EPA Management Directive 715 Report Deliberative Draft Fiscal Year 2013


1

EPA Management Directive 715 Report



United States

Environmental Protection Agency

MD 715 Report
Fiscal Year 2013

Protecting Human Health and the Environment

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EPA Management Directive 715 Report

EEOCFORM

715-01
PART A - D

U.S. Equal Employment Opportunity Commission
FEDERAL AGENCY ANNUAL
EEO PROGRAM STATUS REPORT

PART B

Total

For period covering October 1, 2012 to September 30, 2013.

1. Agency

1.a. 2nd level reporting component

1.b. 3rd level reporting component

1.c. 4th level reporting component

2. Address

3. City, State, Zip Code

4. CPDF Code

5. FIPS code(s)

1. U.S. Environmental Protection Agency

N/A

N/A

N/A

2.1200 Pennsylvania Avenue, NW

3. Washington, DC 20460

4. EP

5. 11

1. Enter total number of permanent full-time and part-time employees

2. Enter total number of temporary employees

3. Enter total number employees paid from non-appropriated funds

4. TOTAL EMPLOYMENT [add lines B 1 through 3]

1. Head of Agency
Official Title

2. Agency Head Designee

3. Principal EEO Director/Official
Official Title/series/grade

4. Title VII Affirmative EEO
Program Official

5. Section 501 Affirmative Action
Program Official

6. Complaint Processing Program
Manager

7. Other Responsible EEO Staff

1. 15,888

2. 1,114

3. 0

4. 17,002

1. Gina McCarthy, Administrator
Environmental Protection Agency

2. Robert Perciasepe, Deputy Administrator
Environmental Protection Agency

3. Vicki Simons, Acting Director
Office of Civil Rights, SES

4. Cynthia Burrows

Acting Assistant Director for Affirmative Employment,
Analysis Accountability

5. Christopher Emanuel

Disability Employment Program Manager

6. Cynthia Darden

Assistant Director for Title VII

7. Mirza P. Baig

National Affirmative Employment Program Manager

8. William Haig
National Reasonable Accommodations Coordinator

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EPA Management Directive 715 Report

EEOC FORM

715-01
PART A - D

U.S. Equal Employment Opportunity Commission
FEDERAL AGENCY ANNUAL
EEO PROGRAM STATUS REPORT

PART D

List of Subordinate Components Covered in This

Subordinate Component and Location (City/State)



Report

Headquarters Program Offices in Washington DC; Research
Triangle Park, NC; Cincinnati, OH; Las Vegas, NV
Office of the Administrator

Office of Administration and Resources Management

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Office of the Cliief Financial Officer

Office of Enforcement & Compliance Assurance

Office of General Counsel

Office of the Inspector General

Office of International and Tribal Affairs

Office of Enviromnental Information

Office of Prevention Pesticides & Toxic Substances

Office of Research & Development

Office of Solid Waste & Emergency Response

Office of Water



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Regional Offices

Region 1: Boston, MA
Region 2: New York, NY
Region 3: Philadelphia, PA
Region 4: Atlanta, GA
Region 5: Chicago, IL
Region 6: Dallas, TX
Region 7: Lenexa, KS
Region 8: Denver, CO
Region 9: San Francisco, CA
Region 10: Seattle, WA

Program Labs:

OAR/ORIA/NAREL: Montgomery, AL
ORD, NRM Research Lab: Ada, OK
ORD/NERL: Athens, GA
ORD/NHEER Labs:

Narragansett, RI
Gulf Breeze, FL
Duluth, MN
Corvallis, OR

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EPA Management Directive 715 Report

EEOC FORMS and Documents include in this report:

"Executive Summary [FORM 715-01
PART El, that includes:

X

"Optional Annual Self-Assessment Checklist Against Essential Elements
FORM 715-01 PART G1

X

Brief paragraph describing
EPA's mission and mission-
related functions

X

*EEO Plan To Attain the Essential Elements of a Model EEO Program
FORM 715-01 PART HI for each Droarammatic essential element
requiring improvement

X

Summary of results of agency's
annual self-assessment
against MD-715 "Essential
Elements"

X

*EEO Plan To Eliminate Identified Barrier
FORM 715-01 PART II for each identified barrier

X

Summary of Analysis of Work
Force Profiles including net
change analysis and
comparison to RCLF

X

*Special Program Plan for the Recruitment, Hiring, and Advancement of
Individuals With Targeted Disabilities for agencies with 1,000 or more
employees FORM 715-01 PART J1

X

Summary of EEO Plan
objectives planned to eliminate
identified barriers or correct
program deficiencies

X

*Copy of Workforce Data Tables as necessary to support Executive
Summary and/or EEO Plans

X

Summary of EEO Plan action
items implemented or
accomplished

X

*Copy of data from 462 Report as necessary to support action items
related to Complaint Processing Program deficiencies, ADR effectiveness,
or other compliance issues.

X

*Statement of Establishment of
Continuing Equal Employment
Opportunity Programs [FORM 715-
01 PART F1

X

*Copy of Facility Accessibility Survey results as necessary to support EEO
Action Plan for building renovation projects

N/A

"Copies of relevant EEO Policy
Statements

X

"Organizational Chart

X

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EPA Management Directive 715 Report

EEOCFORM
715-01
PARTE

U.S. Equal Employment Opportunity Commission
FEDERAL AGENCY ANNUAL
EEO PROGRAM STATUS REPORT

U. S. Environmental Protection Agency

For period covering October 1, 2012 to September 30, 2013.

EXECUTIVE SUMMARY
Agency Mission

The mission of the United States Environmental Protection Agency (EPA or Agency) is to protect
human health and the environment. EPA programs and activities are focused on protecting the air
we breathe, the water we drink, and the places we live. To accomplish this mission, EPA partners
with federal, state, and local stakeholders to enforce the nation's environmental laws and
regulations; conducts world class research; provides financial assistance to state recipients and
grantees in support of environmental programs; and employs a highly-educated and diverse
workforce. Given the broad scope and critical importance of EPA's mission, it recognizes that
meeting the multitude of responsibilities to the public can only be accomplished with a diverse,
dynamic, and world-class workforce. To that end, EPA works vigorously to remove any identified
barriers to equal employment opportunity and attract, hire, retain, and promote the most talented
individuals in accordance with merit systems principles.

EPA's Office of Civil Rights (OCR) in partnership with the Office of Administration and
Resources Management (OARM), Office of Diversity, Advisory Committee Management and
Outreach (ODACMO), previously the Office of Diversity, Outreach, and Collaboration, and the
Office of General Counsel (OGC), are dedicated to developing and implementing programs to
protect EPA's employees and applicants from employment discrimination.

EPA is pleased to share this brief summary of the programs, activities, and accomplishments for
Fiscal Year (FY) 2013, which document our efforts toward building and sustaining a model Equal
Employment Opportunity (EEO) program based on the six essential elements identified by the U.S.
Equal Employment Opportunity Commission (EEOC).

Demonstrated Commitment from Agency Leadership

In FY 2013, EPA leadership demonstrated their commitment to EEO. EPA's new Administrator,
Gina McCarthy, took her oath of office in July 2013 and less than six months after her
confirmation, she signed the EEO policy statement. The statement was signed on December 18,
2013, and issued on January 2, 2014. EPA's 2013 EEO policy statement prohibits discrimination
based on race; color; religion; sex, including pregnancy, sex stereotyping, gender identity or gender
expression; national origin; sexual orientation; physical or mental disability; age; protected genetic
information; parental status; marital status; political affiliation; or retaliation based on previous
EEO activity. The EEO policy statement also reaffirms the EPA's intolerance for any type of
harassment - either sexual or nonsexual, and promotes the use of alternative dispute resolution
(ADR) methods to resolve workplace disputes. The EEO policy statement advises employees and

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EPA Management Directive 715 Report

applicants of their right to seek redress if they believe that they have been subjected to
discrimination.

In FY 2013, EPA demonstrated that the entire Agency is responsible for civil rights. On May 1,
2013, EPA issued Order No. 4700 creating the Deputy Civil Rights Official (DCRO) position in
each Assistant Administratorship (AAship) and region. DCROs are senior leaders whose
performance appraisals explicitly require them to work with OCR on national civil rights efforts as
well as overseeing civil rights programs within their respective organizations.

EPA has a full-time National Reasonable Accommodation Coordinator (NRAC), who manages its
National Reasonable Accommodation Program as a chief subject matter expert (GS 15). The
NRAC works closely with collateral duty Local Reasonable Accommodation Coordinators
(LORACs), who are assigned in every EPA region, Research Triangle Park (RTP), and Cincinnati
Lab. Each coordinator is trained on the Agency's Reasonable Accommodation Procedure, which is
based on the Rehabilitation Act of 1973, 29 U.S.C. §501 and 508, as amended. The in-depth
training includes information about: 1) the reasonable accommodation request process; 2) the
interactive process; 3) the importance of maintaining confidentiality and providing
accommodations in a timely manner; and 4) union negotiated procedures. The LORACs, in close
coordination with the NRAC, and Regional EEO and HR Officers, also provide a variety of training
and assistance to managers and employees to ensure that requests for accommodation are processed
in a prompt and judicious manner. For example, in FY 2013, 5 training courses throughout the
regions and AAships were provided, which were attended by 87 managers/supervisors and 25
employees. Furthermore, EPA continues to hold Senior Executives accountable for fostering
diversity for all employees including those individuals with disabilities, pursuant to Executive
Order 13548 through their performance appraisal.

In addition, both the NRAC and Assistant Reasonable Accommodation Coordinator (ARAC) serve
as Co-Chairs of the Section 508 Executive Council. As such, they collaborated with the Section
508 Coordinator and developed a 2.5 hour training course for all managers/supervisors and
employees. In FY 2013, the NRAC and ARAC conducted 31 classes attended by 270
managers/supervisors and 149 employees. The course was offered in Regions 1, 2, 4, 5, 6, 8, 10, as
well as the Office of Environmental Information (OEI) Program Office. Additionally, attendees
included managers/supervisors and employees from EPA labs, including RTP, Narragansett,
Houston, Gulf of Mexico, Athens, Cincinnati, and Edison labs.

Information about how to file an EEO complaint is accessible to employees and applicants through
EPA's intranet and internet sites. EPA policies on harassment and reasonable accommodation for
qualified individuals with disabilities are discussed in courses that all new Agency supervisors are
required to complete. Moreover, OCR continues to consult the EEO and Diversity Advisory
Council (EDAC), which is comprised of subject matter experts from the Office of Civil Rights;
Office of Human Resources; Office of Diversity, Advisory Committee Management and Outreach;
and Office of General Counsel, on an as needed basis as OCR developed the FY 2013 MD 715
Report and planned activities.

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EPA Management Directive 715 Report

In the summer of FY 2013, OARM established a Diversity and Inclusion Advisory Committee
(DIAC). The DIAC operates as a standing subcommittee of the Human Resources Council and
provides senior leadership oversight, counsel, and recommendations concerning EPA's diversity
and inclusion efforts. The DIAC is comprised of a cross-section the agency's senior executives and
key stakeholders, including Special Emphasis Program Managers (SEPMs), Non-Labor Employee
Groups (NLEGs), EEO Officers, and Union representatives. The DIAC meets quarterly to address
the effectiveness of EPA's diversity and inclusion efforts. The focus of the DIAC is to provide
recommendations to OHR about what activities should be implemented to promote diversity and
inclusion.

Integration of EEO into EPA's Strategic Mission

In FY 2013, EPA regions and Administratorships (AAships) each created their own MD-715
Action Plans, which incorporated EEO, Human Resources, and Diversity initiatives. In addition,
these Action Plans promoted the six essential elements of a model EEO Program, and the following
five focus areas identified by OCR: 1) policies or procedures related to hiring, promotions, or
retention; 2) efficient complaint processing; 3) special emphasis programs and outreach; 4)
disability and Reasonable Accommodation Program initiatives and training; and 5) diversity and
workplace best practices. Throughout FY 2013, OCR provided technical assistance visits for each
region and AAship, in which feedback was provided on these Action Plans. Accordingly, each
region and AAship FY 2013 Accomplishment Report, attached herein, provides a comprehensive
look at EPA's zealous efforts to create a model EEO program.

EPA has eight Special Emphasis Programs (SEP) Council Chairs, led by four senior-level National
Program Managers who share responsibility for the American Indian/Alaska Native Employment
(AIANAC), Asian American and Pacific Islander Advisory Council (AAPIAC), Black Employment
Program Advisory Council (BEPAC), Federal Women's Program Advisory Council (FWPAC),
Women In Science and Engineering (WISE), Hispanic Employment Program (HEP) Advisory
Council, Lesbian, Gay, Bisexual and Transgender Advisory Council (LGBTAC), Older Workers
Program, and Persons with Disability Advisory Council (PWDAC). There are also Special
Emphasis Managers in every region, AAship, and labs that work closely with the National Program
Managers.

As part of EPA's FY 2013 Cross-Cutting Fundamental Strategy Action Plan, EPA committed to
maintaining a talented and diverse workforce, providing employees with a flexible and
collaborative work environment, and equipping them with the tools to work effectively in today's
business environment. In accordance with this goal, ODACMO and OHR developed procedures to
broaden opportunities for outreach and recruitment such as developing and issuing a consolidated
list of coordinated Agency-wide participation in external outreach/recruitment events, and analyzed
workforce participation in the Successful Leader Program to establish a baseline to evaluate the
potential impact of further efforts to develop the existing workforce.

