
42
-------
&EPA
ideas and suggestions. Throughout the process, however, we will be
listening to the ideas and experiences of all interested stakeholders, in
order to leverage the successes and seize on the good work that is already
occurring on this topic.
The overarching goals of this Plan are to enable overburdened
communities to have full and meaningful access to the permitting process
and to develop permits that address environmental justice issues to the
greatest extent practicable.
To achieve our goals, the Environmental Justice Permitting Initiative will
"[i]dentify and develop tools to support the consideration of environmental
justice during implementation of permitting programs" to reduce
"exposures for those at the greatest risk," as stated in the Fiscal Year (FY)
2011-2015 EPA Strategic Plan, Cross-Cutting Fundamental Strategy:
Working for Environmental Justice and Children's Health (Strategic Plan).10
Our goals help to fulfill:
Executive Order 12898, "Federal Actions to Address Environmental
Justice In Minority Populations and Low-Income Populations," which
tasks each federal agency with "achieving environmental justice as part
of its mission by identifying and addressing, as appropriate,
disproportionately high and adverse human health or environmental
effects of its programs, policies, and activities on minority populations
and low-income population."11
The Administrator's priority of Expanding the Conversation on
Environmentalism and Working for Environmental Justice, which
heralds "a new era of outreach and protection for communities
historically underrepresented in EPA decision making" and calls for
"including] environmental justice principles in all of our decisions."12
EPA's mission to protect human health and the environment.
1
The success of this Environmental Justice Permitting Initiative will depend
on participation from many offices within EPA, both at Headquarters and
the regions, as well as numerous external stakeholders (see Section 2.3,
Community Engagement and Stakeholder Outreach).
10 U.S. Environmental Protection Agency, FY 2011-2015 EPA Strategic Plan: Achieving Our Vision,
September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html.
11 Clinton, William J., Executive Order 12898, "Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations," February 11, 1994, Federal Register 59, No. 32:
7629.
12 Jackson, Lisa P., "Seven Priorities for EPA's Future." January 12, 2010. Available at:
http://blog.epa.gov/administrator/2010/01/12/seven-priorities-for-epas-future/.
Plan EJ 2014: Appendix, Implementation Plans 43
-------
&EPA
The Office of Air and Radiation has been designated the Headquarters lead.
The Office of General Counsel has agreed to act as co-lead. Region 1 is the
Lead Region. Staff and managers from these three offices, with guidance
from the Office of Enforcement and Compliance Assurance/Office of
Environmental Justice, have formed a Steering Committee to manage the
Environmental Justice Permitting Initiative.
The Steering Committee is chaired by the Principal Deputy Assistant
Administrator, Office of Air and Radiation; the Associate General Counsel,
Cross-Cutting Issues Law Office, Office of General Counsel; and the Deputy
Regional Administrator, Region 1.
The Environmental Justice Permitting Initiative has a small group composed
of key senior EPA Headquarters and regional leaders (Senior Leaders) to
provide high level recommendations as well as a cross-Agency workgroup
of EPA Headquarters and regional staff to do the work. The workgroup
contains staff from every EPA region, as well as staff from the Office of Air
and Radiation, the Office of Enforcement and Compliance Assurance, the
Office of Environmental Information, the Office of General Counsel, the
Office of International and Tribal Affairs, the Office of Research and
Development, the Office of Solid Waste and Remediation, and the Office of
Water.
Staff support for the Environmental Justice Permitting Initiative is provided
the Office of Policy Analysis and Review, Office of Air and Radiation.
Plan EJ 2014: Appendix, Implementation Plans 44
-------
v°/EPA
2.0
The strategies and activities outlined below describe the charge to the
Environmental Justice Permitting Workgroup over the next several years.
In the meantime, we strongly encourage offices and individuals at EPA and
external to the Agency to continue their ongoing practice of furthering
integration of environmental justice into the permitting process (e.g.,
regional review of state permits). Indeed, we encourage offices and
individuals to share new issues, potential tools, and recommendations with
the workgroup and communicate lessons learned.
"-IS
Strategies to achieve the goals of this implementation plan are specific to
each goal:
Strategy 1: Develop tools that will enhance the ability of overburdened
communities to participate fully and meaningfully in the permitting
process.
These tools will focus on ensuring that overburdened communities are fully
informed about the potential impacts of permitted activities and
understand the information they receive. In addition, we will explore ways
of promoting regular dialogue between overburdened communities and
the regulated facilities at all stages of the permitting process, including
early involvement, and after a permit has been issued.
Strategy 2: Concurrently with Strategy 1, develop tools to assist
permitting authorities to meaningfully address environmental justice in
permitting decisions.
These tools will focus on how environmental justice can be incorporated
into the permitting process, including the range of potential permitting
measures that can be used to avoid or reduce potential environmental
justice effects.
Strategy 3: Implement these tools at EPA and work with others to do the
same.
We will first focus on implementing tools related to EPA-issued permits.
Thereafter, we will engage in supporting and encouraging other federal
agencies, as well as state, local, and tribal permitting authorities, to
develop environmental justice strategies for their environmental
permitting decisions.
Plan EJ 2014: Appendix, Implementation Plans 45
-------
&EPA
2.2
All of the activities below support our goal to develop and implement tools
to better enable overburdened communities to have full and meaningful
access to the permitting process and for permits to address environmental
justice issues to the greatest extent practicable. These tools include
guidance, best practices, templates, reports, checklists, case studies,
mapping and screening tools, protocols, trainings, and sample language.
Activity 1: Conduct initial internal research to begin to create a
preliminary list of potential tools and finalize the implementation plan
(March-June 2011, Completed).
* Activity 1.1: Conduct an initial literature review - including a review of
previous NEJAC papers, publications, and other recommendations -to
identify an initial list of existing and needed tools (Completed, see
Appendix A).
Activity 1.2: Convene a cross-Agency workgroup. The workgroup met
for the first time on March 7, 2011, and will carry out the proposed
activities in this implementation plan (Completed).
Activity 1.3: Review and evaluate the permitting process for a
minimum of three federal permits with environmental justice
considerations, for use as case studies to identify existing and needed
tools13 (Completed). The workgroup reviewed the permitting process
for three federal permits and will continue to review other permits to
solicit lessons learned and guide our next steps.
Activity 1.4: Coordinate overlapping strategies with other Plan EJ
2014 elements and consider integrating and leveraging activities
between them (Ongoing).
Activity 1.5: Issue the final implementation plan (Completed).
Activity 2: Solicit initial existing and recommended tools from internal
and external stakeholders (March-June 2011).
Individual EPA programs and regions, as well as other federal agencies,
states, local agencies, and tribal governments, have already developed and
implemented numerous tools that consider environmental justice issues
during the permitting process. These entities as well as community and
advocacy groups, industry and trade organizations, and experts have first-
hand experience and knowledge about the relevant issues and ideas for
what tools are needed. Outreach to these experts provides the workgroup
an important opportunity to gather the tools and begin to identify the most
effective and replicable ones.
In addition to reviewing all of the comments submitted during the formal
public comment period (which ended Friday, April 29, 2011), the
workgroup solicited additional comments via an external e-mail and an
13 The Strategic Plan charges the Environmental Justice and Permitting Initiative to "Convene a cross-
Agency workgroup on the consideration of environmental justice in federal EPA permits and review, at
a minimum, three federal permits with environmental justice considerations (by September 2011)."
Plan EJ 2014: Appendix, Implementation Plans 46
-------
&EPA
internal EPA memo focused on collecting ideas for tools and informative
case studies. From these responses, we followed up with individuals and
organizations to get more detailed information and comments. We also
conducted targeted outreach to national umbrella groups via meetings,
conference calls, and direct emails; and hosted a series of public listening
sessions in June 2011. Finally, we set up a NEJAC Permitting Workgroup
that has already met three times to provide guidance throughout our
process; and we will continue to gather information from all stakeholders
and involve them in our work.
Activity 3: Create an initial list of priority tools and corresponding
deliverablesfor Year 1 (June 2011).
Activity 4: Develop, test, and finalize priority tools for EPA-issued permits
(June 2011-April 2012).
* Activity 4.1: Develop priority tools, amend existing tools, and identify
those ready for potential immediate use at EPA (June-October 2011).
Activity 4.2: Identify opportunities to test the draft tools through
ongoing permit activities (June-October 2011).
Activity 4.3: Solicit comments both internally and externally on the
draft tools (October 2011-February 2012).
Activity 4.4: Incorporate comments and finalize tools (April 2012).
Activity 5: Determine the bestformat(s) or vehicle(s) to convey and
implement the final tools (guidance, policy, rulemaking, etc.) (December
2 01 I/early 2012).
Activity 6: Create a more detailed timeline for 2012-2014 deliverables
for the workgroup (early 2012).
Per Activity 5, we intend to finalize the first suite of tools by early 2012.
We will then focus on implementing these tools for EPA-issued permits via
trainings and other efforts to test, revise, and institutionalize their use at
EPA (while also looking for additional opportunities to develop more tools).
In 2012-2014, our anticipated activities may include:
Implement first suite of tools via trainings at EPA.
Implement "train-the-trainers" seminars to help train community
organizations and other interested entities on newly developed tools.
Continually review the effectiveness of the tools and trainings, update
and revise existing tools, develop additional tools, and update and
revise trainings.
Engage in supporting and encouraging other federal agencies as well as
state, local, and tribal permitting authorities to achieve environmental
justice goals for their permit decisions.
Plan EJ 2014: Appendix, Implementation Plans 47
-------
&EPA
The workgroup, with assistance from the Small Business Ombudsman and
the Office of Environmental Justice, has developed a plan for early and
continued stakeholder involvement. Our efforts will include public
comment periods, requests for information, meetings, conference calls,
and direct and targeted outreach to internal and external experts and
stakeholders to seek their early and continued input. Activity 2, above,
describes the workgroup's efforts to date, including public listening
sessions conducted in June 2011 and the formation of a NEJAC Permitting
Workgroup to provide guidance throughout our process.
Because of the states' unique and important role in permitting, EPA has
emphasized, and will continue to emphasize, early and ongoing outreach to
state environmental departments to collect their success stories and
lessons learned. EPA will work with them to identify potential
opportunities to test draft tools (see Activity 4.2) and specifically seek out
their comments and suggestions (see Activity 4.3).
EPA also welcomes comments and participation from all stakeholders and
has already reached out to these stakeholder groups as well as others:
Association of State and Interagency Working Group on
Territorial Solid Waste Environmental Justice.
Management Officials .... . ... , ,
National Association of Clean Air
ASTSWMO . . . ,MA/~AM
v ' Agencies (NACAA).
Association of State & Interstate ., .. . . . .. , _.
National Association for Clean
Water Pollution Control ... . . . /.,.,,.,,.»
Water Agencies (NACWA).
Administrators (ASIWPCA).
National Tribal Operations
Business organizations and trade _ .^ ,*,-r~^
b Committee (NTOC).
associations.
North American Hazardous
Clean Air Act Advisory Committee *,*.-,*,
Matena s Management
(CAAAH
^ ;" Association (NAHMMA).
Community advocacy groups. ., ^ J..., ^ .,
y y & K . Northeast Waste Management
Environmental Council of the Officials'Association (NEWMOA).
States (ECOS). _iU , , . . , ^ ^
Other federal agencies and state,
Ground Water Protection Council local, and tribal permitting
(GWPC). agencies.
We will also reach out to these key stakeholder groups in the near future:
Asian American Native American Pacific Islanders Servicing Institutions
(AANAPISIs).
Hispanic Servicing Institutions (HSIs).
Historical Black Colleges and Universities (HBCUs).
Tribal Colleges and Universities (TCUs).
Plan EJ 2014: Appendix, Implementation Plans 48
-------
&EPA
3.0 DELIVERABLES
ACTIVITIES
Activity 1.1: Conduct an initial
literature review - including a
review of previous NEJAC
papers, publications, and other
recommendations - to identify
an initial list of existing and
needed tools.
Activity 1.2: Convene a cross-
Agency workgroup.
Activity 1.3: Review and
evaluate the permitting process
fora minimum, of three federal
permits with environmental
justice considerations, for use
as case studies to identify
existing and needed tools.
Activity 1.4: Coordinate
overlapping strategies with
other Plan EJ 2014 cross-
Agency elements and consider
integrating and leveraging
activities between them.
Activity 1.5: Issue the final
implementation plan.
Activity 2: Solicit existing and
recommended tools from
internal and external
stakeholders.
Activity 3: Create an initial list
of priority needed tools and
corresponding deliverables for
Year 1 .
Activity 4.1 : Develop priority
tools, amend existing
resources, and identify those
ready for potential immediate
use at EPA.
Activity 4.2: Identify
opportunities to test the draft
tools through ongoing permit
activities, and solicit comments
and recommendations.
DELIVERABLES MILESTONES
See Appendix A.
The workgroup met for
the first time on March 7,
2011, and will continue
to meet throughout the
duration of this project.
Identification of a
minimum of three federal
permits with
environmental justice
considerations.
List of existing and
needed tools from the
case studies.
Regular meetings with
other cross-Agency
workgroups.
Final implementation
plan.
List of existing and
needed tools from
internal and external
stakeholders.
Initial list of tools and
corresponding
deliverables for Year 1 .
Initial suite of draft tools.
Comments and
recommendations based
on our initial testing of
the draft tools.
Completed
Completed
Completed
Completed
Ongoing
Completed
June 2011
June 2011
October
2011
October
2011
Plan EJ 2014: Appendix, Implementation Plans
49
-------
&EPA
ACTIVITIES
Activity 4.3: Solicit additional
comments both internally and
externally.
DELIVERABLES MILESTONES
Additional comments.
February
2012
Activity 4.4: Incorporate
comments and finalize tools.
Revised tools.
April 2012
Activity 5: Determine the best
format(s) or vehicle(s) to
convey and implement the
recommendations and tools
(finalization, policy, rulemaking,
etc.).
Decision on how best to
convey and implement
the tools.
Early 2012
Activity 6: Create a more
detailed timeline for 2012-2014
deliverables for the workgroup.
More detailed timeline that
may include:
Implement first suite of
tools via trainings at
EPA.
Implement "train-the-
trainers" seminars to
help train community
organizations and other
interested entities on
newly developed tools.
Continually review the
effectiveness of the tools
and trainings, update
and revised existing
tools, develop additional
tools, and update and
revise trainings.
Engage in supporting
and encouraging other
federal agencies as well
as state, local and tribal
permitting authorities to
achieve environmental
justice goals for their
permit decisions.
2012
4.0 REPORTING
We will report annually on progress in implementing the strategies
outlined in this implementation plan and will update, as necessary, the
activities and deliverables outlined here. For information, please contact
Michelle Roos, 202-573-2549, Roos.Michelle@epa.gov
Plan EJ 2014: Appendix, Implementation Plans
50
-------
&EPA
ri
This implementation plan outlines a process by which the workgroup will
research, solicit ideas for, prioritize, and then develop a suite of tools to
better enable overburdened communities to have full and meaningful
access to the permitting process and for permits to address environmental
justice issues to the greatest extent practicable. For the first year, our
activities will focus on developing a cohesive suite of tools most applicable
to EPA-issued permits, and also collecting a larger set of tools for a public
database.
Our initial research, request for comments, meetings, conference calls, and
one-on-one conversations have revealed this list of potential tools for EPA-
issued permits, but the list is neither prescriptive nor exhaustive. Over the
next few years of the Environmental Justice and Permitting Initiative, we
may decide not to develop some of these potential tools; similarly, we may
decide to add new potential tools to the list as we continue to gather ideas
and suggestions. Below is merely a draft list in the early stages of our
multi-year process. Please note that some of the proposed tools might be
applicable only to specific permit types (e.g., Prevention of Significant
Deterioration [PSD], National Pollutant Discharge Elimination
System [NPDES], Resource Recovery and Conservation Act [RCRA], etc.):
Public Involvement/Communication
Environmental Justice and Permitting Enhanced Public Participation
Guidance (potentially with a strong recommendation for pre-
application public meetings).
Environmental Justice and Permitting Public Participation Fact Sheet
and Website in support of the above-mentioned guidance.
Environmental Justice and Permitting Public Participation Outreach
Template and Checklist in support of the above-mentioned guidance.
Updated and condensed guidance, best practices, and checklists for
effective means of conducting public outreach and notification,
potentially including:
o Public notifications outside of newspapers (multi-media press
releases and advertisements, use of internet and SMS, but not
exclusive reliance on such technologies).
o Documents written in plain language.
o Translations of documents in appropriate languages.
o Direct and targeted outreach to community organizations and
institutions.
o Making documents physically accessible and free to
communities.
o Proving per diem or other financial resources for community
members to attend meetings.
o Scheduling meetings during non-working hours.
o Providing third party attorneys and scientists as resources for
communities.
Plan EJ 2014: Appendix, Implementation Plans 51
-------
&EPA
o Periodic engagement and notification throughout the
permitting process, including when there are changes to the
scope of the permit application or when environmental studies
are taking place.
o Model processes to improve information flow between the
facility, community, and permitting authority.
Web-based, searchable, updated contact lists, by EPA region, of
community organizations and tribal government and indigenous
organizations to facilitate outreach.
Guidance on developing long-term communication protocols with
specific overburdened communities that reflect the communities'
preferences for how to receive information and provide feedback into
permitting decisions.
Decision tools to assist all parties in understanding the nature of
disproportionate impacts and mitigating effects of permitting
measures.
The development of an Environmental Justice Permit Social Network
site (a one-stop shop/central point of communication run by a permit
writer to gather all relevant background materials and better
communicate with stakeholders - via postings and Really Simple
Syndication [RSS] feeds).
Permit process descriptions of when, where, and how the public can
get involved.
Guidance on translation issues.
Guidance for facilities on creating a real dialogue with communities
early on in the process (potentially including identifying ways to talk
outside of permit actions, avoiding an adversarial relationship, and
suggestions for community benefit projects).
Guidance on how to communicate cumulative impacts and/or risk
assessments to the community.
Guidance for EPA on providing quarterly or other regular updates to
communities and organizations on environmental justice issues,
responses and actions taken, and trends.
Permit Process
Permit Checklist (possibly in different languages and in plain language).
Permit Process Flowchart (possibly including staff contact information
per region and media office).
Guidance including case studies on if/when, where and how to conduct
an environmental justice analysis or assessment and how to integrate
these into permit conditions, mitigation actions, and/or clean-up
activities outside of permitting.
Guidance on how environmental justice analyses/assessments can be
integrated into other existing assessment requirements for permitting.
Guidance on using existing and proposed EPA screening tools (including
EJScreen, EJView, Community-Focused Exposure and Risk Screening
Tool [C-FERST], Census Tract Ranking Tool for Environmental Justice
Plan EJ 2014: Appendix, Implementation Plans 52
-------
&EPA
[CenRANK], Environmental Justice Strategic Enforcement Tool [EJSEAT],
etc.) in the permitting process.
Guidance, methodology and/or tools to conduct cumulative impacts
analysis.
Guidance/protocols on integrated permitting approaches, including the
coordination of permitting actions, public comments periods, public
notices, meetings, and hearings per facility and/or community between
numerous permitting actions and/or across media.
Guidance/tools to conduct exposure-based (health effects) modeling
and assessments, and how to integrate those results into permits.
Best practices, guidance, and trainings on using a variety of existing
tools in new ways to better address environmental justice concerns
(best available control technology [BACT]; offsets; monitoring,
recordkeeping, and reporting; startups, shutdowns, and malfunctions
[SSMs]; lower potential to emit; AP-42 emissions factors,14 and Clean
Air Act Title V operating permit approvals).
Guidance based on lessons learned from watershed analysis processes
(total burden analysis, cross-media effects, etc.).
Permit Conditions - How to Integrate Environmental Justice
into Actual Permit Conditions
Best practices, guidance, and trainings on developing permits to
include issues important to local communities
Resources to facilitate and/or fund the placement of more fenceline
and community-based monitors in overburdened communities.
Best practices, guidance, trainings, and protocols on developing permit
conditions to better address and protect indigenous peoples' cultural
and subsistence resources.
Guidance on how to conduct traditional knowledge information
gathering and how to integrate that into permit conditions.
Protocols for factoring environmental justice into permit conditions,
regardless of the level of public participation.
Best practices, guidance, and trainings on minimizing issuance of
emergency permits.
Interagency and Government-to-Government Guidance and
Protocols
Guidance, protocols, and trainings for utilizing the role of the
Interagency Working Group for Environmental Justice to work across
federal agencies on permits on tribal lands.
Guidance on how to integrate government-to-government consultation
and environmental justice executive orders and expectations into
permitting processes.
An emissions factor is the formula EPA uses to calculate the emissions from key source categories.
AP-42 is the document EPA compiles the factors into. It is used by industry and states to develop
emissions inventories and project emissions from sources, usually in the permitting process to set
emissions limits.
Plan EJ 2014: Appendix, Implementation Plans 53
-------
&EPA
Guidance on developing partnerships with states that support more
direct collaboration with communities in the permitting process.
Guidance on assisting other federal agencies to integrate
environmental justice into their environmental permitting decisions.
Guidance on how to conduct joint processing agreements across
permitting authorities (including joint comment periods and hearings
to be held, and final permits to be issued on a cooperative basis).
Education/Training
Expansion of EPA environmental justice trainings, including:
o Environmental Justice Fundamentals.
o Environmental justice and permitting (for all media).
o Online trainings.
Community-based trainings, resources, and websites, including:
o Permitting processes (for all media).
o Preparing public comments.
o Environmental justice assessment or screening tools.
o Leadership development.
o Job skills relevant to local industry and facility needs.
o Advanced legal training on major statues.
A network of EPA experts accessible to the public, hotline of experts,
and/or on-line question-and-answer (Q&A) portal on issues of
importance to environmental justice and permitting.
Technical assistance resources.
A collective learning forum and regular national conference call(s) for
EPA staff and managers responding to specific permit challenges.
"Outside" of Traditional Permitting
Guidance and trainings on using resources and programs outside of
permitting including:
o Helping communities develop and adopt community-specific,
comprehensive environmental justice plans.
o Community Action for a Renewed Environment (CARE).
o Encouraging the creation of Supplemental Environmental
Project (SEP)-like mitigation projects (diesel retrofits, off-site
street sweeping, tree planting, landscaping, public playgrounds
and green spaces, etc.).
o Good Neighbor/Environmental Benefit Agreements.
o Performance Partnership Agreements.
o Memoranda of Agreement/Understanding involving EPA,
communities, facilities; and state, local, or tribal governments.
o Increasing and maintaining active listening, engagement, and
follow-up with communities outside of permitting actions.
o Creating plain language summaries of proposed or existing
permit-related regulations that have a greater impact on
overburdened communities, and/or a plain language guide for
Plan EJ 2014: Appendix, Implementation Plans 54
-------
&EPA
rulemaking with the purpose of educating citizens on how to
influence the rulemaking process in a meaningful way.
Cross-Cutting/Other
Environmental justice and permitting e-Library (i.e., an
online/searchable database of tools organized by key features to serve
as a resource to permit writers and the public looking for tools and
ideas that have been used successfully and could be replicated).
Guidance, trainings, and other resources on making better use of other
EPA roles, such as oversight, in which EPA affects how other permitting
authorities implement federal permitting requirements.
General and comprehensive guidance on how to incorporate
environmental justice into all aspects of permitting.
Plan EJ 2014: Appendix, Implementation Plans 55
-------
&EPA
September 2011
Led by
Office of Enforcement and Compliance Assurance
and Region 5
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans 56
-------
&EPA
Goals At-A-G lance
To fully integrate
consideration of
environmental justice
concerns into the planning
and implementation of
OECA's program
strategies, case targeting
strategies, and
development of remedies
in enforcement actions to
benefit overburdened
communities.
1.0 INTRODUCTION
This implementation plan sets forth goals, strategies, and activities to
advance environmental justice through compliance and enforcement,
under the U.S. Environmental Protection Agency (EPA)'s Plan EJ 2014. It
was developed by the Office of Enforcement and Compliance Assurance
(OECA) and EPA Region 5, as Lead Region for OECA for Fiscal Year (FY)
2011-13, in consultation with all EPA regions, the Office of Environmental
Justice, and the Office of General Counsel.
1.1 Goals
OECA and the EPA regions, in collaboration with other EPA offices and the
U.S. Department of Justice (DOJ), are committed to taking action to further
ensure that our most overburdened communities are given particular
consideration as we implement the Agency's enforcement and compliance
program. Through this implementation plan, we intend to focus and
accelerate our efforts to identify, assess, and address environmental justice
concerns in these communities when developing and implementing OECA's
program strategies, civil and criminal enforcement activities, and
compliance activities.
Our goal for the next three years is to fully integrate consideration of
environmental justice concerns into the planning and implementation of
OECA's program strategies, case targeting strategies, and development of
remedies in enforcement actions to benefit these communities. We also
plan to accelerate our ongoing efforts to communicate more effectively
with these communities about our enforcement actions and program
activities. Through these efforts, we hope to further advance the Agency's
environmental justice goals of fair treatment and meaningful involvement,
and to help address environmental justice concerns in overburdened
communities.
1.2 Organizational Structure
OECA and Region 5 (as OECA Lead Region) share responsibility for
developing this implementation plan. This work is co-chaired by OECA's
Principal Deputy Assistant Administrator and Region 5's Deputy Regional
Administrator. The co-chairs called upon OECA's standing Environmental
Justice Council, consisting of the Directors and/or Deputy Directors of all
OECA offices, the Lead Region Enforcement and Environmental Justice
Manager, and supporting staff to develop this plan. The Associate General
Counsel, Cross-Cutting Issues Law Office, Office of General Counsel,
participates regularly in the OECA Environmental Justice Council meetings
and has been of invaluable assistance in developing this plan.
Plan EJ 2014: Appendix, Implementation Plans
57
-------
&EPA
OECA and regional managers conducted an open discussion of this plan at
the January 26, 2011, Senior Enforcement Managers meeting in New
Orleans, Louisiana. Following that discussion, the draft plan was revised to
incorporate agreed-upon modifications and additions. OECA and all EPA
regions will use this implementation plan as a dynamic document, making
improvements as we learn through experience in implementation.
Plan EJ 2014: Appendix, Implementation Plans 58
-------
v°/EPA
- .".'
OECA has f\ve major strategies for Advancing Environmental Justice
through Compliance and Enforcement:
* Advance environmental justice goals through selection and
implementation of National Enforcement Initiatives.
Advance environmental justice goals through targeting and
development of compliance and enforcement actions.
Enhance use of enforcement and compliance tools to advance
environmental justice goals in regional geographic initiatives to address
the needs of overburdened communities.
