FY 2011-FY 2014 Title VI of the Civil Rights Act Progress Report &EPA :s". t? f\ i*&L ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 x>EPA TITLE VI Progress Report May 4, 2015 U.S. Environmental Protection Agency Office of Civil Rights Velveta Golightly-Howell, Director Lilian Dorka, Deputy Director 1 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 1.0 INTRODUCTION In accordance with Title VI of the Civil Rights Act of 1964 (Title VI), EPA maintains a program to ensure that recipients of Federal financial assistance do not operate their programs or activities affecting human health or the environment in ways that have discriminatory effects based on race, color, or national origin. In furtherance of that goal, the EPA Office of Civil Rights (OCR) developed a Title VI Plan that sets forth goals, strategies and activities to provide a roadmap as OCR builds a robust Title VI and external civil rights program.1 The Title VI Plan was developed as a supplement to EPA's Plan EJ 2014, a multi-year comprehensive strategy to advance environmental justice and meet the mandate of Executive Order 12898.2 This FY 2011 - FY 2014 Title VI Progress Report focuses on OCR's Title VI accomplishments, new compliance strategies that have been implemented, and high-priority deliverables that have been completed.3 2.0 ACCOMPLISHMENTS 2.1 CASE MANAGEMENT AND RESOLUTION During the last four fiscal years, EPA's priority of building a model civil rights program has been evidenced by OCR's renewed commitment to: 1) strategic management of its Title VI complaint docket; 2) successful resolution of complaints;4 and 3) settlement of significant Title VI matters. 1 In addition to Title VI, OCR implements Section 504 of the Rehabilitation Act of 1973, 29 United States Code (U.S.C.) § 794; Section 13 of the Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C. § 1251; and the Age Discrimination Act of 1975, 42 U.S.C. §§ 6101 - 6107, which collectively prohibit discrimination based on race, color, national origin, disability, sex and age. OCR's implementing regulation for civil rights statutes is set forth at 40 Code of Federal Regulations (C.F.R.) Part 7. 2 U.S. Environmental Protection Agency, Office of Environmental Justice, Plan EJ 2014, at 2 (Sept. 2011), available at: EPA's Website http://www.epa.gov/environmentaliustice/resources/policv/plan-ei-2014/plan-ei-2011-09.pdf. Plan EJ 2014 aims to: 1) protect individuals' health and the environment in overburdened communities; 2) empower communities to take action to improve their health and the environment; and 3) establish partnerships with Federal, tribal, state and local governments to promote sustainable communities where a clean environment and healthy economy can thrive. 3 OCR has reviewed public comments to the Title VI supplement to Plan EJ 2014. As a result, OCR incorporated some of the recommendations received from the public during the implementation of the strategies and completed deliverables set forth in Section 4.0. 4 In FY 2013, OCR reduced its docket of open investigations by over forty percent. 2 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 The Title VI settlements include: • EPA Investigation Results in Expansion of Public Participation at Illinois Environmental Protection Agency: On April 18, 2013, OCR entered into a settlement agreement with the Illinois Environmental Protection Agency (IEPA), which agreed to take a number of concrete steps to improve its public participation program. The agreement resolved a Title VI complaint alleging that IEPA intentionally discriminated against the African-American residents of Ford Heights, Illinois, by not providing an opportunity for meaningful involvement in the decision-making process during the issuance of construction permits for the Midwest Micronutrients processing facility and for the trial use of wood biomass fuel at the Geneva Energy facility. The Title VI investigation raised concerns regarding the adequacy of lEPA's notice to the Ford Heights community. In the settlement, IEPA agreed to: (1) expand the scope of its Environmental Justice Public Participation Policy (EJ PPP); (2) revise its EJ PPP so that permitting activities in areas identified as potential EJ communities will be given an appropriate level of outreach; (3) post information on its website concerning grievances received pursuant to lEPA's EJ Grievance Procedure; (4) redesign its online permit tracking system webpage to further facilitate the implementation of the EJ PPP; and (5) create a system that will identify all projects in potential EJ communities and notify lEPA's EJ Officer who will determine the appropriate outreach activities.5 • San Joaquin Valley United Air Pollution Control District Increases Opportunities for Meaningful Public Involvement: EPA strongly supports the use of alternative dispute resolution (ADR). Consistent with this policy and EPA's Title VI implementing regulations, OCR encourages the use of informal resolution techniques, including ADR, to resolve Title VI complaints. On February 1, 2013, the San Joaquin Valley Unified Air Pollution