In FY 2013, EPA integrated EEO into its strategic mission. In FY 2013, ODACMO managed the
completion of the Diversity and Inclusion Strategic Plan (DISP), which is effective from FY 2012
to 2016, and is based on three interrelated goals: 1) Workforce Diversity. Recruit from a diverse,

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qualified group of potential applicants to secure a high-performing workforce drawn from all segments
of American society; 2) Workplace Inclusion. Cultivate a culture that encourages collaboration,
flexibility, and fairness to enable individuals to contribute to their full potential and further retention;
and 3) Sustainability. Develop structures and strategies to equip leaders with the ability to manage
diversity, be accountable, measure results, refine approaches on the basis of such data, and
institutionalize a culture of inclusion. For example, in support of the DISP, activities were initiated
throughout FY 2013 which included: 1) the creation of the DIAC, the cross-section of senior
executives and key stakeholders to address the effectiveness of EPA's diversity and inclusion
efforts; 2) the development of an enhanced diversity dashboard tool for workforce analysis and
reporting; and 3) the oversight of senior leadership support and engagement with Special Emphasis
program managers and employee resource groups. Together, these goals are intended to ensure a
One EPA workplace that engages, utilizes and leverages the talents and contributions of all
employees. It should be noted that the concept of One EPA was initiated by former Administrator
Lisa Jackson in January 2010, and encompasses the following principles:

•	Outcome Orientation: We focus on achieving extraordinary outcomes and connect our day-
to-day actions to them.

•	Alignment: We develop a shared understanding of problems and synchronize our efforts to
implement solutions all can support.

•	Relationships: We maintain strong, collaborative relationships inside and outside the
Agency based on effective communication and mutual respect.

•	Inclusiveness: We seek out diverse views and tools in building creative, integrated
solutions.

•	Ownership: The world views each of us as "EPA," so we feel ownership over the Agency as
a whole and deliver on our promises to each other, the public and our mission.

In FY 2013, OCR, ODACMO, and the regions in collaboration with other agencies provided
observance and commemorative events to broaden the understanding and appreciation of a diverse
and inclusive work environment throughout EPA and the greater federal community. These events
provide visibility to the respective groups and cultures, and present an opportunity to expand the
conversation on related issues, goals and concerns. EPA officials and management took active roles
in the events and employees were encouraged to attend. The national observances and
commemorative months included: Disability Employment Awareness Month; American Indian and
Alaska Native Heritage Month; Dr. Martin Luther King, Jr. National Birthday Observance; African
American History Month; Women's History Month; Federal Inter-Agency Holocaust
Remembrance Program; Asian American and Pacific Islander Heritage Month; Lesbian, Gay,
Bisexual, and Transgender Pride Month; and, Hispanic Heritage Month.

In FY 2013, ODACMO also encouraged Regions and AAships to: 1) provide strategic and
coordinated outreach to demographic groups with lower than expected representation; 2) leverage
Minority Academic Institution (MAI) partnerships as an outreach tool; and 3) consider using the
information contained in the Diversity Dashboard in developing and monitoring the effectiveness of
targeted outreach strategies.

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In FY 2013, OHR implemented a 2013 Memorandum of Understanding to create a formal
partnership with Gallaudet University, an educational institution for the hearing impaired, through
which OHR and OARM coordinated and organized the placement of 14 hearing impaired student
volunteers at EPA's Headquarters Program Offices during the 2012-2013 school year.

Management and Program Accountability

Management and program accountability for EEO is a commitment from the top down.
Administrator McCarthy has renewed EPA's dedication to EEO by signing the EEO policy
statement. Moreover, through EPA policies, training, and leadership actions, EPA communicates a
clear and consistent message that managers and employees share a responsibility for creating a
workplace in which discrimination is not tolerated.

To ensure accountability throughout civil rights programs in the regions and AAships, OCR
conducted eleven Technical Assistance Visits with Regions and AAships to provide feedback on
their FY-2013 Action Plans and enhance their development of planned activities to address triggers
identified in prior MD-715 Reports.

To improve accountability over EPA's Senior Executive Service (SES), OCR has worked for many
years to collect applicant flow data. In FY 2013, for the first time, the Executive Resources
Division (ERD) captured applicant flow data for external applicants to SES vacancy
announcements, which although not required by EEOC's MD 715 Instructions to agencies, will be
a useful tool in the agency's efforts to evaluate the impact of its planned activities on all levels of
selection. EPA is currently in the process of migrating to the Department of Interior National
Business Center (NBC) HR Line of Business (LOB) system, which may include the capability to
collect applicant flow data from internal SES candidates. This innovation would allow ERD to
collect internal applicant flow data in 2014.

In FY 2013, EPA began collaborating with the Department of Interior (DOI) to take advantage of
the Talent Management System, an extensive data system that maintains records of employee
training activities. Specifically, EPA plans to implement the Learning Management Module
component of the Talent Management System, which will allow EPA to offer a full catalog of
training courses to all employees, track participation, and assist in employee development planning.
EPA anticipates that the enhancement of the SES applicant flow data collection process, and the
system to track training participation rates will further its ability to examine whether barriers to
equal employment opportunity exist.

To improve accountability over EPA's career development programs, OHR and ODACMO started
by collecting race/national origin and sex data of GS -13 through GS-15 supervisors who
participated in the Successful Leaders program in FY 2012 and the first three quarters of FY 2013..
ODACMO conducted a limited baseline analysis, which is a preliminary step in EPA's efforts to
determine what motivates employees to participate in the Successful Leader Program. According to
their preliminary analysis, Asian, Black, Hawaiian/Pacific Islander, Hispanics and Two or More
race Females had the highest participation rates in the Successful Leader Program. However, there
was lower participation from White and Native American Males, and no participation from Native

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American Females generally. EPA will continue to monitor participation in the Successful Leader
Program.

EPA has an ongoing commitment to continue to include clear expectations about diversity and EEO
in performance standards for managers. EPA has maintained SES standards that not only focus on
preventing discrimination in hiring activities and promoting merit systems principles, but also require
senior leaders to be personally involved in leading and implementing EEO and civil rights initiatives
consistent with applicable law and executive orders. In addition, at the end of every performance
cycle, the Director of OCR, Performance Review Board members, and Executive Review Board
members evaluate management self-assessments to ensure that the respective rating is an appropriate
reflection of the accomplishments listed.

Proactive Prevention of Unlawful Discrimination

EPA is committed to proactively preventing unlawful discrimination throughout its workforce. In
furtherance of this goal in FY 2013, the DCRO position was created in each AAship and region. As
stated, the DCROs are responsible for the civil rights programs within their respective
organizations, and provides senior level involvement in the development of national strategies and
policies pertaining to civil rights. The DCROs, will in part, consistent with applicable laws,
provide executive support in furthering the EPA's commitment to creating a workplace free of
unlawful discrimination.

In the summer of FY 2013, OARM established the DIAC, which operates as a standing
subcommittee of the Human Resources Council to address the effectiveness of EPA's diversity and
inclusion efforts. The DIAC will proactively prevent unlawful discrimination by regularly
reviewing diversity and inclusion efforts to ensure that they also prevent barriers to EEO.

EPA's NRAC plays an important role with respect to proactive prevention by working to provide
guidance to managers and employees on the reasonable accommodation process, tracking any
trends, and addressing challenges. EPA believes that a lack of training on and knowledge of their
respective responsibilities would likely lead to an increase in mistakes and discrimination
complaints. The NRAC regularly briefs the Director of Civil Rights and LORACs on compliance
with written procedures. EPA has reviewed and updated its Reasonable Accommodation policies
and procedures to ensure that they reflect provisions of the Americans with Disabilities Act
Amendments Act (AD AAA). As part of the proactive efforts, the NRAC delivered five training
courses throughout the regions and AAships, which were attended by 87 managers/supervisors and
twenty-five employees.

In FY 2013, EPA enhanced its targeted outreach and recruitment activities by compiling a list of
diverse recruiting sources for Shared Service Centers to broadly distribute EPA job announcements.
This effort increases the probability that potential applicants from all race/national origin and sex
groups will receive EPA job announcements, and be afforded an opportunity to participate in the
application process, if they desire.

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EPA Management Directive 715 Report

EPA also recognizes that employees' use of the EEO complaint process sometimes cannot be
prevented. EPA emphasizes the use of ADR to assist the parties' effort's to resolve the concerns
raised and to facilitate effective communication between them. EPA managers and supervisors
are required to participate, absent extenuating circumstances, as reiterated by the Administrator in
her 2012 annual EEO Policy Statement. By certifying and training more EEO counselors and
providing informational materials about the benefits of ADR in print and electronically, EPA's
ADR participation rate increased from 33.7% in FY 2012 to 49.41% in FY 2013. These efforts also
increased EPA's rate of providing timely EEO counseling from 69.39% in FY 2012 to 92.11% in
FY 2013.

Efficiency

EPA recognizes the importance of efficiency with respect to EEO and is committed to achieving it.
EPA has made appropriate resources available to ensure there is a sufficient number of EEO
Officers, EEO Specialists, and Special Emphasis Program Managers across EPA so that EEO
matters are handled in a timely and efficient manner - in total, there are over 75 full-time staff
members and an additional approximate 75 collateral duty staff who help EPA administer its EEO
and Diversity Programs.

EPA is constantly reevaluating its EEO/Title VII program to ensure that complaints of
discrimination are handled in the most efficient manner possible. Throughout FY 2013, the
EEO/Title VII program maintained its use of a complaint tracking software, IComplaints, which
helped the staff to decrease its Final Agency Decision (FAD) issuance time by 61% and procedural
letter issuance by 46%. Moreover, the EEO/Title VII team received two extensive trainings on FAD
and procedural dismissal writing, which have enhanced the OCR staffs analysis capabilities and
accordingly, the efficiency of the process.

In a further effort to expedite its investigation completion rate, OCR has eliminated the use of its
contractor in drafting FADs because it found that allowing its two newly hired in-house attorneys to
draft all FADs streamlined the process and produced higher quality analyses. EPA also required all
investigators to attend its refresher EEO training. In addition, OCR maintained its Standard
Operating Procedures (SOPs) to provide guidance regarding the way EEO cases are processed at
EPA; the related SOP facilitates the transition of new staff into the office. It also identifies
expectations for OCR staff regarding an anticipated time table for drafting and conducting the legal
review of FADs. By the end of FY 2013, OCR also amended its statement of work with the
contractor providing investigator services to include penalties where the contractor provides
investigatory materials late.

EPA has also increased its efficiency by certifying and training 11 new EEO counselors. EPA EEO
counselors were required to attend refresher courses in accordance with MD 110, which entailed
mock counseling sessions, updates on EEO case law developments, and guidance from EEO
professionals and attorneys. By virtue of these achievements, EPA has also noticed significant
advancement in both the use and success rate for ADR. Last year, the ADR participation rate was
33.7% and this year it increased to 49.41%. The rate of providing timely EEO counseling also
increased from 69.39% in FY 2012 to 92.11% in FY 2013.

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EPA Management Directive 715 Report

The senior-level NRAC, in partnership with LORACs, also ensured that EPA's reasonable
accommodation process ran efficiently. In particular, 95.5% of reasonable accommodation requests
were processed within established timeframes in FY 2013 due to the NRAC's management. EPA
also collects and maintains several applicant flow and workforce data in several databases that are
accessible to OCR, ODACMO, and OHR to improve their efficiency in planning targeted activities
to create a model EEO program.

In FY 2013, ODACMO provided EPA employees with the opportunity to update their race and
national origin information. By increasing the accuracy of employee race and national origin
information, this effort improved EPA's ability to determine whether barriers exist to equal
employment opportunity in the Senior Grades.

EPA is pleased to participate on the Council of EEO and Civil Rights Executives and the Federal
Interagency Diversity Partnership to share best practices and ideas on ways to enhance the work
environment and the efficiency of EEO programs and activities. EPA benchmarks with other
agencies to learn about successful programs and ways to enhance its Civil Rights Programs.

Responsiveness and Legal Compliance

EPA is committed to ensuring EEO responsiveness and legal compliance. To ensure EEO
responsiveness, EPA mandates managers and supervisors' participation in ADR, absent extenuating
circumstances. Further, legal compliance is prioritized through EPA's timely adherence to EEOC
administrative judge orders. OCR is responsible for compliance with EEOC administrative judge
orders and provides documentation as requested by EEOC in a timely fashion. EPA's serious
dedication to legal compliance is demonstrated by its inclusion of administrative judge
responsiveness in the performance standard of the Assistant Director of Civil Rights for Title VII.
In addition, EPA has systems in place to ensure that monetary or other relief is initiated efficiently.

In furtherance of EPA's commitment to legal compliance in all EEO areas, it has: 1) implemented
training for all professionals that facilitate the EEO complaint process; 2) hired two in-house
attorneys; and 3) completed an SOP. While EPA has reduced both its FAD and
acceptance/dismissal letter completion times by 61% and 46%, respectively, it will address
priorities set forth in the EEOC's feedback to EPA's FY 2012 MD 715 report to continue to
improve.

Workforce Analysis
Total Workforce

At the close of FY 2013, EPA employed 15,888 (93.4%) full/part time permanent and 1,114 (6.6%)
temporary employees for a total of 17,002 employees. This was a significant net decrease of 757
(4.5%) full/part time permanent employees and a net decrease of 296 (21.0%) temporary employees
for a total net decrease of 1,053 (5.8%) employees compared to FY 2012. Males comprised 48.02
% (7,629) of the permanent workforce as compared to 51.86% of the national civilian labor force
(CLF). Females comprised 51.98% (8,259) of the workforce as compared to 48.14% of the CLF.

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EPA Management Directive 715 Report

Representation of Class Groups

The data in Table A1 shows the workforce profile for permanent employees:

White men comprised 36.93% (5,868) of the workforce compared to 38.33% of the CLF.

White women comprised 30.98% (4,922) of the workforce compared to 34.03% of the CLF.

Black men comprised 4.60% (738) of the workforce compared to 5.49% of the CLF.

Black women comprised 13.44% (2,136) of the workforce compared to 6.53% of the CLF.

Hispanic men comprised 2.62% (417) of the workforce compared to 5.17% of the CLF.

Hispanic women comprised 3.24% (514) of the workforce compared to 4.79% of the CLF.

Asian men comprised 3.06% (485) of the workforce compared to 1.97% of the CLF.

Asian women comprised 3.23 % (513) of the workforce compared to 1.93% of the CLF.

Native Hawaiian men comprised 0.05% (8) of the workforce compared to 0.07% of the CLF.