Seek appropriate remedies in enforcement actions to benefit
overburdened communities and address environmental justice
concerns.
Enhance communication with affected communities and the public
regarding environmental justice concerns and the distribution and
benefits of enforcement actions, as appropriate.
2,2
Strategy 1: Advance environmental justice goals through selection and
implementation of National Enforcement Initiatives.
Background. Every three years, OECA selects a limited number of high
priority national environmental and compliance problems to address
through concentrated, nationwide enforcement efforts. In selecting these
areas of focus, OECA looks for important environmental and public health
problems that are caused, at least in part, by widespread failure of
regulated sectors to comply with federal environmental laws, where it
believes that a concentrated federal enforcement effort can make a
difference in correcting violations and reducing pollution. OECA and the
regions solicited input from state agencies to identify potential areas of
focus, and sought public comment on the final list of proposed candidates.
The selected areas of focus are called "National Enforcement Initiatives."
OECA has been, and continues to be, committed to taking environmental
justice factors into consideration when it selects and implements these
National Enforcement Initiatives. One of OECA's primary program goals is
to aggressively go after pollution problems that make a difference to
communities, and we place a high priority on benefits to overburdened
communities in selecting our National Enforcement Initiatives.
Plan EJ 2014: Appendix, Implementation Plans 59
-------
&EPA
Activity 1.1: Selection of National Enforcement Initiatives for FY 2011-
13. In 2010, OECA selected the following six National Enforcement
Initiatives for implementation in FY 2011-2013 after input from the
public, states, and tribes:
o Keeping raw sewage and contaminated stormwater out of our
nation's waters.
o Preventing animal waste from Concentrated Animal Feeding
Operations (CAFO) from contaminating surface and ground
waters.
o Cutting toxic air pollution that affects communities' health.
o Reducing widespread air pollution from the largest sources,
especially the coal-fired utility, cement, glass, and acid sectors.
o Reducing pollution from mineral processing operations.
o Assuring energy extraction sector compliance with
environmental laws.
In selecting these areas of focus, OECA gave significant weight to problems
that affect overburdened communities. For example, raw sewage
discharges from municipal sewer systems often affect poor and minority
communities by contaminating urban waters or causing sewage backups
into their homes. CAFOs are often located near poor rural communities,
and animal waste that gets into ground water can contaminate nearby
residents' drinking water supplies. Toxic air pollution can affect the health
of poor and minority communities that often are located closest to
industrial facilities with toxic air emissions. Widespread air pollution from
coal-fired power plants and other industries can travel long distances and
contributes to respiratory illnesses, such as asthma, that afflict poor and
minority populations and children. Large mineral processing facilities,
which can cause significant contamination of ground and surface waters
with hazardous waste, are often located near poor and minority
communities. Energy extraction activities, which often occur on or near
tribal lands in the west, can cause air or water pollution problems that
affect tribal communities.
Activity 1.2: Implementation of National Enforcement Initiatives for FY
2011-13. OECA will look for opportunities to address environmental
justice concerns as it implements the Agency's National Enforcement
Initiatives for FY 2011-13. A "Strategy Implementation Team,"
consisting of OECA Headquarters and regional representatives, is
responsible for developing implementation strategies and performance
measures for each of the National Enforcement Initiatives. Each
initiative's strategy will consider how environmental justice concerns
can be addressed in carrying out its activities, e.g., by giving priority in
case selection to overburdened communities affected by the pollution
problems we seek to address in each of the initiatives. In developing
remedies in our enforcement cases for the initiatives, we will seek
judicial and administrative remedies that will reduce or eliminate
pollution that may have a disproportionate effect on minority, low-
income, tribal and indigenous populations (see further discussion
Plan EJ 2014: Appendix, Implementation Plans 60
-------
&EPA
under Strategy 4 below). As of the date of the publication of this plan,
OECA has finalized the National Enforcement Initiative strategies and
measures.
Activity 1.3: Selection of National Enforcement Initiatives for FY 2014-
16. In 2013, OECA will call for nominations for the FY 2014-2016
National Enforcement Initiatives, with emphasis on those with
potential opportunities for addressing environmental justice concerns,
and will then select the new initiatives. As we have done previously,
OECA will solicit state input and public comment on the proposed FY
2014-2016 initiatives before they are selected.
Strategy 2: Advance environmental justice goals through targeting and
development of compliance and enforcement actions.
EPA will continue to place a high priority on addressing environmental
justice concerns as it develops the specific targeting and case selection
strategies for both National Enforcement Initiative cases and the many
other enforcement cases that EPA brings in FY 2011-13. As discussed
above, the Strategic Implementation Teams (SITs) for each National
Enforcement Initiative will identify opportunities to protect and benefit
overburdened communities when selecting and developing specific cases.
For example, when selecting specific CAFO facilities for enforcement
action, priority may be given to facilities that are affecting or threatening
the drinking water supplies of poor rural communities.
EPA will also give specific consideration and priority to environmental
justice concerns and overburdened communities when selecting
enforcement actions to address other important compliance problems,
regardless of whether they are part of a National Enforcement Initiative.
For example, in selecting enforcement actions to address violations of
drinking water standards, we will give high priority to addressing violations
at water supply systems that serve poor and tribal communities, as well as
children, one of the most vulnerable populations.
Activity 2.1: Issue internal guidance requiring analysis and
consideration of environmental justice in EPA's compliance and
enforcement program. EPA's enforcement program is already giving
significant consideration to environmental justice concerns in selecting
enforcement areas of focus and targets. For example, as described
above, environmental justice considerations played a significant role in
our selection of national compliance problems to address through
National Enforcement Initiatives. To ensure that EPA enforcement staff
and managers consistently and effectively consider environmental
justice concerns in all their work under EPA's national compliance and
enforcement program, OECA will issue national guidance in 2011 to
reinforce, guide, and accelerate these efforts.
The Agency's national guidance will direct EPA's compliance and
enforcement staff and managers to consider and give significant weight
Plan EJ 2014: Appendix, Implementation Plans 61
-------
&EPA
to environmental justice concerns when they select compliance
problems to focus on, select specific civil or criminal enforcement case
targets, and develop and conduct civil litigation or criminal
prosecution. Given limited resources, EPA managers must make many
strategic choices as they decide which problems to focus on and how to
address them. Protection of the public health is OECA's highest
priority, and protection of the health of overburdened communities is
especially important. While OECA cannot address every problem with
our limited resources, we can ensure that we consider and give
significant weight to the protection of overburdened communities as
we make strategic choices.
For example, in carrying out our National Enforcement Initiative to
address pollution of underground or surface water caused by CAFOs,
EPA must make strategic choices about which watershed areas to focus
on and which particular CAFOs to inspect. A number of factors are
considered in that decision-making process, e.g., the relative severity
of the environmental and public health problems, the degree to which
facilities are known or suspected to have violations that are
contributing to the problem, and the degree to which enforcement
action is likely to be an effective and appropriate tool to correct that
problem. Environmental justice concerns should be considered and
given significant weight in making this decision. For example, if there is
a poor or minority overburdened community whose drinking water
supply is contaminated or at risk of contamination from a nearby CAFO,
that factor weighs in favor of selecting that CAFO as one of our
enforcement case targets.
To ensure that all EPA enforcement personnel consider and address
environmental justice concerns early in the enforcement process, the
Agency, in consultation with DOJ, is revising its internal Model
Litigation Report guidance to call for increased analysis and discussion
of environmental justice considerations in civil case referrals that EPA
sends to DOJ. In addition, EPA will issue guidance calling for analysis
and discussion of environmental justice considerations in the requests
for prosecutorial assistance that the Agency provides to DOJ. These
guidances will be issued in 2011.
In order to implement the direction to consider environmental justice
concerns in selecting and conducting enforcement cases, case teams
will need guidance on how to identify areas of potential environmental
justice concern. EPA has developed a number of screening tools to
assist in identifying areas of potential environmental justice concern.
These include the online mapping tool "EJ View" (formerly known as
the Environmental Justice Geographic Assessment Tool, or EJGAT),
which uses demographic, environmental, health, and facility-level
information to assist in identifying areas with potential environmental
justice concerns. OECA has also developed a screening tool called the
Environmental Justice Strategic Enforcement Assessment Tool
Plan EJ 2014: Appendix, Implementation Plans 62
-------
&EPA
(EJSEAT), which uses these same categories of data to assist in
identifying areas of potential environmental justice concern that may
be appropriate for enforcement action to address the effects of
noncompliance on overburdened communities. A number of EPA's
regions have also developed their own analytic tools and methods for
this purpose.
With all of these screening tools, it is important to remember that they
can only provide a starting point for analysis and decision making as to
whether a community has environmental justice concerns or whether
any enforcement action is appropriate. "Ground truthing" is needed
before drawing any conclusions regarding any particular community or
environmental compliance problem, and, as described above, a
number of other important factors must be taken into consideration
when deciding whether and where to take enforcement actions.
In addition to OECA's efforts to develop screening tools for use in the
enforcement and compliance program, the Agency's Information Tools
Development Workgroup is undertaking a larger effort to develop
guidance on identifying areas of potential environmental justice
concern as a separate effort under EPA's Plan EJ 2014. It will be
important to ensure that OECA's guidance to enforcement case teams
is consistent with the approach(es) developed by the Agency-wide
Environmental Justice Screening Committee. Therefore, upon
completion of the Screening Committee's work, OECA will review its
guidance to ensure that it is consistent with the final Agency decisions
based on the Environmental Justice Screening Committee's work.
Activity 2.2: Review OECA's Enforcement Response Policies to
determine whether any revisions are needed to ensure that
environmental justice concerns are addressed in case development and
resolution. OECA will review its Enforcement Response Policies for the
various statutory and regulatory programs to assess whether any
revisions are needed to ensure environmental justice concerns are
addressed. A plan for the review will be developed by June 30, 2011.
Activity 2.3: Reevaluate use of EJSEAT, as appropriate, in response to
recommendations of the NEJAC and conclusions of the EPA
Environmental Justice Screening Committee. EPA's National
Environmental Justice Advisory Council (NEJAC) thoroughly reviewed
OECA's screening tool, EJSEAT, and provided technical and policy
recommendations to improve this tool in May 2010. OECA responded
to and discussed the NEJAC's recommendations at the NEJAC meeting
in July 2010, and is implementing some of its technical
recommendations. Many of the NEJAC's recommendations raised
policy issues that have broad application and implications for all of the
Agency's environmental justice work. To ensure Agency-wide
consistency, OECA will await the outcome of the Environmental Justice
Screening Committee's work before making final decisions on the
Plan EJ 2014: Appendix, Implementation Plans 63
-------
&EPA
NEJAC's policy recommendations. However, as OECA and the regions
continue to use EJSEAT pending the outcome of the Environmental
Justice Screening Committee's work, the OECA Environmental Justice
Council will assess whether additional changes to EJSEAT
recommended by the NEJAC's review of the tool should be made on an
interim basis.
Activity 2.4: Seek opportunities to advance environmental justice goals
in implementing the Clean Water Act Action Plan. OECA and the Office
of Water (OW) have developed a Clean Water Act Action Plan to
revamp the Agency's permitting, compliance and enforcement
programs so that we more effectively focus our limited resources on
addressing the most important environmental and public health
problems facing the nation. Many of these problems
disproportionately affect poor and minority communities. For
example, urban waters pollution is most likely to affect the health and
welfare of poor communities located along urban waterways. As
OECA, OW, and the regions develop and implement new strategies and
plans under the Clean Water Act Action Plan, we will identify specific
opportunities to address environmental justice concerns.
Many of the opportunities to address environmental justice concerns in
implementation of the Clean Water Act Action Plan will come through the
development of targeting strategies and specific case selection. The Clean
Water Act Action Plan also offers other opportunities to address
environmental justice concerns, such as our increased attention with state
agencies, to the relationship between effective permitting and
enforcement in assuring compliance with the Clean Water Act. Often, the
concerns that are raised to EPA by overburdened communities relate to the
effectiveness of the permit regulating a particular facility, which is an
essential underpinning for effective compliance and enforcement.
Activity 2.5: Seek opportunities to advance environmental justice
goals in conducting the National Enforcement Strategy for RCRA
Corrective Action. OECA's Corrective Action program has set an
aspirational goal of achieving remedy construction at 95 percent of
3,747 RCRA facilities by the year 2020. The National Enforcement
Strategy for Corrective Action (NESCA) provides direction to the
regions, and guidance to states, for assessing, targeting, and
prioritizing the EPA-lead Corrective Action facilities to help meet the
2020 Corrective Action goal. EPA regions are encouraged to focus
attention on identifying and addressing disproportionate effects that
RCRA facilities needing corrective action may have on adjacent or
nearby overburdened populations.
NESCA identifies a variety of mapping tools that regions, states, and
communities can use to view and identify environmental justice concerns.
Each EPA regional office is developing a RCRA Corrective Action 2020
strategy. As part of these strategies, the regions should identify what tools
they plan to use to address environmental justice concerns in their
prioritization. To assist regions with addressing environmental justice
Plan EJ 2014: Appendix, Implementation Plans 64
-------
&EPA
concerns, OECA provided each region with a list of all potential facilities.
OECA used EJSEATto screen and prioritize each facility on these lists of
facilities. The regions will assess their 2020 Corrective Action Universe to
ensure consideration of environmental justice and provide updated RCRA
Corrective Action 2020 strategies in the Spring of 2011.
Activity 2.6: Improve compliance at federal facilities where violations
may affect overburdened communities. Where federal facilities are
located adjacent to or nearby overburdened communities, illegal
pollution or hazardous waste contamination can have a
disproportionate effect on those communities. As part of Plan EJ 2014,
OECA, together with Federal Facility Program Managers in each EPA
region, will accelerate efforts to identify communities with these types
of problems and take enforcement action to ensure that federal
facilities comply with the law and address pollution problems that
affect the communities. In FY 2011 OECA will use EJSEAT and other
tools and information to identify overburdened communities located
near federal facilities that have significant violations of federal
environmental laws. These facilities will be given priority in regional
targeting efforts for compliance and enforcement.
Activity 2.7: Develop tools to identify and track facilities located in
areas with potential environmental justice concerns, and report on
enforcement actions that address environmental justice concerns. To
ensure the success of Activities 2.1-2.6, it will be important to ensure
that environmental justice screening information is available to case
teams, and to track the enforcement and compliance activities that we
implement under this Plan. Therefore, in 2011, OECA will develop and
implement technical programming for the Integrated Compliance
Information System (ICIS) database, an internal tracking system, to
allow for automated reporting on OECA regional and Headquarters
review of EPA civil enforcement cases for potential environmental
justice concern. OECA is in the process of developing this capacity and
will determine in 2011 whether the reporting mechanism in ICIS is
adequate for its needs.
To support OECA's program efforts to improve tracking and reporting of
environmental justice aspects of EPA criminal enforcement case work,
OECA will in 2011 analyze its current docket of investigations for potential
environmental justice concerns, and will revise its internal Criminal Case
Reporting System (CCRS) to capture information concerning potential
environmental justice concerns in criminal enforcement investigations and
prosecutions. OECA will consider environmental justice data, along with
other criminal case tiering information.
Plan EJ 2014: Appendix, Implementation Plans 65
-------
&EPA
Strategy 3: Enhance use of enforcement and compliance tools to advance
environmental justice goals in regional geographic initiatives to address
the needs of overburdened communities.
EPA regions have developed and continue to develop integrated strategies
to focus on particular geographic areas in their regions with overburdened
communities that are disproportionately affected by environmental
problems. Beginning in 2008, for example, each region identified a
"Showcase Community" to focus efforts to address environmental justice
concerns. The regions used integrated strategies for this purpose that
considered the full range of EPA's tools, and a number of these projects
include use of enforcement and compliance assurance tools. Under this
strategy, the regions will ensure that they use their enforcement and
compliance assistance tools effectively to identify and address
environmental and public health problems in areas of environmental
justice concern that are caused or made worse by violations of federal
environmental laws. For example, EPA Regions 3, 4, and 5 are leading a
geographic enforcement initiative focused on Huntington Port, which was
selected in part because screening analysis results indicated a high
potential for environmental justice concerns. This initiative incorporates
enforcement and compliance assistance to reduce pollution and increase
compliance. It also includes workshops to build the community's capacity
to help ensure long-term protection of the environment and public health.
Activity 3.1: Regions will include use of enforcement tools as part of
integrated problem-solving strategies that are focused on particular
geographic areas. OECA and the regions, together with state and other
agencies as appropriate, will evaluate facility compliance in
overburdened communities selected for strategic focus. These
evaluations should be targeted using the best available data and
methods in light of the overall objectives of EPA's enforcement and
compliance assurance work. In this way, community-focused initiatives
can complement the national enforcement initiatives and other sector-
based and program-specific enforcement activities, meeting OECA's
goal of strategically using limited enforcement resources to address the
most significant issues first.
OECA and the regions will tailor compliance evaluation and enforcement
actions as part of integrated strategies to maximize EPA's ability to gain
environmental and public health benefits in overburdened communities.
For example, this could include use of multi-media inspections or process
inspections to comprehensively address potential impacts from violations
at a given facility.
Activity 3.2: Regions will include use of compliance assistance tools as
part of integrated problem-solving strategies focused on particular
geographic areas. OECA and the regions will consider and use
compliance assistance activities to effectively reach large numbers of
small sources with environmental violations that have significant local
impacts on overburdened communities. Compliance assistance tools,
such as counseling, online resource centers, fact sheets, guides,
Plan EJ 2014: Appendix, Implementation Plans 66
-------
&EPA
training, and monitoring, are particularly appropriate, at least as initial
compliance efforts, when widespread violations are found among small
businesses, which often have limited resources and less ability than
major industrial facilities to understand and comply with the
requirements of federal environmental regulations. The EPA and states
have often been successful in improving small businesses' compliance
with environmental regulations through focused outreach and
education efforts.
Strategy 4: Seek appropriate remedies in enforcement actions to benefit
overburdened communities and address environmental justice concerns.
* Activity 4.1: Increase efforts to address environmental justice concerns
through use of injunctive relief, including mitigation, and Supplemental
Environmental Projects in civil enforcement actions, as appropriate.
OECA, the EPA regions, and DOJ are jointly heightening their focus in
civil enforcement cases on potential options to obtain meaningful
environmental and public health benefits to specific overburdened
communities affected by violations of federal environmental laws.
These efforts go beyond traditional injunctive relief to stop illegal
pollution, to mitigate the environmental and public health harm caused
by illegal pollution and, where appropriate and agreed to by
defendants, to include Supplemental Environmental Projects (SEPs)
that provide benefits to communities. For example, in a case involving
illegal discharges of pollutants from a facility that damaged a tribal
fishing area, the relief ordered (in addition to stopping the illegal
discharges) included restocking the fishing ground. EPA has also been
successful in obtaining SEPs from defendants to retrofit diesel school
buses, to reduce the air pollution that children are exposed to. We will
continue and accelerate these types of efforts to reduce pollution
burdens that have a disproportionate impact on minority, low-income,
tribal and indigenous populations.
Activity 4.2: Increase efforts to benefit affected communities through
use of community service and the Crime Victims' Rights Act in criminal
actions. OECA will work with DOJ to (1) explore innovative uses of
criminal sentencing options, e.g., community service or environmental
compliance plans, and (2) take into account information obtained
pursuant to the Crime Victims Rights Act when developing
environmental crimes case resolutions (e.g., restitution).
Activity 4.3: Look for opportunities to work with other federal
agencies, state and local governments, and the business community to
complement and leverage community benefits resulting from
enforcement activities. In addition to the benefits that can be obtained
for overburdened communities through judicial and administrative
enforcement actions, there may be other, parallel opportunities to
obtain additional benefits for the community through cooperation with
other federal agencies, state or local governments, or the business
community. For example, the U.S. Department of Housing and Urban
Plan EJ 2014: Appendix, Implementation Plans 67
-------
&EPA
Development (HUD) may be able to provide housing assistance or
other community benefits in a "brownfields" area where EPA has taken
enforcement action to clean up environmental contamination.
State or local governments may have projects or grant funding that can be
used to improve the community's infrastructure or environment in an area
that is also the focus of EPA compliance or enforcement action. In
situations where air emissions from individual or multiple industrial
facilities continue to adversely affect community health despite their
compliance with emission limitations, some businesses may be willing to
take voluntary action to further reduce the emissions that adversely affect
the community. Examples of such voluntary actions include: a health clinic
established and operated together with local, state, and community
members; a household hazardous waste collection drive; a local company
voluntarily agreeing to post compliance monitoring information directly on
a public website, to allow community members to check on compliance;
and "good neighbor agreements" between local companies and
communities to address facility effects not regulated by a permit or other
law.
EPA will identify specific opportunities, in cases or regional geographic
initiatives, to work with other federal agencies, state and local
governments, and the business community to complement and leverage
benefits resulting from enforcement activities. EPA will document and
share recommendations and best practices for taking action on these
opportunities.
Strategy 5: Enhance communication with affected communities and the
public regarding environmental justice concerns and the distribution and
benefits of enforcement actions, as appropriate.
OECA and the EPA regions with DOJ will increase their efforts to
communicate with affected communities and the public about
enforcement strategies and actions that may affect overburdened
communities. EPA recognizes that communities have a legitimate need to
be informed and to understand the federal government's enforcement
activities to protect their environment and public health, and to have their
voices heard when solutions are being considered to redress
environmental and health problems caused by violations of federal
environmental laws that affect their community. As OECA implements
these strategies for Plan EJ 2014, we commit to increase outreach to
communities and to provide more information about environmental and
public health problems caused by failure to comply with federal
environmental laws, efforts to address those problems, and available
judicial and administrative solutions to those problems that can address
the communities' concerns and needs.
At the same time, it is important for communities to understand the
legitimate and essential need to protect the confidentiality of enforcement
Plan EJ 2014: Appendix, Implementation Plans 68
-------
&EPA
activity when a case is under development and in settlement negotiations.
This is essential to assure that effective enforcement, and its ultimate
benefits for the community, will not be undermined and adversely affected
by premature disclosure of confidential enforcement information. While
this consideration will necessarily limit the amount and kind of information
that EPA is able to share with the community at various stages of
enforcement activity, we are committed to sharing as much information as
possible, to enable communities to be informed and to have their voices
heard in the determination of appropriate resolutions for violations of
federal environmental laws that affect them.
While increased communication efforts are important, it is no less
important to receive input from communities on potential violations. OECA
will continue to invite tips and complaints, including through such means as
EPA's on-line reporting badge and the EPA fugitives web page.
Activity 5.1: Provide affected communities with information about
enforcement actions and meaningful opportunities for input on
potential environmental justice concerns and remedies to be
implemented. As OECA and the regions develop and implement our
enforcement actions, we will seek to identify communities with
environmental justice concerns that could benefit from enhanced
communication and consultation regarding enforcement activities, and
provide the communities with additional information (consistent with
the confidentiality requirements needed to protect the integrity of
enforcement actions). As appropriate, OECA and the regions will also
provide opportunities for communities to provide input on
environmental justice concerns and remedies to be sought in
enforcement actions that affect their communities. This information
will be provided through EPA's website, local information repositories,
and other appropriate means.
Activity 5.2: Improve website information and other public information
materials to explain EPA's site cleanup enforcement processes. OECA
and the regions recognize that the Agency's enforcement processes
concerning hazardous waste site cleanup that affect communities with
potential environmental justice concerns, are often complicated and
can be difficult for the public to understand and to follow. To increase
communities' ability to understand our enforcement processes, we will
coordinate across EPA offices to maximize website information on
cleanup enforcement at specific sites, develop and make available fact
sheets to better explain EPA's cleanup enforcement process, and
prepare for internal EPA use a compendium of "best practices" that will
encourage and facilitate EPA employees' efforts to make cleanup
enforcement information more available to the public.
Activity 5.3: Enhance communication of the environmental justice
benefits of EPA's enforcement actions. EPA's enforcement actions
frequently provide significant benefits to overburdened communities,
including reduction of air or water pollution, cleanup of toxic and
hazardous waste, and additional community benefits such as diesel bus
Plan EJ 2014: Appendix, Implementation Plans 69
-------
&EPA
retrofits and other benefits made available through SEPs. However,
the community is best able to appreciate these benefits when they
have good information about these actions. Therefore, OECA and the
regions will accelerate efforts to communicate, through press releases,
EPA's website, and other means, the benefits of our enforcement
actions for overburdened communities. To ensure nationwide
consistency in this effort, we will issue internal guidance for this
purpose in 2011.
Plan EJ 2014: Appendix, Implementation Plans 70
-------
&EPA
3.0 DELIVERABLES
Strategy 1: Advance environmental justice goals through selection and
implementation of National Enforcement Initiatives.
ACTIVITIES
Activity 1.1: Consider
environmental justice in
selecting National
Enforcement Initiatives
(NEIs)forFY2011-13.
DELIVERABLES
Selection of National
Enforcement Initiatives for
FY 2011-13.
MILESTONES
Completed
Activity 1.2: Advance
environmental justice goals
through implementation of
NEIs.
Strategic Implementation
Team (SIT) strategies to
include opportunities to
advance environmental
justice goals.
April 30,
2011
Activity 1.3: Consider
environmental justice in
nominating and selecting
National Enforcement
Initiatives for FY 2014-16.
Call for nominations for FY
2014-16 NEIs to include
request to identify
opportunities to advance
environmental justice goals.
In 2013
Strategy 2: Advance environmental justice goals through targeting and
development of compliance and enforcement actions.
ACTIVITY
Activity 2.1: Issue internal
guidance calling for analysis
and consideration of
environmental justice in
EPA's compliance and
enforcement program,
including using available tools
and approaches to identify
areas of potential
environmental justice
concern.
DELIVERABLES
Issue guidance to EPA
managers and staff that
calls for consideration of
environmental justice in
EPA's compliance and
enforcement program.
Revise Model Litigation
Report Guidance to call for
increased analysis and
discussion of environmental
justice in judicial referrals.
Consider environmental
justice data, along with
criminal case tiering
information.
Issue guidance calling for
discussion of environmental
justice issues in requests for
prosecutorial assistance.
MILESTONES
April 30,
2011
Draft by
June 30,
2011; Final
by Sept. 30,
2011
Ongoing
August 31,
2011
Plan EJ 2014: Appendix, Implementation Plans
71
-------
&EPA
ACTIVITY
Activity 2.2: Review
OECA's Enforcement
Response Policies to
determine whether any
revisions are needed to
ensure that environmental
justice concerns are
addressed in case
development and resolution.
DELIVE RABIES
MILESTONES
Develop a plan and
timetable for review of
Enforcement Response
Policies.
