Integrating

Environmental Justice Into
Emergency Response
Preparedness and
Management


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Integrating Environmental Justice into
Emergency Response Preparedness and Management

This document outlines steps to enhance the effectiveness of EPA's emergency response functions
to ensure such efforts are inclusive, equitable, and responsive in following EPA's mission to
protect human health and the environment. EPA's traditional emergency response role primarily
has been responding to the potential and actual threats and impacts from the release of hazardous
substances, contaminants, or pollutants and discharges of oil. However, EPA may also address the
impacts of community water and wastewater systems during an Emergency Support Function
(ESF) #3 mission for Stafford Act responses. These incidents are often in areas populated by
underserved and overburdened communities.

In 2006, the National Environmental Justice Advisory Council's (NEJAC) report, 2005 Gulf Coast
Hurricanes and Vulnerable Populations: Recommendations for Future Disaster
Preparedness/Response, called for changes in EPA's emergency response procedures, notably:

•	Incorporate an environmental justice function and staffing support in the Incident
Command System (ICS) structure

•	Develop public participation guidelines for disaster response situations, and promote their
adoption and use by relevant emergency response organizations in both the public and
private sectors

Following the April 2010 Deep Water Horizon oil spill, EPA deployed an EJ staff member to the
Gulf to serve as a liaison officer for environmental justice. Similarly, following the aftermath of
October 2012 Superstorm Sandy, staff was again deployed to the region to facilitate identifying
and responding to the concerns of underserved and overburdened communities. EJ staff liaisons
achieved varying levels of effectiveness and acceptance due to a lack of a clear role and function in
the overall response structure. These limitations played out once again during the Flint drinking
water response. After these emergency response efforts (each of which occurred in different parts
of the country with different circumstances and with varying levels of responsiveness to
vulnerable populations), EPA recognized the need for more proactive consideration of the
concerns of environmental justice communities during emergency response operations.

The Agency has made some changes to its practice over the last decade to address the need for
more proactive consideration of environmental justice in responses. In 2007, the Office of
Emergency Management (OEM) revised EPA's Incident Management Handbook (IMH), and
retained these changes in both the January 2016 and April 2020 updates, to include the following
environmental justice-related responsibilities for three key leadership positions (KLP):

•	Incident Commander (IC) [page 7-3, Item d]: "Ensure adequate resources are devoted to
Liaison staff to assure that environmental justice issuesi- receive appropriate attention."

•	Public Information Officer (PIO) [page 7-5, Item o-p]: "Ensure that community relations
activities are effectively coordinated with other Command and General Staff functions. This

1 For purposes of this document and incorporation into the IMH and any other document, environmental justice issues
will be understood to include concerns of overburdened and vulnerable communities including communities of color,
low-income communities, tribal and indigenous communities, and issues affecting other vulnerable populations such
as persons with disabilities.


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includes outreach, in coordination with the Command Staff Liaison Officer, to vulnerable
populations during the course of the response in collaboration with regional environmental
justice and tribal offices. Ensure the community feedback and issues are effectively
coordinated with the LNO."

• Liaison Officer (LNO) [p7-8, Item m, o]: "Ensure Environmental Justice issues are addressed
in a timely manner and briefed to the IC/UC as necessary;" "Coordinate frequently
regarding Environmental Justice issues and outreach to vulnerable populations with the
Command Staff PIO, who has responsibility for community outreach activities."

Later in 2016, the Agency issued EPA Order 2010, Crisis Communications Plan, which states that
community outreach is a vital component of the Agency's overarching communications strategy
during a response. Response-specific Crisis Communication Plans identify several key
communication considerations that are to be specifically addressed by agency Public Information
Officers (PIO) during an incident, including community engagement, a commitment to language
access obligations, and environmental justice. The Order notes that EPA's community involvement
coordinators are highly experienced in determining what environmental messages are important
to the public and whether key messages are being disseminated to the public in an
understandable, timely, accurate, and consistent manner. The Plan also establishes that the
Agency will assess limited English proficient populations and needs and develop information that
addresses environmental justice factors.

These modifications have been important improvements to the integration of environmental
justice and the consideration of the needs of vulnerable populations during an emergency
response. However, a more explicit inclusion of environmental justice considerations into EPA's
emergency management processes would build on previous recommendations provided to, and
improvements already implemented by, the Agency. The Office of Environmental Justice and
External Civil Rights (OEJECR), in collaboration with OEM, believe that the recommendations
outlined below will build on these improvements to ensure consistent, coordinated, and effective
consideration of environmental justice throughout EPA's emergency responses over time. Leads
and co-leads for each recommendation are included in brackets after the recommendation.