Native Hawaiian women comprised 0.07 % (11) of the workforce compared to 0.7% of the CLF.
American Indian men comprised 0.28% (44) of the workforce compared to 0.55% of the CLF.
American Indian women comprised 0.43% (69) of the workforce compared to 0.53% of the CLF.
Two or More Races Men comprised 0.43% (69) of the workforce compared to 0.26% of the CLF.
Two or More Races women comprised 0.59% (94) of the workforce compared to 0.28% of the
CLF.

EPA also collected information concerning its temporary employees which can be found in Tables
A1 and Bl.

At the close of FY 2013, EPA employed 196 (1.23%) full/part time permanent and 5 (0.45%)
temporary employees for a total of 201 (1.18%) employees with Targeted Disabilities. The federal-
wide goal is 2.0%. This was a net decrease of 28 (12.50%) full/part time permanent employees and
a net increase of 2 (66.67%) temporary employees for a net decrease of 26 (11.45%) employees
compared to FY 2012.

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U. S. Environmental Protection Agency

For period covering October 1, 2012 to September 30, 2013.

CERTIFICATION of ESTABLISHMENT of CONTINUING
EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS

I, Helena Wooden-Aguilar, Acting Director of Civil Rights, am the Principal EEO
Director/Official for the US Environmental Protection Agency.

EPA has conducted an annual self-assessment of Section 717 and Section 501 programs against
the essential elements as prescribed by EEO MD-715. If an essential element was not fully
compliant with the standards of EEO MD-715, a further evaluation was conducted and, as
appropriate, EEO Plans for Attaining the Essential Elements of a Model EEO Program, are
included with this Federal Agency Annual EEO Program Status Report.

EPA has also analyzed its workforce profiles and conducted barrier analyses aimed at detecting
whether any management or personnel policy, procedure or practice is operating to disadvantage
any group based on race, national origin, gender or disability. EEO Plans to Eliminate Identified
Barriers, as appropriate, are included with this Federal Agency Annual EEO Program Status

I certify that proper documentation of this assessment is in place and is being maintained for
EEOC review upon request.

Report.

Signature of Principal EEO Director/Official
Certifies that this Federal Agency Annual EEO Program
Status Report is in compliance with EEO MD-715.

Date

Signature of Agency Head or Agency Head Designee

Date

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EPA Management Directive 715 Report

Part G: Agency Self-Assessment



Essential Element A: Demonstrated Commitment From Asencv Leadership
Requires EPA head to issue written policy statements ensuring a workplace free of
discriminatory harassment and a commitment to equal employment opportunity.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's Status
Report

Yes

No

Compliance Indicator: EEO policy statements are up-to-date.

1. EPA Head was installed on June 18, 2013. The
EEO policy statement was issued September 7,
2012 by the previous Acting Administrator. Was
the EEO Policy Statement issued within 6-9
months of the installation of EPA Head? If no,
provide an explanation.

X



New Administrator issued
policy statement in
January 2014.

2. During the current Agency Head's tenure, has
the EEO Policy Statement been reissued annually?
If no, provide an explanation.

X





3. Are new employees provided a copy of the
EEO Policy Statement during orientation?

X





4. When an employee is promoted into the
supervisory ranks, is s/he provided a copy of the
EEO Policy Statement?

X





5. Have the heads of subordinate reporting
components communicated support of all Agency
EEO policies through the ranks?

X





6. Has EPA made written materials available to all
employees and applicants, informing them of the
variety of EEO programs and administrative and
judicial remedial procedures available to them?

X





7. Has EPA prominently posted such written
materials in all personnel offices, EEO offices, and
on EPA's internal website? [see 29 CFR
§1614.102(b)(5)]

X





Compliance Indicator: Agency EEO policy is vigorously enforced

3y Agency management.

8. Are managers and supervisors evaluated on
their commitment to Agency EEO policies and
principles, including their efforts to:

X





9. resolve problems/disagreements and other
conflicts in their respective work environments as
they arise?

X

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EPA Management Directive 715 Report

10. address concerns, whether perceived or real,
raised by employees and following-up with
appropriate action to correct or eliminate tension in
the workplace?

X





11. support EPA's EEO Program through
allocation of mission personnel to participate in
community outreach and recruitment programs
with private employers, public schools and
universities?

X





12. ensure full cooperation of employees under
his/her supervision with EEO office officials such
as EEO Counselors, EEO Investigators, etc.?

X





13. ensure a workplace that is free from all forms
of discrimination, harassment and retaliation?

X





14. ensure that subordinate supervisors have
effective managerial, communication and
interpersonal skills in order to supervise most
effectively in a workplace with diverse employees
and avoid disputes arising from ineffective
communications?

X





15. ensure the provision of requested religious
accommodations when such accommodations do
not cause an undue hardship?

X





16. ensure the provision of requested disability
accommodations to qualified individuals with
disabilities when such accommodations do not
cause an undue hardship?

X





17. Have all employees been informed about what
behaviors are inappropriate in the workplace and
that this behavior may result in disciplinary
actions?

X





18. Describe what means were utilized by EPA to
so inform its workforce about the penalties for
unacceptable behavior. This was listed in the
Administrator's Policy Statement that was
distributed to all employees. It was also included
in a variety of EEO trainings conducted by EPA
and is reiterated throughout Agency by EEO and
HRO staff. It is also included in EPA's Table of
Penalties, which is accessible to all employees
through the intranet.

X

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EPA Management Directive 715 Report

19. Have the procedures for reasonable
accommodation for individuals with disabilities
been made readily available/accessible to all
employees by disseminating such procedures
during orientation of new employees and by
making such procedures available on the World
Wide Web or Internet?

X





20. Have managers and supervisor been trained on
their responsibilities under the procedures for
reasonable accommodation?

X

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EPA Management Directive 715 Report

Essential Element B: Integration of EEO into EPA'

3 Strategic Mission

Requires that EPA's EEO programs be organized and structured to maintain a workplace that is
free from discrimination in any of EPA's policies, procedures or practices and supports EPA's
strategic mission.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's status
report.

Yes

Compliance Indicator: The reporting structure for the EEO Program provides the Principal
EEO Official with appropriate authority and resources to effectively carry out a successful EEO
Program.

21. Is the EEO Director under the direct
supervision of EPA head? [see 29 CFR
§1614.102(b)(4)]

For subordinate level reporting components, is the
EEO Director/Officer under the immediate
supervision of the lower level component's head
official?

(For example, does the Regional EEO Officer
report to the Regional Administrator?)

22. Are the duties and responsibilities of EEO
officials clearly defined?

23. Do the EEO officials have the knowledge,
skills, and abilities to carry out the duties and
responsibilities of their positions?

24. If EPA has 2nd level reporting components, are
there organizational charts that clearly define the
reporting structure for EEO programs?

N/A

25. If EPA has 2nd level reporting components,
does EPA-wide EEO Director have authority for
the EEO programs within the subordinate
reporting components?

N/A

If not, please describe how EEO program authority
is delegated to subordinate reporting components.

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EPA Management Directive 715 Report

Compliance Indicator: The EEO Director and other EEO professional staff responsible for
EEO programs have regular and effective means of informing EPA head and senior
management officials of the status of EEO programs and are involved in, and consulted on,
management/personnel actions.

26. Does the EEO Director/Officer have a regular
and effective means of informing EPA head and
other top management officials of the
effectiveness, efficiency and legal compliance of
EPA's EEO program?

X





27. Following the submission of the immediately
preceding FORM 715-01, did the EEO
Director/Officer present to the head of EPA and
other senior officials the "State of EPA" briefing
covering all components of the EEO report,
including an assessment of the performance of
EPA in each of the six elements of the Model EEO
Program and a report on the progress of EPA in
completing its barrier analysis including any
barriers it identified and/or eliminated or reduced
the impact of?

X





28. Are EEO program officials present during
agency deliberations prior to decisions regarding
recruitment strategies, vacancy projections,
succession planning, selections for training/career
development opportunities, and other workforce
changes?

X





29. Does EPA consider whether any group of
employees or applicants might be negatively
impacted prior to making human resource
decisions such as re-organizations and re-
alignments?

X





30. Are management/personnel policies,
procedures and practices examined at regular
intervals to assess whether there are hidden
impediments to the realization of equality of
opportunity for any group(s) of employees or
applicants? [see 29 C.F.R. § 1614.102(b)(3)]

X

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EPA Management Directive 715 Report

31. Is the EEO Director included in EPA's
strategic planning, especially EPA's human capital
plan, regarding succession planning, training, etc.,
to ensure that EEO concerns are integrated into
EPA's strategic mission?

X





Compliance Indicator: EPA has committed sufficient human resources and budget allocations
to its EEO programs to ensure successful operation.

32. Does the EEO Director have the authority and
funding to ensure implementation of agency EEO
Action Plans to improve EEO program efficiency
and/or eliminate identified barriers to the
realization of equality of opportunity?

X





33. Are sufficient personnel resources allocated to
the EEO Program to ensure that agency self-
assessments and self-analyses prescribed by EEO
MD-715 are conducted annually and to maintain
an effective complaint processing system?

X





34. Are statutory/regulatory EEO related Special
Emphasis Programs sufficiently staffed?

X





35. Federal Women's Program - 5 U.S.C. 7201; 38
U.S.C. 4214; Title 5 CFR, Subpart B, 720.204

X





36. Hispanic Employment Program - Title 5 CFR,
Subpart B, 720.204

X





37. People With Disabilities Program Manager;
Selective Placement Program for Individuals With
Disabilities - Section 501 of the Rehabilitation
Act; Title 5 U.S.C. Subpart B, Chapter 31,
Subchapter 1-3102; 5 CFR 213.3102(t) and (u); 5
CFR 315.709

X





38. Are other agency special emphasis programs
monitored by the EEO Office for coordination and
compliance with EEO guidelines and principles,
such as FEORP - 5 CFR 720; Veterans
Employment Programs; and Black/African
American; American Indian/Alaska Native, Asian
American/Pacific Islander programs?

X

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EPA Management Directive 715 Report

Compliance Indicator: EPA has committed sufficient budget to support the success of its EEO
Programs.

39. Are there sufficient resources to enable EPA
to conduct a thorough barrier analysis of its
workforce, including the provision of adequate
data collection and tracking systems

40. Is there sufficient budget allocated to all
employees to utilize, when desired, all EEO
programs, including the complaint processing
program and ADR, and to make a request for
reasonable accommodation? (Including
subordinate level reporting components?)

41. Has funding been secured for publication and
distribution of EEO materials (e.g. harassment
policies, EEO posters, reasonable accommodations
procedures, etc.)?

42. Is there a central fund or other mechanism for
funding supplies, equipment and services
necessary to provide disability accommodations?

43. Does EPA fund maj or renovation proj ects to
ensure timely compliance with Uniform Federal
Accessibility Standards?

44. Is the EEO Program allocated sufficient
resources to train all employees on EEO Programs,
including administrative and judicial remedial
procedures available to employees?

45. Is there sufficient funding to ensure the
prominent posting of written materials in all
personnel and EEO offices? [see 29 C.F.R. §
1614.102(b)(5)]

46. Is there sufficient funding to ensure that all
employees have access to this training and
information?

47. Is there sufficient funding to provide all
managers and supervisors with training and
periodic up-dates on their EEO responsibilities:

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EPA Management Directive 715 Report

48. for ensuring a workplace that is free from all
forms of discrimination, including harassment and
retaliation?

X





49. to provide religious accommodations?

X





50. to provide disability accommodations in
accordance with EPA's written procedures?

X





51. in the EEO discrimination complaint process?

X





52. to participate in ADR?

X

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EPA Management Directive 715 Report

Essential Element C: Management and Program Accountability

This element requires EPA Head to hold all managers, supervisors, and EEO Officials
responsible for the effective implementation of EPA's EEO Program and Plan.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's status
report

Yes

No

Compliance Indicator: EEO program officials advise and provide appropriate assistance to
managers/supervisors about the status of EEO programs within each manager's or supervisor's
area or responsibility.

53. Are regular (monthly/quarterly/semi-annually)
EEO updates provided to management/supervisory
officials by EEO program officials?

X





54. Do EEO program officials coordinate the
development and implementation of EEO Plans
with all appropriate agency managers to include
Agency Counsel, Human Resource Officials,
Finance, and the Chief information Officer?

X





Compliance Indicator: The Human Resources Director and the EEO Director meet regularly to
assess whether personnel programs, policies, and procedures are in conformity with
instructions contained in EEOC management directives, [see 29 CFR § 1614.102(b)(3)]

55. Have time-tables or schedules been
established for EPA to review its Merit Promotion
Program Policy and Procedures for systemic
barriers that may be impeding full participation in
promotion opportunities by all groups?

X





56. Have time-tables or schedules been
established for EPA to review its Employee
Recognition Awards Program and Procedures for
systemic barriers that may be impeding full
participation in the program by all groups?

X

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EPA Management Directive 715 Report

57. Have time-tables or schedules been
established for EPA to review its Employee
Development/Training Programs for systemic
barriers that may be impeding full participation in
training opportunities by all groups?

Compliance Indicator: When findings of discrimination are made, EPA explores whether or
not disciplinary actions should be taken.

58. Does EPA have a disciplinary policy and/or a
table of penalties that covers employees found to
have committed discrimination?

59. Have all employees, supervisors, and
managers been informed as to the penalties for
being found to perpetrate discriminatory behavior
or for taking personnel actions based upon a
prohibited basis?

60. Has EPA, when appropriate, disciplined or
sanctioned managers/supervisors or employees
found to have discriminated over the past two
years?

Please see response below.

If so, cite number found to have discriminated and list penalty/disciplinary action for each type
of violation.

Response: There was one finding of discrimination during this time period, and as of the date
of this report, management is considering appropriate disciplinary action in accordance with
EPA's Table of Penalties; however, no final decision have yet been made.

61. Does EPA promptly (within the established
time frame) comply with EEOC, Merit Systems
Protection Board, Federal Labor Relations
Authority, labor arbitrators, and District Court
orders?