June 30,
2011
Activity 2.3: Re-evaluate
use of EJSEAT, as
appropriate, in response to
recommendations of the
NEJAC and conclusions of
the EPA Environmental
Justice Screening
Committee.
Finalize implementation of
the NEJAC technical
recommendations for
EJSEAT already accepted.
Reconsider and finalize
response to the NEJAC
recommendations on
EJSEAT following issuance
of final work product by
Environmental Justice
Screening Committee (to
ensure consistency).
June 30,
2011
Within 180
days
following
issuance of
final work
product of
Environmen
tal Justice
Screening
Committee
Activity 2.4: Seek
opportunities to advance
environmental justice goals in
implementing the Clean
Water Action Plan.
As EPA develops and
implements new strategies
and plans under the Clean
Water Act Action Plan, we
will identify specific
opportunities to address
environmental justice
concerns.
Ongoing
Activity 2.5: Seek
opportunities to advance
environmental justice goals in
conducting the National
Enforcement Strategy for
RCRA Corrective Action.
Screen all facilities in the
2020 Corrective universe
that are subject to the
National Enforcement
Strategy for RCRA
Corrective Action for
potential environmental
justice concerns.
Identify as priorities for
enforcement, Corrective
Action sites using the
potential for environmental
justice concerns as a factor.
Completed
Ongoing
Plan EJ 2014: Appendix, Implementation Plans
72
-------
&EPA
ACTIVITY
Activity 2.6: Improve
compliance at federal
facilities where violations may
affect overburdened
communities.
DELIVE RABIES
Use EJSEAT to identify
overburdened communities
located near federal
facilities. Identify those that
have significant
environmental violations for
priority consideration by
regional federal facility
program targeting efforts, for
compliance assistance and
potential enforcement.
MILESTONES
Ongoing
Activity 2.7: Develop
tracking and reporting tools
on potential environmental
justice concerns and results
in enforcement actions.
Develop and implement
technical/programming
requirements for the ICIS
database.
Develop reporting guidance.
Revise the Criminal Case
Reporting System (CCRS)
to capture information
concerning potential
environmental justice
concerns in criminal
enforcement investigations
and prosecutions.
Ongoing;
Draft
guidance by
March 30,
2012
Ongoing
Ongoing
Strategy 3: Enhance use of enforcement and compliance tools to advance
environmental justice goals in regional geographic initiatives to address the
needs of overburdened communities.
ACTIVITY
Activity 3.1: Regions will
include use of enforcement
tools as part of integrated
problem-solving strategies
that are focused on particular
geographic areas.
DELIVERABLE,
Regions will be asked to
include enforcement efforts
(e.g., through targeting and
inspections) when applying
integrated problem-solving
strategies in selected
geographic areas with
environmental justice
concerns. For example,
some regions incorporated
such an approach into their
Environmental Justice
Showcase Community
projects.
Document accomplishments
and future plans for including
enforcement in these
geographic initiatives.
MILESTONES
Ongoing
December
31,2011
Plan EJ 2014: Appendix, Implementation Plans
73
-------
&EPA
Activity 3.2: Regions will
include use of compliance
assistance tools as part of
integrated problem-solving
strategies (e.g., as applied in
the Showcase Communities),
that are focused on particular
geographic areas.
DELIVERABLES
Regions will be asked to
evaluate appropriate
compliance assistance tools
when applying integrated
problem-solving strategies in
selected geographic areas
with environmental justice
concerns. For example,
some regions incorporated
such an approach into their
Environmental Justice
Showcase Community
projects.
Document accomplishments
and future plans for including
compliance assistance in
these geographic initiatives.
MILESTONES
Ongoing
December
31,2011
Strategy 4: Seek appropriate remedies in enforcement actions to benefit
overburdened communities and address environmental justice concerns.
ACTIVITY
Activity 4.1: Increase efforts
to address environmental
justice concerns through use
of injunctive relief, including
mitigation, and SEPs in civil
enforcement actions.
DELIVERABLES
On case-specific basis,
coordinate with DOJ on
potential options in judicial
cases for injunctive relief,
including mitigation, and
SEPs that will deliver
substantial and meaningful
environmental benefits to
specific environmental
justice communities.
Assess opportunities for
increasing environmental
justice benefits in remedies
in administrative actions.
MILESTONES
Ongoing
Ongoing
Activity 4.2: Increase efforts
to benefit overburdened
communities through use of
community service and the
Crime Victims' Rights Act
(CVRA) in criminal actions.
Work with DOJ to (1)
explore innovative uses of
criminal sentencing options,
e.g., community service
and/or environmental
compliance plans, and (2)
take into account information
obtained pursuant to the
CVRA when developing
environmental crimes case
resolutions (e.g., restitution).
Ongoing
Provide comments on the
DOJ/Attorney General's
CVRA Guidelines.
Completed
Plan EJ 2014: Appendix, Implementation Plans
74
-------
&EPA
DELIVERABLES
Coordinate with DOJ in their
implementation of CVRA
guidelines for federal
environmental prosecutions.
Evaluate use of restitution,
community service, and
CVRA in federal
environmental prosecutions,
and issue guidance to
investigators.
MILESTONES
Ongoing
Ongoing
Activity 4.3: Look for
opportunities to work with
other federal agencies, state
and local governments, and
the business community to
complement and leverage
community benefits resulting
from enforcement activities.
Identify specific
opportunities, in cases or
regional geographic
initiatives, to work with other
federal agencies, state and
local governments, and the
business community to
complement and leverage
benefits resulting from
enforcement activities.
Document and share
recommendations and best
practices for taking action on
these opportunities.
Ongoing
December
31,2011
Strategy 5: Enhance communications with affected communities and the
public regarding environmental justice concerns and the distribution and
benefits of enforcement actions, as appropriate.
ACTIVITY
Activity 5.1: Provide
affected communities with
information about
enforcement actions and
meaningful opportunities for
input on potential
environmental justice
concerns and remedies to be
sought, as appropriate.
DELIVERABLES
Identify communities where
enhanced communication
and consultation regarding
enforcement matters is
appropriate.
Provide communities with
information about
enforcement actions and
meaningful opportunities for
input on potential
environmental justice
concerns and remedies to be
sought, as appropriate
MILESTONES
Ongoing
Ongoing
Activity 5.2: Improve
website information on
cleanup enforcement,
develop fact sheets to better
explain the cleanup
enforcement process, and
prepare a compendium of
best practices.
Coordinate across EPA
offices to maximize website
information on cleanup
enforcement at specific sites.
Ongoing
Participate in the
development of fact sheets
that explain the cleanup
enforcement process.
Ongoing
Plan EJ 2014: Appendix, Implementation Plans
75
-------
&EPA
DELIVERABLES
Prepare compendium of best
practices.
MILESTONES
December
31,2011
Activity 5.3: Enhance
communication of
environmental justice
benefits of EPA's
enforcement actions.
Develop policy on
communicating in press
releases and similar
statements the
environmental justice
benefits of EPA's
enforcement actions.
August 31,
2011
Plan EJ 2014: Appendix, Implementation Plans
76
-------
vvEPA
OECA will report annually on progress in implementing the strategies
outlined in this implementation plan, and will update as necessary, the
activities and deliverables outlined here. For information, please contact
Loan Nguyen, 202-564-4041, Nguyen.Loan@epa.gov; or Eileen Deamer,
312-886-1728, Deamer.Eileen@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 77
-------
&EPA
September 2011
Led by
Office of Solid Waste and Emergency Response,
and Regions 2, 3, and 4
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans 78
-------
&EPA
Goals At-A-G lance
To strengthen community-
based programs to
engage overburdened
communities and build
partnerships that promote
healthy, sustainable, and
green communities.
1.0 INTRODUCTION
For over forty years, the U.S. Environmental Protection Agency (EPA)'s top
priority has been protecting human health and the environment. The
Agency has learned that communities must be the driver for local solutions.
Consequently, EPA has implemented numerous programs that support
community empowerment and provide community benefits at all levels,
from basic educational and leadership development to comprehensive
approaches to achieving healthy, sustainable, and green communities.
These efforts include financial assistance programs such as Environmental
Justice, Community Action for a Renewed Environment (CARE), Brownfields
Area-Wide Planning, and Tribal grants. They also include other place-based
programs such as EPA's Local Climate and Energy, Childhood Asthma,
Sustainable Communities and Smart Growth, Urban Waters, Superfund,
and Brownfields programs. EPA undertakes these programs in
collaboration with other federal agencies, state, tribal, and local
governments, and multiple stakeholders. Significantly, EPA's ten regions
play a leading role in implementing these programs.
While communities continue to impress EPA with their dedication, their
innovative ideas, and most importantly their ability to bring real change to
their communities, we realize that far too many communities still lack the
capacity to affect environmental conditions. Many minority low-income,
tribal, and indigenous communities continue to live in the shadows of the
worst pollution and face some of the harshest effects.
The Plan EJ 2014 Supporting Community-Based Action Programs
implementation plan builds upon an Agency effort to improve the
effectiveness of EPA's place-based community programs through better
information access, coordination, and leveraging. Through this process,
EPA hopes to make "community" an organizing principle for our work. To
implement this principle, EPA is currently doing the difficult foundational
work of internally aligning and coordinating its programs. The resulting
foundation will enable EPA, particularly its regions, to more effectively
expand partnerships, build local capacity, and foster health and economic
benefits in overburdened communities, as well as aligning EPA programs
and investments with those of other federal agencies, state, local, and
tribal governments, and other stakeholders.
1.1 Goals
EPA will strengthen community-based programs to engage overburdened
communities and build partnerships that promote healthy, sustainable, and
green communities.
To accomplish this goal, EPA will build upon and leverage Agency efforts to
promote greater coordination in the use of programs and tools that
support community empowerment. EPA will pursue this goal at all levels,
Plan EJ 2014: Appendix, Implementation Plans
79
-------
&EPA
from basic educational and leadership development to comprehensive
approaches to achieving healthy, sustainable, and green communities.
Through these efforts, EPA will make the Agency's resources more
accessible to underserved communities, while achieving greater internal
efficiency through feedback and better understanding of implementing
community-based programs. This approach will result in environmental,
health, and economic improvements in such communities.
1.2
The Office of Solid Waste and Emergency Response (OSWER) and regions 2,
3, and 4 are responsible for designing and implementing the Plan EJ 2014
Supporting Community-Based Action Programs focus area. They will be
supported by the Office of Water (OW), the Office of Air and Radiation
(OAR), the Office of Policy (OP), the Office of Enforcement and Compliance
Assurance (OECA), the Office of Environmental Justice (OEJ), the Office of
the Chief Financial Officer (OCFO), and Regions 1, 6, and 10.
The EPA recognizes that Supporting Community-Based Action Programs is
cross-cutting in nature and requires the participation of all EPA programs
and regions. This integrated One EPA approach enables the Agency to
better engage and empower communities and other stakeholders,
particularly those who have been historically under-represented, in order
to support and advance environmental protection and foster
environmental, health, and economic benefits for all communities.
Plan EJ 2014: Appendix, Implementation Plans 80
-------
v°/EPA
- .".'
EPA will employ six strategies in the Supporting Community-Based Action
Programs Implementation Plan that are tied to the larger Plan EJ 2014
goals and Agency priorities.
1. Advance environmental justice principles by building strong state and
tribal partnerships through the National Environmental Performance
Partnership System (NEPPS) and National Program Manager (NPM)
guidance.
2. Identify scalable and replicable elements of successful Agency
community-based programs and align multiple EPA programs to more
fully address the needs of overburdened communities.
3. Promote an integrated One EPA presence to better engage
communities in the Agency's work to protect human health and the
environment.
4. Foster community-based programs modeled on the Community Action
for a Renewed Environment (CARE) principles.
5. Explore how EPA funding, policies, and programs can inform or help
decision makers to maximize benefits and minimize adverse impacts
when considering current land uses in decision making, planning, siting,
and permitting.
6. Promote equitable development opportunities for all communities.
2,2
This section describes the ten major activities EPA will undertake to
implement these strategies to support community-based programs.
Strategy 1: Advance environmental justice principles by building strong
state and tribal partnerships through the National Environmental
Performance Partnership System (NEPPS) and National Program
Manager (NPM) guidance
This effort will advance the Administrator's priorities on environmental
justice and children's health through state, tribal, and grant work plans.
EPA regions will work with states and tribes to advance environmental
justice by improving environmental conditions and public health in
overburdened communities.
EPA has established a workgroup and schedule a series of meetings to hold
discussions. The workgroup will make recommendations and develop
appropriate language to incorporate environmental justice principles and
Title VI to better protect overburdened communities. This effort will
demonstrate how the Agency can positively affect overburdened
Plan EJ 2014: Appendix, Implementation Plans 81
-------
&EPA
communities through its partnerships, agreements, work plans and grants
that are governed by NEPPS and NPM guidance principles.
The workgroup will promote state and tribal engagement with affected
communities in their discussions and decision-making processes. The
workgroup has identified two key activities to address as part of its effort
to advance environmental justice through NEPPS and NPM guidance:
Activity 1: Provide recommendations that mutually support
community involvement; resource and data sharing; and monitoring,
tracking, and training within programs implemented through
performance partnership agreements, tribal agreements, and work
plans guided by NEPPS and NPM documents.
o Address specific issues and identify barriers within current
practices to incorporating environmental justice principles into
NEPPS and NPM process.
o Develop recommendations on how to best integrate
environmental justice principles into state and tribal grant
work plans.
o Promote state and tribal involvement in environmental justice
discussions, reviews, and decision making to incorporate
environmental justice principles into the NEPPS and NPM
processes.
o Coordinate with NEPPS and NPM efforts, exploring current
regional practices and lessons learned to develop language for
environmental justice guidance on community-based programs
for inclusion in the annual NPM and NEPPS guidance.
o Identify Agency programs to pilot the inclusion of
environmental justice principles into negotiated work plans
and tribal agreements.
o Incorporate lessons learned from pilot demonstrations of
environmental justice in negotiated work plans and tribal
agreements into NPM and NEPPS annual guidance.
Activity 2: Develop language for environmental justice principles
including Title VI guidance (as appropriate with all Agency grants) for
inclusion in the FY 2013 NEPPS and FY 2012 NPM guidance through
collaboration and discussions with Office of Congressional and
Intergovernmental Relations (OCIR), Office of Civil Rights (OCR),
regional offices, and states.
o Consult Agency legal resources for guidance in integrating
environmental justice considerations and Title VI guidance
through NEPPS and NPM guidance documents.
o Review language from Performance Partnership Agreements
(PPAs), Performance Partnership Grants (PPGs), and grants of
Agency and state programs being implemented under NEPPS
and NPM guidance.
Plan EJ 2014: Appendix, Implementation Plans 82
-------
&EPA
Strategy 2: Identify scalable and replicable elements of successful Agency
community-based programs and align multiple EPA programs to more
fully address the needs of overburdened communities.
EPA has achieved great success with community-based programs that help
build capacity to address critical issues affecting overburdened
populations. In order to help Agency community-based programs learn
from experience, this workgroup will engage both headquarters and
regional offices regarding their successes and lessons learned with
community-based programs. The workgroup will also review Office of
Policy's (OP) list of 26 existing Agency community-based programs and
existing evaluations of select Agency EJ programs to identify effective
programmatic elements of successful place-based programs that help to
support healthy and sustainable communities.
This is part of EPA's efforts to improve the effectiveness of its community-
based programs through better information access, coordination, and
leveraging. This effort focuses on making "community" an organizing
principle of our work, increasing community access to our programs, and
improving environmental protection and the quality of life at the
community level. The workgroup has identified two key activities to
improve EPA's community-based efforts to produce tangible results in
overburdened communities.
Activity 3: Review Agency and key outside community-based
programs, and existing evaluations of select Agency programs, to
identify scalable and replicable program elements which encourage
place-based solutions to environmental justice issues, strengthen and
promote partnerships, and support healthy and sustainable
communities.
Activity 4: Make recommendations on how EPA can align its
community-based programs, particularly in EPA's regions to more fully
address the needs of overburdened communities.
Strategy 3: Promote an integrated One EPA presence to better engage
communities in the Agency's work to protect human health and the
environment.
The organizational structure of EPA presents a challenge for many
communities that are addressing multiple environmental issues. The
reality is that most Americans see EPA as a single entity. More and more
communities are seeking comprehensive environmental solutions that cut
across individual media programs. We will find the best solutions when we
work consistently in a unified way. What we can achieve as One EPA to
assure a clean and healthy environment for all is far greater than the
results of multiple uncoordinated efforts. One EPA is a mindset that values
alignment - investing our time and energy to define together the outcomes
we want and how to get there. It entails our persistent search for more
integrated ways of reaching solutions that better protect the environment.
This involves headquarters and regions working together to target areas of
concerns.
Plan EJ 2014: Appendix, Implementation Plans 83
-------
&EPA
The workgroup has identified the following key activity to address as part
of its effort to promote a One EPA presence.
Activity 5: Target three approaches to promote an integrated One EPA
presence where EPA will find the best solution by working in a
consistent and unified way.
EPA will identify opportunities to present an integrated One EPA
presence through:
1. Conferences and listening sessions.
2. Communication and outreach to better engage communities.
3. Capacity building through workforce development and job
training.
Strategy 4: Foster community-based programs modeled on Community
Action for a Renewed Environment (CARE) principles.
The CARE program was developed from lessons learned from EPA
community-based programs (e.g., Brownfields, Environmental Justice,
Community-Based Environmental Protection, etc.) and advice from the
2004 NEJACto "initiate community-based, collaborative, multi-media, risk
reduction pilot projects."15 The CARE principles will be applied to a One
EPA approach toward testing regional approaches for joint planning and
non-EPA funding of community partnerships. These partnerships will
engage private industry, businesses, foundations, universities and
community colleges, and other groups.
The workgroup has identified the following three key activities to address
as part of its effort to foster community-based programs modeled on CARE
principles:
Activity 6: Develop a community-based partners (CBP) initiative for
opportunities in underserved and environmentally overburdened
neighborhoods to collaborate with federal agencies, private industry,
foundations, and other institutions to implement the CARE principles.
o In developing the CBP program, EPA will assess and implement
ways by which the Agency can better act as a conduit to bring
together underserved communities with federal agencies,
private industry, businesses, foundations, universities, and
other institutions.
Activity 7: Develop a CBP program that caters to grassroots or
emerging community groups with little to no organizational or
technical capacity.
o This second type of CBP program will address Agency concerns
in reaching out to those community groups who have been
unsuccessful in competing for government grants.
National Environmental Justice Advisory Council, Ensuring Risk Reduction in Communities with
Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts, December 2004. Available at:
http://www.epa.gov/compliance/ei/resources/publications/neiac/neiac-cum-risk-rpt-122104.pdf.
Plan EJ 2014: Appendix, Implementation Plans 84
-------
&EPA
Activity 8: Identify technical assistance resources, program staff, and
regional staff available to aid overburdened communities with issues
related to their areas of expertise.
Strategy 5: Explore how EPA funding, policies, and programs can inform
or help decision makers to maximize benefits and minimize adverse
impacts when considering current land uses in decision making, planning,
siting, and permitting.
EPA is aware of communities concerns about land use planning. To
respond to these concerns, EPA will explore how our programs affect land
use planning, siting, and decision making in overburdened communities.
While land use planning is usually a local government responsibility, EPA
can provide interested jurisdictions with information on best practices
regarding policies and approaches that can benefit all community
stakeholders and minimize adverse impacts.
Building upon its work with the interagency Partnership for Sustainable
Communities, EPA can support a broad discussion forum to explore how
interested jurisdictions might better address the issues of overburdened
communities when making local land use decisions. Due to the cross-
cutting nature of land use planning and its effect on communities, EPA will
work collaboratively with state agencies that, subsequently, will work with
communities and other stakeholders to identify issues and opportunities.
EPA has identified the following activity to implement its effort to examine
land use decision making, planning, and siting in underserved and
overburdened communities:
Activity 9: Establish a workgroup and seek stakeholder feedback to
explore ways the Agency's work intersects with land use decision
making, planning, and siting.
o This workgroup will produce information discussing
environmental concerns that may affect land use planning,
siting, and permitting decisions. This workgroup will be
comprised of select EPA offices, and state, local, and tribal
governments. The workgroup will also develop a
complementary training course for stakeholders with the goal
of increasing awareness of land-use decision making, and its
effect on communities.
Plan EJ 2014: Appendix, Implementation Plans 85
-------
&EPA
Strategy 6: Promote equitable development opportunities for all
communities.
EPA has a range of financing and technical assistance vehicles in place that
communities might be able to tap if they had basic, understandable
information about how to do so. However, ensuring equitable access to
them can be a formidable challenge for communities and organizations
unfamiliar with EPA's processes for both distributing and leveraging these
resources. Therefore, EPA needs to foster a climate in which more
equitable development opportunities can be realized, by providing tailored
information on financing and related tools and strategies, including
outreach to agencies whose complementary tools could be given a greater
community focus.
Activity 10: Promote equitable development opportunities.
o This workgroup will conduct research on existing financing
vehicles; prepare an analysis (that will integrate existing Office
of the Chief Financial Officer (OCFO)/Environmental Financial
Advisory Board (EFAB) tools, as appropriate); produce an "EPA
Agency-wide Financing and Technical Assistance Vehicle:
Strategies to Apply Them to Support Equitable Community
Development" and post on the web; and prepare an outreach
memorandum to other key agencies, to encourage application
of their tools in ways that promote equitable development.
2,3 !
Community engagement and stakeholder partnership activities are
integrated into the different strategies and activities of this
implementation plan. Many strategies and activities of this plan resulted
from community dialogues and the NEJAC advice and recommendations.
In addition, we will coordinate our community outreach and stakeholder
involvement efforts with OEJ.
Plan EJ 2014: Appendix, Implementation Plans 86
-------
&EPA
3.0 DELIVERABLES
The table below provides a list of activities to be completed with
deliverables and associated milestones.
DELIVERABLES
Activity 1:
Recommendations on
advancing
environmental justice
principles in work
plans and agreements.
MILESTONES
Necessary expertise identified for
developing recommendations.
Recommendations on how to best
integrate NEPPS principles into
state, tribal, and grant work plans.
Agency programs to pilot the
inclusion of environmental justice
into negotiated work plans and
tribal agreements identified.
June 30,
2011
September
30,2011
September
30,2012
Activity 2:
Development of
appropriate language
for incorporating
environmental justice
principles in work
plans and agreements.
The Office of General Counsel
(OGC) guidance on
environmental justice and Title VI
language.
Proposed language on
environmental justice including
Title VI guidance for community-
based (CB) programs for FY 2013
NEPPS guidance and FY 2012
NPM guidance developed.
June 30,
2011
September
30,2012
Activity 3: List of
scalable and replicable
elements of CB
programs.
Workgroup established to
coordinate with OP and look at
Agency and outside CB
programs.
List of scalable and replicable CB
program elements developed.
March 31,
2011
October 28,
2011
Activity 4:
Recommendations on
aligning Agency CB
programs.
Recommendations on aligning
Agency CB programs.
December
31,2011
Activity 5: Target
three approaches to
promote an integrated
One EPA presence.
Conferences and listening
sessions
Communication and outreach to
better engage communities.
Capacity building through
workforce development and job
training.
July 1,
2011
July 29,
2011
December
31,2011
Plan EJ 2014: Appendix, Implementation Plans
87
-------
&EPA
Activity 6: Develop
and implement CBP
program based on the
CARE model.
Communities with the established
framework in place to implement
this program identified by EPA
regional offices.
Select communities and engage
partnership opportunities.
Preliminary program initiated.
Lessons learned from selected
communities developed.
August
2011
September
2011
June 2012
Activity 7: Develop
and implement CBP
program for grassroots
or emerging
community groups.
Develop a process to select
communities.
Preliminary program initiated.
Lessons learned from selected
communities developed.
December
2011
January
2012
January
2013
Activity 8: Identify
resources available to
underserved
communities.
Identify areas of need.
Reach out to offices and regions
to identify resources and staff.
Develop a list and a system for
updating the list.
September
2011
October
2011
May 2012
Activity 9: Explore
how EPA funding,
policies, and programs
can inform and help
local decision makers
to maximize benefits
and minimize adverse
effects from land use
decision making,
planning, and siting.
Establish a workgroup.
Set up a series of meetings to
begin looking at intersection of
Agency work and land use
planning.
Develop an outreach strategy to
get stakeholder feedback.
Develop training course for
stakeholders.
Develop a tool to showcase
findings
May 2011
March 2011
June 2011
December
2011
December
2011
Activity 10: Promote
equitable development
opportunities.
Conduct research on financing
vehicles.
Prepare the Analysis (which will
integrate existing OCFO and
EFAB tools as appropriate).
Produce an "EPA Agency-wide
Financing and Technical
Assistance Vehicle: Strategies to
Apply Them to Support Equitable
Community Development"
and post on the web.
Prepare an outreach
memorandum to other key
agencies, to encourage
application of their tools in ways
that promote equitable
development.
August 1,
2011
September
30,2011
December
31,2011
December
31,2011
Plan EJ 2014: Appendix, Implementation Plans
88
-------
v°/EPA
Progress reports on this implementation plan will be generated annually.
The planned deliverables and milestones for each of the activities are
described in Section 3.0. Each of the offices responsible will further refine
and develop the activities during the process of implementation. For
information, please contact Pat Carey, 202-566-0199, Carey.Pat@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 89
-------
&EPA
1. Community Action for a Renewed Environment (Leads: OW and OAR)
OAR
2. Community-Based Childhood Asthma Program
3. Local Climate and Energy Program (Climate Showcase Communities)
4. EPA School Monitoring Initiative
OSWER
5. Brownfields - Training, Technical Assistance Grants, including Technical
Assistance to Brownfields Communities (TAB) grants
6. Targeted Brownfields Assessment
7. Superfund Job Training Initiative
8. Superfund Redevelopment Initiative
9. Superfund Community Technical Assistance Grants
10. Brownfields Sustainability Pilots
11. Brownfields Assessment, Cleanup, and RLF Grants, including
Brownfields Area-Wide Planning Pilots
12. Superfund Technical Assistance Services for Communities (TASC)
Program
13. Environmental Workforce Development and Job Training Grants
14. Partnership for Sustainable Communities Brownfields Pilots (2010)
15. RE-Powering Feasibility Studies
16. Brownfields and Land Revitalization Technical Support Centers
OW
17. Five Star Restoration Grants Program
18. Lead in Schools Program
29. Urban Waters Initiative
20. Stormwater/Sanitary Sewer Overflow (SSO)/Combined Sewer Overflow
(CSO) permits
Office of Chemical Safety and Pollution Prevention (OCSPP)
21. Community-Based Lead Grant Program
22. Tribal Lead Grant Program
OP
23. Smart Growth Program
Office Indian Affairs (OIA)
24. Indian Environmental General Assistance Program
OECA
25. Environmental Justice Showcase Communities
26. Environmental Justice Small Grants Program
Plan EJ 2014: Appendix, Implementation Plans 90
-------
&EPA
September 2011
Led by
Office of Water and Region 6
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans
91
-------
&EPA
Goals At-A-G lance
To facilitate the active
involvement of all federal
agencies in implementing
EO 12898 by minimizing
and mitigating
disproportionate, negative
impacts while fostering
environmental, public
health, and economic
benefits for overburdened
communities.