Control District (the District) and Greenaction for Health and Environmental Justice (Greenaction) signed a settlement agreement resolving all issues related to the Avenal Title VI complaint filed with OCR. As stated in the settlement agreement, "the District and Greenaction have worked together to enhance meaningful public involvement in the District's permit processing actions."6 The complainants and recipient reached their agreement through an ADR process, with the assistance of a mediator provided by EPA. • EPA Title VI Complaint Investigation and Compliance Review Results in Protections for Migrant Agriculture Workers in Louisiana: On December 15, 2011, OCR reached a settlement agreement with the Louisiana Department of Agriculture and Forestry (LDAF) to provide critical protections for migrant agriculture workers. Through the agreement, LDAF 5 The settlement agreement is available at: EPA's Website http://www.epa.eov/civilriehts/TitleVlcases/title6.iepa.rev.pdf. 6 The settlement agreement between San Joaquin Valley United Air Pollution Control District (District) and Greenaction for Health and Environmental Justice at 6 (Feb. 1, 2013) is available at EPA's Website http://www.epa.gov/civilrights/TitleVlcases/final %20ga aped settlement2-l-13.pdf. EPA is not a party to this agreement, so all questions related to the specific terms or the implementation of the agreement should be directed to the District or Greenaction. 3 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 voluntarily agreed to: (1) adopt and disseminated a written Worker Protection Interview Policy to allow for telephonic interviews when a complainant or witness is unavailable for an in-person interview; (2) provide LEP individuals meaningful access to its Worker Protection program consistent with EPA's LEP Guidance, as required by Title VI; (3) contract for translators and/or interpreters; (4) conduct training consistent with the agreement for all relevant LDAF employees; (5) conduct at least eight outreach sessions for relevant stakeholders across the state in which it will discuss language access; and (6) provide to OCR and EPA Region 6 compliance reports that will identify the specific actions/steps that LDAF has taken to comply with the agreement.7 The above settlements were successes in OCR's ongoing endeavor to build a model civil rights program. OCR will continue forward in its commitment to protecting and empowering vulnerable communities, using ADR, investigation tools and other available methods. 2.2 STRATAGIES AND ACTIVITIES In the original Title VI Plan, OCR committed to four strategies and eleven activities. During the past four fiscal years, OCR has built a record of accomplishments: Strategy 1: Establish a robust Title VI Pre-Award and Post-Award Compliance Program. Activity 1.1: Reform pre-award compliance program to further ensure compliance with Title VI by revising EPA Form 4700-4 and developing Title VI terms and conditions. EPA has inserted a Title VI "term and condition" in all of its domestic assistance agreements. The term and condition seeks to remind EPA recipients of their existing obligations under Title VI when applicable.8 In addition, on June 30, 2014, the Office of Management and Budget approved a revised EPA Form 4700-4 (Pre-award Compliance Review Report for All Applicants and Recipients Requesting EPA Financial Assistance). While applicants and recipients continue to have the same substantive requirements under 40 C.F.R. Part 7, the revised EPA Form 4700-4 now requires that applicants and recipients certify that they have a nondiscrimination notice accessible to individuals with disabilities, a civil rights coordinator, a grievance procedure, a language access services policy, and demographic data on the race, color, national origin, sex, age or disability of their service populations. 7 The settlement agreement is available at: DOJ's Website http://www.justice.gov/crt/about/cor/Pubs/newsletter/news(Sfcs/iulv2014/EPA Louisiana Agreement 5-2008.pdf. The findings of fact are available at: EPA's Website http://www.epa.gov/civilrights/TitleVlcases/ldaf/EPA-File-No-04R- 08-R6-Findings-of-Fact-Title-VI-lnvestigation.pdf and EPA's Website http://www.epa.gov/civilrights/TitleVlcases/ldaf/EPA-File-No-04R-08-R6-Findings-of-Fact-Compliance-Review.pdf. 8 The Title VI term and condition is available at: EPA's Website http://www.epa.gov/ogd/tc ian 2014.pdf. 4 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 Activity 1.2: Improve post-award compliance to further ensure compliance with Title VI by seeking stakeholder input and developing options for a post-award compliance program. OCR meets regularly with stakeholders, including environmental advocates, representatives from business and industry, tribal organizations, the Environmental Council of the States, as well as Federal, state and local agencies. In addition, OCR continues to work with the EPA Office of Grants and Debarment (OGD) on a compliance monitoring program. Activity 1.3: Develop Title VI technical assistance for EPA federal financial assistance recipients. OCR has provided