62. Does EPA review disability accommodation
decisions/actions to ensure compliance with its
written procedures and analyze the information
tracked for trends, problems, etc.?

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EPA Management Directive 715 Report

Essential Element D: Proactive Prevention

Requires that EPA head makes early efforts to prevent discriminatory actions and eliminate
barriers to equal employment opportunity in the workplace.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's status
report

Yes

Compliance Indicator: Analyses to identify and remove unnecessary barriers to employment
are conducted throughout the year.

63. Do senior managers meet with and assist the
EEO Director and/or other EEO Program Officials
in the identification of barriers that may be
impeding the realization of equal employment
opportunity?

64. When barriers are identified, do senior
managers develop and implement, with the
assistance of EPA EEO office, agency EEO Action
Plans to eliminate said barriers?

65. Do senior managers successfully implement
EEO Action Plans and incorporate the EEO Action
Plan Objectives into agency strategic plans?

66. Are trend analyses of workforce profiles
conducted by race, national origin, sex and
disability?

67. Are trend analyses of the workforce's major
occupations conducted by race, national origin, sex
and disability?

68. Are trends analyses of the workforce's grade
level distribution conducted by race, national
origin, sex and disability?

69. Are trend analyses of the workforce's
compensation and reward system conducted by
race, national origin, sex and disability?

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EPA Management Directive 715 Report

70. Are trend analyses of the effects of
management/personnel policies, procedures and
practices conducted by race, national origin, sex
and disability?

X





Compliance Indicator: The use of Alternative Dispute Resolution (ADR) is encouraged by
senior management.

71. Are all employees encouraged to use ADR?

X





72. Is the participation of supervisors and
managers in the ADR process required?

X

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EPA Management Directive 715 Report

Essential Element E: Efficiency

Requires that EPA head ensure that there are effective systems in place for evaluating the
impact and effectiveness of EPA's EEO Programs as well as an efficient and fair dispute
resolution process.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's status
report

Yes

Compliance Indicator: EPA has sufficient staffing, funding, and authority to achieve the
elimination of identified barriers.

73. Does the EEO Office employ personnel with
adequate training and experience to conduct the
analyses required by MD-715 and these
instructions?

Please see H-l.

74. Has EPA implemented an adequate data
collection and analysis systems that permit
tracking of the information required by MD-715
and these instructions?

75. Have sufficient resources been provided to
conduct effective audits of field facilities' efforts to
achieve a model EEO program and eliminate
discrimination under Title VII and the
Rehabilitation Act?

76. Is there a designated agency official or other
mechanism in place to coordinate or assist with
processing requests for disability accommodations
in all major components of EPA?

77. Are 90% of accommodation requests
processed within the time frame set forth in EPA
procedures for reasonable accommodation?

Compliance Indicator: EPA has an effective complaint tracking and monitoring system in
place to increase the effectiveness of EPA's EEO Programs.

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EPA Management Directive 715 Report

78. Does EPA use a complaint tracking and
monitoring system that allows identification of the
location and status of complaints and length of
time elapsed at each stage of EPA's complaint
resolution process?

79. Does EPA's tracking system identify the issues
and bases of the complaints, the aggrieved
individuals/complainants, the involved
management officials and other information to
analyze complaint activity and trends?

80. Does EPA hold contractors accountable for
delay in counseling and investigation processing
times?

If yes, briefly describe how: In the event of a delay, contract payment is reduced or the contract
is not renewed.

81. Does EPA monitor and ensure that new
investigators, counselors, including contract and
collateral duty investigators, receive the 32 hours
of training required in accordance with EEO
Management Directive MD-110?

82. Does EPA monitor and ensure that
experienced counselors, investigators, including
contract and collateral duty investigators, receive
the 8 hours of refresher training required on an
annual basis in accordance with EEO Management
Directive MD-110?

Compliance Indicator: EPA has sufficient staffing, funding and authority to comply with the
time frames in accordance with the EEOC (29 C.F.R. Part 1614) regulations for processing
EEO complaints of employment discrimination.

83. Are benchmarks in place that compares EPA's
discrimination complaint processes with 29 C.F.R.
Part 1614?

84. Does EPA provide timely EEO counseling
within 30 days of the initial request or within an
agreed upon extension in writing, up to 60 days?

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EPA Management Directive 715 Report

85. Does EPA provide an aggrieved person with
written notification of his/her rights and
responsibilities in the EEO process in a timely
fashion?

86. Does EPA complete the investigations within
the applicable prescribed time frame?

Please see H-2.

87. When a complainant requests a final agency
decision, does EPA issue the decision within 60
days of the request?

Please see H-2.

88. When a complainant requests a hearing, does
EPA immediately upon receipt of the request from
the EEOC AJ forward the investigative file to the
EEOC Hearing Office?

89. When a settlement agreement is entered into,
does EPA timely complete any obligations
provided for in such agreements?

90. Does EPA ensure timely compliance with
EEOC AJ decisions which are not the subject of an
appeal by EPA?

Compliance Indicator: There is an efficient and fair dispute resolution process and effective
systems for evaluating the impact and effectiveness of EPA's EEO complaint processing
program.

91. In accordance with 29 C.F.R. §1614.102(b),
has EPA established an ADR Program during the
pre-complaint and formal complaint stages of the
EEO process?

92. Does EPA require all managers and
supervisors to receive ADR training in accordance
with EEOC (29 C.F.R. Part 1614) regulations, with
emphasis on the federal government's interest in
encouraging mutual resolution of disputes and the
benefits associated with utilizing ADR?

93. After EPA has offered ADR and the
complainant has elected to participate in ADR, are
the managers required to participate?

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EPA Management Directive 715 Report

94. Does the responsible management official
directly involved in the dispute have settlement
authority?

Compliance Indicator: EPA has effective systems in place for maintaining and evaluating the
impact and effectiveness of its EEO programs.

95. Does EPA have a system of management
controls in place to ensure the timely, accurate,
complete and consistent reporting of EEO
complaint data to the EEOC?

Please see H-2.

96. Does EPA provide reasonable resources for
the EEO complaint process to ensure efficient and
successful operation in accordance with 29 C.F.R.
§ 1614.102(a)(1)?

97. Does EPA EEO office have management
controls in place to monitor and ensure that the
data received from Human Resources is accurate,
timely received, and contains all the required data
elements for submitting annual reports to the
EEOC?

98. Do EPA's EEO programs address all of the
laws enforced by the EEOC?

99. Does EPA identify and monitor significant
trends in complaint processing to determine
whether EPA is meeting its obligations under Title
VII and the Rehabilitation Act?

100. Does EPA track recruitment efforts and
analyze efforts to identify potential barriers in
accordance with MD-715 standards?

Please see H-3.

101. Does EPA consult with other agencies of
similar size on the effectiveness of their EEO
programs to identify best practices and share
ideas?

Compliance Indicator: EPA ensures that the investigation and adjudication function of its
complaint resolution process are separate from its legal defense arm of agency or other offices
with conflicting or competing interests.

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EPA Management Directive 715 Report

102. Are legal sufficiency reviews of EEO matters
handled by a functional unit that is separate and
apart from the unit which handles agency
representation in EEO complaints?

X





103. Does EPA discrimination complaint process
ensure a neutral adjudication function?

X





104. If applicable, are processing time frames
incorporated for the legal counsel's sufficiency
review for timely processing of complaints? Yes

X



Please see H-2.

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EPA Management Directive 715 Report

Essential Element F: Responsiveness and Lenal Compliance

This element requires that federal agencies are in full compliance with EEO statutes and EEOC
regulations, policy guidance, and other written instructions.

EEOC MD 715 Agency Assessment Questions

Measure has
been met

For all unmet measures,
provide a brief explanation
in the space below or
complete and attach an
EEOC FORM 715-01
PART H to EPA's status
report

Yes

Compliance Indicator: Agency personnel are accountable for timely compliance with orders
issued by EEOC Administrative Judges.

105. Does EPA have a system of management
control to ensure that agency officials timely
comply with any orders or directives issued by
EEOC Administrative Judges?

Compliance Indicator: EPA's system of management controls ensures that EPA timely
completes all ordered corrective action and submits its compliance report to EEOC within 30
days of such completion.

106. Does EPA have control over the payroll
processing function of EPA? If Yes, answer the
two questions below.

107. Are there steps in place to guarantee
responsive, timely, and predictable processing of
ordered monetary relief?

108. Are procedures in place to promptly process
other forms of ordered relief?

Compliance Indicator: Agency personnel are accountable for the timely completion of actions
required to comply with orders of EEOC.

109. Is compliance with EEOC orders
encompassed in the performance standards of any
agency employees?

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EPA Management Directive 715 Report

If so, please identify the employees by title in the comments section, and state how
performance is measured. Compliance is specifically included in performance standards of the
Assistant Director of the Employment Complaints Resolutions Division. The position is
currently vacant due to the retirement of the previous Assistant Director. The vacancy has been
announced and a selection is expected shortly.

110. Is the unit charged with the responsibility for
compliance with EEOC orders located in the EEO
office?

If not, please identify the unit in which it is located, the number of employees in the unit, and
their grade levels in the comments section. N/A

111. Have the involved employees received any
formal training in EEO compliance?

Does EPA promptly provide to the EEOC the following documentation for completing
compliance:

112. Attorney Fees: Copy of check issued for
attorney fees and /or a narrative statement by an
appropriate agency official, or agency payment
order dating the dollar amount of attorney fees
paid?

113. Awards: A narrative statement by an
appropriate agency official stating the dollar
amount and the criteria used to calculate the
award?

114. Back Pay and Interest: Computer print-outs
or payroll documents outlining gross back pay and
interest, copy of any checks issued, narrative
statement by an appropriate agency official of total
monies paid?

115. Compensatory Damages: The final agency
decision and evidence of payment, if made?

116. Training: Attendance roster at training
session(s) or a narrative statement by an
appropriate agency official confirming that
specific persons or groups of persons attended
training on a date certain?

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EPA Management Directive 715 Report

117. Personnel Actions (e.g., Reinstatement,
Promotion, Hiring, Reassignment): Copies of SF-
50s

X





118. Posting of Notice of Violation: Original
signed and dated notice reflecting the dates that the
notice was posted. A copy of the notice will suffice
if the original is not available.

X





119. Supplemental Investigation: 1. Copy of letter
to complainant acknowledging receipt from EEOC
of remanded case. 2. Copy of letter to complainant
transmitting the Report of Investigation (not the
ROI itself unless specified). 3. Copy of request for
a hearing (complainant's request or agency's
transmittal letter).

X





120. Final Agency Decision (FAD): FAD or copy
of the complainant's request for a hearing.

X





121. Restoration of Leave: Print-out or statement
identifying the amount of leave restored, if
applicable. If not, an explanation or statement.

X





122. Civil Actions: A complete copy of the civil
action complaint demonstrating same issues raised
as in compliance matter.

X





123. Settlement Agreements: Signed and dated
agreement with specific dollar amounts, if
applicable. Also, appropriate documentation of
relief is provided.

X

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EPA Management Directive 715 Report

Part H Plan to Correct Deficiencies

Part H-l: EEO Staff and MD 715

STATEMENT OF
MODEL PROGRAM
ESSENTIAL ELEMENT
DEFICIENCY:

(Part G: Q-73) Does the EEO Office employ personnel with
adequate training and experience to conduct the analyses
required by MD 715 and these instructions? No.

OBJECTIVE:

To further improve the training and skills of EEO personnel in
the Office of Civil Rights and in the Regions to enable them to
administer all aspects of the EEO process.

RESPONSIBLE
OFFICIAL:

Director, Office of Civil Rights

DATE OBJECTIVE
INITIATED:

September 1, 2010

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

December 12, 2013

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

EPA hired outside expert/consultant to review structure, management
and staff and to make recommendations concerning EEO Office in
order to help EPA establish a model EEO program.

Completed
March 2011

Within thirty days of receiving the consultant's recommendations,
EPA will develop and implement an Action Plan, which will include
identifying managerial challenges; strengthening employees' skills;
and creating adequate oversight measures for timely completion of the
MD 715 report and other EEO functions.

Completed
April 2011

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EPA Management Directive 715 Report

Establish Executive Committee to develop strategy to continue to
strengthen Agency's EEO and Civil Rights Program.

Completed
August 2011

Share information with all Office of Civil Rights staff about the
availability of resources to help each of them create an Individual
Development Plan (IDP), containing individual goals consistent with
organizational goals.

Completed
November 2011

Re-evaluate and revise the performance standard for OCR,
Affirmative Employment Analysis and Accountability staff to clarify
the expectations and functions.

Completed
October 2012

Hire new program analyst staff in the Office of Civil Rights, OCR,
Affirmative Employment Analysis and Accountability Division
subject to budgetary constraints, who will be primarily responsible for
MD 715-related statistical analysis.

Completed
July 2013

Based on the recommendations of Executive Committee, implement
the proposed organizational realignment with the Office of Diversity,
Advisory Committee Management and Outreach.

Completed
July 2013

Monitor progress of staff training and development related to
affirmative employment programs and MD 715.

Completed
September 2013

Conduct MD 715 Barrier Analysis Training for Affirmative
Employment Analysis and Accountability division and MD-715
stakeholders.

Completed
December 2013

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE:

Although EPA has submitted MD 715 Reports in accordance with regulatory deadlines every
year since 2010, the Office of Civil Rights continues to realign the mission and enhance the
capacity of its staff in the Affirmative Employment Analysis and Accountability division
(AEAA). In Fiscal Year (FY) 2011, AEAA was identified as having substantial deficiencies
by an Agency-commissioned report from a management consulting firm. The report described
one of the Office of Civil Right's challenges as being related to deficiencies in the
qualifications, knowledge, and training of some staff in the Office of Civil Rights. The Civil
Rights Executive Committee, led by EPA's Deputy Administrator, developed an
implementation strategy to help address the deficiencies identified.