RECOMMENDATIONS

1) Integrate Environmental Justice priorities into EPA's National Approach to Response
(NAR) structure and develop Management Objectives/Incident Objectives, as needed -

In compliance with the National Incident Management System (NIMS) and per Order #2071 on
EPA's National Approach to Response (NAR), EPA has created a coordinated structure to
enhance the Agency's ability to implement the operational components of a response by
maintaining communication and coordination among senior management, providing resource
support at a national- or regional-level, and supporting the incident command structure in the
field. These structures include the Policy Coordinating Committee (PCC), which addresses
significant intra- and inter-agency national policy issues; the National Incident Coordinator
(NIC) and Regional Incident Coordinator (RIC) positions, who coordinate cross-programmatic
policy and resource needs; and the National Incident Coordination Team (NICT) and Regional
Incident Coordination Team (RICT), which support the efforts of the NIC and RIC, respectively.
To ensure that environmental justice is embedded in a response, when appropriate, we


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recommend that the RIC work in tandem with the NIC and PCC to develop management
objectives for individual responses to provide general direction and/or convey Agency
priorities around ensuring responses are equitable. Sample management response objectives
include but are not limited to:

•	Assist with facilitating greater inter- and intra-governmental coordination to protect
vulnerable underserved and overburdened populations

•	Ensure that the needs and concerns of vulnerable populations are being adequately
considered and addressed.

The RIC should then ensure that Incident Objectives developed by the regional IMT align and
help achieve the management objectives developed for environmental justice. [RIC(s) and
IC(s) from the impacted Region(s) in coordination with the NIC (if nationally-significant
incident)]

2)	Engage Environmental Justice expertise in early assessments, as needed -- Add an EJ

representative, ideally either a Regional EJ Coordinator, their division manager, or a
manager/senior staff from OEJECR, to regional and/or headquarters incident management
assessment processes, as appropriate. By engaging the EJ representative during early-
assessments, the Agency can better plan for how to identify potential environmental justice
concerns, issues, and vulnerable populations. For example, EJ representatives could
participate in early assessments of household hazardous waste (HHW), regulated facilities,
and/or staging areas. This representative can share concerns about EJ directly with the LNO
based upon firsthand knowledge of tools such as EJScreen in addition to on-the-ground
connections and relationships maintained by the EJ program. For instance, by bringing
together skilled use of EJScreen and other tools and insights from local contacts built on
existing relationships, current or previous recipients of EJ grants, networks accessible through
current or previous members of the National Environmental Justice Advisory Council (NEJAC),
and historical knowledge by EJ program personnel, the EJ representative has a high likelihood
of accelerating EPA's ability to have firsthand knowledge of local circumstances and
sensitivities in a matter of hours. [RIC(s) and IC(s) from the impacted Region(s) in
coordination with the NIC (if nationally-significant incident)]

3)	Incorporate an environmental justice function and staffing support within the IMT and
EOC structures, where appropriate. To ensure that environmental justice issues are
addressed in a timely manner and briefed to the Incident Command/Unified Command as
necessary, we propose that a cadre of EJ Response Facilitators be identified from throughout
the EPA regional and headquarters program offices to serve within EPA's ICS structure,
including in roles with EJ-related functions previously laid out in EPA's IMH. EJ Response
Facilitator personnel should possess the skills and situational awareness to ensure that
environmental justice is incorporated into response activities. It is absolutely critical that the
Agency understand where these facilitators will function within the ICS organization to ensure
consistency and acceptance of their function. Having a dedicated support staff with the
specific focus for environmental justice issues and populations will greatly enhance EPA's
ability to ensure that the needs and concerns of the most vulnerable populations are being
adequately included. [RIC(s), IC(s), and REOC Managers from the impacted Region(s) and NIC


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and HQ EOC Manager from HQ for incorporating EJ function support (if nationally significant
incident); OEJECR for revisions to existing Job Aids and position checklists]

The EJ Response Facilitators cadre could reside within one or more of the following roles,
including in IMT/field and EOC venues, especially for responses of greater scope and
complexity. This cadre will be fully trained and deployable in accordance with the training
requirements detailed in Attachment A.