1.0 INTRODUCTION
Executive Order 12898, "Federal Actions to Address Environmental Justice
in Minority Populations and Low-Income Populations" (EO 12898), signed
in 1994, calls on all federal agencies to focus attention on, and work with
other stakeholders to, eliminate or remediate the unduly high and adverse
human health or environmental effects that exist in these communities. In
other words, it called for federal agencies to achieve environmental justice.
EO 12898 directs each federal agency to "make achieving environmental
justice part of its mission by identifying and addressing, as appropriate,
disproportionately high and adverse human health or environmental
effects of its programs, policies, and activities on minority populations and
low-income populations," including tribal populations.16
1.1 Goals
Everyone in America deserves to live, work, and play in a healthy and
sustainable community. The goal of this implementation plan is to
facilitate the active involvement of all federal agencies in ensuring a
healthy, sustainable, and green community, as well as equitable
development, for all people. To better achieve this goal, the U.S.
Environmental Protection Agency (EPA) is leading the Administration's
effort to fully implement EO 12898. As each federal agency reinvigorates
its effort to make environmental justice part of its mission, EPA will focus
on helping each federal agency participate in a coordinated approach that
acknowledges the disproportionately high and adverse human health and
environmental impacts on overburdened communities, while providing
access to the environmental, public health, and economic benefits of EPA's
programs.
A coordinated and holistic approach is essential to ensure that we address
the full scope of adverse human health and environmental effects in
overburdened communities, legacy pollution problems rooted in historical
discrimination, and cumulative impacts; and to ensure that all communities
participate in, and benefit from, the transition to a clean energy economy.
1.2 Organizational Structure
The Office of Water (OW) and Region 6 will serve as co-leads for the
Fostering Administration-Wide Action on Environmental Justice cross-
Agency focus area. OW will be supported by the Office of Environmental
Justice (OEJ), the Office of Solid Waste and Emergency Response (OSWER),
the Office of Federal Activities (OFA), the Office of Civil Rights (OCR), and
the Office of Congressional and Intergovernmental Relations (OCIR).
Clinton, William J., Executive Order 12898, "Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations," February 11, 1994, Federal Register 59, No. 32:
7629.
Plan EJ 2014: Appendix, Implementation Plans
92
-------
&EPA
EPA recognizes that Fostering Administration-Wide Action requires
coordination with the White House Council on Environmental Quality
(CEQ), other federal agencies, and EPA's ongoing interagency activities. In
addition, the OFA will address the issues related to the National
Environmental Policy Act (NEPA), and the OCR will address issues related to
Title VI of the Civil Rights Act of 1964. Interagency coordination will also
involve the Federal Interagency Working Group on Environmental Justice
(EJ IWG), which was established under EO 12898 and was reconvened in
September 2010.
Plan EJ 2014: Appendix, Implementation Plans 93
-------
v°/EPA
- .".'
EPA, in conjunction with the White House CEQ and the EJ IWG, has
identified four major strategies for Fostering Administration-Wide Action
on Environmental Justice:
* Assist other federal agencies to integrate environmental justice in their
programs, policies, and activities.
Work with other federal agencies to strengthen use of interagency
legal tools, such as NEPA and Title VI of the Civil Rights Act of 1964.
Foster healthy and sustainable communities, with an emphasis on
equitable development and place-based initiatives.
Strengthen community access to federal agencies.
:'.; " ities
The following activities are intended to carry out the strategies identified
for this implementation plan.
Strategy 1: Assist other federal agencies to integrate environmental
justice in their missions, programs, policies, and activities.
EPA will lead the Administration's effort to better integrate environmental
justice into federal agency programs, policies, and activities by chairing the
EJ IWG. The Administration is dedicated to ensuring that everyone has the
opportunity to live in a healthy and sustainable community, particularly
those living in overburdened communities. As part of this Administration-
wide effort, EPA has taken the lead in reinvigorating the EJ IWG. Under EO
12898, the EJ IWG is chaired by the EPA Administrator and comprised of
principals from other agencies. The purpose of the EJ IWG is to guide,
support, and enhance federal environmental justice and community-based
activities.
The following five activities will be conducted to implement this strategy:
Activity 1.1: Chair and convene EJ IWG Principal, Deputy, and Senior
Staff meetings. EPA and the other federal agencies place a high priority
on facilitating the integration of environmental justice into federal
agency programs, policies, and activities. For example, in 2010, EPA
and CEQ reconvened the EJ IWG for the first time in over a decade.
The White House, EJ IWG members, and other federal agency
representatives expressed their commitment to meet their
responsibilities under EO 12898. EPA and CEQ also hosted the first
White House Forum on Environmental Justice. At the Forum, EJ IWG
members and other federal agency representatives reengaged with
environmental justice advocates about issues that are important to
overburdened communities. Moving forward, EPA will continue to lead
EJ IWG meetings and events.
Plan EJ 2014: Appendix, Implementation Plans 94
-------
&EPA
Activity 1.2: Chair, assist, and oversee each federal agency's effort to
update or develop its environmental justice strategy. This
Administration is committed to identifying, evaluating, and reducing
environmental and human health burdens while increasing
environmental and human health benefits in overburdened
communities. Accordingly, each federal agency will update, or in some
cases develop, an environmental justice strategy that will be
responsive to the environmental and human health needs of
overburdened communities.
Activity 1.3: Lead the effort to organize regional events. EPA and other
federal agencies recognize that, to successfully address the needs of
overburdened communities, federal agencies must engage
environmental justice stakeholders in and around their communities.
To further this effort, EPA will lead the development of regional events
where EJ IWG members and other federal agency representatives will
meet with environmental justice stakeholders to discuss and help
resolve issues that are important to communities in each region.
Activity 1.4: Develop and provide tools that help environmental justice
and other stakeholders identify federal information and resources. This
Administration recognizes the need to provide federal resources,
contact information, lessons learned, and other information to
environmental justice stakeholders. As a result, EPA will develop
information and resource tools to promote collaboration between
federal agencies and environmental justice stakeholders and improve
opportunities for environmental justice stakeholders to utilize federal
resources.
Activity 1.5: Convene a group of senior attorneys from across the
federal government to promote the integration of environmental
justice into their agencies' actions. In partnership with the U.S.
Department of Justice (DOJ), EPA's Office of General Counsel (OGC),
the Office of Enforcement and Compliance Assurance (OECA), and the
Office of Regional Counsel (ORC) will bring together attorneys from
agencies across the federal government that have an interest in
environmental justice. We will convene monthly meetings at the staff
level to share information about legal issues the agencies have
encountered and think through the role of agency attorneys in
promoting their agencies' environmental justice policies. We also hope
to develop other forms of information-sharing tools. Our goal is to
help EJ IWG members and other agencies with environmental justice
interest to understand the legal tools available to them to promote
environmental justice.
Plan EJ 2014: Appendix, Implementation Plans 95
-------
&EPA
Strategy 2: Work with other federal agencies to strengthen use of
interagency legal tools, such as the National Environmental Policy Act and
Title VI of the Civil Rights Act of 1964.
National Environmental Policy Act (NEPA)
NEPA is an important tool that can be used to help advance the goals of
environmental justice. NEPA emphasizes transparency and public
involvement and promotes better, more responsible decision making by
the federal government. Namely, NEPA requires federal agencies to assess
and disclose environmental impacts, which include environmental justice
considerations, when proposing actions. Further, under the Clean Air Act
(CAA) Section 309, EPA is mandated to review Environmental Impact
Statements (EIS), comment in writing, and make those comments available
to the public. These reviews include an assessment of whether the
requirements of EO 12898 and the accompanying Presidential
Memorandum on environmental justice are considered and integrated
within the NEPA process. We have identified a number of activities that
EPA, in concert with other federal agencies, can take to strengthen all
agencies' abilities to incorporate environmental justice into major federal
activities.
Activity 2.1: Articulate a consistent message about the need to
incorporate environmental justice into NEPA implementation efforts.
We will articulate a clear, consistent message about need to
incorporate environmental justice considerations into NEPA
implementation efforts. We will reinforce the utility of NEPA as a tool
to effect good environmental decision making and take environmental
justice into account through CAA Section 309 reviews. In addition to
improving internal collaboration on environmental justice, a clear
message will enable the Agency to send consistent messages to
external stakeholders.
Activity 2.2: Enable federal NEPA practitioners to enhance
consideration and execution of environmental justice requirements in
NEPA implementation efforts. We will develop tools to help federal
NEPA practitioners in EPA and other agencies enhance environmental
justice considerations in NEPA implementation efforts by identifying
and disseminating best practices in general and in specific sectors.
These tools can assist agencies in analyzing environmental impacts and
community concerns and will emphasize the benefits of having robust,
agency-specific formal NEPA-specific environmental justice guidance.
Title VI of Civil Rights Act of 1964
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis
of race, color, and national origin, including matters related to language
access for limited English proficient persons, by recipients of federal
financial assistance. Under EPA's Title VI regulations, recipients of EPA
financial assistance are prohibited from, among other things, using "criteria
or methods of administering its program which have the effect of
Plan EJ 2014: Appendix, Implementation Plans 96
-------
&EPA
subjecting individuals to discrimination based on their race, color, or
national origin." For example, facially-neutral policies or practices that
result in discriminatory effects violate EPA's Title VI regulations, unless it is
shown that they are justified and that there is no less discriminatory
alternative. In addition, EPA's regulations and Title VI prohibit intentional
discrimination by recipients. Other similar laws prohibit discrimination on
the basis of age, sex, and disability by recipients of federal financial
assistance.
OCR has identified two activities that EPA, in concert with DOJ, can take to
strengthen the use of Title VI:
Activity 2.3: Consult with DOJ to strengthen the use of Title VI of the
Civil Rights Act of 1964 by re-evaluating the approach for analyzing
Title VI complaints.
Activity 2.4: Collaborate with DOJ and within EPA, to develop
compliance strategies and actions to address non-compliance.
Strategy 3: Foster healthy and sustainable communities, with an
emphasis on equitable development and place-based initiatives.
Increasingly, environmentally and economically burdened communities are
seeking comprehensive solutions that address adverse human health and
environmental effects, as well as health disparities, while enabling these
communities to make a transition to sustainable community development.
Communities are calling upon federal agencies to work in a coordinated
manner. Resulting efforts will improve community access to the
environmental, public health, and economic benefits that define a healthy
and sustainable community.
By mobilizing the resources of all federal agencies, the EJ IWG can foster
efforts to ensure that we address adverse human health and
environmental effects in overburdened communities, including legacy
pollution problems rooted in historical discrimination and cumulative
impacts, and ensure that all communities participate in, and benefit from,
the transition to a clean energy economy.
As a result of community input and the White House Forum on
Environmental Justice, the EJ IWG identified four areas of significant
concern to overburdened communities:
Green Jobs and Clean Energy.
Healthy and Sustainable Communities.
Climate Change and Adaptation.
Goods Movement.
The following activity will be conducted to implement Strategy 3.
Activity 3.1: Recommend ways to enhance federal interagency
coordination in support of healthy and sustainable communities as well
as equitable development. EPA, in conjunction with other federal
Plan EJ 2014: Appendix, Implementation Plans 97
-------
&EPA
agencies, will develop a proposal to the EJ IWG for how federal
agencies can coordinate action in each of the four areas identified
above to improve the health and sustainability of overburdened
communities in the implementation of existing executive orders and
administration priorities. Federal agencies will make community
engagement an important part of our efforts to identify environmental
justice issues and opportunities for interagency collaboration. Actions
should be based on the following principles:
o Designate an EJ IWG agency to serve as lead.
o Build on and leverages existing Administration initiatives.
o Enhance existing policies or programs to address
environmental justice issues.
o Identify data needs and success measures.
o Identifies place-based project for coordinated action, if
appropriate.
o Address issues of community access to resources and technical
assistance.
o Promote state, regional, local, and tribal partnerships.
o Utilize regional forums and other community outreach to
inform federal actions.
Strategy 4: Strengthen Community Access to Federal Agencies.
In the priorities outlined by Administrator Lisa Jackson last year, she
highlighted the importance of expanding the conversation on
environmentalism and working for environmental justice. With that
priority in mind, the Administrator acknowledged the importance of
reaching out to and engaging with communities. As part of this interagency
focus on environmental justice, one of EPA's goals is to strengthen the
ability of communities to access the federal programs and the expertise
that they need to realize their goals for a healthy and sustainable way of
life. In support of that goal, EPA will implement actions that eliminate
barriers, make connections, fill gaps, and reduce duplication so that
communities are better able to access the federal resources they need.
Activity 4.1: Community Needs Inventory Pilot. In order to determine
the areas of interagency cooperation that need improvement, the EPA
regions will select three communities of concern about which they
have extensive knowledge. Each EPA region will develop an inventory
of the communities' already-identified needs and then identify the
federal agency(ies) that could address each need. Once that has been
accomplished for all regions, a data set of thirty communities will be
available so that the EJ IWG can identify trends - for example, those
three or four federal agencies whose assistance is needed in the
broadest number of communities. The product of this internal EPA
analysis will be a request to the Administrator to approach those
agencies through the EJ IWG for a commitment and the development
of strategies.
Plan EJ 2014: Appendix, Implementation Plans 98
-------
&EPA
Activity 4.2: Targeted Training for Communities. EPA will identify
appropriate delivery mechanisms to convey information to
communities on existing federal programs and expertise relevant to
them. This information will be based on the work already underway in
the EJ IWG and EPA's Office of Policy (OP) to catalog existing federal
programs and expertise. Potential delivery mechanisms include
trainings, conferences, and webinars.
Activity 4.3: Review Federal Partners Meeting. EPA will review action
items from the April 2010 Federal Partners Meeting, determine which
recommendations support strengthening community access to federal
agencies, and determine how to incorporate them into this
implementation plan. This will result in a more robust implementation
plan in the future and will help advance the outcomes of the Federal
Partners Meeting. This is being done in coordination with Plan EJ 2014
community-based action efforts.
Activity 4.4: Coordination with Agency Community-Based Coordination
Efforts. A member of this Fostering Administration-Wide Action on
Environmental Justice Workgroup will participate on the parallel
workgroup under the OP's Community-Based Coordination Efforts
(CBCE) Initiative's cross-Agency External Coordination Workgroup. This
person will ensure that environmental justice communities' needs are
adequately addressed in each of the activities recommended and
ultimately undertaken. The CBCE cross-Agency External Coordination
Workgroup is recommending a number of activities, including:
o Cataloguing existing community-based efforts with interagency
coordination.
o Mining existing community-based efforts with interagency
coordination for best practices.
Improving community access to federal agency resources, including a
website portal that will serve as a one-stop shop for communities to access
all federal agencies according to searchable needs and key words.
Plan EJ 2014: Appendix, Implementation Plans 99
-------
&EPA
2,3 arid
Community engagement and stakeholder partnership activities are
integrated into the different strategies and activities of this
implementation plan. Many of the strategies and activities in this plan
resulted from community dialogues and the National Environmental Justice
Advisory Council's (NEJAC) advice and recommendations. In addition, we
will coordinate our community outreach and stakeholder involvement
effortswithOEJ.
Plan EJ 2014: Appendix, Implementation Plans 100
-------
&EPA
3.0 DELIVERABLES
Strategy 1: Assist other federal agencies to better integrate environmental
justice into agency programs, policies, and activities.
ACTIVITY
Activity 1.1: Chair and
convene EJ IWG
Principal, Deputy, and
Senior Staff meetings.
DELIVERABLES
Chair annual
Principals/Deputies
meetings.
Chair Senior Staff
meetings/calls.
MILESTONES
By the end of
2011
Monthly
Activity 1.2: Chair,
assist, and oversee
each federal agency's
effort to update or
develop its
environmental justice
strategy.
Oversee the
finalization of each
Agency's
environmental justice
strategy.
By the end of
2011
Activity 1.3: Lead the
effort to organize
regional events.
Hold at least one
event in each EPA
region, or in
appropriate
equivalent.
By the end of
2011
Activity 1.4: Develop
and provide tools that
help environmental
justice and other
stakeholders identify
federal information and
resources.
Publish a draft
Federal
Environmental
Justice Directory and
draft Federal
Resource Guide.
Review EPA's EJ
IWG website.
Update EPA's EJ
IWG website.
By the end of
2011
Annually
As appropriate
Activity 1.5: Convene
a group of senior
attorneys from across
the Administration in
order to promote the
integration of
environmental justice
into their agencies'
actions.
Conduct meetings on
regular basis.
As appropriate
Plan EJ 2014: Appendix, Implementation Plans
101
-------
&EPA
Strategy 2: Work with other federal agencies to strengthen use of
interagency legal tools, i.e., National Environmental Policy Act and Title VI
of Civil Rights Act of 1964.
ACTIVITY
Activity 2.1: Articulate
a consistent message
about the need to
incorporate
environmental justice
into NEPA
implementation.
DELIVERABLES
Issue a directive to NEPA
reviewers emphasizing
environmental justice,
reinforcing the utility of NEPA
through CAA Section 309
reviews as a tool to effect
good decisions and take into
account environmental justice
considerations.
Stakeholder outreach:
Work with regional
managers. Post on web.
MILESTONES
March 31, 2011
Activity 2.2: Enable
federal NEPA
practitioners to
enhance consideration
and execution of
environmental justice
requirements in NEPA
implementation.
Engage with federal agencies
to identify unique or "best
practices." Develop
information on "best practices"
for implementing
environmental justice
requirements in the NEPA
process and post on the
internet.
Stakeholder outreach:
Work with EPA
environmental justice
experts and regional
NEPA practitioners.
Share with the NEJAC.
Work with the EJ IWG, White
House CEQ, federal agencies,
and the NEJAC to urge that all
federal agencies with NEPA
responsibilities have robust
agency-specific guidance in
place setting forth a process to
meaningfully consider
environmental justice in the
NEPA EIS process. EPA will
identify and disseminate
examples/components of
strong guidance.
Stakeholder outreach: EJ
IWG, White House CEQ,
NEJAC.
Develop a best practices tool
for regulators to analyze
specific environmental impacts
and identify typical community
concerns for a particular
sector.
September 30,
2011
June 30, 2011
September 31,
2011
Plan EJ 2014: Appendix, Implementation Plans
102
-------
&EPA
1 ACTIVITY
Activity 2.3: Develop
a plan of action, in
consultation with DOJ,
which will outline how
EPA will re-evaluate the
approach for analyzing
Title VI complaints.
Activity 2.4:
Collaborate with DOJ
and EPA to develop
compliance strategies
and actions to address
non-compliance.
DELIVERABLES MILESTONES
Stakeholder outreach:
Work with affected
regions, communities, and
federal and state
regulators.
Convene stakeholder dialogue
to discuss the re-evaluation of
the approach for analyzing
Title VI complaints.
Stakeholder Outreach:
Work with EPA; DOJ;
state agencies;
businesses; and civil
rights, environmental
justice, community, and
other experts.
Develop a comprehensive
plan of action that will outline
how EPA will implement this
approach.
Stakeholder Outreach:
Work with EPA and DOJ.
Convene EPA, DOJ, and other
federal agencies to hold
stakeholder dialogues to
discuss the development of
compliance strategies and
actions to address non-
compliance.
Stakeholder Outreach:
Work with EPA, DOJ, and
other federal agencies.
June 30, 2011
September 30,
2011
November 30,
2011
Plan EJ 2014: Appendix, Implementation Plans
103
-------
&EPA
Strategy 3: Foster Healthy and Sustainable Communities, with emphasis on
equitable development and place-based initiatives.
1 ACTIVITY DELIVERABLES MILESTONES
Activity 3.1:
Recommend ways by
which the EJ IWG can
enhance interagency
coordination in support
of healthy and
sustainable
communities.
Develop proposal to EJ IWG
for how federal agencies can
coordinate action to improve
the health and sustainability of
overburdened communities in
the implementation of existing
executive orders and
administration priorities, in the
at least two of the following
four areas:
Clean Jobs and Clean
Energy.
Healthy and Sustainable
Communities.
Climate Change and
Adaptation.
Goods Movement.
September 30,
2012
Strategy 4: Strengthen Community Access to Federal Agencies.
ACTIVITY
Activity 4.1:
Community Needs
Inventory Pilot.
DELIVERABLES
Inventory of three Region 6
environmental justice
communities' needs and
corresponding federal
agencies.
Inventory of 27 remaining
regional environmental justice
communities' needs and
corresponding federal
agencies.
Analysis of commonalities and
trends.
Recommendations made to
Administrator to take to the EJ
IWG.
MILESTONES
April 30, 2011
By June 15,
2011
By December
31,2011
By May 31,
2012
Activity 4.2: Targeted
Training for
Communities.
Assessment of program
cataloging results in the
EJ IWG and OP efforts.
Identification of best
delivery mechanisms to
reach communities.
By September
30,2011
Plan EJ 2014: Appendix, Implementation Plans
104
-------
&EPA
1 ACTIVITY
Activity 4.3: Review
Federal Partners
Meeting
Recommendations.
Activity 4.4:
Coordination with
Agency CBCE Initiative.
DELIVERABLES MILESTONES
Identification of
recommendations from the
April 2010 Federal Partners
Meeting to determine which to
incorporate.
Draft options paper for
Executive Management
Council (EMC) review.
Form workgroups to
implement selected actions.
By June, 2011
By February 15,
2011
To be
determined
Plan EJ 2014: Appendix, Implementation Plans
105
-------
vvEPA
Progress reports on this implementation plan will be made annually. The
planned deliverables and milestones for each of the activities are described
above. Each of the offices responsible will further refine and develop the
activities during the process of implementation. For information, please
contact Sherri White, 202-564-2462, White.Sherri@epa.gov; or Alice
Walker, 202-529-7534, Walker.Alice@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 106
-------
&EPA
September 2011
Led by
Office of Research and Development
And Region 7
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans 107
-------
&EPA
Goals At-A-G lance
To substantially support
and conduct research that
employs participatory
principles and integrates
social and physical
sciences aimed at
understanding and
illuminating solutions to
environmental and health
inequalities among
overburdened populations
and communities in the
United States.
1.0 INTRODUCTION
Under Plan EJ 2014, the U.S. Environmental Protection Agency (EPA) has
committed to building a strong scientific foundation for supporting
environmental justice and conducting disproportionate impact analysis,
particularly methods to appropriately characterize and assess cumulative
impacts. These efforts will help to ensure that EPA brings the best science
to decision making around environmental justice issues.
This Science Tools Development Implementation Plan discusses
overarching goals, strategies, and activities, including a science and
research agenda for the Agency. The science and research activities
described in this plan build upon discussions and recommendations from
"Strengthening Environmental Justice and Decision Making: A Symposium
on the Science of Disproportionate Environmental Health Impacts" (March
17-19, 2010) and the workshop on "Analytical Methods for Assessing the
Environmental Justice Implications of Environmental Regulations" (June 9-
10, 2010). The March 2010 Symposium was the principal event for the
Agency to identify science needs for environmental justice and stimulate
ideas for innovative research to meet those needs.
1.1 Goals
Our goal is that, within five years, EPA will substantially support and
conduct research that employs participatory principles and integrates
social and physical sciences aimed at understanding and illuminating
solutions to environmental and health inequalities among overburdened
populations and communities in the United States. This goal supports our
vision that all Agency decisions will make use of the information, data, and
analytic tools produced. Our goal has two specific elements:
1. Improve the scientific basis for environmental regulatory and policy
decisions in order to ensure that everyone enjoys the same degree of
protection from environmental and health hazards and equal access to
the decision-making process to have a healthy environment in which to
live, learn, and work.
2. In order to increase the relevance of science to policy making,
transform how EPA formulates, designs, prioritizes, conducts, and
fosters more citizen participatory, inclusive, co-production of
knowledge, and collaborative processes within the scientific research
enterprise.
Plan EJ 2014: Appendix, Implementation Plans
108
-------
&EPA
We have five major strategies to achieve our goals.
1. Apply integrated transdisciplinary and community-based participatory
research approaches with a focus on addressing multi-media,
cumulative impacts and equity in environmental health and
environmental conditions.
2. Create mechanisms to incorporate perspectives from community-
based organizations and community leaders into EPA's research
agendas and engage in collaborative partnerships with them on science
and research to address environmental justice.
3. Leverage partnerships with other federal agencies on issues of
research, policy, and action to address health disparities.
4. Build and strengthen the technical capacity of Agency scientists on
conducting research in partnership with impacted communities and
translating research results to inform change.
5. Build and strengthen technical capacity of community-based
organizations and community environmental justice and health leaders
to address environmental health disparities and environmental
sustainability issues.
1, !
Multiple aspects of the physical environment in which we live, learn, work,
and play can put certain groups of people "at higher risk." Also, individuals
and groups may experience disadvantages related to their gender,
lifestage, socioeconomic status, race, ethnicity, disability, education,
geographic location, or other characteristics historically linked to
discrimination or exclusion. This complex interaction between the physical
environment and other conditions of social disadvantage contributes to
known social disparities in environmental health outcomes.
Since 1994, as stated in the Executive Order 12898 (EO 12898), it has been
incumbent upon all federal agencies including EPA to identify and address
disproportionately high and adverse human health or environmental
effects on minority and low-income populations that may result from their
programs, policies, and activities. The concept of disproportionate
environmental health impacts and burdens refers to the finding that some
populations systematically experience higher levels of risks and impacts
than the general population. (Brulle and Pellow 2006) This perspective
recognizes that multiple factors, including social, psychosocial, economic,
physical, chemical, and biological determinants may contribute to
disproportionately high and adverse human health or environmental
impacts.
Plan EJ 2014: Appendix, Implementation Plans 109
-------
&EPA
The importance of science in environmental decision making at EPA
emphasizes the need for data and information that is sound and
defensible, reproducible, and informative. For environmental justice
stakeholders, it is even more important that the science underlying EPA's
decisions appropriately accounts for the multiple exposures to chemical
stressors and cumulative impacts from multiple exposures that they
experience in their communities. Further, the social and real world context
in which exposures to environmental contaminants occur also needs to be
explicitly considered and reflected in EPA's scientific research and analysis
as emerging evidence demonstrates that social context may enhance the
toxic effects of both single and multiple environmental contaminant
exposures. Such considerations require new models for assessing the
toxicity of environmental hazards, advanced methods for analyzing
complex interactions between multiple stressors, and enhanced access to
community-level wisdom and resources.
