&EPA
    United States
    Environmental Protection
    Agency
Plan EJ 2014
    Considering
Environmental Justice
    in Permitting
                            Plan EJ 2014 is EPA's roadmap for
                            integrating environmental justice into
                            its programs and policies.

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CONSIDERING ENVIRONMENTAL JUSTICE
               IN PERMITTING

               Implementation Plan
                  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

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                                              PLAN EJ 2014 AT A GLANCE

                                 Plan EJ 2014 is the U.S. Environmental Protection Agency (EPA)'s
                                 roadmap to integrating environmental justice into its programs and policies.
                                 The year marks the 20th anniversary of the signing of Executive Order
                                 12898 on environmental justice. Plan EJ 2014 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.
                                 As the EPA's overarching environmental justice strategy, Plan EJ 2014 has
                                 three major sections: Cross-Agency Focus Areas, Tools Development
                                 Areas, and Program Initiatives.
                                 The Cross-Agency Focus Areas are:
                                       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.

                                 The Tools Development Areas are:
                                       Science.
                                       Law.
                                       Information.
                                       Resources.

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                      Table of Contents
                      1.0   INTRODUCTION	1
                        1.1 Goals	2
                        1.2 Organizational Structure	3
                      2.0   IMPLEMENTATION	4
                        2.1 Strategies	4
                        2.2 Activities	5
                        2.3 Community Engagement and Stakeholder Outreach	7
                      3.0   DELIVERABLES	8
                      4.0   REPORTING	9
                        Potential Tools	10
                      ACRONYMS	15

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 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.1

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,
                                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.
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                               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 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.

                               1.1 Goals
                               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).2

                               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."3
                                  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."4
                                  EPA's mission to protect human health and the environment.
                               2 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.
                               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.
                               4 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/.
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                             1.2 Organizational Structure
                             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).

                             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.
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                                 2.0    IMPLEMENTATION
    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.
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.


2.1 Strategies

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.
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                              2.2 Activities
                              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 tools5 (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
                               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)."
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                              workgroup solicited additional comments via an external e-mail and an
                              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 Oil/early 2 012).

                              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.
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                             2.3  Community Engagement and Stakeholder Outreach
                             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
                                 Territorial Solid Waste
                                 Management Officials
                                 (ASTSWMO).
Interagency Working Group on
Environmental Justice.
                                 Association of State & Interstate
                                 Water Pollution Control
                                 Administrators (ASIWPCA).
                                 Business organizations and trade
                                 associations.
                                 Clean Air Act Advisory Committee
                                 (CAAAC).
                                 Community advocacy groups.
                                 Environmental Council of the
                                 States (ECOS).
                                 Ground Water Protection Council
                                 (GWPC).
National Association of Clean Air
Agencies (NACAA).
National Association for Clean
Water Agencies (NACWA).
National Tribal Operations
Committee (NTOC).
North American Hazardous
Materials Management
Association (NAHMMA).
Northeast Waste Management
Officials' Association (NEWMOA).
Other federal agencies and state,
local, and tribal permitting
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).
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                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
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                                       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
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                              Potential Tools
                              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.
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                                     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 indigenous6
                                  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.
                              6 When the term "indigenous" is used in this document, it refers to entities and individuals in the
                              United States only.
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                                 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 [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,7 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.
                              7 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.
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                                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.
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                             "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 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.
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                            ACRONYMS
                            AANAPISIs     Asian American Native American Pacific Islanders
                                          Servicing Institutions
                            ASTSWMO     Association of State and Territorial Solid Waste
                                          Management Officials
                            ASIWPCA      Association of State & Interstate Water Pollution Control
                                          Administrators
                            BAG"         Best Available Control Technology
                            C-FERST       Community-Focused Exposure and Risk Screening Tool
                            CARE         Community Action for a Renewed Environment
                            CAAAC        Clean Air Act Advisory Committee
                            CenRANK      Census Tract Ranking Tool for Environmental Justice
                            ECOS         Environmental Council of the States
                            EJSEAT        Environmental Justice Strategic Enforcement Tool
                            EPA          U.S. Environmental Protection Agency
                            FY            Fiscal Year
                            GWPC        Ground Water Protection Council
                            HSIs          Hispanic Servicing Institutions
                            HBCUs        Historical Black Colleges and Universities
                            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
                            NEWMOA     Northeast Waste Management Officials' Association
                            NEJAC        National Environmental Justice Advisory Council
                            NTOC         National Tribal Operations Committee
                            Q&A         Question-and-Answer
                            RSS          Really Simple Syndication
                            SEP          Supplemental Environmental Project
                            SSMs         Startups, Shutdowns, and Malfunctions
                            TCUs         Tribal Colleges and Universities
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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

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