>	Liaison Officer (LNO) has the responsibility for contributing to the attainment of
stakeholder objectives by effectively coordinating with stakeholders and understanding
their concerns. The LNO is the main point of contact for ensuring environmental justice
concerns are addressed by the IMT. EJ Response Facilitators will assist the LNO (i.e., as an
Assistant LNO or ALNO) by coordinating with environmental justice stakeholders to elicit
their input into the response process, which will be briefed to the Incident
Command/Unified Command, as necessary. Also, given that LNOs are tasked with the
information flow between the incident command and other governmental agencies, EJ
Response Facilitators will support the LNO function by assisting with facilitating greater
inter- and intra-governmental coordination to protect vulnerable populations. It is
important to note that other governmental agencies may also be subject to obligations
related to public involvement and language access pursuant to civil rights laws, including
Title VI of the Civil Rights Act of 1964 and the Rehabilitation Act.

>	Public Information Officer (PIO) manages and coordinates a spectrum of public information
activities, including community outreach and concerns, message strategies, and multi-
lingual and cultural issues inclusive of responsibilities for managing and coordinating
conformity and compliance with accessibility policies (e.g., EPA Order 1000.32 and
Executive Order 13166). These activities include outreach to vulnerable populations
throughout the course of the response, in collaboration with and assistance to the LNO and
PIO. EJ Response Facilitators will support community relations and public engagement
efforts. For instance, EJ Response Facilitators could be deployed to focus on assessing
stakeholder concerns and environmental justice issues in support of PIO efforts to develop
and implement a community relations strategy in an Assistant PIO (APIO) or Community
Relations Specialist (CRS) role.

>	Technical Specialist, functioning within the IMT and reporting to the Liaison Officer
(preferred approach) or serving elsewhere in the response organization, as determined by
the Incident Commander, based on management and/or incident objectives developed for
the response and the exigencies of the situation.

o EJ Desk Officer, a technical specialist functioning within the HQ Emergency
Operations Center (EOC) or the Regional EOCs (REOCs), which support the
Incident Management Team (IMT) by assigning and coordinating agency
resources and providing immediate reach-back support as appropriate. The EJ
Desk Officer, activated when the need arises (particularly in the regional offices
where on-site deployment is not critical), will assist the IMT in ensuring that
environmental justice concerns of impacted communities are addressed. By


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assisting IMT staff in the assessment of community needs and identifying
potential disparate impacts of response decisions, the EJ Desk Officer will help
bring attention to the importance of identifying, understanding, and engaging
communities with environmental justice concerns. The EJ Desk Officer will also
help facilitate interaction and coordination and provide situational awareness to
the RIC, NIC, and other senior management.

To assist in formally integrating the consideration of environmental justice into response efforts,
position checklists and position-specific job-aids for other positions should be developed and/or
updated. These would include, at a minimum:

>	Job Aids: Revise job aids for LNO stakeholder staff and PIO community relations staff which
lay out best practices and key steps to ensuring environmental justice concerns are
identified and considered.

>	Position Checklist: Develop position checklists of tasks for the EJ Technical Specialist and
the EOC/REOC EJ Desk Officer positions.

4) Implement training and other related requirements. To support the effort to formally
deploy EJ Response Facilitators to assist with a response, as well as to more broadly ensure
that environmental justice concerns are effectively considered, as appropriate, during a
response, the following training and certifications are required:

• Ensure that EI Response Facilitators meet minimum training requirements in

accordance with NIMS and EPA policy. As such, each EJ Response Facilitator should:

>	Enroll as a member of the appropriate regional or headquarters Response Support
Corps (RSC), the Agency's standing resource of EPA volunteers who provide critical
support to the Agency during an EPA emergency response. This will be done in
accordance with the recruitment, activation, deployment, training, exercising, etc.,
requirements outlined in EPA Order 2072. This reserve of EPA employees stands ready
to provide whatever support is needed, based on their qualifications. Each regional and
headquarters program has its own reserve of RSC members who can be activated when
needed to assist with an emergency response.

>	Take required on-line training, attend appropriate orientation training(s), etc.
Attachment A summarizes the required training suggested for EJ Response Facilitators.
Also listed are optional trainings which individual EJ Response Facilitators may find
useful.

>	Attend EJ Response Facilitator-specific training (to be developed). This training,
including annual refresher sessions, should incorporate best practices and lessons
learned from previous experiences, while focusing on developing consistency while
respecting the flexibility needed for individual responses during emergency responses.