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EPA Management Directive 715 Report

In FY 2012, EPA began the implementation of that strategy, perhaps most notably by
initiating the reorganization of the functions of AEAA and the Office of Diversity, Advisory
Committee Management and Outreach (ODACMO). In particular, Special Emphasis
observance functions regarding outreach and Heritage Month were transitioned under the
leadership and management of ODACMO in July 2013. At this time, the Affirmative
Employment division was renamed AEAA and the staff began to focus primarily on the
development and implementation of Management Directive 715 Programs. These
responsibilities were added to the Performance Appraisal and Recognition System (PARS) of
AEAA staff members. EPA believes that this transition will result in continued improvements
in its MD 715 Program. The new focus of AEAA staff is on: 1) barrier analysis through the
careful examination of Agency policies, practices, and procedures; 2) working with senior
leaders and managers, including the Office of Human Resources (OHR), and ODACMO, in
developing Action Plans to address and correct any identified deficiencies or barriers to EEO;
and 3) monitoring the implementation of action plans, as well as writing and submitting the
MD 715 Report in a timely manner.

EPA is pleased that every Region and AAship have their own MD 715 Action Plan with
specific goals and accomplishments, which support the FY 2012 MD 715 report and are
included as an attachment to this report and demonstrate the scope and impact of EPA's
affirmative programs of EEO. Although Region and AAship Action Plans have been included
in EPA's MD 715 Reports since 2011, the AEAA staff conducted Technical Assistance Visits,
for the first time in 2013, to provide feedback and identify linkages between Action Plan
commitments and EPA's overall MD 715 goals.

In FY 2013, the Office of Civil Rights prioritized training and improving the capacity of
AEAA staff to complete the analysis required by MD 715. Since July 2013, an attorney
advisor in the Civil Rights and Finance Law Office has provided on-the-job training to the
AEAA staff on a one-on-one basis, which included tasks designed to help build the staffs
capacity, such as discussing and implementing a project management strategy for completion
of the MD 715; analyzing third quarter applicant flow data; gathering facts about the status of
planned items, etc. In August 2013, the AEAA staff attended the EEOC's Basics of MD 715
training. In addition, the Defense Equal Opportunity Management Institute (DEOMI)
presented barrier analysis training to the AEAA staff from December 9 to December 12, 2013.

Despite these successes, AEAA experienced a gap in managerial leadership when its former
Assistant Director retired in March 2013. Nonetheless, EPA is happy to report
that an Acting AEAA Director was appointed on December 2, 2013, and EPA has selected a
permanent AEAA Assistant Director. EPA continues to identify AEAA as an area that should
be closely monitored to ensure sufficient progress and improvement as the Agency continues
to develop a Model EEO Program.

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EPA Management Directive 715 Report

Part H-2: Timeliness and Effectiveness of
EEO Complaints Processing Program

STATEMENT OF
MODEL PROGRAM
ESSENTIAL ELEMENT
DEFICIENCY:

(Part G: Q-86) Does EPA complete the investigations within
the applicable prescribed time frame? No.

(Part G: Q-87) When a complainant requests a final Agency
decision, does EPA issue the decision within 60 days of the
request? No.

(Part G: Q-104) If applicable, are processing timeframes
incorporated for the legal counsel's sufficiency review for
timely processing of complaints? Yes.

OBJECTIVE:

To ensure that EEO investigations and final Agency decisions
are consistently completed within the timeframes proscribed by
EEOC MD 110 and 29 C.F.R. Part 1614.

To ensure that legal counsel is given adequate time to conduct
sufficiency reviews while still meeting regulatory timeframes.

RESPONSIBLE
OFFICIAL:

Director, Office of Civil Rights

Assistant Director, Employment Complaints Resolutions
Division

Deputy Regional Administrators

DATE OBJECTIVE
INITIATED:

March 1, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2014

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

The Office of Civil Rights will develop effective performance terms
with its contract investigators to ensure timely completion of
investigations.

Completed
April 2011

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EPA Management Directive 715 Report

The Office of Civil Rights will develop and implement a plan
consistent with federal procurement policies to terminate contracts for
failure to comply with established timeframes.

Completed
September 2011

The Office of Civil Rights will develop and implement a new
complaint status report tracking system, which tracks all complaint-
related events and will share the reports within the EEO community.

Completed
September 2011

The Office of Civil Rights will work with a new contractor (United
States Postal Service) to handle EEO complaint investigations.

Completed
October 2011

The Office of Civil Rights will enhance EEO Officer and counselor
training on meeting deadlines.

Completed
February 2012

The Office of Civil Rights will evaluate the effectiveness of the new
iComplaints system.

Completed
September 2012

The Office of Civil Rights will conduct analysis of the ADR program
including ways to improve utilization.

Completed
June 30, 2013

The Office of Civil Rights will develop Standard Operating
Procedures, case tracking processes, guidance on updating Regional
offices concerning complaint-specific events, and specific timeframes
that will enable EPA to meet complaint-related deadlines.

Completed
June 30, 2013

The Director of the Office of Civil Rights and the Assistant Director,
Employment Complaints Resolutions Division will evaluate these new
practices and periodically conduct a quality assurance review of
complaint process procedures and processes.

Completed
September 30, 2013

The Office of Civil Rights will evaluate United States Postal Service
and make modifications if needed.

Completed
September 1, 2013

The Office of Civil Rights will generate reports (No FEAR, 462
Reports) to develop briefings for EEO Officers and Agency
management.

May 1, 2014

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The Office of Civil Rights will evaluate the effectiveness of its newly
developed Statements of Work with United States Postal Service
(USPS), the contractor responsible for conducting investigations into
complaints of discrimination.

September 1, 2014

The Office of Civil Rights will evaluate the effectiveness of the
complaint-related timeframes it has incorporated into its Standard
Operating Procedures.

September 1, 2014

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE:

(Q-86) At the end of FY 2013, EPA's Office of Civil Rights (OCR) experienced a 46%
decrease in the completion time for procedural dismissals and a reduction in time for the
completion of investigations regarding newly filed cases from 194 days in FY 2012 to 180
days in FY 2013. OCR also eliminated its backlog of long-overdue cases and now, only has
cases pending in investigation that were filed in 2012 or later. In September 2013, the
Employment Complaint Resolutions Staff (ECRS) attended two days of in-depth training
regarding best practices for researching and writing letters of acceptance/dismissal. By virtue
of this training, ECRS staff members enhanced their subject matter expertise, enabling them to
work more efficiently in preparing letters of acceptance/dismissal and processing complaints
in a timely fashion.

With respect to investigations, the Interagency Agreement between EPA and USPS, signed
September 2011, has enhanced OCR's ability to complete investigations within the established
timeframes and improved the quality of investigations. USPS has an excellent track record
with respect to the timely processing of investigations. OCR has been working with USPS on
an ongoing basis to refine the investigations process, and finalized the Statements of Work
with USPS on September 1, 2013.

In addition, OCR has made full use of the complaints tracking system, iComplaints, procured
during FY 2012. In FY 2013, ECRS staff succeeded in converting all active cases to the
system. This new system from the Micropact Corporation provides easy complaint tracking
and monitoring systems concerning the identification, location, and status of a complaint
throughout the lifecycle of the EEO complaint process. The ECRS staff received extensive
training on iComplaints. In addition, OCR worked with Regional EEO Officers to deploy
iComplaints, which allows for better tracking of complaints at the regional level. The use of
iComplaints has also assisted in improving investigation completion time as it provides readily
available information about each case and complainant.

After completing its planned activity of enhancing EEO Officer and Counselor training on
meeting deadlines, OCR determined that additional efforts in this area would benefit its
program. In April 2013, OCR overhauled its EEO Counselor training program to provide

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EPA Management Directive 715 Report

Counselors with an extensive training each month that included EEO case updates from in-
house attorneys, mock counseling experiences, and mentorship. In FY 2013, OCR also
trained and certified eleven new Counselors. These efforts have led to a 92% reduction in
untimely counseling in FY 2013. In addition, they have helped to improve efficiency of the
formal complaint process by ensuring that ECRS staff utilizes their time primarily on analysis
rather than additional fact gathering.

(Q-87) During FY 2013, OCR continued to eliminate a backlog of final agency decisions
(FADs). While in FY 2012 OCR had pending FADs that dated back to 2008, at the end of FY
2013, OCR's oldest FAD was from 2010. Moreover, OCR reduced its issuance time for
FADs by 61% between FY 2012 and FY 2013. The aforementioned Interagency Agreement
between EPA and USPS, the hiring of two in-house attorneys for OCR over the last two fiscal
years, and the use of Agency attorneys on details has enhanced OCR's ability to complete
FADs in a timely manner. The ECRS staff also received a comprehensive five-day training on
the preparation of FADs and review of Reports of Investigation.

(Q-104) EPA is committed to improving EEO complaint processing, and believes that it is
continuing to make substantial progress towards achieving this goal in FY 2013. As noted, in
2012 OCR drafted a comprehensive Standard Operating Procedure outlining complaint
procedures. The tools and resources described have helped and should continue to help in
incorporating sufficient time for legal reviews by increasing the likelihood that cases
submitted to the Office of General Counsel, Civil Rights and Finance Law Office for legal
review are thoroughly investigated, and the FADs are well-written as well as provided
sufficiently in advance of the expiration of the regulatory 60-day time requirement.

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EPA Management Directive 715 Report

Part H-3: Tracking and Analysis of Recruitment Efforts

STATEMENT OF
MODEL PROGRAM
ESSENTIAL ELEMENT
DEFICIENCY:

(Part G: Q-100) Does EPA track recruitment efforts and
analyze efforts to identify potential barriers in accordance with
MD 715 standards?

OBJECTIVE:

To create a mechanism for proactive information and
communications exchanged among EPA's national recruitment
program staff, selecting officials, organizational program
management/regional human resources staff, and leadership in
the Human Resources Shared Service Centers to shape
recruitment efforts in their early stages and help reduce barriers.
The desired goal is to focus recruitment efforts to enhance
diversity in the applicant pools.

RESPONSIBLE
OFFICIAL:

Assistant Administrator, Office of Administration & Resources
Management

Associate Assistant Administrator, Office of Diversity,
Advisory Committee Management and Outreach
Director, Office of Human Resources
Director, Office of Civil Rights

DATE OBJECTIVE
INITIATED:

November 1, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2016

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

Draft guidebook on hiring flexibilities and authorities for managers
and organizations, covering key approaches to recruitment and
selection, particularly through hiring authorities under Schedule A.

Completed
May 2011

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EPA Management Directive 715 Report

Develop "road show" presentation package to support managers'
guidebook and in-person presentations by representatives of the
recruitment staff on hiring flexibilities and approaches to managers.

Completed
January 2012

Collaborate with program management officers and regional human
resources officers on content and messaging of guidebook and "road
show."

Completed
January 2012

Finalize guidebook and launch "road show."

Completed
February 2012

The Director of Human Resources will evaluate these new practices
and make any necessary changes or modifications.

Completed
May 2012

The Office of Civil Rights will conduct a quarterly review of ongoing
MD 715 programs to strengthen Agency Accountability. (OCR)

Completed
July 2012

The Office of Human Resources and Office of Diversity Advisory
Committee Management Office will collect and analyze the
race/national origin and sex data of participants in FY 12 and first
three quarters of FY 13 Successful Leader Program.

Completed
July 2013

The Office of Human Resources will develop a process for collecting
internal Senior Executive Service applicant flow data.

March 2014

The Office of Human Resources will update the guidebook on hiring
flexibilities and authorities and ensure that the updated information is
broadly distributed to EPA selecting officials.

March 2014

The Office of Human Resources will finalize the supervisory
guidebook on selections and hiring authorities and launch in-person
presentations throughout EPA Regions and AAships.

March 2014

The Office of Civil Rights will finalize a survey to collect data related
to the use and composition of hiring/interview panels from the last
quarter of FY 12 to the first three quarters of FY 13.

March 2014

The Office of Human Resources will update the exit interview form
and process to track the motivation for employees' departure from
Agency employment.

March 2014

The Office of Human Resources will launch a Learning Management
System to track Agency employees' participation in career
development activities, including trainings, details, and e-learning to
determine whether participation in such programs impacts the

September 2014

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EPA Management Directive 715 Report

probability that individuals will apply for and qualify for senior grade
positions.

The Office of Human Resources will collect internal Senior Executive
Service applicant flow data.	

September 2014

The Office of Human Resources will evaluate the effectiveness of its
strategic recruitment plan and guidance.	

September 2015

The Office of Human Resources will circulate a report highlighting
the career development data collected in the Learning Management
System.	

September 2015

REPORT OF ACCOMPLISHMENTS AND MODIFICATIONS TO OBJECTIVE:

Since 2011, EPA has collected applicant flow data for new hires and internal promotions in
five major occupations, and the senior grades. However, FY 2013 is the first year that EPA
has collected external Senior Executive Service applicant flow data. Moreover, in July 2013,
the Office of Human Resources (OHR) collaborated with the Office of Diversity, Advisory
Committee Management, and Outreach (ODACMO) to collect race/national origin and sex
data of participants in the Successful leaders Program during FY 2012 and the first three
quarters of FY2013. ODACMO will use the data to analyze the participation rates of
race/national origin and sex groups, and determine what motivates participation in EPA's
Successful Leader Program.

EPA will soon implement several modifications to this objective to address the triggers
highlighted in its workforce data and in furtherance of EPA's effort to identify any potential
barriers to equal employment opportunity. These modifications include the following actions
which EPA will take by the end of the fourth quarter of FY 14: 1) a process for collecting
internal Senior Executive Service applicant flow data will be developed; 2) the guidebook on
hiring flexibilities and authorities will be updated and broadly distributed to EPA selecting
officials; and 3) the supervisory guidebook on selections and hiring authorities will be
finalized and in-person presentations throughout EPA Regions and AAships will be launched.

