# gk j PLAN EJ 2014 RESOURCES TOOLS DEVELOPMENT DRAFT IMPLEMENTATION PLAN Led by Office of Administration and Resources Management Plan EJ 2014 is EPA's roadmap to integrate environmental justice (EJ) into its programs and policies. 2014 represents the 20th anniversary of the signing of Executive Order 12898 on environmental justice. ------- Comments regarding the Resources Tools Development Draft implementation Plan can be submitted on Regulations.gov Docket # EPA-HQ-OECA-2011-0290. Comments will be accepted through April 29, 2011. For more information on Plan EJ 2014, visit the US EPA's Office of Environmental Justice website at: http://www.epa.gov/environmentaliustice/plan-ei/index.html. ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 1.0 INTRODUCTION 1.2 Goals The Office of Administration and Resource Management's (OARM) 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. 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, One-EPA approach to organizing and implementing the Agency's community-based grants programs, streamlining grants processes consistent with 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/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 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 citizens and community groups to achieve healthy, sustainable, and green communities, 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. This goal includes establishing a 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 the 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. 1 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 OARM's Office of Diversity, Outreach and Diversity (ODOC) will work with the National Program Offices 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 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 Organizational Structure Grants and Technical Assistance: As communicated by Catherine McCabe and Bharat Mathur 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, Office of Grants and Debarment (OGD), OARM, and the Director, Financial Policy and Planning Staff, Office of Financial Management (OFM), 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 OGC (Co-Chairs) • Timely Award Subgroup: OGD and Office of Solid Waste and Emergency Response (OSWER) (Co-Chairs) The Grants Workgroup has broad representation from 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 by May 13, 2011. 2 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 2.0 IMPLEMENTATION 2.1 Strategies 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/ORC/Program Office Dialog on Community-Based Grant Opportunities Strategy 7: 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 a One-EPA approach for recruitment and outreach 2.2 Activities 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 • Draft recommendations for improving community group access to EPA grant programs to be presented to Executive Management Committee (EMC) in March 2011 • Soliciting informal feedback from communities (e.g., CARE Program workshops) • Conducting outreach to Regions and National Program Managers (NPMs) via conference calls and sharing of drafts. 3 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 Strategy 2: Improve Delivery of Technical Assistance to Communities • Develop Technical Assistance Center approach • Preliminary draft options to be presented to the EMC in March 2011 • Need senior management guidance on initial concepts before obtaining informal feedback from communities • Will conduct outreach to Regions and NPMs via conference calls and sharing of drafts Strategy 3: Strengthen Grants Training for Communities • Create umbrella, basic on-line grant training for communities, EJ-specific on-line training, and program-specific training (e.g., CARE, Urban Waters) • Training modules in place by December 2011 • Will obtain informal community feedback as modules developed • Will 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 • Develop and implement appropriate grant competition tools (e.g., listservs, webinars) • Tools in place by October 2011 • Obtaining informal community input through Regional/HQ websites • Will work with Regions and NPMs to develop and implement tools Strategy 5: Revise Grant Policies that are Unduly Restrictive • Revise Delegation 1-86 and indirect cost rate policies • Temporarily revised delegation issued November 2010 • Simplified Indirect Cost Rate (ICR) policy in place by October 2011 • Will obtain informal community feedback once draft ICR policy developed • Will conduct outreach to Regions and NPMs by providing opportunity to comment on draft policy issuance • Will explore simplification of other policies Strategy 6: Encourage Office of General Counsel/Office of Regional Counsel/Program Office Dialog on Community-Based Grant Opportunities • Conduct periodic OGC/ORC/OEJ meetings and OGC guidance on scope of community-based grant authorities • First OGC/ORC/OEJ call held 01/05/11 • Next OGC/ORC/OEJ call scheduled for 2/2/11 • Awaiting OGC legal guidance on scope of grant authorities • Discussions must be coordinated with larger OGC effort on existing legal authorities 4 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 Strategy 7: Improve timeliness of Brownfields Grant Awards • Draft recommendations for consistent Brownfields award times to be issued 1/31/11 • Draft recommendations will be shared with EPA's Grants Management Officers (GMOs) and OSWER and finalized by May 2011 • 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/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 June 24, 2011 Activity 2: Develop effective marketing materials and strategy July 29, 2011 Activity 3: Develop a National Conference Toolkit by August 19, 2011 Activity 4: Develop a National Outreach Calendar by August 19, 2011 OARM will also provide Agency-wide diversity training for hiring officials. 