>	Participate in additional response-related training events, as offered, such as
presentations, periodic IMT exercises, etc. [OEJECR]

Develop and conduct environmental justice-specific training module(s) (conducted
broadly to various staff engaged in response efforts or as part of selected position-specific


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courses). These modules would address ways to enhance the effectiveness of EPA's
emergency response functions to ensure such efforts (including decisions) are inclusive,
fair, and responsive in addressing the concerns of vulnerable and underserved
communities about environment and public health. Senior EPA environmental justice staff
(headquarters or regions, as appropriate) would assist in delivering these modules.
[OEJECR, in collaboration with OEM]

¦	Broad EJ and Emergency Response Training for EPA's Response Staff: Such
trainings would focus on best practices for ensuring that environmental justice
issues/concerns are addressed, as well as understanding the "how" of engaging
underserved and overburdened communities and assessing environmental justice
concerns, and incorporate checklists for response staff which incorporate
environmental justice best practices appropriate for staff response functions. See
Attachment B for an example of a workshop to be conducted within a region.
Alternately, these training modules can be incorporated into or held in conjunction
with regional ICS-based exercises.

¦	Incorporate EJ topics into the Agency's ICS training:_Ideally, a discussion about
integrating EJ principles and outlining best practices should be incorporated into
the Agency's advanced ICS and position-specific training courses (where
appropriate).

•	Develop and conduct training on environmental justice tools for use in emergency
management activities, including a session developed specifically for regional emergency
management staff, as well as one focused on adapting EJSCREEN for responses. [OEJECR, in
collaboration with OEM]

•	Add an EI Response Facilitator certification to the Field Readiness database, as well as
offer "Environmental Justice" among the list of expertise and skills. An EJ Response
Facilitator certification and the environmental justice skill would be set with restricted
data entry rights and managed by OEJECR. [OEJECR, in collaboration with OEM]

5) Develop and promote the adoption and use of public participation guidelines for

disaster response situations by relevant emergency response organizations in both the
public and private sectors. As the Agency continues to update and standardize its use of
public participation guidelines, it should consider developing relevant guidelines that reflect
the unique nature of public engagement during disaster response. Public engagement is not
limited to traditional one-way outreach, nor is it limited to the general public. Rather,
engagement includes providing opportunities for community voices and concerns to be
considered, while engaging non-governmental and environmental organizations invested in
community resiliency. [OEJECR, in collaboration with OEM]

• Public Participation Guidelines: Review existing guidelines for disaster response to
ensure they are reflective of environmental justice considerations. NEJAC
recommendations and EPA's policies may be helpful in this review (for example, the
NEJAC Model Guidelines for Public Participation, the EPA Policy on Environmental


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Tustice for Working with Federally Recognized Tribes and Indigenous Peoples, etc.].
[OEJECR]


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Attachment A
Training

In support of EPA's preparedness for nationally significant incidents, each EJ Response Facilitator will
adhere to ICS training standards in compliance with the National Incident Management System (NIMS).

Trainings for EJ Emergency Response Facilitators

REQUIRED (for tlcploymcnl)

EPA Response Support Corps (RSC) Orientation (one-time)

IS-lOO.ci Introduction to Incident Command System. ICS-100 (one-time)

IS-200.CI Basic Incident Command System for Initial Response. ICS-200 (one-time)

IS~7QQ.bi National Incident Management System (NIMS) An Introduction (one-time)

IS-SOO.d National Response Framework fNRFl, An Introduction (one-time)

24-Hour HAZWOPER Health and Safety Training (one-time with annual 8-hour refresher training)
EJ Response Facilitator-specific trainings [under development] (one-time with annual refresher)
Region-specific Community Outreach Response Team (CORT) trainings and/or exercises (as convened)
OPTIONAL

EPA. FEMA. or USCG versions ofICS-300 Intermediate ICS for Expanding Incidents

EPA. FEMA. or USCG versions of ICS-400 Advanced ICS Command and General Staff - Complex Incidents

EPA WEBINAR: Regional Emergency Operations Center. This webinar describes the function and
operation of Regional and Headquarters Emergency Operations Centers. Developed for Response
Support Corps (RSC) members in regional offices and at EPA HQ. See also FEMA IS-2200 Basic
Emergency Operations Center Functions.

EPA ESF-10 From No Mission to Mission. This course is for members of the Response Support Corps
(RSC) and On-Scene Coordinators (OSC) who are not experienced in working under the Stafford Act
process. Participants gain insights into the following: (1) The Mission Assignment process, (2) A
presidential declaration after a disaster occurs, (3) Activation of Emergency Support Function (ESF) 10,
and (4) Action Request Forms (ARF), Mission Assignments, task orders, and closeouts

FEMA IS-288.A: The Role of Voluntary Organizations in Emergency Management. This course provides a
basic understanding of the history, roles, and services of disaster relief voluntary agencies in providing
disaster assistance.