These emerging needs indicate that new ways of conducting scientific
inquiry to inform environmental decision are needed at EPA. Such
expansion and advancement of EPA's scientific agenda, methods, models,
research inquiry approaches, and information resources is necessary for
the Agency to adequately address environmental justice stakeholder's
concerns about environment, sustainability, and health inequalities. These
advancements take on additional importance when viewed in the context
of the Agency's mandate to achieve environmental justice as required by
EO 12898, and its ability to effectively contribute towards Healthy People
2020's overarching goals to achieve health equity, eliminate health
disparities, improve the health of all groups, and create social and physical
environments that promote good health for all.17
Conversely, health and environment status can influence, for example, the
social and institutional arrangements, which can lead to both negative and
positive outcomes cumulatively impacting the health of a community. The
cumulative impact has greater and farther-reaching consequences than any
one factor or event alone; this is particularly evident among vulnerable
low-income and underserved populations. In order to determine the
positive and negative health and environmental impacts during some of
the social processes described above, the scientific research requires both
quantitative and qualitative approaches.
The goals, strategies, and activities for this implementation plan build upon
the science recommendations articulated at the March 2010 symposium,
Strengthening Environmental Justice Research and Decision- Making: A
Symposium on the Science of Disproportionate Environmental Health
Impacts, and the subsequent "100-Day Challenge" Report developed by the
Agency in response to recommendations generated from the symposium.
Healthy People is a set of goals and objectives with 10-year targets designed to guide national health
promotion and disease prevention efforts to improve the health of all people in the United States.
Plan EJ 2014: Appendix, Implementation Plans 110
-------
&EPA
A consistent theme throughout the March 2010 symposium was the
linkages between science and policy. These discussions were framed
within the context of identifying research and scientific needs that are
necessary to ensure that environmental justice concerns and social
disparities in environmental health are incorporated in EPA's decisions for
the purpose of advancing EPA policy on environmental justice. Several
conceptual frameworks have been published in the last few years that
relate environmental justice and health disparities to upstream, structural
determinants of health (CSDH 2008; Gee and Payne-Sturges 2004; Krieger
2001; Habermann and Gouveia 2008; Morello-Frosch 2002; Morello-Frosch
and Shenassa 2006; Schulz et al 2002; Wakefield and Baxter 2010).
Symposium participants suggested several actions that EPA and other
federal agencies take in order to reduce data gaps in the area of
environmental justice, overcome limitations in the theories and methods
for conducting research on environmental health disparities and
particularly research supported by the federal government, and overcome
limitations in practice of risk assessment at EPA. The science
recommendations from environmental justice advocates and other
stakeholders are captured in Appendix C.
Plan EJ 2014: Appendix, Implementation Plans 111
-------
&EPA
i; .
The specific science and research actions described in Section 2.0 were
developed through a cross-Agency workgroup for the Agency's 100-Day
Report follow-up to the March 2010 Symposium. Representation on the
workgroup included the Office of Air and Radiation (OAR), the Office of
Chemical Safety and Pollution Prevention (OCSPP), the Office of Policy (OP),
the Office of Solid Waste and Emergency Response (OSWER), the Office of
Water (OW), the Office of Research and Development (ORD), and Regions
6, 7, 8, and 10. Region 7 serves as ORD's Lead Region.
Going forward, ORD, as lead for the Science Tools Development
Implementation Plan, proposes to establish a more permanent structure
within ORD, which we are planning to name the Environment Health and
Society Workgroup. This workgroup will serve as ORD science experts and
points of contact on environmental justice, environmental disparities, and
disproportionate impacts science issues. ORD's National Center for
Environmental Research (NCER) and the Office of Science Policy (OSP) will
jointly sponsor and co-chair this new workgroup. The co-chairs will also
lead the Plan EJ 2014 Science Tools Development Workgroup and monitor
the Science Implementation Plan for Plan EJ 2014. ORD is considering re-
constituting the intra-agency group on science for the 100-Day Report to
serve as the Plan EJ 20114 Science Group. ORD will coordinate with all the
Plan EJ 2014 implementation workgroups to ascertain how current
activities can be better tailored or leveraged to address Plan EJ 2014
workgroups' science needs under the five strategies (listed in Section 1.2)
and to identify future science activities.
Plan EJ 2014: Appendix, Implementation Plans 112
-------
v°/EPA
2.0
Below we describe several major science and research activities under the
five strategies. These activities will be carried out with existing resources,
provided these resources remain available.
' ' "
Strategy 1: Apply integrated transdisciplinary and community-based
participatory research approaches with a focus on addressing multi-
media, cumulative impacts and equity in environmental health and
environmental conditions.
Activity 1.1: Establish an Integrated Transdisciplinary ORD Research
Program on Environment and Community Health -Sustainable and Healthy
Communities Research Program.
The new Administration at EPA and in particular in ORD recognizes that
fragmented research programs cannot solve 21st century environmental
challenges including disparities in environmental health. ORD is leading the
way by integrating 12 research programs that were mostly media-specific
into four transdisciplinary programs aligned with EPA's new Strategic Plan.
As part of this re-structuring, ORD is fully establishing and supporting a new
integrated transdisciplinary research program on environment and
community health known as "Sustainable and Healthy Communities." This
program seeks to adopt a more holistic view of environment and health as
its conceptual framework, take on research projects that address many of
the topics raised at the Symposium, and conduct research in a manner
consistent with principles of community-based participatory research.
Both ORD intramural and extramural resources from existing human
health, land, sustainability, and ecosystems research programs would be
directed to support this new program. For this new research program to
be successful, implementation of many of the recommended actions on
capacity building within ORD and incorporating community perspectives is
critical.
As part of the new Sustainable and Healthy Communities Research
Program (SHCRP), EPA's new Science to Achieve Research (STAR) grant
solicitations are being considered to support tribal community
environmental health research and to establish Centers of Excellence on
Environment and Health Disparities to examine the joint impacts of social
and physical environmental conditions, processes and systems on health in
collaboration with the National Institutes of Health's (NIH) National Center
on Minority Health and Health Disparities (NCMHD).
Plan EJ 2014: Appendix, Implementation Plans 113
-------
&EPA
Benefits to EPA Stakeholder Communities
ORD's new research program is responsive to suggestions from
stakeholders to create and institute a new scientific research approach
that develops a more holistic understanding of the environmental and
health. This approach will also integrate perspectives from community
residents and leaders, community-based non-governmental
organizations (NGOs), and community health and environmental
quality advocates in the development of EPA's scientific research
agendas, as well as in data collection, conduct of risk and exposure
assessments, and risk management decisions.
The hallmark of the integrated proposed transdisciplinary approach is
"systems thinking," which seeks to understand the complex
interactions between social, natural, and built environmental systems,
conditions and policies that impact human health and well-being. To
explicitly address environmental justice concerns, this program will
need to direct its attention to how these complex interactions result in
unequal environmental health conditions or disproportionate impacts
among (diverse) disadvantaged population groups, communities,
neighborhoods and individuals.
Anticipated outcomes of this program include new information and
tools to support more holistic environmental decision making at
national, regional, state, tribal, and local levels. It is anticipated that
this program will also inform strategies for alleviating systemic drivers
of racial and socio-economic disparities in environmental health
outcomes and access to healthy environments.
Impacts on EPA Programs and Activities
The Assistant Administrator for ORD announced the re-structuring of
ORD's 12 media-specific research programs into four integrated
programs in Fall 2010. The Sustainable and Healthy Communities
Research Program is an important part of this effort. This new program
is currently in the early stages of organizing and development. Input
from EPA program offices will be sought in early 2011. Then in late
spring, input from outside stakeholders will be solicited. Bringing
together diversity of disciplines to plan and implement integrated
research programs will make EPA more effective at developing
sustainable solutions to complex, 21st century environmental
problems. It will create a culture where different disciplines are
encouraged to find innovative solutions and will make EPA's research
more timely, relevant and responsive to the short-, medium- and
longer-term needs of our partners and stakeholders. Several external
advisory committees continue to recommend this approach.
Plan EJ 2014: Appendix, Implementation Plans 114
-------
&EPA
Timeframe
Establish and fully support a Sustainable and Healthy Communities
Research Program (Fiscal Year [FY] 2011).
Incorporate ideas and concerns from stakeholders and representatives
from disproportionately impacted communities and populations (FY
2011).
Issue joint Request for Applications (RFA) or other funding mechanisms
to collaborate with NIH National Institute on Minority Health and
Health Disparities to establish Centers of Excellence on Environment
and Health Disparities (FY 2012).
Activity 1.2: Develop technical guidance, analytic methods, tools and data
to advance the integration of environmental justice in EPA's decision
making.
EPA's regulatory decision making is informed by scientific data and analysis.
To facilitate the process of using scientific data, EPA scientists and decision
makers, as well as communities, community advocates and other
stakeholders, require consistent and systematic guidance on how to
conduct these analyses. They also depend on scientifically valid tools and
methods, as well as information communicated by environmental data.
While the guidance, methods, tools, and data for advancing environmental
health protection has been an area of significant investment by EPA, these
tools of the trade have not been fully adapted or developed to specifically
address environmental justice issues.
EPA's commitment to integrating environmental justice in all of its
decisions, policies, and programs has resulted in investments to develop
technical guidance, analytic methods, tools, and data. For example, EPA is
in the process of developing guidance entitled "Technical Guidance for
Incorporating Environmental Justice into Rulemaking Activities" through
Plan EJ 2014's Incorporating Environmental Justice into Rulemaking
Implementation Plan. This document is expected to aid EPA staff and
managers in incorporating environmental justice into EPA's analytical
frameworks such as risk assessment, and economic analysis, and other
scientific and policy assessments.
EPA's OAR is piloting several kinds of analyses that are useful in informing
managers about the potential environmental justice implications of air
rulemakings. OAR is evaluating and testing several analytical approaches
including: (1) proximity-based socio-demographic analyses, which highlight
the characteristics of those living closest to sources of air pollution; (2)
exposure and health risk modeling that breaks out data based on socio-
demographic characteristics (e.g., race, income); and (3) benefits mapping
that shows the distribution of benefits of a regulation to various socio-
demographic groups. OAR expects to learn from their experiences in using
these approaches. OAR will revise its methods accordingly, as it seeks to
do a better of job of identifying rules that may present environmental
justice concerns and to understand more fully the implications of air rules
Plan EJ 2014: Appendix, Implementation Plans 115
-------
&EPA
on overburdened populations. OAR's experiences will help to inform the
overall Agency effort to develop the technical guidance.
ORD plans to evaluate existing tools developed by ORD scientists with
respect to appropriateness and ease of use for lay experts in communities.
To improve access to Agency tools, ORD plans to work with stakeholders to
develop a series of free regionally-based trainings on EPA's information and
assessment tools. ORD also plans to partner with EPA regional offices,
other federal agencies, and consortia of environmental justice and
community health non-profits and community-based organizations to host
community-based tools workshops and Regional Tools Summits. There will
be a specific focus on tools to evaluate environmental justice and health
disparities policies and programs.
ORD proposes to continue to develop cumulative risk/impact assessment
techniques and analytics, tools, and mapping methods that can be applied
at multiple geographic scales. For example, ORD has committed $8 million
in research investment through STAR grants on cumulative risk assessment
methods that incorporate community social contexts (non-chemical
stressors) and indicators of population vulnerability (see
http://www.epa.gov/ncer/cumulativerisk). The Agency will ensure
research results from these new STAR grants on cumulative risks, and
chemical and non-chemical stressors are well disseminated and used by
EPA program offices.
ORD's Office of the Science Advisor (OSA) and the National Exposure
Research Laboratory (NERL) have launched an initiative to develop a web-
based cumulative risk assessment tool, the Community Cumulative
Assessment Tool (CAAT). This tool will enable a more complete and
thorough evaluation and understanding of physiological and socioeconomic
stressors that result in cumulative impacts in U.S. communities and
populations. This broader framework for decision making leads to
inherently more sustainable outcomes as a result of a more complete
understanding of the factors constituting and contributing to risk in
identified populations.
The CCAT is designed to implement a multi-media approach to cumulative
risks in communities facing environmental justice issues; and will leverage
datasets, research, and certain Geographic Information System (GIS)
capabilities that were developed for C-FERST in the Communities and
Cumulative Risk Research Program in ORD. The CCAT will also reflect the
cumulative impact considerations outlined in the "Technical Guidance for
Incorporating Environmental Justice into Rulemaking Activities" and
provide insight on environmental justice to the Risk Assessment Forum
(RAF) Technical Panel developing the EPA Cumulative Risk Assessment
(CRA) Guidelines. The project is directly responsive to the recognition that
vulnerability and health disparities are interrelated and must be studied
within the risk assessment paradigm. The developers of the CCAT will
engage with environmental justice and community-based stakeholders to
Plan EJ 2014: Appendix, Implementation Plans 116
-------
&EPA
inform the development of the CCAT and related agency cumulative risk
assessment guidelines. This approach purposely builds skills among EPA
scientists to design research and risk assessment protocols informed by
collaboration with affected communities.
At the March 2010 Symposium, participants requested EPA to develop
easy-to-use GIS tools. ORD's National Atlas of Ecosystem Services is
developing an Urban Atlas, which will include high-resolution mapping for
100-250 populated areas selected along several gradients of concern (e.g.,
size, location, demographics, and environmental and health condition). It
will feature selected small towns and rural communities, including rural
Tribal lands. By mapping the current availability of "green" infrastructure
and applying existing models for pollutant removal, water storage, and
other functions, ORD's National Atlas will estimate the extent to which
ecosystem services contribute to the basic needs of populated places.
Additionally, the Atlas will reveal under-served areas where
management to enhance specific ecosystem services would benefit
community health and well-being. This local component of the
Atlas will include demographic mapping to identify overburdened
sub-populations that may benefit disproportionately from "green"
infrastructure and/or are disproportionately underserved. The
Atlas will permit stratification of urban and other populated areas
to develop separate estimates of ecosystem services for
communities identified as socially vulnerable. Additionally, it will
incorporate accessible health data to map aspects of population
susceptibility to diminished or degraded services. EPA is
conducting this project in collaboration with multiple federal
agencies, including the U.S. Forest Service, the U.S. Geological
Survey, and the Centers for Disease Control and Prevention, as well
as academic and other educational organizations. EPA regions and
ORD's Human Health Research Program are interacting with
communities to identify priority issues and build capacity for
working with mapping tools to inform risk evaluation and
management decisions.
EPA's ORD is also developing an Environmental Quality Index tool for
measuring county level environmental quality, which will increase
understanding about how multiple stressors simultaneously contribute to
health disparities in minority, low-income, tribal, and indigenous
populations.
Plan EJ 2014: Appendix, Implementation Plans 117
-------
&EPA
Benefits to EPA Stakeholder Communities
The development of guidance, methods, tools, and data to advance the
integration of environmental justice into EPA's decision-making
processes is responsive to several comments provided by stakeholders.
For example, these activities address suggestions that EPA consider the
areas of policy, capacity building, and promoting healthy and
sustainable communities. These stakeholder comments recommend
EPA to: (1) develop analytic and assessment tools and data collection
approaches that can be used by community health advocates and
environmental justice groups; (2) adopt multi-media cross-program
approaches to addressing cumulative environmental exposures in
stakeholder communities, as well as restructuring risk assessment to
better account for multiple stressors; (3) increase community capacity
to assess their environment; (4) develop a more holistic understanding
of environment and health; and (5) integrate environmental justice in
all its decisions. Better integration of environmental justice into EPA's
decisions directly benefits communities impacted by EPA's regulatory
activities. The overarching goal of developing these tools of the trade
is to aid EPA staff to develop regulatory options that fully protect the
health and environment of all people, as well as help communities to
better understand their environmental problems.
Community-based "stakeholders" will benefit from CCAT through
access to improved information that integrates their own
understanding of local conditions with data drawn from EPA's
databases. Depending upon application, benefits may include
improved capacity to collaborate with Agency experts, identify
priorities, and pursue risk reduction strategies to improve public health
and the environment.
Key outcomes of the Urban Atlas will be to inform community
members and decision makers as to how natural resources are critical
community assets, and how their absence or degradation may be
contributing to cumulative burdens on human health and well-being.
Furthermore, the integrated, multi-media approach of the Urban Atlas
will provide information on the co-benefits accrued to the community
when applying ecosystem services to mitigate specific environmental
contaminants or other priority health risks.
Impacts on EPA programs and activities
These actions are also responsive to several core focus areas of EPA's
Plan EJ 2014 and the principles on environmental justice articulated in
EPA's Strategic Plan for 2011-2015. It is also responsive to the
mandate in EO 12898 which requires that EPA identify and address
disproportionately high and adverse human health or environmental
effects of its policies, programs and activities on minority, low income,
and tribal populations.
Results produced by the new research grants on cumulative risks and
impacts will demonstrate successful approaches to incorporating
community knowledge into the development of such tools and the
Plan EJ 2014: Appendix, Implementation Plans 118
-------
&EPA
application of qualitative approaches and social science methods into
cumulative impact assessments. EPA's programs will benefit from the
development of the CCAT through engaging with stakeholders to
address the community-based assessment of cumulative risks with
environmental justice concerns.
Intensive engagement with environmental justice stakeholders will
improve the incorporation of these issues in the design of the CRA
Guidelines. The CCAT will improve the capacity of EPA regional risk
assessors to assist communities in understanding the complexity of
risk, and provide the means by which to identify priorities. Also the
CRA-EJ software will assist programs in implementing the planned
"Technical Guidance for Incorporating Environmental Justice into
Rulemaking Activities" by facilitating a step-by-step approach to
evaluating cumulative risks and impacts. More broadly the CRA
Guidelines will affect risk-based decision making across the full range of
EPA's programs, nationally, regionally, and more locally. The CCAT is a
project under the RAF CRA Technical Panel, and will directly
incorporate environmental justice into CRA and thus introduce
environmental justice risk-based considerations throughout EPA's
policies and decision making.
The process for developing these tools, data, methods, and guidance
will lead to innovative approaches and tools for incorporating
environmental justice concerns in EPA's regulatory and policy decision
making. Other innovations include identifying research needs and data
gaps on topics such as environmental public health indicators to assess
disparities, equity impact assessment methods, metrics to assess
inequities in risk assessments to support rule making, and policy and
program evaluation. ORD plans to bridge these data gaps through both
intramural and extramural research programs.
Initial community interaction for the development of the Urban Atlas
will proceed through EPA's existing initiatives such as the CARE and
Environmental Justice Showcase Communities programs and the
EPA/U.S. Department of Housing and Urban Development (HUD)/U.S.
Department of Transportation (DOT) Partnership for Sustainable
Communities, and their EPA liaisons. Information about ecosystem
services will expand options for improving community health and well-
being, and clarify economic and other trade-offs involved in alternate
environmental mitigation and remediation decisions. The selection of
focal areas along several gradients is designed to facilitate the
application of observed linkages between community welfare and
ecosystem services to additional populated places of concern to EPA.
Plan EJ 2014: Appendix, Implementation Plans 119
-------
&EPA
Timeframe
Develop final draft of technical guidance by FY 2013.
Develop and refine screening tools that identify air rules that raise
potential environmental justice concerns (FY 2011).
Determine the analytical tools are most appropriate for particular types
of air rulemaking (FY 2011-12).
Identify any additional analytical tools that may be needed to better
understand the environmental justice implications of air rulemakings
(FY 2011-12).
Host community-based tools workshop(s) and Regional Tools Summits
with focus on environmental justice and health disparities, to solicit
recommendations and inform EPA's actions on tools under Plan EJ
2014 (FY 2012-13).
Develop final Environmental Quality Index (Long term).
Beta test a prototype of the CCAT in early 2012.
Complete first phase of the Urban Atlas will be completed in FY 2013;
incorporate additional populated areas will begin in FY 2012 and FY
2013, contingent upon funding.
Strategy 2: Incorporate perspectives from community-based
organizations and community leaders into EPA research agendas and
engage in collaborative partnerships on science and research to address
environmental justice.
A few initiatives are highlighted here to better engage with communities in
EPA science activities and implementation of regulatory programs.
Activity 2.1: Establish Community Engagement Initiative.
OSWER has launched the Community Engagement Initiative (CEI),
www.epa.gov/oswer/engagementinitiative/. which is designed to enhance
OSWER and regional offices' engagement with local communities and
stakeholders (e.g., state and local governments, tribes, academia, private
industry, other federal agencies, non-profit organizations) to help them
meaningfully participate in government decisions on land cleanup,
emergency preparedness and response, and the management of hazardous
substances and waste.
Activity 2.2: Re-engage with National Environmental Justice Advisory
Committee.
ORD intends to establish a health and research workgroup or
subcommittee within National Environmental Justice Advisory Committee
(NEJAC) to advise the EPA Administrator and ORD in the area of scientific
research, health impacts, and environmental risks and exposures that
directly relate to environmental justice. An initial task of the workgroup
will be to advise ORD on the development of the Sustainable and Health
Communities Research Program.
Plan EJ 2014: Appendix, Implementation Plans 120
-------
&EPA
Activity 2.3: Support Community-based Participatory Research.
Participatory research methods will be integrated into the new ORD
research program on Sustainable and Healthy Communities and new
extramural research solicitations to support CBPR are under consideration.
A significant feature of the Sustainable and Health Communities Research
program will be community and regional based projects. Applying
participatory research methods will be the hallmark of this new program
within ORD. Community-based participatory research (CBPR) fosters more
complete understandings of the existing interactions between
environmental conditions, human health and ecosystems. Researchers,
practitioners, community members, and funding institutions have
increasingly recognized the importance of comprehensive, holistic, and
participatory approaches to environmental research and later stages of
intervention. For EPA, applying CBPR in its scientific research and program
planning promises to lead to more appropriate solutions for the persistent
and uneven social disparities in health as well as access to clean and safe
environments.
Benefits to EPA Stakeholder Communities
These actions are in agreement with suggestions from environmental
justice stakeholders to integrate perspectives from community
residents and community leaders in the development of the EPA's
scientific research agendas as well as in data collection.
OSWER's CEI will include direct outreach to state and local
governments, tribes, academia, private industry, other federal
agencies, and non-profit organizations. The CEI is designed to help
stakeholders have meaning participation in EPA's decisions on land
cleanup, emergency preparedness and response, and the management
of hazardous substances and waste. It will also improve OSWER efforts
to protect human health and the environment through site cleanups
and other risk reduction activities.
Re-establishing a NEJAC health and research workgroup or
subcommittee would provide a critically needed formal mechanism for
environmental justice stakeholders, community-based organizations to
provide input and feedback into the EPA/ORD research initiatives.
Presently, ORD lacks any mechanism for public input into its research
agenda. If concerns about environmental and health inequalities are
not "on the table" they will be not be addressed by the EPA research
enterprise. However it must be recognized that a NEJAC subcommittee
cannot be the only approach for soliciting the contribution of
environmental justice stakeholders. ORD will need to identify
additional approaches for soliciting input and collaborating with
environmental justice stakeholders (e.g., through regional outreach,
the Regionally Applied Research Effort (RARE) program, and partnering
with EPA program offices and other federal agencies). Creating formal
mechanisms for receiving stakeholder input assures that community
wisdom, perspectives and values are duly considered and
accommodated in the development of ORD's new program. Moreover,
Plan EJ 2014: Appendix, Implementation Plans 121
-------
&EPA
such mechanisms assure that the results of this program, which
subsequently influence decision making at EPA, also consider robust
community input.
Impacts on EPA programs and activities
Nearly all of OSWER programs and activities will be impacted by the
various CEI actions. The CEI is designed to enhance OSWER and
regional offices' engagement with local communities and stakeholders,
and to help them meaningfully participate in government decisions on
land cleanup, emergency preparedness and response, and the
management of hazardous substances and waste.
The first task for this NEJAC workgroup could be to advise ORD on
developing the Sustainable and Healthy Communities Research
Program initiative, which is currently being discussed. Since this
research program is in its early stages of development, engaging a
NEJAC workgroup now could be extremely beneficial to ORD to help set
the course, identify critical research questions that should be
addressed and how best to solicit input and potential partnerships with
community-based organization and environmental justice leaders such
as hosting public forums on the Sustainable Community Environments
and Public Health research program.
Timeframe
Each of the CEI actions has defined deliverables and timeline for their
completion. Nearly all of the actions have significant deliverables due
in FY 2011.
Incorporate ideas and concerns from stakeholders and representatives
from disproportionately impacted communities and populations (FY
2011).
Establish a NEJAC workgroup on research by FY 2012.
Issue joint RFA or other funding mechanism to collaborate with NIH
National Institute Minority Health and Health Disparities to establish
national research Centers of Excellence on Environment and Health
Disparities (FY 2012).
Strategy 3: Leverage partnerships with other federal agencies on issues
of research, policy, and action to address environmental and health
disparities.
Environmental justice and related concerns for health inequalities are
complex and multi-dimensional. Solutions to these societal problems
require intersectoral and intergovernmental actions. Environmental justice
is not solely EPA's responsibility, just as health disparities cannot be seen
solely as a U.S. Department of Health and Human Services problem. At
present, governmental approaches to promoting and managing health and
it determinants, namely the environment, are fragmented. Symposium
participants recognized in order to achieve environmental justice, a multi-
stakeholder, multi-system approach is required. Within federal agencies,
we need to strengthen federal interagency collaboration to improve
Plan EJ 2014: Appendix, Implementation Plans 122
-------
&EPA
research that can impact environmental and health practice, programs, and
policy and formulate solutions for communities.
Activity 3.1: Join the Federal Collaboration on Health Disparities.
EPA's ORD will actively participate on the interagency Federal Collaboration
on Health Disparities Research (FCHDR) and represent EPA on the Executive
Steering Committee (http://minorityhealth.hhs.gov/fchdr/). The Executive
Committee of the FCHDR was created to bring together selected agency
representatives to seek practical solutions to advance health disparities
research, and foster greater federal coordination, collaboration, and
communication around the elimination of health disparities.
Federal departments represented on the Executive committee include:
U.S. Department of Education
National Institute on Disability and Rehabilitation Research
U.S. Department of Housing and Urban Development
U.S. Department of Justice
U.S. Department of Veterans Affairs
U.S. Environmental Protection Agency
National Science Foundation
U.S. Department of Health and Human Services (HHS), Centers for
Disease Control and Prevention
HHS, Health Resources and Services Administration
HHS, National Institute for Minority Health and Health Disparities
HHS, Office of Minority Health
The FCHDR's goal is to ensure that health disparities research is conducted
as an integrated and inclusive field of study, rather than as an aggregate of
independent research activities occurring in separate research domains.