technical assistance to EPA recipients: • On March 21, 2006, OCR issued public involvement guidance to EPA recipients administering permitting programs.9 • On June 25, 2004, OCR issued guidance clarifying that Title VI requires EPA recipients to take reasonable steps to provide limited English proficient (LEP) individuals meaningful access to their programs and activities.10 • On August 20, 2013, OCR provided language access services training at the annual meeting of the Association of Structural Post Control Regulatory Officials (ASPCRO); in September 2013, OCR developed a Limited English Proficiency Fact Sheet; and on November 13, 2013, OCR provided training on serving LEP individuals to the State Federal Insecticide Fungicide and Rodenticide Act (FIFRA) Group, an organization of State officials interested in the Federal/State co-regulation of pesticides under the FIFRA. • On June 5, 2014, "Title VI Online" was posted on the OCR website. Currently, the website offers case information.11 This is in addition to the settlement agreements and findings of fact previously found on the OCR website. • OCR is currently developing a Post-Award Compliance Toolkit to assist EPA recipients in understanding their obligations under Title VI, Section 504 of the Rehabilitation Act of 1973, Title IX of the Education Amendments of 1972, the Age Discrimination Act of 1975, and Section 13 of the Federal Water Pollution Control Act Amendments of 1972. 9 U.S. Environmental Protection Agency, Office of Civil Rights, Title VI Public Involvement Guidance for EPA Assistance Recipients Administering Environmental Permitting Programs, 71 Fed. Reg. 14207 (March 21, 2006), available at: EPA's Website http://www.epa.gov/civilrights/TitleVlcases/title6 public involvement guidance.3.13.13.pdf. 10 U.S. Environmental Protection Agency, Office of Civil Rights, Guidance to Environmental Protection Agency Financial Assistance Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons, 69 Fed. Reg. 35602 (June 25, 2004), available at: GPO's Website http://www.gpo.gov/fdsvs/pkg/FR- 2004-06-25/pdf/04-14464. pdf. 11 Title VI Online is available at: EPA's Website http://www2.epa.gov/ocr/complaints-filed-epa-under-title-vi-civil- rights-act-1964. 5 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 Activity 1.4: In consultation with the U.S. Department of Justice, EPA will reevaluate its Title VI regulations and propose any necessary revisions. The Justice Department has been consulted regarding a reevaluation of EPA's Title VI implementing regulation. Activity 1.5: EPA will review its programmatic standard operating procedures and templates for processing civil rights complaints and conducting compliance reviews. To achieve uniformity in efficiency in the allocation of resources to perform the civil rights functions, EPA has issued two internal orders: • EPA Order 4701, issued on May 1, 2013, established a protocol for processing, investigating and resolving complaints and to better leverage the resources and expertise of EPA senior leaders in Title VI cases. OCR has implemented EPA Order 4701 and will continue to do so into the future. • EPA Order 4700, issued May 1, 2013, established Deputy Civil Rights Officials (DCROs) positions. The DCROs, senior leaders from each region and program, have civil rights responsibilities for local implementation of the Title VI program in their regions or programs, and they are charged with working with OCR on national policy and strategy development. Strategy 2: Strengthen Title VI in EPA's National Program Manager Guidance, performance partnership agreements and performance partnership grants. Activity 2.1: Coordinate with EPA offices to determine how Title VI can be incorporated into EPA's National Program Manager Guidance. EPA included Title VI compliance language in the FY 2013 and FY 2014 National Program Manager (NPM) Guidances, which set forth program priorities and key actions for the upcoming year. The NPM Guidance establishes program priorities for EPA regional offices for each national program. Activity 2.2: Coordinate with EPA offices to determine how Title VI can be incorporated into EPA's performance partnership agreements and performance partnership grants. In FY 2013 and FY 2014, EPA included Title VI compliance language in Performance Partnership Agreements (PPA) and Performance Partnership Grants.12 Performance Partnership Agreements describe 12 Each grant recipient agrees to comply with the current EPA general terms and conditions available at: http://www.epa.gov/ogd/tcjan_2014.pdf. These EPA general terms and conditions set forth recipients' nondiscrimination obligations under Title VI. 6 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 EPA-funded activities carried out by State agencies to address water quality, air quality, hazardous waste and/or nuclear waste. Strategy 3: Partner with other Federal agencies to strengthen compliance with Title VI. Activity 3.1: Participate in and coordinate with the Environmental Justice Interagency Workgroup (EJIWG) Subcommittee for Title VI of the Civil Rights Act. Under Executive