2.3 Community Engagement and Stakeholder Partnership Plan 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 (e.g., feedback from the National Environmental Justice Advisory Council (NEJAC)) may be required for certain activities, including the development/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. 2.4 Adjustments Grants and Technical Assistance: OGD will carefully monitor and evaluate the impact of revised policy and procedures in FY 2012. If the Agency and communities are not realizing the desired outcomes, OGD and the Workgroup make necessary adjustments in FY 2013 to reach the desired outcomes. 5 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 3.0 DELIVERABLES 3.1 Schedule of Deliverables Grants and Technical Assistance: Appendix A 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 Task Force will complete all of these priority activities by the end of 2011. 3.2 Measures Grants and Technical Assistance: See Appendix B. Workforce Diversity: Measures will be developed in a collaborative manner once the Task Force is convened. 3.3 Reporting 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 fiscal year 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 Task Force is convened. For information, please contact: Antoinette Powell-Dickson, 202-566-0738, powell-dickson.antoinette@epa.gov. 6 ------- Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011 4.0 APPENDICES Appendix A: Acronyms CARE - Community Action for a Renewed Environment EMC - Executive Management Committee GMO - Grants Management Officers NEJAC - National Environmental Justice Advisory Council NPM - National Program Managers OARM - Office of Administration and Resource Management OAR - Office of Air and Radiation OCFO - Office of the Chief Financial Officer OCHP - Office of Children's Health Protection OCSPP - Office of Chemical Safety and Pollution Prevention ODOC - Office of Diversity, Outreach and Collaboration OEJ - Office of Environmental Justice OFM - Office of Financial Management ORC - Office of Regional Counsel OGC - Office of General Counsel OGD - Office of Grants and Debarment Appendix B: Table of Deliverables and Measures See Pages 8-9. 7 ------- Strategy Number Q2 FY11 Q3FY11 Q4FY11 Q1FY12 Q2FY12 Q3FY12 Q4FY12 Q1FY13 - FY 14 Measures Strategy 1: Increase Transparency & Efficiency in Providing Community- Based Grant Opportunities Brief EMC on draft options for improving grant delivery system Refine reform options based on EMC and community feedback Finalize reform options Begin implementation Continue implementation Continue implementation Continue implementation Conduct evaluation and make necessary adjustments Reduction in Regional workload; Increase in community grant applications Strategy 2: Improve Delivery of Technical Assistance to Communities Brief EMC on preliminary draft options Refine reform options based on EMC and community feedback Finalize reform options Begin drafting of grant or contract RFP(s) Issue RFP(s) RFP closes Evaluate applications an make selections for service provider(s) Monitor service provider(s), conduct evaluation, and make necessary adjustments Compliance with performance measures in grant/contract workplan(s); Degree of utilization by Regions and Communities; Geographic distribution of outreach activities Strategy 3: Strengthen Grants Training for Communities Complete development of draft umbrella and EJ on-line training Obtain community & EPA feedback; initiate program- specific trainings Evaluate feedback; continue to develop program- specific trainng Complete all training Roll-out training to communities Provide training Provide training Conduct evaluation of training and make necessary adjustments Community satisfaction as measured by customer feedback Strategy 4: Improve Community Awareness of Grants Competition Process Seek input from EPA grants community via Regional/HQ websites Evaluate community feedback; Obtain EPA feedback Evaluate feedback; finalize competition tools Roll-out competition tools to communities Promote use of tools Promote use of tools Evaluation of effectiveness of tools Tools adjusted based on results of evaluation # of, and participation in, webinars; Increase in applications from new organizations (OEJ) ------- Strategy Number Q2FY11 Q3FY11 Q4FY11 Q1FY12 Q2FY12 Q3FY12 Q4FY12 Q1FY13- FY14 Measures Strategy 5: Revise Grant Policies that are unduly restrictive Inform programs of temporary revised version of Delegation 1- 86 Issue final revised version of Delegation 1-86 Assess need for additional changes to delegation and make adjustments as necessary Increase in # of single-statute awards Strategy 5: Revise Grant Policies that are unduly restrictive Draft policy to simplify indirect cost rules; solicit feedback on changes to other policies Issue draft revision to indirect cost policies and other identified policies Issue final revised indirect cost rate policy/other revised policies Implement Continue to implement Continue to implement Continue to implement Conduct evaluation and make necessary adjustments # of communities that take advantage of simplified indirect cost rates Strategy 6: Encourage OEJ- OGC/ORC-Program Office Dialog on Community-Based Grant Issues Hold kick-off meeting to clarify roles and responsibilities for eligibility reviews Second quarterly meeting Quarterly meeting Quarterly meeting Quarterly meeting Quarterly meeting Quarterly meeting Conduct evaluation and make necessary adjustments Increase in timeliness of Program Office/ OGC/ORC eligibility reviews Strategy 6: Encourage OEJ- OGC/ORC - Program Office Dialog on Community-Based Grant Issues Schedule for issuance of OGC guidance on the scope of existing grant authorities to be determined Reduction in # of legally ineligible grant applications Strategy 7: Improve Timeliness of Brownfields Grant Awards Develop draft approach Consult with HQ/ Regional Program & Grants Offices Finalize strategy and begin to implement Implement Continue to implement Continue to implement Continue to implement Conduct evaluation and make necessary adjustments Reduction in award times across Grants Offices ------- |