By the end of FY 14, EPA is pleased to report that: 1) a Learning Management System will be
developed to track employees' participation in career development, including trainings,
details, and e4earning; 2) internal Senior Executive Service applicant flow data will be
collected for analysis in the FY 14 MD-715 Report; 3) the effectiveness of EPA's strategic
recruitment plan and guidance will be evaluated; and 4) the exit interview form and process
will be updated to collect data concerning employees' departure from Agency employment.

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Part 1-1: New Hires

STATEMENT OF
CONDITION THAT WAS
A TRIGGER FOR A
POTENTIAL BARRIER:

Provide a brief narrative
describing the condition at
issue. How was the
condition recognized as a
potential barrier?

Data comparisons between the Relevant Civilian Labor Force
(RCLF), application, qualification, and selection rates in some
major occupations revealed instances of lower than expected
application, qualification, and/or selection rates.

BARRIER ANALYSIS:
Provide a description of the
steps taken and data
analyzed to determine
cause of the condition.

EPA reviewed the statistical data associated with new hires
(Table A7) for employees in six of its largest occupational
categories. In addition, EPA reviewed its applicant flow data
and analyses from 2011 and 2012. Although the exhaustive list
of triggers is provided in each personnel transaction section,
certain triggers were highlighted for illustrative purposes but not
because they were more important or worse than other triggers.

The seven largest occupations include 0028 Environmental
Protection Specialist, 0301 Miscellaneous Administration and
Program Specialist, 0343 Management/Program Analyst, 0401
General Biological Science (Research), 0819 Environmental
Engineer (Research), 0905 General Attorney, and 1301
Physical/Environmental Scientist (Research). Although General
Attorneys in Series 0905 constitute one of EPA's major
occupations, data could not be gathered for this job series
because of the unique characteristics that apply to the selection
process associated with excepted service positions. As
mentioned in the planned activities noted below, EPA plans to
develop a process to collect data for 0905 General Attorneys in
2014.

Application

In comparing the RCLF to the application rate, it appears that
EPA experienced a level of success in its recruitment efforts.
For instance, Black Males and Females, and Two or more Race
Males and Females, for a second year, applied for positions at
rates well above their representation in the RCLF in every major
occupation series. In FY 2013, Hispanic Males also applied for

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positions at rates above their representation in the RCLF in all
occupations.

The triggers associated with the application rates of Native
Hawaiian Males appear to have improved in FY 2013, when
they applied for positions at rates at or higher than their
representation in the RCLF in all major job occupations as
compared to FY 2012, where triggers were noted in 2 major job
occupations, 0301 Miscellaneous Administration and Program
Specialist and 0819 Environmental Engineer.

On the other hand, Hispanic Females, for the second
consecutive year, applied for positions at rates below their
representation in the RCLF in the 0301 Miscellaneous
Administration and Program Specialist occupational series,
although they applied at or above their representation in the
RCLF for all other major occupations in FY 2013.

The triggers in the application rate of White Females appear to
have increased since 2011. In FY 2011 and 2012, triggers were
noted in the application rate of White Females in 3 major
occupational series: 0301 Miscellaneous Administration and
Program Specialist, 0343 Management/Program Analyst, and
0401 General Biological Science. However, in FY 2013, White
Females applied for positions at rates lower than their
representation in the RCLF in 5 major occupational series.

For more detailed information about the specific race/national
origin and sex groups that applied for major occupation
positions at rates lower than their representation in the RCLF,
please see the following chart:

Race, National Origin and

Sex

Occupational Series

Hispanic Females

0301

White Males

0028, 0343, 0401, 0819

White Females

0028, 0301, 0343, 0401, 1301

Asian Males

0301, 0343, 1301

Asian Females

0301,0343, 0401, 1301

Native Hawaiian Females

0819

American Indian Males

0343,0401, 1301

American Indian Females

0343

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will try to determine whether an Agency policy, practice or

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EPA Management Directive 715 Report

procedure is causing certain race/national origin and sex groups
to apply for major occupation positions at rates that are less than
anticipated. EPA has planned a number of activities to address
the aforementioned triggers, which are referenced below and
include: updating the hiring flexibilities and authorities
guidebook; and evaluating the effectiveness of it strategic
recruitment plan. After these planned activities are completed,
EPA will evaluate whether they have impacted the triggers
noted above.

Qualification

EPA looked at the qualification rate for major occupations by
comparing it to the application rate of the respective population.
EPA appears to have experienced a few small successes with
qualification rates. For example, in FY 2013, the qualification
rates of Hispanic, White, and Asian Males was lower than their
application rate in less major occupations than in FY 2012.

Also, Asian Males went from having triggers noted in their
qualification rate in four major occupational series in FY 2012
to having a trigger noted in one major occupational series in FY
2013.

The qualification rates of White, Asian, and Native Hawaiian
Females were higher than their application rates in all major
occupational series except 0819 Environmental Engineer and
1301 Physical/Environmental Scientist respectively. White and
Asian Females qualification rates were higher than their
application rates in all major occupational series in FY 2012.
Similarly, in the 1301 Physical/Environmental Scientist series,
Native Hawaiian Females qualification rates were higher than
their application rates in FY 2012. Accordingly, in FY 2013,
triggers were associated with the qualification rates of White,
Asian, and Native Hawaiian Females, which were different than
those present in FY 2012.

Also, triggers have been identified in the qualification rate of
Black Males in the following five occupational series since FY
2011: 0028 Environmental Protection Specialist, 0301 Misc
Administration and Program Specialist, 0343
Management/Program Analyst, 0401 General Biological
Science, and 0819 Environmental Engineer.

For more detailed information about the specific race/national
origin and sex groups that were qualified for major occupation

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positions at rates lower than their application rates, please see
the following chart:

Race, National Origin and

Occupational Series

Sex



Hispanic Males

0028, 0301, 0343, 0401, 1301

Hispanic Females

0819

White Males

0028, 0301, 0343

White Females

0819

Black Males

0028,0301,0343, 0401,
0819, 1301

Black Females

0301, 0401, 0819

Asian Males

1301

Asian Females

0301

Native Hawaiian Males

0301, 0819

Native Hawaiian Females

1301

American Indian Males

0301, 0028, 0343, 0401, 0819,
1301

American Indian Females

0028, 0401

Two or More Race Males

0301, 0343, 0819

Two or More Race Females

0028, 0301, 0819, 1301

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will try to determine whether an Agency policy or practice
is causing certain race/national origin and sex groups to be
qualified for major occupation positions at rates that are less
than their application rate. EPA has planned a number of
activities to address the aforementioned triggers. After these
planned activities are completed, EPA will evaluate whether
they have impacted the triggers noted above.

Selection

EPA looked at the selection rate for major occupations by
comparing it to the qualification rates of the respective
population. The selection rates of Hispanic Females were
higher than their qualification rates in all major occupation
series. This is notable because triggers had been identified in
the selection rates of Hispanic Females in 3 major occupational
series in FY 2012.

In FY 2013, the selection rates of Hispanic Males were no
longer lower than their qualification rates in 0028
Environmental Protection Specialist, 0401 General Biological

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EPA Management Directive 715 Report

Science, 0819 Environmental Engineer; unlike the results of the
FY 2012 analyses.

In contrast, the 2013 selection rates of Asian Males and
Females, and Two or More Race Females were lower than their
qualification rates in every major occupation series. This
appeared to be a continuation of the FY 2012 trend, in which
triggers were associated with the selection rates of Asian Males
in every major occupational series. In FY 2013, triggers were
also noted in the selection rate of Asian and Two or More Race
Females, which were not noted in FY 2012.

Further, since FY 2011, the selection rate of Asian Females was
lower than their qualification rate in 0301 Miscellaneous
Administration and Program Specialist and 1301
Physical/Environmental Scientist.

For more detailed information about the specific race/national
origin and sex groups that were selected for major occupation
positions at rates lower than their qualification rates, please see
the following chart:

Race, National Origin and

Sex

Occupational Series

Hispanic Males

0301, 0343

White Males

0301

White Females

0819, 1301

Black Males

0028, 0301, 0401, 0819, 1301

Black Females

0343, 0401

Asian Males

0028, 0301, 0343, 0401, 0819,
1301

Asian Females

0028, 0301, 0343, 0401, 0819,
1301

Native Hawaiian Males

0028, 0301, 0401, 0819, 1301

Native Hawaiian Females

0028, 0301, 0343

American Indian Males

0028, 0301, 0343, 0819, 1301

American Indian Females

0301, 0343, 0401, 0819, 1301

Two or More Race Males

0028, 0401, 0819, 1301

Two or More Race Females

0028, 0301, 0343, 0401, 0819,
1301

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will try to determine whether an Agency policy or practice
is causing certain race/national origin and sex groups selected
for major occupation positions at rates that are less than their

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qualification rate. EPA has planned a number of activities to
address the aforementioned triggers, which are detailed below
and include tracking the use of hiring/interview panels to
increase their prevalence throughout EPA. After these planned
activities are completed, EPA will evaluate whether they have
impacted the triggers noted above.

STATEMENT OF
IDENTIFIED BARRIER:
Provide a succinct
statement of EPA policy,
procedure or practice that
has been determined to be
the barrier of the undesired
condition.

At this time, EPA continues to investigate whether any specific
policy, practice, or procedure is causing any of the identified
lower than expected participation rates. In FY 2013, EPA
implemented the following planned activities to determine what
may have caused the less than anticipated application,
qualification, and selection rates: 1) created a formal diversity
and inclusion council with visible leadership involvement to
ensure implementation of the Diversity and Inclusion Strategic
Plan; 2) created a list of diverse recruiting sources so that EPA
job announcements published on USAJobs would be sent to
them; and 3) compiled and posted a list of EPA's Memorandum
Of Understanding with MAIs, to provide greater transparency
and better leverage the MAI partnerships. The improvement in
the application rate of Hispanic Males; the qualification rate of
Asian Males; and the selection rate of Hispanic Females may
possibly be the result of EPA's FY 2013 planned activities.

Nonetheless, EPA's application, qualification, and selection
rates suggest that it should closely examine: 1) its outreach and
recruitment policies, practices and procedures for the 0343
Management/Program Analyst occupational series to determine
whether any agency policy, practice or procedure is causing
certain race/national origin and sex groups not to apply; 2) its
qualification policies and practices for the 0301 Miscellaneous
Administration and Program Specialist and 0401 General
Biological Science to determine whether any agency policy,
practice or procedure is causing certain race/national origin and
sex groups not to be found qualified for these positions; and 3)
its selection policies and practices for all major occupational
series to determine whether any agency policy, practice or
procedure is causing certain race/national origin and sex groups
not to be selected for positions.

OBJECTIVE:

State the alternative or
revised Agency policy,
procedure or practice to be
implemented to correct the
undesired condition.

EPA will continue its analysis of the hiring process, including
recruitment, qualification and selection, associated with the
above-identified lower than expected participation rates for
several occupational series.

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RESPONSIBLE
OFFICIAL:

Director of Office of Diversity, Advisory Committee
Management and Outreach Management and Outreach
Director of Human Resources
Director of Office of Civil Rights
Deputy Civil Rights Officials

DATE OBJECTIVE
INITIATED:

February 15, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2015

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

The Office of Human Resources will implement its plan to market the
creation and benefits of individual development plans to employees
and supervisors.

Completed
February 2013

Create a formal diversity and inclusion council with visible leadership
involvement to ensure implementation of the Diversity and Inclusion
Strategic Plan.

Completed
July 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile a list of diverse recruiting sources for Shared
Service Centers to send copies of EPA job announcements published
on USAJobs.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile and post a list of EPA's Memorandum Of
Understanding with MAIs, to provide greater transparency and better
leverage the MAI partnerships.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach in consultation with Senior Management will complete a
Diversity Roadmap which will set forth timelines, action items, and

Completed
October 2013

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EPA Management Directive 715 Report

specific deliverables based on the Diversity and Inclusion Strategic
Plan.



The Office of Human Resources will utilize two surveys to establish
baseline data going back through FY 2012 that captures: 1) EPA
hiring managers' satisfaction with selected applicants (survey
instrument: OPM Chief Human Capital Officer's 6-Month
Management Hiring Satisfaction Survey); and 2) Satisfaction of EPA
new hires with their new positions (survey instrument: components of
the existing EPA New Hire Survey).

Completed
November 2013

The Office of Diversity, Advisory Committee Management and
Outreach will issue Agency-wide guidance on using the Dashboard.

Completed
December 2013

The Office of Civil Rights will finalize a survey to collect data related
to the use and composition of hiring/interview panels from the last
quarter of FY 12 to the first three quarters of FY 13.

June 2014

Support a "One Great Place to Work Initiative" committing EPA to
foster a work environment that nurtures and advances the talents,
drive, and interests of all employees. This campaign is built around
three principal areas: Supportive Work Environments, Professional
Development, and Benefits and Amenities.

March 2014

The Office of Human Resources will update the guidebook on hiring
flexibilities and authorities and ensure that the updated information is
broadly distributed to EPA selecting officials.

March 2014

The Office of Human Resources will update and finalize the
guidebook on hiring flexibilities and authorities, ensure that the
updated information is broadly distributed to EPA selecting officials,
and launch in-person presentations throughout EPA Regions and
AAships.

March 2014

Office of Civil Rights and Office of Human Resources will evaluate
the data from the Management Hiring Satisfaction Survey to
determine whether there are any procedural barriers associated with
the development of vacancy announcements and outreach efforts.

August 2014

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The Office of Administration and Resources Management will
provide Agency-wide SEPM training to enhance proficiency in
furthering diversity, inclusion and equal employment opportunities.

June 2014

The Office of Diversity, Advisory Committee Management and
Outreach will develop a targeted outreach strategy detailing Agency-
wide outreach efforts for developmental opportunities.

June 2014

The Office of Diversity, Advisory Committee Management and
Outreach will revise the Diversity Dashboard to use datasets
consistent with those used in the MD-715 report in order to increase
the utilization of the Diversity Dashboard in developing and
monitoring the effectiveness of targeted outreach strategies.