Order 12250, the Attorney General shall coordinate the implementation and enforcement of Title VI. To operate a civil rights program in compliance with the Attorney General's "standards and procedures for taking enforcement actions and for conducting investigations and compliance reviews," OCR regularly participates in the meetings of the Environmental Justice Interagency Working Group's Subcommittee for Title VI.13 Activity 3.2: Collaborate with DOJ to identify best practices and provide technical assistance. The Justice Department has been consulted regarding best practices for EPA's Title VI and external civil rights program. OCR expects to take further action based on this collaboration in 2015. Strategy 4: Advance Limited English Proficiency Initiative. Activity 4.1: Issuance of EPA's Limited English Proficiency Order. On July 28, 2011, EPA issued EPA Order 1000.32, "Improving Access to Services for Persons with Limited English Proficiency" (LEP)." The Order was a significant step toward ensuring EPA's compliance with Executive Order 13166 (EO 13166), "Improving Access to Services for Persons with Limited English Proficiency"14 and more specifically, with the Memorandum issued by United States Attorney General Eric Holder on February 17, 2011, which called for a "renewed commitment" to language access and compliance with EO 13166 (AG Memo.)15 EPA Order 1000.32 set forth the EPA's expectations and requirements to ensure compliance with EO 13166, including, calling for the gathering of critical information about each of EPA program and regional office's missions, populations served, and level and type of service that was being provided to LEP customers. That information is being considered as EPA moves forward with more the development and implementation of a comprehensive agency-wide implementation plan as well as program and regional office-specific sub-plans. 13 Executive Order 12250, Leadership and Coordination of Nondiscrimination Laws, 45 Fed. Reg. 72,995 (Nov. 4,1980), available at: Archives Website http://www.archives.gov/federal-register/codification/executive-order/12250.html. 14 65 Fed. Reg. 50,121 (Aug. 16, 2000). 15 Attorney General Eric Holder, Memorandum to Heads of Federal Agencies regarding the Federal Government's Renewed Commitment to Language Access Obligations Under Executive Order 13166 (Feb. 17, 2011), available at: the LEP Website http://www.lep.gov/13166/AG 021711 EO 13166 Memo to Agencies with Supplement.pdf. 7 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 Activity 4.2: Evaluate and Consider Information Submitted by EPA's Program and Regional Offices in FY 2011 and 2012 in developing a comprehensive EPA LEP implementation plan and office-specific sub plans. An evaluation of the information obtained reveals significant progress toward providing persons who have limited-English proficiency with meaningful access to EPA services, programs, and activities. • The Office of the Administrator, Regions 1 through 10, the Office of Administration and Resources Management, the Office of Chemical Safety and Pollution Prevention, the Office of Solid Waste and Emergency Response, the Office of Air and Radiation, the Office of International and Tribal Affairs, the Office of Water, the Office of Environmental Information, the Office of Enforcement and Compliance Assurance, the Office of the Chief Financial Officer, and the Office of Research and Development, already provide significant language access services. • Parts of EPA's website are available in five foreign languages: Spanish, Mandarin Chinese (both traditional and simplified), Korean, and Vietnamese.16 • EPA's National Service Center for Environmental Publications (NSCEP) provides environmental publications in twenty-two different foreign languages: Arabic, Armenian, Cambodian, Chinese, French, German, Haitian Creole, Hindi, Hmong, llocano, Italian, Japanese, Korean, Laotian, Polish, Portuguese, Russian, Simplified Chinese, Spanish, Tagalog, Thai, and Vietnamese.17 Activity 4.3: Designate an Agency Language Assistance Coordinator who will lead EPA's agency-wide LEP access efforts. • In January, 2015, OCR's Deputy Director was designated as EPA's LEP Access Coordinator (LEP AC.) The LEP AC will work in coordination with the Office of Public Affairs to ensure EPA complies with EO 13166 and the AG Memo in ensuring language access. Activity 4.4: As required by the AG Memo, establish an intra-agency Language Access Working Group (Working Group) that truly represents the sub-missions of each of EPA's program and regional offices. The EPA Working Group will consist of representatives from each of EPA's program and regional offices who will: 1) Serve as the program/regional office's language access coordinator; 2) Assess the program/regional office's operations for LEP needs and gaps in service; 3) Assist in developing an EPA-wide LEP implementation plan that includes policies and procedures to implement the plan; 16 Access to the foreign language websites is available at: EPA's Website http://www.epa.gov/. 