FCHDR members will work together to explore needs and opportunities for
pooling scientific expertise and resources to conduct, translate, and
disseminate research most needed to accelerate the elimination of health
disparities.
FCHDR goals and strategies are to:
1. Identify health disparities challenges including the scientific and
practical evidence most relevant to underpinning future policy and
action.
2. Increase and maintain awareness about federal government efforts
and opportunities to address health disparities.
3. Determine how evidence can be translated into practice to address
health disparities and promote innovation.
4. Advise on possible objectives and measures for future research,
building on the successes and experiences of health disparities experts.
5. Publish reports that will contribute to the development of the FCHDR
strategic vision and plan.
Plan EJ 2014: Appendix, Implementation Plans 123
-------
&EPA
Activity 3.2: Engage with President's Task Force on Environmental Health
Risks and Safety Risks to Children.
EPA's OAR, the Office of Children's Health Protection (OCHP), ORD, and
others are collaborating and participating with other federal agencies on
the newly re-established President's Task Force on Environmental Health
Risks and Safety Risks to Children. One focal area of their work is on
asthma disparities among minority and disadvantaged children. In early
December 2010, a Federal Workshop on Asthma Disparities was held in
Washington, D.C., to foster interagency coordination on development and
implementation of a detailed Federal Action Plan to address asthma
disparities.
Benefits to EPA Stakeholder Communities
More coordinated federal approach to research, policy, and action to
address environmental justice health disparities.
Impact on EPA programs and activities
EPA's participation in these three federal initiatives will identify and
create opportunities to combine resources to tackle issues of
disparities in health and access to clean environments; and will
increase access and exposure of all EPA offices, including ORD, to non-
traditional EPA disciplines such as social science and concepts such as
social determinants of health.
Timeframe
ORD's participation with the federal collaboration is ongoing.
Participation with other federal agencies on the President's Task Force
on Environmental Health Risks and Safety Risks to Children to work on
asthma disparities among minority and disadvantaged children that can
be addressed through interagency coordination on development and
implementation of a detailed Federal Action Plan (FY 2011- 2015).
Strategy 4: Build and strengthen the technical capacity of EPA scientists
on conducting research and related science activities in partnership with
impacted communities and translating research results to inform change.
Along with efforts to increase technical capacity in communities, EPA needs
to build up its capacity to work with communities in order for real progress
to be made. Several recommendations from the Symposium address this
issue and call for EPA to:
Train EPA staff on effective outreach and dialog with communities;
Develop capacity within the Agency.
Provide training for EPA risk assessors and managers on community
engagement.
Consider using qualitative approaches in risk assessment.
Establish multi-disciplinary teams to work on issues.
Encourage multidisciplinary teams in environmental health research.
Explore approaches for interacting with communities that can build
collective efficacy and social capital.
Plan EJ 2014: Appendix, Implementation Plans 124
-------
&EPA
Support participation of communities as equal partners in research;
include them as equal partners in the co-production of knowledge.
Include community representatives and perspectives in the design of
studies/research.
Social science disciplines like social epidemiology indicate that EPA needs
to look more at upstream factors - social processes that ultimately process
the disparities in risks and health outcomes.
Activity 4.1: Provide training to EPA scientists on CBPR.
Both ORD and OSWER intend to provide training to scientists on principles
of community-based participatory research, health disparities, and
environmental justice. Both offices will look for opportunities to
collaborate on providing training for staff. For example, OSWER's
Community Involvement and Program Initiatives Branch (CIPIB) sponsors a
Community Involvement University (CIU) to provide training courses for
Superfund Program Community Involvement Coordinators (CIC) and other
EPA and EPA-affiliated staff. Participants are provided with the necessary
skills, techniques, and practices to engage the community in the Superfund
process. CIU offers a variety of courses each year at regional offices and at
national conferences or training events. These courses could be offered to
ORD scientists and modified to address community-engagement in more of
the research context.
In order to design appropriate capacity training program, ORD will first
evaluate current understanding and research capacity of ORD sciences
regarding principles of community-based participatory research, health
disparities, and environmental justice. ORD will then design and
implement training for its staff.
Activity 4.2: Build Social Science Capacity within ORD.
The National Center for Environmental Research (NCER) is developing an
ORD research agenda for behavioral and social sciences as they impact and
affect environmental protection as well as the evolution of environmental
policy. Environmental justice consideration will be critical to this research
agenda. ORD will conduct Individual and focus group interviews of
behavioral and social science experts to solicit their thoughts and identify
the most relevant current research as well as known gaps in four areas:
behavioral economics, decision theory, management science, and risk
perception. Following the expert interview, NCER will host a workshop
with the scientific leaders identified through the interview phase (30-50
people).
NCER plans to establish a cooperative agreement with a professional
society concerned with applying the social science research to
contemporary environmental health issues. This effort is intended to help
ORD devise approaches and methods for truly incorporating the social
Plan EJ 2014: Appendix, Implementation Plans 125
-------
&EPA
sciences into its research and assessment activities. Activities under the
cooperative agreement could include:
Providing training to ORD staff on incorporating qualitative approaches
and social science methods into cumulative impact assessments.
Developing approaches to incorporate community knowledge in such
tools for cumulative impact assessments.
Offering webinars and training to cultivate analytical skills among ORD
staff to examine the social and economic systems that create
cumulative adverse environmental impacts in communities.
Activity 4.3: Develop Environmental Justice Risk Management Training for
OPP.
The Office of Pesticide Programs (OPP) has created a new training module
as a part of its regular staff training program to ensure that environmental
justice and sensitive population considerations are fully incorporated and
more clearly characterized in the pesticide risk assessment process. The
training module consists of two components: (1) addressing general
background on environmental justice, and (2) integrating environmental
justice considerations through OPP risk management to address
environmental justice issues identified by the risk assessments.
Benefits to EPA Stakeholder Communities
Impacted communities and environmental justice leaders should see
improved interactions with Agency scientists.
The goal of OPP's training is to provide the tools to better identify
potential environmental justice issues. Enhanced risk assessment
methodologies will result from a closer and more focused look at the
toxicity and exposure patterns specific to each pesticide and pesticide
use that could present a disproportionate risk. Areas now considered
in pesticide risk assessment (hazard assessment, dietary exposure,
occupational and resident exposure, incident data) will be considered
through an environmental justice lens.
Impact on EPA programs and activities
We anticipate that the capacity of Agency scientists to conduct
research in partnership with impacted communities, to understand and
employ social science methods in environmental research, and
translate research results to inform change will be greatly improved.
This will help ORD's Sustainable and Healthy Communities Research
Program meet its objectives.
The OPP training program will improve how environmental justice is
incorporated by risk managers. This training is expected to influence
pesticide registration and re-registration decisions to more robustly
incorporate environmental justice considerations. To date, 10 training
sessions on the first component and a total of 160 OPP staff completed
the training.
Plan EJ 2014: Appendix, Implementation Plans 126
-------
v°/EPA
Timeframe
Host scientist to scientist workshop on behavioral and social sciences
(late FY 2011).
Design a research capacity training program for ORD scientists, which
could include self-paced training on community-based and
participatory research CBPR offered by Michigan Public Health Training
Center and joint courses through OSWER's Community Involvement
University (FY 2012-2013).
Complete the new OPP module on risk management training by early
FY 2012. The goal will be to have 100 percent of risk assessors and
managers trained by the end of FY 2012.
Strategy 5: Build and strengthen technical capacity of community-based
organizations and community environmental justice and health leaders to
address environmental health disparities and environmental
sustainability issues.
Community capacity has been defined as "a set of dynamic community
traits, resources, and associational patterns that can be brought to bear for
community-building and community health improvement" (Norton et al
2002). "Community capacity building activities" are those designed to
increase community capacity and emphasize (1) assets and empowerment
(versus disease and deficiency); (2) the role of bottom-up, community-
determined processes and agendas (versus top-down/externally
determined ones); and (3) the processes for developing community
competence.
The commissioned paper on community-capacity presented at the March
2010 Symposium identified important domains of action to strengthen
community capacity, including leadership, participation, skills, resources,
social and organizational networks, sense of community and understanding
of community history, community power, community values, community
cohesion, language capacity, and community information.
(See http://www.epa.gov/ncer/events/calendar/2010/marl7/papers.html)
In addressing all of these domains, strategies for enhancing community
capacity may include training and technology transfer, technical assistance,
community-based participatory research, empowerment approaches,
community organizing, and social action. Commissioned paper authors
noted that capacity-building strategies that give more control to
communities (e.g., CBPR, empowerment, and community organizing) may
more fully address the fundamental causes of environmental disparities
than more agency controlled processes (e.g., training and technical
assistance).
(See
http://www.epa.gov/ncer/events/calendar/2010/marl7/presentations/fre
udenberg.pdf)
Plan EJ 2014: Appendix, Implementation Plans 127
-------
v°/EPA
These community-driven strategies are more labor and resource intensive
and require a higher level of commitment from communities, researchers,
and agencies, as well as a new set of capabilities on the part of Agency
personnel with regard to the skills needed to, for example, facilitate
meetings, communicate clearly, and create an atmosphere of inquiry and
trust.
In order to more effectively reduce disparate environmental exposure and
engage the public in making environmental policy decisions, the EPA must
engage relevant constituencies in participation processes early, provide
these constituencies with the resources and information that can
contribute to effective participation, and ensure that the outcomes reflect
participation. Specifically, helping communities develop the capacities to
create, access, use, and interpret scientific information and changing
Agency practices to better incorporate community voices in scientific
activities and decisions will be a key and proper task for EPA. EPA,
therefore, proposes the following actions to establish programs and
provide federal government support to increase technical and scientific
capacity in communities.
Activity 5.1: Build Awareness and Community Capacity to Address Asthma
Disparities.
In response to the growing asthma problem where minority, low-income,
tribal, and indigenous populations are disproportionately affected, EPA's
OAR established the Asthma Program to promote scientific understanding
of environmental asthma triggers and ways to manage them. The program
collaborates with partners to support research and educate the public
about asthma and ways to manage environmental triggers. Partners
include government agencies, universities and research centers, the health
care community, nonprofit organizations, and community programs. Major
program activities center around the Communities in Action for Asthma
Friendly Environments initiative, and include support for real time peer-to-
peer learning, technology transfer and resources for community-based
asthma programs through an online network
(www.AsthmaCommunityNetwork.org). "pacing" events (National Asthma
Forum, regional events and webinars), and support to non-profit
organizations focused on health care provider training, improving school
environments and raising public awareness about asthma (see also
Supporting Community-Based Action Programs, Strategy 2, Activity 3).
Activity 5.2: Build Tribal Community Capacity to Monitor Air Quality.
OAR has a long history of supporting capacity building among tribal
environmental professionals, primarily through its partnership with the
Institute for Tribal Environmental Professionals (ITEP) at Northern Arizona
University, which OAR has supported for over 15 years. Consistent with
our trust responsibility to tribes, OAR works with tribes to increase their
capability to address their environmental concerns. OAR supports the
training and educational efforts of ITEP in the areas of air quality and
Plan EJ 2014: Appendix, Implementation Plans 128
-------
&EPA
climate change impacts and adaptation planning, as well as the work of the
Tribal Air Monitoring Support (TAMS) Center, which builds and strengthens
the technical capacity of tribal staff. The TAMS Center cross-trains tribal air
professionals on air monitoring, indoor air quality, radon, and asthma (see
also Supporting Community-Based Action Programs, Strategy 2).
Activity 5.3: Increase Citizen Participation in Science and Decisions.
ORD proposes to create a program, in partnership with other governmental
agencies, private non-profits, professional societies, and private
foundations, to develop the capacity of community leaders to understand
the role of science in decision making and influence the decision-making
process and on the use of data and other information to document
disparities and concerns in their communities.
Activity 5.4: Establish Centers of Excellence on Environment and Health
Disparities.
Several new extramural research solicitations are under consideration to
fund research that address specific research needs and topics raised at the
March 2010 Symposium and that fully employ CBPR approaches such as
establishing Centers of Excellence on Environment and Health Disparities.
The aim for these Centers will be to examine the joint impacts of social and
physical environmental conditions and processes on health, link with
community health clinics to increase their capacity to address occupational
and environmental health concerns of their constituents, and design policy
solutions to ameliorate and prevent disparities.
Activity 5.5: Build diverse environmental workforce and enhancing the
capacities of Minority Academic Institutions (MAI) to engage in scientific
research and workforce training
The National Center for Environmental Research's (NCER) Fellowship
Program is implementing several initiatives to strengthen EPA's efforts to
encourage and support environmental justice research among the next
generation of environmental scientists and engineers. For example,
Environmental justice research topics are highlighted in the STAR
Fellowships RFA and environmental justice considerations have been
included as review criteria under "Broader Societal Impacts" for all
fellowship applications.
As part of the Greater Research Opportunities (GRO) fellowship, NCER has
a goal of enhancing capacity at academic institutions that are not well
funded for environmental research capacity, including HBCUs. ORD
considers ineligible those institutions identified as receiving more than $35
million in annual federal research. NCER has increased resources allotted
to the GRO program to increase GRO funded students, which can enhance
our efforts in this area.
OSWER will support research through the Faculty and Student Teams
(FaST) Program, a cooperative effort between the U.S. Department of
Plan EJ 2014: Appendix, Implementation Plans 129
-------
&EPA
Energy (DOE) Office of Science and the National Science Foundation (NSF).
Faculty from colleges and universities with limited research facilities and
those institutions serving populations, women and minorities
underrepresented in the fields of science, engineering, and technology are
encouraged to apply for the FaST program. The FaST program will support
a team comprised of one faculty member and two to three undergraduate
students. The program provides hands-on research opportunities in the
DOE or EPA national laboratories during the summer. The faculty member
identifies a mutually beneficial research area amenable to collaboration by
the faculty member and the laboratory scientist.
The EPA Region 6 University-Community Partnerships initiative will
facilitate and nurture a partnership between universities and community
groups to increase overburdened communities' capacity to address their
environmental challenges through technical assistance. Memorandums of
Understanding (MOU) are in place between EPA Region 6 and the
University of Texas El Paso (UTEP) and EPA Region 6, EPA's Office of Water
and Texas A&M Kingsville.
Within the federal government, EPA has been a leader in the use of
collaborative approaches to accomplish strategic goals and objectives.
Learning from this rich experience can help the Agency realize the full
potential of collaborative processes and accelerate environmental
progress. The ability to collaborate effectively with MAIs will become more
important as the growing complexity of environmental problems will
require diverse approaches to developing innovative solutions. Failure to
tap into MAIs represents a missed opportunity for advancing
environmental protection and stewardship. For example, MAIs in the
Southeast and the Southwest could be leveraged for strategic projects
targeting climate change impacts and adaptation, and engaging
populations that are vulnerable to climate change.
Benefits to EPA Stakeholder Communities
These capacity-building actions can help the public to address
environmental health issues and to allow them to effectively
participate in environmental health decision making and will increased
confidence that concerns about the power dynamics between
academic, government researchers, and communities will be taken
seriously.
Actions undertaken by the Asthma Program will equip stakeholder
communities and organizations to assess, organize and sustainably
deploy community resources to reduce or eliminate exposure to
asthma triggers, and improve health outcomes and the quality of life
for people with asthma. The actions help support and strengthen the
capacity of health care and environmental professionals, schools, and
community-based organizations to develop comprehensive asthma
care strategies in partnership with impacted communities and to
spread their results to accelerate improvements across the national
asthma care landscape.
Plan EJ 2014: Appendix, Implementation Plans 130
-------
&EPA
Through the partnership with ITEP, tribes are better able to fashion
their own responses to environmental issues including climate change,
and have a better understanding of how they can effectively
participate in the environmental decision making of federal, state and
local regulatory agencies.
Research through the proposed Centers of Excellence will be specially
aimed at benefiting disadvantaged, undeserved, and environmentally
overburdened communities or groups.
Requiring NCER fellowship applicants to consider and explain the
environmental justice implications of their research will help develop a
new generation of environmental scientists, engineers, and policy
makers who are cognizant of environmental justice -related issues that
can arise in research and thus adjust approaches accordingly to
promote broad environmental protection.
Increasing the reach of the GRO program will promote research and
training at Minority Serving Institutions (MSIs), which may have special
expertise on environmental justice matters.
Through the Region 6 partnerships with University of Texas and Texas
A&M Kingsville, EPA will increase knowledge about best approaches for
community-university partnerships.
Impact on EPA programs and activities
The Communities in Action initiative and the online Network, Asthma
Community Network will surface important, field-tested community
strategies that the Asthma Program will use to bolster the Agency's
national asthma education and outreach efforts.
When tribal perspectives are effectively communicated, EPA is more
cognizant of Tribal issues and is able to make more informed and
responsive decisions concerning its rules, programs and policies. As
tribes take more responsibility for implementing air programs, EPA may
be able to reduce some of its implementation efforts.
The proposed research-oriented activities will help institute program
development and strategic institutional change within EPA. The goal is
to increase democratization in the conduct of and community access to
EPA/ORD research. The proposed activities will produce: (1) consistent
and validated principles of community engagement in research for ORD
and EPA programs; (2) improved science and research results that are
more relevant to environmental problems faced by the public and
more effectively translated to inform policy change and intervention;
and (3) inclusion of environmental justice considerations as review
criteria that serve as a model for other competition-based EPA
programs. These results will promote a culture that considers
environmental justice implications in all agencies funding actions and
activities.
The process of increasing the reach of the GRO program will translate
into stronger outreach to MSIs and highlight the critical role MSIs play
in the nation's research and development enterprise to solve pressing
environmental protection challenges.
Plan EJ 2014: Appendix, Implementation Plans 131
-------
&EPA
The intent of Region 6's existing MOU's are to: (1) improve the quality
of environmental science and technical education; (2) increase the
relevance of UTEP research projects to EPA's environmental and public
health mission; and (3) increase number of culturally diverse students
electing to pursue graduate study and research careers in areas
including science, engineering, and mathematics. It is expected that
UTEP's capacity to develop environmental specialists for potential EPA
employment will be significantly enhanced while important
contributions will be made to EPA's overall research and
developmental programs.
Timeframe
Support and grow an online community network of stakeholders that
serves as a real time resource for mentoring and collaboration to
support community asthma management programs (FY 2011 and
ongoing).
Develop web-based tools that facilitate collaboration, problem solving,
and learning among leaders of asthma programs (FY 2011 and
ongoing).
Facilitate knowledge transfer among stakeholders through EPA
sponsorship of "pacing" events, including the National Asthma Forum,
regional events and webinars for community-based asthma programs
(FY 2011 and ongoing).
Train health care professionals to improve their ability to integrate the
assessment of environmental factors into a comprehensive, culturally
appropriate asthma care plan, based on national standards of care (FY
2011 and ongoing).
Continue funding for ITEP and the TAMS Center (ongoing).
Continue OAR involvement in developing ITEP's curriculum and
training, and oversight of the TAMS Center (ongoing).
Institute a pilot program on "meet the decision makers" on
environmental health and environmental justice that would
accommodate up to 15 community leaders (FY 2013).
Issue joint RFA or other funding mechanism to collaborate with NIH
National Institute Minority Health and Health Disparities to establish
national research Centers of Excellence on Environment and Health
Disparities (FY 2012).
Highlight Environmental Justice Research topics in the STAR
Fellowships RFA (ongoing).
Plan EJ 2014: Appendix, Implementation Plans 132
-------
Community outreach and engagement plans are integrated into the
individual science actions described above. The most significant science
actions that will include community outreach and partnerships are ORD's
Sustainable and Health Communities Research Program, OSWER's
Community Engagement Initiative and the extramural research funding
under consideration.
Plan EJ 2014: Appendix, Implementation Plans 133
-------
&EPA
3.0 DELIVERABLES
Strategy 1: Apply integrated transdisciplinary and community-based
participatory research approaches with a focus on addressing multi-media,
cumulative impacts, and equity in environmental health and environmental
conditions.
ACTIVITIES
Activity 1.1: Establish
an Integrated
Transdisciplinary ORD
Research Program on
Environment and
Community Health -
Sustainable and Healthy
Communities Research
Program.
DELIVERABLES
Research program framework
developed (ORD - SHCRP
Team).
Regional listening sessions to
gather input from
communities. Incorporate
ideas and concerns from
stakeholders and
representatives from
disproportionately impacted
communities and populations
(ORD - SHCRP Team).
RFA to support Extramural
research on Tribal
Community Health (ORD -
NCER).
RFA to support Extramural
research to support Centers
of Excellence on Environment
and Health Disparities (ORD
- NCER).
MILESTONES
February
2011
Spring 2011
FY2012
FY2012
Activity 1.2: Develop
technical guidance,
analytic methods, tools
and data to advance the
integration of
environmental justice in
EPA decision making.
Environmental Justice
Technical Guide (ORD, OEJ,
OP).
Community Cumulative
Assessment Tool (CCAT)
(ORD - NERL and OSA).
Environmental Quality Index
Tool (ORD - NHEERL).
Regional Tools Summits
(ORD - OSP and SHCRP
Team).
Environmental justice
screening tools for air rules
(OAR).
Urban Atlas (ORD -
NHEERL).
FY2013
EarlyFY2012
Long-term
FY2012-
2013
FY 2011 -
2012
First phase
complete FY13
Plan EJ 2014: Appendix, Implementation Plans
134
-------
&EPA
Strategy 2: Incorporate perspectives from community-based organizations
and community leaders into the EPA's research agendas and engaging in
collaborative partnerships on science and research to address
environmental justice.
ACTIVITIES
Activity 2.1: Establish
Community Engagement
Initiative (OSWER).
DELIVERABLES
Conduct training of OSWER
staff on CBPR(OSWER).
MILESTONES
Ongoing
Activity 2.2: Re-engage
National Environmental
Justice Advisory
Committee.
Establish a research
workgroup under NEJAC to
advise ORD on the
development of the
Sustainable and Health
Communities Research
Program (ORD - NCER and
OSP; OEJ).
FY2012
Activity 2.3: Support
Community-Based
Participatory Research.
RFA to support extramural
research on Tribal
Community (ORD-NCER).
RFA to fund Extramural
research to support Centers
of Excellence on Environment
and Health Disparities (ORD
- NCER).
Regional listening sessions to
gather input from
communities. Incorporate
ideas and concerns from
stakeholders and
representatives from
disproportionately impacted
communities and populations
(ORD - Rick Linthurst and
SHCRP Team).
FY2012
FY2012
Spring 2011
Plan EJ 2014: Appendix, Implementation Plans
135
-------
&EPA
Strategy 3: Leverage partnerships with other federal agencies on issues of
research, policy and action to address environmental and health
disparities.
ACTIVITIES
Activity 3.1: Join the
Federal Collaboration on
Health Disparities.
IELIVERABLES
Potential collaboration on
research funding with sister
federal agencies; better
coordination of research
needs on health disparities
across federal government
(ORD).
MILESTONES
Ongoing
Activity 3.2: Engage
with President's Task
Force on Environmental
Health Risks and Safety
Risks to Children.
Federal Action Plan to
address asthma disparities
(OCHP, ORD, OAR).
FY2011-
2015
Strategy 4: Build and strengthen the technical capacity of EPA scientists on
conducting research and related science activities in partnership with
impacted communities and translating research results to inform change.
ACTIVITIES
Activity 4.1: Provide
training to EPA
scientists on CBPR.
DELIVERABLES
Survey ORD scientists' needs
and awareness about
CBPR(ORD - OSP and
NCER).
Develop a training plan for
ORD scientists (ORD - OSP
and NCER).
Collaborate with OSWER to
modify and offer courses
under the Community
Involvement University (ORD
and OSWER).
MILESTONES
FY2012
2013
FY2012
2013
FY2012
2013
Activity 4.2: Build
Social Science
Capacity within ORD.
Host scientist to science
workshop on behavioral and
social sciences (ORD-NCER).
An ORD research agenda for
behavioral and social sciences
(ORD-NCER).
Cooperative Agreement with a
Social Science professional
society (ORD- NCER).
FY 2011
2012
FY2012
2013
FY2012
2013
Plan EJ 2014: Appendix, Implementation Plans
136
-------
&EPA
ACTIVITIES
DELIVERABLES
Activity 4.3: Develop
Environmental Justice
Risk Management
Training forOPP.
Training module to ensure
environmental justice and
sensitive population
considerations are fully
incorporated and more clearly
integrated throughout OPP risk
management processes
(OPP).
100% of OPP risk assessors
and managers properly trained
on environmental justice in risk
management (OPP).
MILESTONES
By early
FY2012
End of
FY2012
Strategy 5: Build and strengthen technical capacity of community-based
organizations and community environmental justice and health leaders to
address environmental health disparities and environmental sustainability
issues.
ACTIVITIES
Activity 5.1: Build
Community Capacity to
Address Asthma
Disparities.
DELIVERABLES
Establish an online community
network available to
stakeholders as a year-round
resource for mentoring and
collaboration and designed to
support community asthma
management programs (OAR).
Develop web-based tools that
facilitate collaboration, problem
solving, and learning among
leaders of asthma programs
(OAR).
Hosting the National Asthma
Forum and Awards Program
and regional pacing events for
community-based programs
(OAR).
Train health care
professionals, to improve their
ability to integrate the
assessment of environmental
factors into a comprehensive,
culturally appropriate asthma
care plan, based on national
standards of care (OAR).
MILESTONES
FY 2011 and
ongoing
FY 2011 and
ongoing
FY 2011 and
ongoing
FY 2011 and
ongoing
Plan EJ 2014: Appendix, Implementation Plans
137
-------
&EPA
ACTIVITIES
Activity 5.2: Build
Tribal Community
Capacity to Monitor Air
Quality.
DELIVERABLES MILESTONES
Continue funding for ITEP and Ongoing
the TAMS Center (OAR).
Activity 5.3: Increase
Citizen Participation in
Science and Decisions.
Cooperative agreement to
support a citizen scientist
fellowship program - a meet
the decision makers" on
environmental health and
environmental justice (ORD-
NCER).
FY2013
Activity 5.4: Establish
Centers of Excellence
on Environment and
Health Disparities.
RFA to support Extramural
research to support Centers of
Excellence on Environment
and Health Disparities (ORD -
NCER)
FY2012
Activity 5.5: Build
diverse environmental
workforce and
enhancing the
capacities of MAI to
engage in scientific
research and workforce
training.