June 2014

The Office of Human Resources and Office of Civil Rights will
analyze: 1) EPA's recruitment policies and practices for the 0301
Miscellaneous Administration and Program Specialist, 0343
Management/Program Analyst, 0401 General Biological Science,
0819 Environmental Engineer, and 1031 Physical
Scientist/Environmental Scientist occupational series to determine
whether any agency policy, practice or procedures is causing some
individuals not to apply for positions; 2) its qualification policies and
practices for all major occupational series to determine whether any
agency policy, practice or procedure is causing the triggers
associated with the qualification rates; and 3) its selection policies
and practices for all major occupational series to determine whether
any agency policy, practice or procedure is causing the triggers
associate with the selection rates.

August 2014

The Office of the Director of Human Resources will develop, in
coordination with the Associate Assistant Administrator for
Diversity, Outreach and Collaboration, Director of Office of Civil
Right and the Office of General Counsel, a strategic recruitment plan
and guidance document, which will be disseminated to all supervisors
in EPA.

September 2014

The Office of Civil Rights will collaborate with the Office of
Enforcement and Compliance Assurance, Office of General Counsel,
and Office of Human Resources to create a process to collect, retain,
and analyze applicant flow data for Series 0905 Attorney positions.

December 2014

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EPA Management Directive 715 Report

EPA will evaluate the effectiveness of it strategic recruitment plan
and guidance document and make necessary modifications or
changes.

September 2015

Report of Accomplishments and Modifications to Objective

Despite the impact the FY 2013 budget constraints had on the hiring in EPA's major
occupational series, EPA is pleased to report some improvements in the application,
qualification, and selection rates of certain race/national origin and sex groups were
accomplished. In particular, the triggers noted in the application rates of Hispanic Males and
the selection rates of Hispanic Females diminished in FY 2013. EPA believes that these
improvements may be the result of its completion of several FY 2013 planned activities.

In July 2013, the Office of Administration and Resources Management (OARM) created the
Diversity and Inclusion Advisory Committee (DIAC), a formal diversity and inclusion council
with visible leadership involvement to ensure that the Diversity and Inclusion Strategic Plan is
implemented. In September 2013, the Office of Diversity, Advisory Committee Management
and Outreach (ODACMO) provided EPA employees with the opportunity to update their race
and national origin information. By increasing the accuracy of employee race and national
origin information, this effort improved the quality of the data necessary to determine whether
barriers exist to equal employment opportunity in the hiring of new employees.

In addition, ODACMO and Shared Service Centers collaboratively created a list of diverse
recruiting sources so that EPA job announcements published on USAJobs would be sent to
them. The goal is to create a Standard Operating Procedure (SOP), which requires Shared
Service Centers to provide every EPA vacancy announcement to diverse recruiting sources.
Likewise, ODACMO compiled and posted a list of EPA's Memorandum Of Understanding
with MAIs, to improve the utilization of Minority Academic Institutions (MAIs) partnerships.

For example, EPA routinely provides job announcements to North Carolina Central University
and in FY 2013, it hosted a: 1) networking event at City College of New York, a Hispanic-
Serving Institution; and 2) career fair for the National Society of Black Engineers and the
American Indian Society of Engineers and Scientists.

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PART 1-2: Promotions

STATEMENT OF
CONDITION THAT WAS
A TRIGGER FOR A
POTENTIAL BARRIER:

Provide a brief narrative
describing the condition at
issue. How was the
condition recognized as a
potential barrier?

Data comparisons between the application, qualification, and
selection rates for internal competitive promotions in some
major occupations revealed instances of lower than expected
application, qualification, and/or selection rates.

BARRIER ANALYSIS:

Provide a description of the
steps taken and data
analyzed to determine
cause of the condition.

In light of this trigger, EPA reviewed the statistical data
associated with internal promotions (Table A9) for employees in
six of EPA's largest occupational categories. In addition, EPA
reviewed its applicant flow data and analysis from 2011 and
2012. Although the exhaustive list of triggers is provided in
each personnel transaction section, certain triggers were
highlighted for illustrative purposes but not because they were
more important or worse than other triggers.

The seven largest occupations include 0028 Environmental
Protection Specialist, 0301 Miscellaneous Administration and
Program Specialist, 0343 Management/Program Analyst, 0401
General Biological Science (Research), 0819 Environmental
Engineer (Research), 0905 General Attorney, and 1301
Physical/Environmental Scientist (Research). Although General
Attorneys in Series 0905 constitute one of EPA's major
occupations, data could not be gathered for this job series
because of the unique characteristics that apply to the selection
process associated with excepted service positions. As
mentioned in the planned activities noted below, EPA plans to
develop a process to collect data for 0905 General Attorneys in
2014.

Application

EPA looked at participation rates of groups in major
occupations by race, national origin, and sex (Table A6) to the
representation of applicants for internal competitive promotions
(Table A9). EPA recognizes that not every person in a major
occupation may actually apply for an internal competitive

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EPA Management Directive 715 Report

promotion, but EPA elected to use this as a proxy for the
application rate, for purposes of this report only.

In FY 2013, White Males internal promotion application rate is
lower than their participation rate in only one major
occupational series, which is a significant improvement from
FY 2012. Likewise, in FY 2013, fewer triggers were identified
in the application rates of White Females, Black Males and
Females, Asian Females, and Native Hawaiian Females than in
FY 2012.

However, in FY 2013, triggers were noted in the application
rates of Hispanic Males and Females, and American Indian
Males in the following occupational series: 1301 Physical
Scientist and 0401 General Biologist, which were not present in
FY 2013 when these race/national origin and sex groups
experienced no triggers in any occupational series.

For more detailed information about the specific race/national
origin and sex groups that applied for internal promotions at
rates lower than their representation in the relevant occupations
please see the following chart:

Race, National Origin and

Sex

Occupational Series

Hispanic Males

1301

Hispanic Females

1301

White Males

0819

White Females

0028, 0301,0343,0401,1301

Black Males

0819, 1301

Black Females

0028, 0301, 0343, 0819, 1301

Asian Males

0343, 0819, 1301

Asian Females

0301,0401,0819

Native Hawaiian Males

0301, 0401

Native Hawaiian Females

0028, 0819, 1301

American Indian Males

0401

American Indian Females

0028, 0343, 0401, 0819, 1301

Two or More Race Males

1301

Two or More Race Females

0401

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will determine whether an Agency policy, practice or
procedure is causing certain race/national origin and sex groups
to apply for promotions in major occupations at rates that are
less than anticipated. EPA has planned a number of activities to

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EPA Management Directive 715 Report



address the aforementioned triggers, which are detailed below
and include marketing the creation and benefits of individual
development plans to employees and supervisors. After these
planned activities are completed, EPA will evaluate whether
they have impacted the triggers noted above.



Qualification





EPA looked at the qualification rate for internal promotions by
comparing it to the application rates of the respective
population. EPA experienced a few small successes in the
qualification rates for major occupational series. For instance,
in FY 2013, the qualification rates of Hispanic Females and
American Indian Males was lower than their application rates in
less major occupations than in FY 2012. Similarly, triggers
associated with the qualification rates of Hispanic Females
decreased from being present in three major occupational series
in FY 2012 to one major occupational series in FY 2013.



However, the qualification rates of Hispanic and Black males,
and Two or More Race Females were lower than their
application rates in every major occupation series. Although the
same trigger was associated with Hispanic Males in FY 2012,
neither Black Males nor Two or More Race Females had
qualification rates that were lower than their application rates in
every major occupation series in FY 2012.



For more detailed information about the specific race/national
origin and sex groups that are qualified for major occupation
positions at rates lower than their application rates, please see
the following chart:





Race, National Origin and

Sex

Occupational Series







Hispanic Males

0028, 0301,0343, 0401, 0819,
1301







Hispanic Females

0401







White Males

0028, 0301,0343, 0401, 0819







Black Males

0028, 0301,0343, 0401, 0819,
1301







Black Females

0028, 0401, 0819







Asian Males

0301, 0343, 0819, 1301







Asian Females

0401, 1301







Native Hawaiian Males

0343, 0819







Native Hawaiian Females

0028







American Indian Males

0301, 0819

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American Indian Females
Two or More Race Males
Two or More Race Females

0301, 0343, 0401	

0028, 0301,0343, 0401
0028, 0301,0343, 0401, 0819,
1301

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will determine whether an Agency policy or practice is
causing certain race/national origin and sex groups to be
deemed qualified for major occupation internal promotions at
rates that are less than their application rate. EPA has planned a
number of activities to address the aforementioned triggers.
These activities are referenced below and include conducting
SEPM training to enhance proficiency in furthering diversity,
inclusion and equal employment opportunities. After these
planned activities are completed, EPA will evaluate whether
they have impacted the triggers noted above.

Selection

EPA looked at the selection rate for internal promotions by
comparing it to the qualification rates of the respective
population. EPA experienced a few small successes with
selection rates. Specifically, in FY 2013, triggers were
associated with the selection rates of Hispanic Males and
Females, and Black Females in less major occupational series
than in FY 2012. In particular, the amount of triggers noted for
Hispanic and Black Females was nearly cut in half from FY
2012 to 2013.

However, the triggers associated with the selection rates of
Black Males, Asian Females, Native Hawaiian Males and
Females, American Indian Males and Females, and Two or
More Race Males appears to have increased. In FY 2013, the
selection rates of Black Males, Asian Females, Native Hawaiian
Males and Females, American Indian Males and Females, and
Two or More Race Males were lower than their qualification
rates in more major occupational series than in FY 2012.
Moreover, in FY 2011, no triggers were noted in the selection
rates of Native Hawaiian Males and Females.

For more detailed information about the specific race/national
origin and sex groups that are selected for major occupation
positions at rates lower than their qualification rates, please see
the following chart:

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EPA Management Directive 715 Report



Race, National Origin and

Sex

Occupational Series

Hispanic Males

0301. 0343

Hispanic Females

0028, 0301

White Males

0028,0343, 0401, 1301

White Females

0301, 0819, 1301

Black Males

0028, 0301,0401,0819

Black Females

0343

Asian Males

0028,0301, 0401, 0819

Asian Females

0028, 0301, 0343, 0819, 1301

Native Hawaiian Males

0028, 0819

Native Hawaiian Females

0301

American Indian Males

0028, 1301

American Indian Females

0401

Two or More Race Males

0028, 0301, 0343, 0401,0819

Two or More Race Females

0028, 0301, 0343, 0401, 0819

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will determine whether an Agency policy or practice is
causing certain race/national origin and sex groups to be
selected for major occupation internal promotions at rates that
are less than their qualification rate. EPA has planned a number
of activities to address the aforementioned triggers; these
activities are referenced below and include creating a survey to
evaluate the use of hiring/interview panels. After these planned
activities are completed, EPA will evaluate whether they have
impacted the triggers noted above.

STATEMENT OF
IDENTIFIED BARRIER:

Provide a succinct
statement of EPA policy,
procedure or practice that
has been determined to be
the barrier of the undesired
condition.

At this time, EPA continues to evaluate whether any specific
Agency policy, practice, or procedure is causing any of the
identified lower than expected participation rates. In FY 2013,
EPA implemented several planned activities to examine whether
a barrier to equal employment opportunity existed including: 1)
implemented its plan to market the creation and benefits of
individual development plans to employees and supervisors; 2)
created a formal diversity and inclusion council with visible
leadership involvement to ensure implementation of the
Diversity and Inclusion Strategic Plan; 3) compiled a list of
diverse recruiting sources for Shared Service Centers to send
copies of EPA job announcements published on USAJobs; 4)
compiled and posted a list of EPA's Memorandum Of
Understanding with MAIs to better leverage the MAI
partnerships; and 5) created an electronic repository of EPA

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EPA Management Directive 715 Report



mentorship programs. The improvement in the application,
qualification, and selection rates of White Males, and Hispanic
and Black Females in certain major occupational series may be
the result of EPA's FY 2013 planned activities.



Nonetheless, EPA's application, qualification, and selection
rates suggest that it should closely examine: 1) its policies,
practices, and procedures related to internal announcements of
occupational series to determine whether any Agency action is
causing the lower than expected application rates; and 2) its
hiring policies, practices, and procedures for all major
occupational series to determine whether any Agency action is
causing the lower qualification and selection rates.

OBJECTIVE:

State the alternative or
revised Agency policy,
procedure or practice to be
implemented to correct the
undesired condition.

EPA will continue its analysis of the application, qualification
and selection policies and practices associated with the above-
identified lower than expected qualification and selection rates
for several occupational series.

RESPONSIBLE
OFFICIAL:

Director of Office of Diversity, Advisory Committee

Management and Outreach

Director of Human Resources

Director of Office of Civil Rights

Deputy Civil Rights Officials

DATE OBJECTIVE
INITIATED:

February 15, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2015

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

The Office of Human Resources will implement its plan to market the
creation and benefits of individual development plans to employees
and supervisors.

Completed
February 2013

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EPA Management Directive 715 Report





Create a formal diversity and inclusion council with visible leadership
involvement to ensure implementation of the Diversity and Inclusion
Strategic Plan.

Completed
July 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile a list of diverse recruiting sources to which
Shared Service Centers will send copies of EPA job announcements
published on USAJobs.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile and post a list of EPA's Memorandum Of
Understanding with MAIs, to better leverage the MAI partnerships.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach will create an electronic repository of EPA mentorship
programs.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach in consultation with Senior Management will complete a
Diversity Roadmap which will set forth timelines, action items, and
specific deliverables based on the Diversity and Inclusion Strategic
Plan.

Completed
October 2013

The Office of Diversity, Advisory Committee Management and
Outreach will issue Agency-wide guidance on using the Dashboard.

Completed
December 2013

The Office of Civil Rights will finalize a survey to collect data related
to the use and composition of hiring/interview panels from the last
quarter of FY 12 to the first three quarters of FY 13.

June 2014

Support a "One Great Place to Work Initiative" committing EPA to
foster a work environment that nurtures and advances the talents,
drive, and interests of all employees. This campaign is built around
three principal areas: Supportive Work Environments, Professional
Development, and Benefits and Amenities.