17 These publications are available at: EPA's Website http://nepis.epa.gov/EPA/html/foreign index.html. 8 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 4) Develop a program/regional office-specific language access sub-plan, which includes procedures for implementing the sub-plan specific to the mission of the specific office; and 5) Maintain responsibility for ensuring that office's senior leadership is fully briefed about the role and responsibilities of the program/regional office relative to EO 13166 and ensuring access for LEP persons. • As of February, 2015, the Working Group is in place, fully functioning and has met several times. • Through the Working Group, the EPA is establishing a culture of language access throughout the EPA. EPA will now have a cadre of individuals throughout the EPA who understand the requirements of the EO as well as how to use available resources to provide access to LEP customers. Activity 4.5: EPA will reach out to external stakeholder to obtain input and information about how EPA can improve its efforts to meet the needs of its LEP communities. • By July 2015, EPA will hold at least one external stakeholder forum in order to obtain input about how EPA can improve its language service efforts. Activity 4.6: Developing a comprehensive EPA LEP Directive, Plan and Procedures (that incorporates EPA Order 1000-32) which includes all legally required standards, information, and procedures to guide all EPA language access efforts. • By January 2016, EPA will have in place a final EPA LEP Directive, Plan and Procedures. The Plan and Procedures will act as guidance to EPA's program and region offices on how to provide meaningful access to LEP individuals and will include SOPs for how to obtain translation, interpretation, and telephonic interpretation services. Activity 4.7: Develop EPA program and regional office-specific sub-plans that track the comprehensive EPA Plan Directive, and Procedures. • By January 2017, all EPA program and office-specific sub-plans will be in place. Activity 4.8: Implement an Agency-wide contract that will serve all EPA program and regional offices and that will ensure effective, efficient and timely access to necessary language services for LEP persons. • By June, 2015, EPA will have in place an Agency-wide contract that will serve all EPA program and regional offices and that will ensure effective, efficient and timely access to necessary language services for LEP persons. The contract will provide: 1. Telephonic interpretation services that will allow each EPA program and regional office staff access to over 175 languages in less than two minutes; 2. Professional in-person interpretation services for all of EPA's program and regional offices, and; 9 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 3. Professional document translation services. 4. By the end of FY 2015, EPA will conduct comprehensive "user" briefings and training related to the LEP contract services delineated above for EPA staff. Activity 4.9: Ensure that the public is aware that EPA is fully equipped to serve LEP persons and ensure access to EPA services, programs and activities. • By March 2016, EPA will develop an external roll-out strategy for ensuring the public is aware of EPA's language access efforts. 3.0 DELIVERABLES Strategy 1: Establish a robust Title VI Pre-Award and Post-Award Compliance Program. ACTIVITY DELIVERABLES MILESTONES Activity 1.1: Reform ore-award compliance program to further ensure compliance with Title VI. • Develop Title VI Term and Condition. • Revise EPA Form 4700-4, and secure approval from the Office of Management and Budget. • Completed • Completed Activity 1.2: Inwove oost- award compliance monitoring program to further ensure compliance with Title VI. • Develop options for a Title VI post-award compliance program. • Seek stakeholder input. • Launch the compliance pilot program • Completed • Completed • Completed 10 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 ACTIVITY DELIVERABLES MILESTONES Activity 1.3: Develop Title VI technical assistance for EPA Federal financial assistance recipients. • Develop draft Title VI compliance toolkit for EPA Federal financial assistance recipients. • Finalize Title VI compliance toolkit for EPA Federal financial assistance recipients. • Seek stakeholder input. • Conduct quarterly training sessions for Federal financial assistance recipients. • June 2015 • December 2015 • Ongoing • 2016 Activity 1.4: In consultation with DOJ, EPA will reevaluate its Title VI regulations and make any necessary changes. • Complete evaluation of EPA Title VI implementing regulations for potential revision. • Issue notice of proposed rulemaking in Federal Register as a rulemaking for public comment. • Engage interested stakeholders, as appropriate. • Completed • December 2015 • Ongoing Activity 1.5: EPA will review its programmatic standard operating procedures and templates for processing civil rights complaints and conducting compliance reviews. • Revise standard operating procedures. • Draft a Complaints and Compliance Review Manual for EPA Case Managers. • Finalize a Complaints and Compliance Review