Highlight environmental justice
research topics in the STAR
Fellowships RFA. Include
environmental justice
considerations as review
criteria under "Broader Societal
Impacts" for all fellowship
applications (ORD-NCR)
Support research through the
FaST Program and provide
university faculty and students
to have hands-on research
opportunities in DOE or EPA
national laboratories (OSWER)
Establish a University-
Community Partnerships
initiative to provide technical
assistance to local community
groups and increase number of
culturally diverse students
electing to pursue graduate
study and research careers
(Region 6).
Completed
and ongoing
Ongoing
To be
determined
(TBD)
Plan EJ 2014: Appendix, Implementation Plans
138
-------
vvEPA
There is no overall reporting plan for the science activities at this time.
However, program reporting may occur by the individual program offices
responsible for each activity. For information, please contact Devon Payne-
Sturges, 703-347-8055, Payne-Sturges.Devon@epa.gov; or Chris Saint, 202-
564-9839, Saint.Chris@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 139
-------
v°/EPA
:'..-..
Brulle RJ and Pellow DN (2006). Environmental Justice: Human Health and
Environmental Inequalities. Annual Review of Public Health. Vol 27: pp 103-
24.
CSDH (2008). Closing the gap in a generation: health equity through action
on the social determinants of health. Final Report of the Commission on
Social Determinants of Health. Geneva, World Health Organization.
Gee GC and Payne-Sturges DC. 2004. Environmental Health Disparities: A
Framework Integrating Psychosocial and Environmental Concepts.
Environmental Health Perspectives. VOLUME 11, NUMBER 17. pp!645-
1653.
Habermann M and Gouveia N. 2008. Environmental Justice: an ecossocial
health approach. RevSaude Publica 42(6). Pp 1 - 7.
Krieger N. 2001. Theories for social epidemiology in the 21st century: an
ecosocial perspective. International Journal of Epidemiology. Vol 30: pp
668- 677.
Morello-Frosch RA. 2002. Discrimination and the political economy of
environmental inequality. Environment and Planning C: Government and
Policy. Volume 20, pages 477 - 496
Morello-Frosch R. and Shenassa ED. 2006. The Environmental "Riskscape"
and Social Inequality: Implications for Explaining Maternal and Child Health
Disparities. Environmental Health Perspectives. VOLUME 114. NUMBERS.
Pp. 1150-1153.
Norton B, Mcleroy K, Burdine J, Felix M, and Dorsey A. 2002. Community
capacity: Concept, theory and methods, in DiClemente R, Crosby R, Kegler
M, eds. Emerging Theories in Health Promotion Practice and Research. San
Francisco: Jossey-Bass.
Schulz AJ, Williams DR, Israel BA, Lempert LB. 2002. Racial and Spatial
Relations as Fundamental Determinants of Health in Detroit. The Milbank
Quarterly, Vol. 80, No. 4. Pp 677-707.
Wakefield S.E.L and Baxter J. 2010. Linking Health Inequality and
Environmental Justice: Articulating a Precautionary Framework for
Research and Action. ENVIRONMENTAL JUSTICE. Volume 3, Number 3. pp
95-102.
Plan EJ 2014: Appendix, Implementation Plans 140
-------
&EPA
Symposium participants recommended several actions to reduce research
or data gaps, overcome limitations in the theories and methods for
conducting environmental research, particularly research supported by
federal government, and limitations in practice of risk assessment. The
science recommendations are described below. The first sentence is a
summary statement meant to capture the main points of the individual
recommendations from the Symposium that follow, including
recommendations from the Environmental Justice-Caucus letter that was
sent to Lisa Garcia, Senior Advisor to EPA Administrator for Environmental
Justice.
1. Create and institute a new scientific research approach to develop
more holistic understanding of environment and health. One of the
potential outcomes of this new framework is to inform environmental
policies related to environmental justice and address environmental
health disparities. Several recommendations from the symposium point to
EPA to adopt a more holistic view of the environment and the impacts on
population health: "[the] EPA/ORD's research agenda needs to be
reframed, inequality and inequity needs to be a part of the discussion [and
research]; there needs to be a shift to not only look at risks and exposures,
but to consider root and fundamental causes, need to start where it
(inequality) begins; [the] EPA likes to start the analysis and research at a
level that does not address the history and root causes of health endpoints,
risks and exposures; analyze the environment in a broader context,
evaluate the interaction between the social and the physical environments;
a better framework is needed for combining physical and psychosocial
science in research and practice; use social determinants of health and
health disparities research framework to conduct research on cumulative
impacts/risks; encourage multidisciplinary teams in environmental health
research; develop the science of interactive effects; social science
disciplines like social epidemiology indicate that [the] EPA needs to look
more at upstream factors - social processes that ultimately process the
disparities in risks and health outcomes; develop measures for the social
environment; test the validity of available vulnerability indices and tools;
encourage multidisciplinary approach to research and analysis; address the
role of institutionalized racism in poor community environmental health;
encourage the consideration of environmental justice in land use planning;
and conduct research with direct policy implications - not research for the
sake of research."
Further, the Environmental Justice-Caucus participants recommend that
"[the] EPA should develop a plan to ensure incorporation of the concept of
vulnerability, particularly its social and cultural aspects in the Agency's
Plan EJ 2014: Appendix, Implementation Plans 141
-------
&EPA
research agendas" and "... in consultation with environmental justice
constituencies, incorporate community principles in its funding guidelines
for research in environmental health and planned and existing actions that
adversely impact public health and quality of life."
2. Integrate perspectives from decision makers such as community
residents, community leaders, community-based NGOs and community
health and environmental quality advocates in the development of EPA's
scientific research agendas as well as in data collection, conduct of
exposure/risk assessments and risk management decisions.
A common recommendation articulated in both the Environmental Justice-
Caucus letter and through discussions the Symposium is the need to
incorporate community perspectives in the development of EPA's
science/research agendas and in the conduct of exposure/risk assessments.
Signatories to the Environmental Justice-Caucus letter recommend that
"[the] EPA and other publicly funded research require the expertise of
environmental justice communities in the research design,
implementation, recommendations and programmatic design that may
result from the research" and "[the] EPA should develop a plan to ensure
incorporation of the concept of vulnerability, particularly its social and
cultural aspects in the Agency's research agendas." Related
recommendations from the Symposium state "include community
representatives and perspectives in the design of studies/research;
communities would like to be involved as [the] EPA sets its research
priorities and agenda as well as the regulatory agenda and priorities; and
there needs to be a research workgroup formed within the NEJAC."
Although the following recommendations from the Symposium stem from
discussions on regulatory actions and capacity building, they also suggest
that EPA/ORD needs to approach its research planning and its
contributions to the development of Agency risk assessment guidance
differently: "create effective mechanisms to listen to community concerns;
develop culturally competent outreach processes. Hire local community
folks with cultural expertise and community knowledge; and improve
incorporation of exposure information for smaller communities and
population groups in national risk assessments."
3. Create EPA funding mechanisms for community-based participatory
research (CBPR) and transdisciplinary research, with a specific focus on
studies that will benefit disadvantaged, undeserved, and environmentally
overburdened communities or groups. The Environmental Justice-Caucus
letter states that "affected communities need to be involved in the conduct
of research to insure that that results are disseminated in an effective and
understandable manner and that research recommendations are reviewed
by the community." Similar recommendations were made at the
Symposium including "support/fund community originated and owned
research; increase support/funding for community based participatory
research; support participation of communities as equal partners in
research; include them as equal partners in the co-production of
Plan EJ 2014: Appendix, Implementation Plans 142
-------
&EPA
knowledge; include community representatives and perspectives in the
design of studies/research."
Further, Environmental Justice-Caucus letter recommends that EPA should
also "develop a set of guidelines for federal environmental health research
that would require community participation with binding ethical and Title
VI guidelines for federally funded researchers in [environmental justice]
communities and tribal nations." This is consistent with comments raised at
the symposium encouraging "federal funders of University researchers to
address the unequal power dynamic that often arises between Universities
and impacted communities that are subject of environmental and public
health research."
4. Collaborate with other federal government agencies on research,
policy-making and other kinds of actions to address environmental health
disparities. Many comments were made about the need to strengthen
interagency efforts: "to address [environmental justice], need interagency
collaboration; government approach to promoting and managing health is
fragmented; agencies need to work together to formulate solutions for
communities; other agencies should integrate [environmental justice] in all
their activities."
5. Enhance the capacities of Minority Academic Institutions (MAI) to
engage in scientific research and workforce training. For instance, help
MAI institutions to provide training opportunities for minority students in
relevant scientific disciplines. Several statements were made at the
Symposium that there was a lack of diversity in the academic institutions
represented at the meeting and as presenters. HBCUs need to be involved
in this new and expanded area of research on environmental health
disparities.
6. Develop and implement a multi-media approach to cumulative
contamination exposures in environmental justice communities.
Restructure risks assessment practice to better account for multi-
stressors that cumulatively impact community and population health and
recognize that the concepts that vulnerability and health disparities are
interrelated. These recommendations from the Environmental Justice-
Caucus letter echo many of the concerns and other recommendations
raised at the Symposium on the topic of cumulative impacts. Comments
from the Symposium include "communities see their environment as a
whole not pieces; [the] EPA needs to address the issue of non-concordance
between risk assessment results and community experience; vulnerability
should be an integral part of cumulative risk assessment even it must be
analyzed using qualitative measures; incorporate social vulnerabilities and
cultural risks in risk assessments and cumulative risks/impact assessments;
incorporate background risk in risk assessment; consider using qualitative
approaches in risk assessment; adopt a quality of life approach; risk
assessment should move away from individual lifestyles to one that
considers the social context; focus on health and well-being as opposed to
Plan EJ 2014: Appendix, Implementation Plans 143
-------
&EPA
risk, illness and death; [the] EPA should recognize that stressors in
communities that are unaccounted for are not considered in risk
assessments; adopt a systems approach to risk assessment and decision
making; and [the] EPA should use information on cumulative impacts in all
its decisions."
7. Establish programs and provide federal government support to
increase technical and scientific capacity in communities. This capacity
building can help the public to address environmental health issues and
to allow them to effectively participate in environmental health decision
making. The Environmental Justice- - Caucus letter recommends that
"grant/funding programs be expanded to provide support directly to
[environmental justice] communities, [environmental justice] organizations
and networks, Tribes and Native organizations to assess and act on
[environmental justice] issues." Additionally Symposium participants
advocated that "[the] EPA include community-based organizations, leaders
and residents in the co-production of knowledge and the scientific bases
for environmental decision making; make resources available to develop
technical skills of community leaders on science and decisions; develop
technical expertise within the communities; and commit resources to
develop networks and centers/consortia with universities to support
community groups with technical matters and participation in decision
making."
8. Develop analytic and assessment tools, and data collection approaches
that could be used by community health advocates and environmental
justice groups. Availability of appropriate tools and training on use of such
tools would also help increase technical capacity of communities. For
example recommendations include "work with local governments to
provide access to data sources; influence their [local governments] data
collection approaches; develop mapping tools that communities can use;
encourage community engagement in the collection of data by
government; explore the approach of using communities to collect data to
overcome limitations of government data such as privacy issues and poor
geospatial resolution; and develop zoning maps that are accessible to
communities; regional councils of government can provide accurate city
level data for community research."
9. Build capacities and skills among EPA/ORD staff and scientists to
conduct research and other science related activities in equal partnership
with impacted communities. This step must include diversifying EPA's
technical and scientific expertise in the social sciences. Concomitant with
efforts to increase technical capacity in communities, EPA/ORD needs to
build up its capacity to work with communities in order for real progress to
be made. Several recommendations from the Symposium address this
issue: "train EPA staff on effective outreach and dialog with communities;
develop capacity within the agency; provide training for EPA risk assessors
and managers on community engagement; consider using qualitative
approaches in risk assessment; multi-disciplinary teams are needed to work
Plan EJ 2014: Appendix, Implementation Plans 144
-------
&EPA
on issues; encourage multidisciplinary teams in environmental health
research; social science disciplines like social epidemiology indicate that
EPA needs to look more at upstream factors - social processes that
ultimately process the disparities in risks and health outcomes; explore
approaches for interacting with communities that can build collective
efficacy and social capital; support participation of communities as equal
partners in research; include them as equal partners in the co-production
of knowledge; and include community representatives and perspectives in
the design of studies/research."
10. EPA and other agencies should integrate environmental justice in all
EPA activities, including policy making, regulatory actions, research and
public outreach. An important place for intervention for environmental
justice is regulation and rule-making. Example recommendations from the
Symposium on the use of science and information to address
environmental justice concerns in decision making include "develop
measures of environmental health disparities to monitor temporal and
spatial trends in disparities, and also whether environmental regulation is
effective; stratify research data by race and income to better analyze
disparate impacts; account for differences in the effect of lead on
hypertension which is more pronounced in chronically stressed individuals
in regulatory assessments and policies; develop tools for equity
assessment; test the validity of available vulnerability indices and tools;
base decisions on good science that passes the tests of reliability,
repeatability and peer review; good data are legally defensible; and present
policy choices and equity impacts to Administrator as a standard
consideration in decision making."
Plan EJ 2014: Appendix, Implementation Plans 145
-------
&EPA
September 2011
Led by
Office of General Counsel
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans 146
-------
&EPA
Goals At-A-G lance
To provide legal
assistance to EPA policy
makers and other Agency
decision makers to
advance their
environmental justice
objectives.
1.0 INTRODUCTION
Plan EJ 2014 established a road map to help the U.S. Environmental
Protection Agency (EPA) integrate environmental justice into its programs.
The Plan outlined five cross-Agency focus areas. The five focus areas are:
1. Incorporating Environmental Justice into Rulemaking.
2. Considering Environmental Justice Concerns in EPA's Permitting
Process.
3. Accelerating Compliance and Enforcement Initiatives.
4. Supporting Community-Based Action Programs.
5. Fostering Administrative-Wide Action on Environmental Justice.
In addition, Plan EJ 2014 identifies four tools to support the cross-Agency
efforts. One of the tools relates to identifying opportunities to use existing
legal authorities to advance environmental justice. The Office of General
Counsel (OGC) has been assigned primary responsibility for this tool. This
implementation plan discusses the goal, strategy, and activities associated
with the development and dissemination of information about EPA's
environmental justice-related legal authorities.
1.1 Goals
The goal of this Initiative is to provide legal assistance to EPA policy makers
and other Agency decision makers to advance their environmental justice
objectives. Our vision is that the Agency will use law as a tool to advance
environmental justice. By providing advice on EPA's discretionary legal
authorities to advance environmental justice, OGC will support the five
cross-Agency focus areas. In particular, OGC's advice will help EPA officials
to (1) implement forward-leaning environmental justice policies with
acceptable legal risk; and (2) identify new opportunities to promote their
environmental justice policy objectives. This initiative will advance
Administrator Lisa Jackson's environmental justice priority, her
commitment to the rule of law, and EPA's overarching mission to protect
human health and the environment.
1.2 Organizational Structure
OGC will give leadership to Plan EJ 2014's focus areas by helping EPA to
integrate environmental justice into its day-to-day business. As the chief
legal adviser to the EPA, OGC provides ongoing legal support for Agency
rules and policies, case-by-case decisions (such as permits and response
actions), and legislation, which includes all of Plan EJ 2014's elements.
OGC's practice areas include all of the Agency's programs (i.e., land, air,
water, etc.), as well as cross-cutting law areas that including environmental
justice, tribal law, and civil rights. OGC regularly interfaces with all the EPA
program offices and regions, as well as EPA's ten Offices of Regional
Counsel.
Plan EJ 2014: Appendix, Implementation Plans
147
-------
&EPA
OGC will accomplish its goal of providing legal assistance to EPA policy
makers and other Agency decision makers to advance their environmental
justice objectives by providing legal support to each cross-Agency focus
area workgroup.
OGC's activities will promote a sound legal framework for the tools and
programs developed by the five focus area workgroups. We will use the
resources of OGC and the Offices of Regional Counsel, both at the staff and
senior leadership levels, to develop our advice to Plan EJ 2014's
workgroups. The persons primarily responsible for coordinating the
development and communication of this advice will be the counseling
attorneys assigned to each workgroup, in collaboration with senior Agency
attorneys and the General Counsel. OGC will conduct this activity
contemporaneously with the work of the five cross-Agency focus areas.
OGC will participate in the stakeholder outreach implemented by each
focus area that we serve.
OGC will provide legal support to each cross-Agency focus area workgroup
through the following activities:
Activity 1: Counseling attorneys will serve as workgroup members for
each cross-Agency focus area. These attorneys are drawn from OGC
and its regional offices.
Activity 2: Regional Counsels and OGC Associate General Counsels will
convene regularly to identify legal issues and develop advice in support
of the five focus areas.
Activity 3: The General Counsel will provide active oversight, direction,
and decision making on all aspects of Plan EJ 2014, in consultation with
the EPA's Senior Leadership.
Activity 4: OGC will convene a group of senior attorneys from across
the federal government to promote the integration of environmental
justice into their agencies' actions.
OGC will participate in the stakeholder outreach implemented by each
focus area that we serve.
The Office of General Counsel might adjust this implementation plan after a
period of implementation.
Plan EJ 2014: Appendix, Implementation Plans
148
-------
vvEPA
This portion of the implementation plan incorporates by reference the
deliverables, schedules, measures, and reports identified in the
implementation plans for the five cross-Agency focus areas. For
information, please contact David Coursen, 202-564-0781,
Coursen.David@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 149
-------
SEPA
September 2011
Led by
Office of Policy and Office of Environmental Information
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans
150
-------
&EPA
Goal At-A-Glance
To develop a more
integrated,
comprehensive, efficient,
and nationally consistent
approach for collecting,
maintaining, and using
geospatial information
relevant to overburdened
communities.
1.0 INTRODUCTION
In 1994, Executive Order 12898 (EO 12898) mandated that each federal
agency make achieving environmental justice part of its mission by
identifying and addressing disproportionately high and adverse human
health or environmental effects of its programs, policies, and activities on
minority, low-income, tribal, and indigenous populations. In implementing
EO 12898, EPA programs and regions have developed a variety of internal
environmental justice screening tools and other Geographic Information
Systems (GIS) applications. These applications, such as the Environmental
Justice Strategic Enforcement Assessment Tool (EJSEAT), EJView, and
others, have played an important role as the Agency worked to integrate
environmental justice into its programs, policies, and activities. Senior EPA
leadership has been asked to focus on developing a nationally consistent
environmental justice screening tool in order to better meet the Agency's
responsibilities of protecting public health under EO 12898 and our goals
under Plan EJ 2014.
In addition, EPA is developing a suite of tools, data, and services known as
EPA's GeoPlatform that will help coordinate and consolidate mapping
activities, applications, and data across the Agency. The GeoPlatform will
support a wide variety of uses across the Agency, including components of
the nationally consistent environmental justice screening tool, and other
data and applications that may be of interest to environmental justice
stakeholders.
1.1 Goal
The goal of this implementation plan is to develop a more integrated,
comprehensive, efficient, and nationally consistent approach for collecting,
maintaining, and using geospatial information relevant to overburdened
communities. EPA will accomplish this goal by: (1) developing a common
Agency-wide mapping platform -the GeoPlatform, (2) creating a nationally
consistent environmental justice screening tool, and (3) incorporating
appropriate elements of the screening tool into the GeoPlatform.
1.2 Organizational Structure
The Office of Environmental Information (OEI) has the lead on the
GeoPlatform, and the Office of Policy (OP) has the lead on the nationally
consistent screening tool.
The development of EPA's GeoPlatform is being led by OEI, with oversight
from the Agency's GIS Workgroup Steering Committee (comprised of
representation from six regions), the Office of Research and Development
(ORD), the Office of Chemical Safety and Pollution Prevention (OCSPP), the
Office of Water (OW), and the EPA Quality and Information Council (QIC).
The QIC is the Agency's decision making body for addressing enterprise-
wide technology issues and developing policies to guide EPA decision
Plan EJ 2014: Appendix, Implementation Plans
151
-------
&EPA
makers in the area of information technology and information
management within the framework of OEI. The QIC is comprised of Senior
Executive Service-level managers from Agency program and regional
offices, and is chaired by the Agency's Chief Information Officer (CIO).
Development of the nationally consistent environmental justice screening
tool is led by OP and is overseen by a steering committee comprised of
Assistant Administrators or their designees from OP, the Office of
Environmental Justice (OEJ), ORD, OEI, and Regions 7, 8, and 9. In addition,
a staff level workgroup meets regularly and has participation from nearly
every program office and region across EPA.
Plan EJ 2014: Appendix, Implementation Plans 152
-------
v°/EPA
ill:
'- ". '
The following three major strategies have been identified as critical
components of the Information Tools Development Implementation Plan:
Develop EPA's GeoPlatform.
Develop a nationally consistent environmental justice screening tool.
Incorporate appropriate elements of the screening tool into the
GeoPlatform
' '
Strategy 1: Develop EPA's GeoPlatform
EPA's GeoPlatform consists of a suite of tools, data and services that will
support a wide variety of uses across the Agency. The GeoPlatform is an
Agency initiative that will serve environmental justice, but also other
important areas such as enforcement and community-based work. The
GeoPlatform will eventually be applied for additional uses, and will provide
access to a wide range of EPA and stakeholder data pertaining to
environmental exposure and risk, ecological condition, public health,
demographic data, and boundary/administrative information, as needed by
EPA programs.
The next several paragraphs describe the GeoPlatform. An understanding
of the structure and philosophy behind the platform is important to seeing
how it will serve environmental justice practitioners. EPA's GeoPlatform
project strives to coordinate activities, applications, and data across the
Agency. We seek to ensure that the opportunity for re-use is maintained
and that data and information is documented and available across the
Agency, to states and tribes, and to our other stakeholder communities.
Our vision is that ultimately everyone has the ability to conduct relevant
geospatial analysis in their area of interest using common data, tools, and
techniques.
Plan EJ 2014: Appendix, Implementation Plans 153
-------
&EPA
The GeoPlatform concept consists of three primary tiers - Applications,
Services, and Data - plus a governance tier (see Figure 1 for the EPA
GeoPlatform conceptual architecture). Details on each tier are provided
below:
Figure 1: Conceptual Architecture for the EPA GeoPlatform
_
Applications
Services
Data
Governance
EPA GeoPlatform
"Online"
EPA Environmental
Analyst
EPA Earth
Other Agency CIS
Applications
Professional CIS
Desktops
Web Services Framework
Discovery Services
Data Access Services
Analytical Services
Shared hosting
Internal Geodata Repository
and Catalog
Integrated GeoDatabase (IGD)
Geodata Gateway (GDG)
External Geodata Repositories
and Catalogs
Data.gov
Federal Geospatial Platform
Policy and Investment Framework
Investment review and optimization
Governance for operational aspects of EPA GeoPlatform
Process and investment strategy to fulfill high priority Agency data needs
Data Tier. The Data components of the EPA GeoPlatform include a wide
range of geospatial data needed for EPA programmatic purposes. Some of
this data is originated and maintained by the Agency, but most of the data
needed is sourced from other public or private sector organizations. Data
components already identified as core sources to be integrated into the
GeoPlatform are the Integrated Geospatial Database (IGD), currently
managed by the OEI/the Office of Information Analysis and Access (OIAA);
the Facility Registry System (FRS), currently managed by OEI/OIC; program
specific databases such as the Toxics Release Inventory (TRI) and
Brownfields, currently managed by the individual program offices; and
externally held geospatial data services, such as for transportation
networks, land use, land cover, and Census data, which come from a
variety of public and private sources. The key to organizing data assets
spread across these different offerings lies in metadata management. The
Agency's "Geospatial Data Gateway" (GDG, http://geogateway.epa.gov)
application will continue to be used for metadata management.
Plan EJ 2014: Appendix, Implementation Plans
154
-------
&EPA
Services Tier. Standardizing our geospatial data management at the Agency
is of critical importance, however, we must also consider the mechanisms
through which we provide Agency staff and other stakeholders access to
different datasets housed in this enterprise. From a technical perspective,
the most effective and re-usable way to broker this access is through open
standards compliant web services. One of the most important components
of the EPA GeoPlatform, then, will be a comprehensive web services tier
that will help ensure that all relevant geospatial data and analytical
components are as widely accessible as possible throughout the enterprise.
Geospatial data access and some geoanalytical services (e.g., buffer and
proximity searches) are being developed to leverage our internal data
stores. Additionally, through catalog services and our application tier
(Environmental Analyst, EPA Portal, etc.), we will be able to leverage
services offered by external public and private providers.
Applications Tier. As part of the EPA GeoPlatform "Release 1" offering,
three central applications will be developed and made available for
Agency-wide use: Environmental Analyst, the EPA Geospatial Portal, and
EPA Earth. Environmental Analyst will be the primary tool initially intended
for environmental justice practitioners. Environmental Analyst is an EPA
custom version of the forthcoming ESRI commercial web application
Community Analyst (http://communityanalyst.esri.com). Environmental
Analyst will feature an interface designed for EPA staff to easily access and
leverage a wide range of geospatial data to carry out their specific tasks.
This represents a major opportunity to consolidate a number of different
internal Program and regional geospatial web applications into a single
one, and a significant portion of the GeoPlatform effort will be dedicated to
outreach and development of opportunities for organizations to have their
data, analytical and reporting requirements integrated into this central
application.
Activity 1.1: Prototype of EPA Environmental Analyst for review.
Activity 1.2: Production release of the EPA Environmental Analyst.
Activity 1.3: Production release of the EPA GeoPlatform (including
initial data services) for use by Environmental Analyst and other
GeoPlatform components.
Strategy 2: Develop the nationally consistent environmental justice
screening tool.
EPA is now taking the next step in creating a nationally consistent
environmental justice screening tool to help identify communities living
with the greatest potential for negative environmental and health effects.
The purpose of the screening tool will be to provide, for locations across
the United States, a comprehensive and nationally consistent tool for
presenting available environmental and demographic data.
The tool will aid decision makers in assessing policy and actions to be taken
by EPA, in accordance with, and pursuant to, applicable law. The tool will
serve as a national baseline screening tool, which can then be
Plan EJ 2014: Appendix, Implementation Plans 155
-------
&EPA
supplemented with additional information and on-the-ground experience
to help identify overburdened communities that may warrant additional
investigation by EPA to help reduce risk and improve public health. OP is
leading a cross-Agency team to identify relevant data and develop
appropriate methods that would serve as the basis of the nationally
consistent screening tool. Asa result of this effort, increased consistency
of data and methods will be brought to environmental justice screening
work across EPA.
Activity 2.1: Hold regular staff workgroup and project steering
committee meetings.
Activity 2.2: Develop a set of options to present to Senior Agency
Officials.
Activity 2.3: Create a working prototype of screening tool.
Activity 2.4: Update the National Environmental Justice Advisory
Council on progress.