IS-368: Including People with Disabilities & Others with Access & Functional Needs in Disaster Operations.
This course provides an overview of disabilities and access and functional needs and explains how
disaster staff can apply inclusive practices in their disaster assignments.

FEMA IS-505: Concepts of Religious Literacy for Emergency Management. The course provides
emergency management professionals with the religious literacy and competency tools needed to learn
how to effectively engage religious and cultural groups and their leaders throughout the disaster
lifecycle.


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Trainings for EJ Emergency Response Facilitators

MA IS-553.A: Coordination between Water Utilities and Emergency Management Agencies This
course seeks to enhance the knowledge and skills of emergency management agencies (EMAs) and
drinking water and wastewater utilities (water sector) to enable more effective cross-sector
relationships.

FEMA IS-6	. This course

describes how to establish and sustain public-private partnerships, as well as how to communicate and
share resources in a partnership.

FEMA IS-909: Community Preparedness: Implementing Simple Activities for Everyone. This course
presents a model program for community preparedness. In addition, resources materials are available
to help organizations conduct simple preparedness activities for everyone.

FEMA IS-2901: Introduction to Community Lifelines. This course introduces the Community Lifelines
construct, an outcome-driven response structure used to achieve incident stabilization. This course
provides an overview of the seven Community Lifelines, including how they promote the importance of
situational awareness, prioritization of response efforts, and decision-making processes during a
disaster response to work toward incident stabilization.


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Attachment B

Workshop: ENHANCING ENVIRONMENTAL JUSTICE IN EMERGENCY RESPONSE (Sample)

Proposed Length: approximately 4 to 8 hours plus 3 hours optional for RSCs
Target Audience:

Primary: On-Scene Coordinators, Remedial Project Managers, Community Involvement
Coordinators, EJ Coordinators/Team, LNOs, PIOs

Other participants may include: Superfund Attorneys, Criminal Investigative Division
Response Support Corp members, and others as identified

Facilitators: Nick Nichols, OEM

Victoria Robinson, OEJECR

To be determined, OEM Program Operations and Coordination Division
To be determined, Regional EJ Team

The session/workshop will focus on ways to enhance the effectiveness of EPA's emergency
response functions to ensure such efforts are inclusive, fair, and responsive in addressing the
concerns of vulnerable and underserved communities about environment and public health.
Panelists will include perspectives from a Regional EJ Coordinator, On-Scene Coordinator, and
video testimonials from communities. The goal is to identify best practices from which
participants can draw to ensure such efforts are inclusive, fair, and responsive.

Specifically, the sessions will provide ways to address environmental justice concerns during an
emergency response. Topics include

A.	Building trust between environmental justice communities and government agencies,

B.	Understanding how response decisions (which often drive long-term recovery, reuse, and
revitalization) can result in possible unintended impacts in communities,

C.	Examining the impact of persistent, inter-related social, economic, and environmental
challenges on community acceptance of proposed remedies, and

D.	Using EJSCREEN to generate a clearer profile of communities with environmental justice
concerns.

The presentations will be followed by interactive group exercises and Q&A sessions, where
attendees can share the challenges they face in incorporating environmental justice principles
throughout a response.

Participants in these sessions/workshop will:

•	Share the challenges they face in incorporating environmental justice principles
throughout a response

•	Learn about how emergency responses can incorporate environmental justice principles
throughout a response and help lay the groundwork for equitable
reuse/revitalization/recovery efforts.


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•	Identify Agency resources and tools that can be used to aid incorporating environmental
justice principles, including examining how to use EJSCREEN

•	Collaborate with other OSCs/RPMs/Community Relations Specialists (CRSs)/Superfund
CICs), etc., about best practices to identifying and understanding environmental justice
concerns before, during, and after site cleanups

Proposed Sessions (order is flexible)

Time

Attendees

Description

3 hours

EJC, CRSs/CICs

Enhancing EJ in Emergency Response & Superfund
Cleanup for CRSs

1.5 hours

All

Adapting EJSCREEN for emergency response

3 hours

OSCs, RPMs, SF
Attorneys

Enhancing EJ in Emergency Response & Superfund
Cleanup for RPMs and OSCs

2 hours

ALL

Interactive group exercise and Q&A session, where
trainees can share the challenges they face in
incorporating environmental justice principles
throughout a response & cleanup.

3 hours

RSC Members

EJ Awareness for RSC Members


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