Manual for EPA Cases Managers. • Ongoing • June 2015 • December 2015 Strategy 2: Strengthen Title VI in EPA's National Program Manager (NPM) Guidance, Performance Partnership Agreements and Performance Partnership Grants. ACTIVITY DELIVERABLES MILESTONES Activity 2.1: Coordinate with EPA offices to determine how Title VI can be incorporated into EPA's National Program Manager (NPM) guidance. • Coordinate with Office of Chief Financial Officer for integrating civil rights into the cross-cutting strategies of EPA's strategic plan. • Develop Title VI compliance language to be included in EPA's NPM Guidance. • Completed • Completed Activity 2.2: Coordinate with EPA offices to determine how Title VI can be incorporated into performance partnership agreements and performance partnership grants. • Develop Title VI compliance language to be included in EPA's performance partnership agreements. • Develop Title VI compliance language to be included in EPA's performance partnership grants. • Completed • Completed 11 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 Strategy 3: Partner with other federal agencies to strengthen compliance with Title VI. ACTIVITY DELIVERABLES MILESTONES Activity 3.1: Participate in, and coordinate with, the EJIWG and its subcommittee for Title VI of the Civil Rights Act. • Participate in, and attend, scheduled meetings. • Ongoing Activity 3.2: Collaborate with DOJ to identify best practices and to provide technical assistance. • Work with DOJ and other Federal agencies to promote best practices and enhance effective compliance with Title VI and actions to address non- compliance. • Ongoing Strategy 4: Advance limited English proficiency initiatives. ACTIVITY DELIVERABLES MILESTONES Activity 4.1: Issuance of EPA's Limited English Proficiency Order. • Issue EPA LEP Order 1000.32. • Collect LEP Information from EPA program offices and regions. • Completed • Completed Activity 4.2: Evaluation and consideration of the information provided by EPA's program and regional offices • Evaluate the information obtained from regional and program officer and consider it in developing an EPA Directive, and Plan and Procedures. • Completed/Ongoing Activity 4.3: Designation of an Agency Language Assistance Coordinator who will lead EPA's agency-wide LEP access efforts. • Have in place a designated EPA LEP Access Coordinator (LEP AC) who will work in coordination with the Office of Public Affairs to ensure EPA complies with EO 13166 and the AG Memo in ensuring language access. • Completed Activity 4.4: Establishment of an intra-agency Language Access Working Group that truly represents the sub- missions of each of EPA's program and regional offices. • Established an intra-agency Language Access Working Group that represents each of EPA's program and regional offices • Completed Activity 4.5: Outreach to external stakeholder to obtain input and information_about how EPA can improve its efforts to meet the needs of its LEP communities. • EPA will hold at least one external stakeholder forum in order to obtain input about how EPA can improve its language service efforts. • Pending Activity 4.6: Development of a comprehensive EPA LEP Directive, Plan and Procedures • Implement an EPA Directive, ad Plan and Procedures that includes all legally required standards, information, and • Pending 12 ------- FY 2011 - FY 2014 Title VI Progress Report, May 2015 ACTIVITY DELIVERABLES MILESTONES (that incorporates EPA Order 1000-32). procedures to guide all EPA language access efforts. Activity 4.7: Development of EPA program and regional office-specific sub-plans that track the comprehensive EPA Plan Directive, and Procedures. • Have in place EPA program and regional office-specific sub-plans that track the comprehensive EPA Plan Directive, and Procedures. • Pending Activity 4.8: Implementation of an Agency-wide contract that will serve all EPA program and regional offices to ensure effective, efficient and timely access to necessary language services for LEP persons. • Implement an Agency-wide contract that will serve all EPA program and regional offices and that provides telephonic interpretation, in-person interpretation, and document translation services and provide staff training. • Pending Activity 4.9: Ensure that the public is aware that EPA is fully equipped to serve LEP persons and ensure access to EPA services, programs and activities. • Develop an external roll-out strategy for ensuring the public is aware of EPA's language access efforts. • Pending 4.0 CONCLUSION This FY 2011 - FY 2014 Title VI Progress Report has summarized OCR's Title VI accomplishments during the last four fiscal years and identified areas on which OCR continues to focus. OCR and its partners have made substantial progress, and OCR looks forward to building even greater capacity and having more successes in protecting community and environmental health. For additional information, please contact OCR Director Velveta Golightly-Howell, 202-564-7272, Golightly- Howell.Velveta@epa.gov; or OCR Deputy Director Lilian Dorka, 202-564-7272, Dorka.Lilian@epa.gov. 13 ------- |