Activity 2.5: Obtain peer review and public comment on a prototype
tool.
Activity 2.6: Revise the tool based on comments.
Strategy 3: Incorporate appropriate elements of the screening tool into
the GeoPlatform.
The development of the GeoPlatform and the concurrent creation of a
nationally consistent environmental justice screening tool provide an
opportunity for the two efforts to reinforce and enhance each other. As
both projects continue to evolve, EPA will be watching for opportunities for
them to work together. Making consistent data and screening methods
available to users of the GeoPlatform would go a long way towards
furthering the Agency's work in environmental justice.
Activity 3.1: Review screening tool data, methods, and requirements to
determine which portions may be appropriate to include in the
GeoPlatform.
Activity 3.2: Incorporate appropriate elements of the prototype
screening tool into the GeoPlatform.
Activity 3.3: Revise GeoPlatform elements of the tool to be consistent
with changes made to the prototype tool in response to peer review
and public comments on screening tool.
2.3
Adjustments to the environmental justice screening approach may be
made after public comment, after peer review, and in response to feedback
from early users. Any required adjustments to the EPA GeoPlatform
datasets or the Environmental Analyst application will also be made to
support changes made to the environmental justice screening approach.
Plan EJ 2014: Appendix, Implementation Plans 156
-------
&EPA
3.0 DELIVERABLES
ACTIVITIES
DELIVERABLES MILESTONE
Strategy 1 : Develop the EPA's GeoPlatform.
Activity 1.1
Activity 1 .2
Activity 1 .3
Prototype of EPA Environmental Analyst for
review.
Production release of EPA Environmental
Analyst.
Production release of EPA GeoPlatform
(including initial data services) for use by
Environmental Analyst and other
GeoPlatform components.
Fiscal Year
(FY) 2011 Q4
FY 2012 Ql
FY 2012 Ql
Strategy 2: Develop the nationally consistent environmental justice
screening tool.
Activity 2.1
Activity 2.2
Activity 2.3
Activity 2.4
Activity 2.5
Activity 2.6
Hold regular staff workgroup and project
steering committee meetings.
Develop a set of options to present to Senior
Agency Officials.
Create a working prototype of screening tool.
Update the National Environmental Justice
Advisory Council on progress.
Obtain peer review and public comment on a
prototype tool.
Revise the tool based on comments.
Ongoing
FY 2011 Q3
FY 2012 Q2
TBD
TBD
TBD
Strategy 3: Incorporate appropriate elements of the screening tool into the
GeoPlatform.
Activity 3.1
Activity 3.2
Activity 3.3
Review screening tool data, methods, and
requirements to determine which portions
may be appropriate to include in the
GeoPlatform.
Incorporate appropriate elements of the
prototype screening tool into the
GeoPlatform.
Revise GeoPlatform elements of the tool to
be consistent with changes made to the
prototype tool in response to peer review and
public comments on screening tool.
Begin FY 2011
Q4 & continue
on a monthly
basis
TBD
TBD
Plan EJ 2014: Appendix, Implementation Plans
157
-------
vvEPA
Progress reports on this implementation plan will be made annually. For
information, please contact: Glynis Hill, 202-564-1139, hill.glynis@epa.gov.
Jerry Johnston, 202-564-3175. iohnston.ierry@epa.gov. or Kim Balassiano,
202-566-0709, balassiano.kim@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 158
-------
SEPA
September 2011
Led by
Office of Administration and Resources Management
U.S. Environmental Protection Agency
Washington, D.C. 20460
Plan EJ 2014: Appendix, Implementation Plans
159
-------
&EPA
Goals At-A-G lance
To develop an efficient
and effective system for
delivering financial and
technical assistance to
communities to empower
them to improve their
health and environment.
1.0 INTRODUCTION
1.1 Goals
The U.S. Environmental Protection Agency (U.S. EPAj's Office of
Administration and Resource Management (OARM)'s implementation plan
has two major components. The first component addresses the Agency's
mechanisms for providing grants and technical assistance to support
community-based action programs. The second component addresses
workforce diversity. The goals of each are discussed below.
Grants and Technical Assistance: OARM's goal is to have an efficient and
effective system for delivering financial and technical assistance to
communities to empower them to improve their health and environment.
This goal includes establishing a transparent, integrated One EPA approach
to organizing and implementing the Agency's community-based grants
programs, streamlining grants processes consistent with the EPA's fiduciary
responsibilities, and providing grants management training to
communities. It also includes providing technical assistance to
communities that find it difficult to manage grants, in order to build their
capacity and strengthen their ability to analyze and use technical
environmental information.
OARM's goal furthers the Administrator's priority of Expanding the
Conversation on Environmentalism and Working for Environmental Justice
by establishing a new paradigm for the delivery of EPA assistance to
minority, low-income, tribal, and indigenous peoples to create healthy and
sustainable neighborhoods. It also responds to the cross-Agency focus area
under Plan EJ 2014 of Supporting Community-Based Action Programs by
building on the success of ongoing EPA grants and technical assistance
activities, such as the Community Action for a Renewed Environment
(CARE) Program. By aligning EPA's grants and technical assistance
programs with the needs of all communities to achieve healthy,
sustainable, green, and equitable development, OARM's vision advances
the Agency's mission of protecting human health and the environment.
The purpose of this implementation plan is to realize OARM's vision over
the next three years by charting a course of action for grants and technical
assistance that will be accomplished collaboratively with communities and
EPA's grants management workforce.
Workforce Diversity: OARM's goal is to achieve an inclusive work
environment by developing an efficient system for the outreach and
recruitment of potential employees. Development of a diversity portal,
using social media tools, will be part of the system to attract qualified,
diverse applicants. OARM will also provide Agency-wide diversity training
for hiring officials.
Plan EJ 2014: Appendix, Implementation Plans
160
-------
&EPA
This goal includes establishing an integrated One EPA approach to
consistently recruit and select, both internally and externally, from diverse
pools, the best-qualified candidates for all positions. The changing
demographics of America mean that the public served by EPA is also
changing. When EPA recruits and retains an inclusive workforce one
that looks like the America it serves and where individual differences are
respected, appreciated, and valued, diversity becomes an organizational
strength that contributes to achieving results.
OARM's Office of Diversity, Outreach, and Collaboration (ODOC), in
conjunction with in collaboration with the Office of Human Resources
(OHR) and the Office of Civil Rights (OCR), will work with the EPA national
program offices and regions to broaden the standard outreach and
recruitment efforts to attract qualified applicants from identified groups
with low inclusion rates in EPA's workforce, in compliance with Equal
Employment Opportunity (EEO) laws. OARM's workforce diversity goal
furthers the Administrator's priority of Expanding the Conversation on
Environmentalism and Working for Environmental Justice by establishing a
new paradigm for selecting and hiring potential employees.
1.2
Grants and Technical Assistance: As communicated by the Deputy
Assistant Administrator, Office of Enforcement and Compliance Assurance
the Deputy Regional Administrator, Region 5, to the Deputy Assistant
Administrators and Deputy Regional Administrators on November 5, 2010,
the Agency will implement the Resources Tools Development elements for
grants and technical assistance through the existing Grants Workgroup
formed under the Deputy Administrator's Community-Based Coordination
Project.
The Grants Workgroup is co-chaired by the Director, the Office of Grants
and Debarment (OGD), OARM; and the Director, Financial Policy and
Planning Staff, the Office of Financial Management (OFM), the Office of the
Chief Financial Officer (OCFO). It includes the following seven Subgroups:
Healthy Communities Coordinated Grants Subgroup: Office of Air and
Radiation (OAR) and Region 9 (Co-Chairs).
Technical Assistance Subgroup: Office of Environmental Justice (OEJ)
(Chair).
Training Subgroup: OCFO (Chair).
Competition Subgroup: OGD (Chair).
Internal Policies Subgroup: OGD (Chair).
Legal Issues Subgroup: OEJ and Office of General Counsel (OGC) (Co-
Chairs).
Timely Award Subgroup: OGD and Office of Solid Waste and Emergency
Response (OSWER) (Co-Chairs).
Plan EJ 2014: Appendix, Implementation Plans 161
-------
&EPA
The Grants Workgroup has broad representation from EPA headquarters
and regional offices.
Workforce Diversity: OARM's ODOC will be establishing a cross-Agency
task force, the Outreach and Recruitment Task Force, with representatives
from national program offices and regional offices to develop a national
strategy to attract a diverse pool of qualified applicants.
Plan EJ 2014: Appendix, Implementation Plans 162
-------
v°/EPA
.".'
Grants and Technical Assistance: Under the framework of the Community-
Based Coordination Project, the Grants Workgroup has the following
charges:
Improve community access to information about available grants and
application processes.
Design streamlined grants processes, grants bundling, and other
approaches that ensure quality awards while reducing transaction costs
to communities seeking assistance.
Design efficient and effective approaches to provide technical
assistance to communities that find it difficult to manage grants.
Coordinate with related ongoing grants streamlining efforts.
To accomplish these charges, the workgroup has established seven
strategies:
Strategy 1: Increase Transparency and Efficiency in Providing
Community-Based Grant Opportunities.
Strategy 2: Improve Delivery of Technical Assistance to Communities.
Strategy 3: Strengthen Grants Training for Communities.
Strategy 4: Improve Community Awareness of Grant Competition
Process.
Strategy 5: Revise Grant Policies that are Unduly Restrictive.
Strategy 6: Encourage OGC/Office of Regional Counsel (ORC)/Program
Office Dialogue on Community-Based Grant Opportunities.
Strategy?: Improve timeliness of Brownfields Grant Awards.
Workforce Diversity: The Outreach and Recruitment Task Force will have
the following charge:
Increase the diverse pool of qualified applicants.
Operate under an integrated One EPA approach for recruitment and
outreach.
Plan EJ 2014: Appendix, Implementation Plans 163
-------
&EPA
2.2
Grants and Technical Assistance: To implement these seven strategies, the
Grants Workgroup has identified a set of priority activities. OGD is
responsible for overseeing the workgroup's progress in completing these
tasks.
Strategy 1: Increase Transparency and Efficiency in Providing
Community-Based Grant Opportunities.
* Activity 1.1: Draft recommendations for improving community group
access to EPA grant programs to be presented to Executive
Management Committee (EMC) in March 2011.
Activity 1.2: Solicit informal feedback from communities (e.g., CARE
Program workshops).
Activity 1.3: Conduct outreach to regions and National Program
Managers (NPMs) via conference calls and sharing of drafts.
Strategy 2: Improve Delivery of Technical Assistance to Communities.
* Activity 2.1: Develop Technical Assistance Center approach.
Activity 2.2: Preliminary draft options to be presented to the EMC in
March 2011.
Activity 2.3: Obtain senior management guidance on initial concepts
before obtaining informal feedback from communities.
Activity 2.4: Conduct outreach to regions and NPMs via conference
calls and sharing of drafts.
Strategy 3: Strengthen Grants Training for Communities.
* Activity 3.1: Create umbrella, basic on-line grants training for
communities, environmental justice-specific on-line training, and
program-specific training (e.g., CARE, Urban Waters).
Activity 3.2: Develop training modules by December 2011.
Activity 3.3: Obtain informal community feedback as modules
developed.
Activity 3.4: Conduct outreach to EPA grants management community
by providing opportunities for review of draft training scripts.
Strategy 4: Improve Community Awareness of Grant Competition
Process.
* Activity 4.1: Develop and implement appropriate grant competition
tools (e.g., listservs, webinars). Tools will be in place by October 2011.
Activity 4.2: Obtain informal community input through
Regional/Headquarters websites.
Activity 4.3: Work with regions and NPMs to develop and implement
tools.
Strategy 5: Revise Grant Policies that are Unduly Restrictive.
* Activity 5.1: Revise Delegation 1-86 and indirect cost rate policies for
environmental justice grants by the end of 2011. Temporarily revised
delegation policies were issued in November 2010.
Plan EJ 2014: Appendix, Implementation Plans 164
-------
&EPA
Activity 5.2: Establish simplified Indirect Cost Rate (ICR) policy by
October 2011.
Activity 5.3: Obtain informal community feedback once draft ICR policy
developed.
Activity 5.4: Conduct outreach to regions and NPMs by providing
opportunity to comment on draft policy issuance.
Activity 5.5: Explore simplification of other policies.
Strategy 6: Encourage Office of General Counsel/Office of Regional
Counsel/Program Office Dialogue on Community-Based Grant
Opportunities.
Activity 6.1: Conduct periodic OGC/ORC/OEJ meetings and OGC
guidance on scope of community-based grant authorities.
OGC/ORC/OEJ calls were conducted on January 5, 2011, and February
2, 2011.
Activity 6.2: Obtain OGC legal_guidance on scope of grant authorities.
Activity 6.3: Coordinate discussions with larger OGC effort on existing
legal authorities.
Strategy 7: Improve timeliness of Brownftelds Grant Awards.
* Activity 7.1: Develop recommendations for consistent Brownfields
award times by August 2011. Draft recommendations will be shared
with the EPA's Grants Management Officers (GMOs) and OSWER. This
is primarily an internal Agency process issue.
The workgroup anticipates that it will complete all of these priority
activities by the end of 2011. It recommends that the Agency codify
workgroup accomplishments in a consolidated Grants Policy approved by
senior Agency management. No additional Full Time Employee (FTE) will
be required to complete agreed-upon tasks. As described above, each
Subgroup under the Grants Workgroup will conduct appropriate
community and stakeholder outreach.
Workforce Diversity: To meet its goals, the Outreach and Recruitment
Task Force has identified four priority activities. OARM's ODOC is
responsible for overseeing the workgroup's progress in completing these
tasks.
* Activity 1: Design an efficient Agency-wide outreach strategy by
January 2012.
Activity 2: Develop effective marketing materials and strategy by
January_2012.
Activity 3: Develop a National Conference Toolkit by January 2012.
Activity 4: Develop a National Outreach Calendar by January 2012.
OARM will also provide Agency-wide diversity training for hiring officials.
Plan EJ 2014: Appendix, Implementation Plans 165
-------
SEPA
Grants and Technical Assistance: As noted in Section 2.2, the Grants
Workgroup is seeking informal feedback from communities in developing
revisions to policies, procedures, and organizational structures. More
formal community feedback (for example, feedback from the National
Environmental Justice Advisory Council [NEJAC]) may be required for
certain activities, including the development and selection of options under
Strategies 1 and 2. As workgroup activities proceed, OARM will consult
with OEJ to determine the need for formal community feedback.
Grants and Technical Assistance: OGD will carefully monitor and evaluate
the effect of revised policy and procedures in Fiscal Year (FY) 2012. If the
Agency and communities are not realizing the desired outcomes, OGD and
the workgroup will make necessary adjustments in FY 2013 to reach the
desired outcomes.
Plan EJ 2014: Appendix, Implementation Plans 166
-------
v>EPA
i """i" i
Grants and Technical Assistance: Appendix B contains a draft schedule of
deliverables along with associated performance measures.
Workforce Diversity: OARM's ODOC is in the process of soliciting
proposals from contractors for diversity training. It is anticipated that the
Outreach and Recruitment Task Force will initiate all of these priority
activities by the end of 2011.
3,2
Grants and Technical Assistance: See Appendix B.
Workforce Diversity: Measures will be developed in a collaborative
manner once the Task Force is convened.
Plan EJ 2014: Appendix, Implementation Plans 167
-------
vvEPA
Grants and Technical Assistance: The Grants Workgroup will provide
quarterly progress updates as part of the Community-Based Coordination
Project. OARM will submit an annual progress report at the end of each FY
as required by Plan EJ 2014. For information, please contact Howard
Corcoran, 202-564-1903, Corcoran.Howard@epa.gov.
Workforce Diversity: Reporting will be developed in a collaborative
manner once the Outreach and Recruitment Task Force is convened. For
information, please contact Antoinette Powell-Dickson, 202-566-0738,
Powell-Dickson.Antoinette@epa.gov.
Plan EJ 2014: Appendix, Implementation Plans 168
-------
&EPA
Appendix B: Table of Deliverables and Measures
Strategy Number Q2FY2011 Q3FY2011 Q*Q Q1FY2012 Q2FY2012 Q3FY2012 Q*QU ^FYan?" Measures
Strategy 1: Increase
Transparency &
Efficiency in Providing
Community-Based
Grant Opportunities.
Strategy 2: Improve
Delivery of Technical
Assistance to
Communities.
Strategy 3:
Strengthen Grants
Training for
Communities.
Strategy 4:
Improve Community
Awareness of Grant
Competition Process.
Brief EMC on
draft options
for improving
grant delivery
system.
Brief EMC on
preliminary
draft options.
Complete
development
of draft
umbrella and
environmental
justice on-line
training.
Seek input
from EPA
grants
community
via
regional/HQ
websites.
Refine
reform
options
based on
EMC and
community
feedback.
Refine
reform
options
based on
EMC and
community
feedback.
Obtain
community
&EPA
feedback;
initiate
program-
specific
trainings.
Evaluate
community
feedback;
Obtain EPA
feedback.
Finalize
reform
options.
Finalize
reform
options.
Evaluate
feedback;
continue
to develop
program-
specific
training.
Evaluate
feedback;
finalize
competitio
n tools.
Begin
implementation
Begin drafting
of grant or
contract
RFP(s).
Complete all
training.
Roll-out
competition
tools to
communities.
Continue
implementation
Issue RFP(s).
Roll-out
training to
communities.
Promote use of
tools.
Continue
implementation
RFP period
closes.
Provide
training.
Promote use of
tools.
Continue
implement
ation.
Evaluate
application
s an make
selections
for service
provider(s)
Provide
training.
Evaluation
of
effectiven
ess of
tools.
Conduct
evaluation
and make
necessary
adjustments.
Monitor
service
provider(s),
conduct
evaluation,
and make
necessary
adjustments.
Conduct
evaluation of
training and
make
necessary
adjustments.
Tools
adjusted
based on
results of
evaluation.
Reduction in
regional workload;
Increase in
community grant
applications.
Compliance with
performance
measures in
grant/contract
workplan(s);
Degree of
utilization by
regions and
Communities;
Geographic
distribution of
outreach activities.
Community
satisfaction as
measured by
customer
feedback.
Number of, and
participation in,
webinars;
Increase in
applications from
new organizations
(OEJ).
Plan EJ 2014: Appendix, Implementation Plans
178
-------
&EPA
O1 FY90n
Strategy Number Q2FY2011 Q3FY2011 Q4FY2011 Q1FY2012 Q2FY2012 Q3FY2012 Q4FY2012 py^fflli Measures
Strategy 5:
Revise grant policies that
are unduly restrictive.
Strategy 5:
Revise grant policies that
are unduly restrictive.
Strategy 6: Encourage
OEJ-OGC/ORC-Program
Office Dialogue on
Community-Based Grant
Issues.
Strategy 6:
Encourage OEJ-
OGC/ORC -Program
Office Dialogue on
Community-Based Grant
Issues.
Strategy 7: Improve
Timeliness of Brownfields
Grant Awards.
Inform
programs of
temporary
rsvissd
version of
Delegation 1-
86.
Draft policy to
simplify
indirect cost
rules; solicit
feedback on
changes to
other policies.
Hold kick-off
meeting to
clarify roles
and
responsibilitie
s for eligibility
reviews.
Schedule for
issuance of
OGC
guidance on
the scope of
existing grant
authorities to
be
determined.
Develop draft
approach.
Issue draft
revision to
indirect
cost
policies and
nthpr
Ull 1 Gl
identified
policies.
Second
quarterly
meeting.
Consult
with HO/
Regional
Program &
Grsnts
Offices.
Issue final
revised
indirect
cost rate
policy/other
revised
policies.
Quarterly
meeting.
Finalize
strategy
and begin
tn
Lu
implement.
Issue final
revised
vsrsion of
Delegation 1-
86.
Implement.
Quarterly
meeting.
Implement.
Continue to
implement.
Quarterly
meeting.
Continue to
implement.
Continue to
implement.
Quarterly
meeting.
Continue to
implement.
Continue to
implement.
Quarterly
meeting.
Continue to
implement.
Assess need
for additional
changes to
delegation
and make
adjustments
as
necessary.
Conduct
evaluation
and make
necessary
adjustments.
Conduct
evaluation
and make
necessary
adjustments.
Conduct
evaluation
and make
nscssssry
adjustments.
Increase in
number of
single-statute
awards.
Number of
communities
that take
advantage of
simplified
indirect cost
rates.
Increase in
timeliness of
Program
Office/
OGC/ORC
eligibility
reviews.
Reduction in
number of
legally
ineligible
grant
applications.
Reduction in
award times
across grants
officss
Plan EJ 2014: Appendix, Implementation Plans
179
-------
This page left intentionally blank
-------
SEPA
AANAPISIs Asian American Native American Pacific Islanders Servicing
Institutions
ADP Action Development Process
Agency U.S. Environmental Protection Agency
ASIWPCA Association of State and Interstate Water Pollution Control
Administrators
ASTSWMO Association of State and Territorial Solid Waste
Management Officials
BAG" Best Available Control Technology
C-FERST Community-Focused Exposure and Risk Screening Tool
CAA Clean Air Act
CAAAC Clean Air Act Advisory Committee
CAFO Concentrated Animal Feeding Operation
CARE Community Action for a Renewed Environment
CB Community-based
CBCE Community-based coordination efforts (initiative)
CBP Community-based partners (program)
CBPR Community-Based Participatory Research
CCRS Criminal Case Reporting System
CEI Community Engagement Initiative
CenRANK Census Tract Ranking Tool for Environmental Justice
CEQ White House Council on Environmental Quality
CHPAC Children's Health Protection Advisory Committee
CIC Community Involvement Coordinator
CIO Chief Information Officer
CIPIB Community Involvement and Program Initiatives Branch
CIU Community Involvement University
CRA Cumulative Risk Assessment
CSO Combined Sewer Overflow
CVRA Crime Victims' Rights Act
DAA Deputy Assistant Administrator
DOE U.S. Department of Energy
DOJ U.S. Department of Justice
Plan EJ 2014: Acronyms
181
-------
vvEPA
DOT U.S. Department of Transportation
DRA Deputy Regional Administrator
DSW Definition of Solid Waste (rule)
ECOS Environmental Council of the States
EEO Equal Employment Opportunity
EFAB Environmental Financial Advisory Board
EIS Environmental Impact Statement
EJIWG Federal Interagency Working Group on Environmental
Justice
EJC Environmental Justice Committee
EJGAT Environmental Justice Geographic Assessment Tool
EJSEAT Environmental Justice Strategic Enforcement Assessment
Tool
EMC Executive Management Council
EO 12898 Executive Order 12898 (on environmental justice)
EPA U.S. Environmental Protection Agency
ESC Executive Steering Committee
FaST Faculty and Student Teams (Program)
FCHDR Federal Collaboration on Health Disparities Research
FRS Facility Registry System
FY Fiscal Year
GDG Geospatial Data Gateway
GIS Geospatial Information System
GMO Grants Management Officers
GRO Greater Research Opportunities (fellowship)
GWPC Ground Water Protection Council
HBCUs Historical Black Colleges and Universities
HHS U.S. Department of Health and Human Services
HSIs Hispanic Servicing Institutions
HUD U.S. Department of Housing and Urban Development
ICIS Integrated Compliance Information System
ICR Indirect Cost Rate
IGD Integrated Geospatial Database
ITEP Tribal Environmental Professionals
Plan EJ 2014: Acronyms
182
-------
vvEPA
LEP Limited English Proficiency
MAI Minority Academic Institutions
MOU Memorandum of Understanding
MSI Minority Serving Institution
NACAA National Association of Clean Air Agencies, comprised of
the State and Territorial Air Pollution Program
Administrators and the Association of Local Air Pollution
Control Officials
NACWA National Association for Clean Water Agencies
NAHMMA North American Hazardous Materials Management
Association
NCER National Center for Environmental Research
NCMHD National Center on Minority Health and Health Disparities
NEI National Enforcement Initiative
NEJAC National Environmental Justice Advisory Council
NEPA National Environmental Policy Act
NEPPS National Environmental Performance Partnership System
NERL National Exposure Research Laboratory
NESCA National Enforcement Strategy for Corrective Action
NEWMOA Northeast Waste Management Officials' Association
NGO Non-governmental organization
NHEERL National Health and Environmental Effects Research
Laboratory
NIH National Institutes of Health
NPM National Program Manager
NSF National Science Foundation
NTOC National Tribal Operations Committee
OAR Office of Air and Radiation
OARM Office of Administration and Resource Management
OCFO Office of the Chief Financial Officer
OCHP Office of Children's Health Protection
OCIR Office of Congressional and Intergovernmental Affairs
OCR Office of Civil Rights
OCSPP Office of Chemical Safety and Pollution Prevention
ODOC Office of Diversity, Outreach and Collaboration
Plan EJ 2014: Acronyms
183
-------
vvEPA
OECA Office of Enforcement and Compliance Assurance
OEI Office of Environmental Information
OEJ Office of Environmental Justice
OFA Office of Federal Activities
OFM Office of Financial Management
OGC Office of General Counsel
OGD Office of Grants and Debarment
OHR Office of Human Resources
OIA Office Indian Affairs
OIAA Office of Information Analysis and Access
OP Office of Policy
OPP Office of Pesticide Programs
ORC Office of Regional Counsel
ORD Office of Research and Development
OSA Office of the Science Advisor
OSP Office of Science Policy
OSWER Office of Solid Waste and Emergency Response
OW Office of Water
PPA Performance Partnership Agreement
PPG Performance Partnership Grants
Q&A Question-and-Answer
QIC Quality and Information Council
RAF Risk Assessment Forum
RARE Regional Applied Research Effort Program
RCRA Resource Conservation and Recovery Act
RFA Request for Applications
RFP Request for proposal
RSS Really Simple Syndication
SAB Science Advisory Board
SEP Supplemental Environmental Project
SHCRP Sustainable and Healthy Communities Research Program
SIT Strategic Implementation Team
SSMs Startups, Shutdowns, and Malfunctions
SSO Sanitary Sewer Overflow
Plan EJ 2014: Acronyms
184
-------
vvEPA
STAR Science to Achieve Research (grant)
TAB Technical Assistance to Brownfields Communities (grant)
TAMS Tribal Air Monitoring Support (Center)
TASC Technical Assistance Services for Communities (program)
TBD To be determined
TCUs Tribal Colleges and Universities
TRI Toxics Release Inventory
UTEP University of Texas El Paso
185
Plan EJ 2014: Acronyms
-------
For more information on Plan EJ 2014, visit the U.S. Environmental Protection Agency's Office of
Environmental Justice website at: http://www.epa.gov/environmentaljustice/plan-ej7
------- |