March 2014

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EPA Management Directive 715 Report

The Office of Human Resources will update the guidebook on hiring
flexibilities and authorities and ensure that the updated information is
broadly distributed to EPA selecting officials.

March 2014

The Office of Human Resources will update and finalize the
guidebook on hiring flexibilities and authorities, ensure that the
updated information is broadly distributed to EPA selecting officials,
and launch in-person presentations throughout EPA Regions and
AAships.

March 2014

Office of Civil Rights and Office of Human Resources will evaluate
the data from the Management Hiring Satisfaction Survey to
determine whether there are any procedural barriers associated with
the development of vacancy announcements and outreach efforts.

August 2014

The Office of Administration and Resources Management will
provide Agency-wide SEPM training to enhance proficiency in
furthering diversity, inclusion and equal employment opportunities.

June 2014

The Office of Diversity, Advisory Committee Management and
Outreach will develop a targeted outreach strategy detailing Agency-
wide outreach efforts for developmental opportunities.

June 2014

The Office of Human Resources and Office of Civil Rights will
analyze: 1) its recruitment policies, practices, and procedures for the
0301 Miscellaneous Administration and Program Specialist, 0343
Management/Program Analyst, 0401 General Biological Science,
0819 Environmental Engineer, and 1031 Physical
Scientist/Environmental Scientist occupational series to determine
whether they are causing the triggers; 2) its qualification policies and
practices for all major occupational series to determine whether they
are causing the triggers; and 3) its selection policies and practices for
all major occupational series to determine whether they are causing
the triggers.

August 2014

The Office of the Director of Human Resources will develop, in
coordination with the Associate Assistant Administrator for
Diversity, Outreach and Collaboration, Director of Office of Civil
Right and the Office of General Counsel, a strategic recruitment plan

September 2014

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EPA Management Directive 715 Report

and guidance document, which will be disseminated to all supervisors
in EPA.



The Office of Civil Rights will collaborate with the Office of
Enforcement and Compliance Assurance, Office of General Counsel,
and Office of Human Resources to create a process to collect, retain,
and analyze applicant flow data for Series 0905 Attorney positions.

December 2014

The Office of Civil Rights will collaborate with the Office of Human
Resources to analyze whether any agency policy, practice or
procedure related to internal competitive promotions is causing: 1)
lower than expected application rates; 2) lower than expected
qualification rates; and 3) lower than expected selection rates.

December 2014

EPA will evaluate the effectiveness of it strategic recruitment plan
and guidance document and make necessary modifications or
changes.

September 2015

Report of Accomplishments and Modifications to Objective

EPA is pleased to report that it accomplished some improvements in the application,
qualification, and selection rates of certain race/national origin and sex groups in FY 2013. In
particular, the triggers noted in the application rates of White Males, qualification rates of
Hispanic Females, and selection rates of Hispanic and Black Females diminished in FY 2013.
EPA believes that these improvements may be the result of its completion of several FY 2013
planned activities.

The Office of Diversity, Advisory Committee Management and Outreach (ODACMO)
embarked on major initiatives: to increase the availability and access to career development
opportunities; and leverage EPA's cadre of SEPMs to advance EPA's workplace Diversity and
Inclusion (D&I).

In July 2013, the Office of Human Resources (OHR) and ODACMO collected and analyzed
the race/national origin and sex data of participants in FY 12 and first three quarters of FY 13
Successful Leader Program, which allows every new supervisor to engage in a full year of
development activities designed to enhance their skills and help them transition successfully
into their new leadership roles. This analysis of participants in the Successful Leader Program
will enable EPA to determine whether barriers exist regarding the policies, practices and
procedures associated with these programs.

In February and July 2013, the OHR offered Individual Development Plan training, which
provided tools for: 1) identifying individual competency strengths and possible areas for

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EPA Management Directive 715 Report

improvement; 2) building an effective development plan; 3) identifying your support
networks; 4) identifying various development activities for to support skill building; and 5)
discovering sources to obtain honest and objective feedback.

In July 2013, The Office of Administration and Resources Management (OARM) created the
Diversity and Inclusion Advisory Committee (DIAC), a formal diversity and inclusion council
with visible leadership involvement to ensure implementation of the Diversity and Inclusion
Strategic Plan. EPA believes that the DIAC will act as a strong platform of engagement on
diversity and inclusion initiatives impacting EPA.

In September 2013, ODACMO provided EPA employees with the opportunity to update their
race and national origin information. By increasing the accuracy of employee race and
national origin information, this effort improved EPA's ability to determine whether barriers
exist to equal employment opportunity in the Senior Grades.

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EPA Management Directive 715 Report

PART 1-3: Senior Grades

STATEMENT OF
CONDITION THAT WAS
A TRIGGER FOR A
POTENTIAL BARRIER:

Provide a brief narrative
describing the condition at
issue. How was the
condition recognized as a
potential barrier?

Data comparisons between the respective feeder pools (one
grade below the grade being analyzed), application,
qualification, and selection rates revealed instances of lower
than expected application, qualification and/or selection rates.

BARRIER ANALYSIS:

Provide a description of the
steps taken and data
analyzed to determine cause
of the condition.

EPA reviewed the statistical data associated with Internal
Selections for Senior Level Positions (Table A11). EPA
analyzed feeder pool information from Chart A4. Although the
exhaustive list of triggers is provided in each personnel
transaction section, certain triggers were highlighted for
illustrative purposes but not because they were more important
or worse than other triggers.

Application

EPA looked at the application rates for Senior Grade positions
(GS 13, GS 14, and GS 15) by comparing them to the
participation rate of the respective population at the next lower
grade (e.g. the feeder pool for GS 13 Hispanic Females is their
overall representation at the GS 12 level, which is a proxy for
the application rates associated with applicant flow data and is
used for purposes of this report only).

The good news is that Hispanic Males, Black Males, Native
Hawaiian Males, American Indian Males, Two or More Races
Males and Females apply for positions in numbers that exceed
their representation in the feeder pool.

In addition, White Males are applying for positions at the GS-
13 and GS-14 levels in numbers above their representation in
the feeder pool. Likewise, Hispanic and Native Hawaiian
Females are applying for positions at the GS-14 and 15 levels
in numbers above their representation in the feeder pool.

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EPA Management Directive 715 Report

However, the data suggests that several groups of Females
apply for positions in numbers less than their representation in
feeder pools, particularly at the GS-13 and GS-14 levels. This
trend was also evident in the workforce data collected in FY
2011 and 2012, where triggers were identified for Females of
all race/national origin groups.

For more detailed information about the specific race/national
origin and sex groups that applied for Senior Grade positions at
rates lower than their representation in the relevant feeder pool,
please see the following chart:

Race, National Origin and

Grades

Sex



Hispanic Females

GS 13

White Males

GS 15

White Females

GS 13, GS 14, GS 15

Black Females

GS 13, GS 14, GS 15

Asian Males

GS 14, GS 15

Asian Females

GS 13, GS 14, GS 15

Native Hawaiian Females

GS 13, GS 14, GS 15

American Indian Females

GS 13, GS 14, GS 15

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will evaluate whether any Agency policy, practice, or
procedure is causing the lower than expected application rates
for Senior Grade positions. EPA has planned a number of
activities to address the triggers referenced below, which
includes creating a targeted outreach strategy for
developmental opportunities. After these planned activities are
completed, EPA will evaluate whether they have impacted the
triggers noted above.

Qualification

EPA looked at the qualification rates for Senior Grade
positions (GS 13, GS 14, and GS 15) by comparing them to the
application rates.

Although White, Asian and American Indian Females are
qualified for GS 13, GS 14, and GS 15 positions at numbers
that exceed their representation in the feeder pool, triggers are
associated with the qualification rate of every other
race/national origin and sex group in at least one grade level.

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EPA Management Directive 715 Report

In particular, Males are qualified for positions in numbers less
than their representation in the feeder pools at the GS-13 and
GS-15 levels. At the GS-13 level, this trend was also evident
in FY 11 and 12, where triggers were identified for Hispanic,
White, Black, American Indian, and Two or More Race Males.

For more detailed information about the specific race/national
origin and sex groups that were found qualified at levels below
their respective application rates, please see the following
chart:

Race, National Origin and

Grades

Sex



Hispanic Males

GS 13, GS 14, GS 15

Hispanic Females

GS 14

White Males

GS 13,GS 15

Black Males

GS 13, GS 14, GS 15

Black Females

GS 14

Asian Males

GS 13

Native Hawaiian Males

GS 15

Native Hawaiian Females

GS 14

American Indian Males

GS 13, GS 14 GS 15

Two or More Race Males

GS 13, GS 14

Two or More Race Females

GS 13 and GS 15

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will continue evaluating whether an Agency policy
practice or procedure is causing certain race/national origin and
sex groups to be qualified for Senior Grade positions at rates
that are less than anticipated. EPA has planned a number of
activities to address the aforementioned triggers, which are
referenced below and include providing training to employees
about how to market and brand their professional skills and
experience. After these planned activities are completed, EPA
will evaluate whether they have impacted the triggers noted
above.

Selection

EPA looked at the selection rate for Senior Grade positions
(GS 13, GS 14, and GS 15) by comparing them to qualification
rate

Although White Males are selected for GS 13, GS 14, and GS
15 positions at numbers that exceed their representation in the

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EPA Management Directive 715 Report

feeder pool, triggers are associated with the selection rate of
every other group in at least one grade level.

In the case of Asian Females, the selection rate is less than
their qualification rate at every Senior Grade level. In FY
2012, Asian Females were also noted as having triggers
associated with their selection rate at every Senior Grade level.

Triggers were also associated with the selection rates of Black,
Asian, American Indian, and Two or More Race Males at two
Senior Grade levels in FY 2013.

For more detailed information about the specific race/national
origin and sex groups that were selected at levels below their
respective qualification rates, please see the following chart:

Race, National Origin and

Grades

Sex



Hispanic Males

GS 15

Hispanic Females

GS 14, GS 15

White Females

GS 13

Black Males

GS 13, GS 14

Black Females

GS 15

Asian Males

GS 14, GS 15

Asian Females

GS 13, GS 14, GS 15

Native Hawaiian Males

GS 13, GS 14

Native Hawaiian Females

GS 15

American Indian Males

GS 14, GS 15

American Indian Females

GS 13

Two or More Race Males

GS 14, GS 15

Two or More Race Females

GS 13, GS 14

In light of this data, EPA will continue to examine whether
barriers to equal employment opportunity exist. In particular,
EPA will evaluate whether any Agency policy, practice or
procedure is causing certain race/national origin and sex
groups to be selected for Senior Grade positions at rates that
are less than anticipated. EPA has planned a number of
activities to address the aforementioned triggers, which are
referenced below and include circulating updated information
about hiring authorities and flexibilities. After these planned
activities are completed, EPA will evaluate whether they have
impacted the triggers noted above.

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EPA Management Directive 715 Report

STATEMENT OF
IDENTIFIED BARRIER:

Provide a succinct statement
of EPA policy, procedure or
practice that has been
determined to be the barrier
of the undesired condition.

At this time, it is not possible to identify a specific policy,
practice or procedure which may be causing any of the
identified lower than expected participation rates. However,
the data suggests that EPA should more closely examine: 1) its
career development opportunities to determine whether they
impact the ability of certain groups to compete for Senior
grades; 2) its hiring process and practices for all Senior Grade
positions to determine whether an Agency action is causing the
triggers associated with applications, qualifications, and
selections.

OBJECTIVE:

State the alternative or
revised Agency policy,
procedure or practice to be
implemented to correct the
undesired condition.

EPA will continue its analysis of the application, qualification,
and selection process for Senior Grade positions associated
with the above-identified lower than expected participation
rates.

RESPONSIBLE
OFFICIAL:

Director of Office of Civil Rights

Director of Office of Diversity, Advisory Committee

Management, and Outreach

Director of Human Resources

Deputy Civil Rights Officials

DATE OBJECTIVE
INITIATED:

February 15, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2016

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EPA Management Directive 715 Report

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

The Office of Human Resources will implement its plan to market the
creation and benefits of individual development plans to employees
and supervisors.

Completed
February 2013

Create a formal diversity and inclusion committee with visible
leadership involvement to ensure implementation of the Diversity and
Inclusion Strategic Plan.

Completed
July 2013

The Office of Human Resources and Office of Diversity Advisory
Committee Management Office will collect and analyze the
race/national origin and sex data of participants in FY 12 and first
three quarters of FY 13 Successful Leader Program.

Completed
July 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile a list of diverse recruiting sources for Shared
Service Centers to send copies of EPA job announcements published
on USAJobs.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach will compile and post a list of EPA's Memorandum Of
Understanding with MAIs, to better leverage the MAI partnerships.

Completed
September 2013

The Office of Diversity, Advisory Committee Management and
Outreach will create an electronic repository of EPA mentorship
programs.

Completed
September 2013

The Office of Human Resources will utilize two surveys to establish
baseline data going back through FY 2012 that captures: 1) EPA hiring
managers' satisfaction with selected applicants (survey instrument:
OPM Chief Human Capital Officer's 6-Month Management Hiring
Satisfaction Survey); and 2) Satisfaction of EPA new hires with their
new positions (survey instrument: components of the existing EPA
New Hire Survey).

Completed
November 2013

The Office of Diversity, Advisory Committee Management and
Outreach in consultation with Senior Management will complete a

Completed
October 2013

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EPA Management Directive 715 Report

Diversity Roadmap which will set forth timelines, action items, and
specific deliverables based on the Diversity and Inclusion Strategic
Plan.



Support a "One Great Place to Work Initiative" committing EPA to
foster a work environment that nurtures and advances the talents,
drive, and interests of all employees. This campaign is built around
three principal areas: Supportive Work Environments, Professional
Development, and Benefits and Amenities.

March 2014

The Office of Human Resources will update and finalize the
guidebook on hiring flexibilities and authorities, ensure that the
updated information is broadly distributed to EPA selecting officials,
and launch in-person presentations throughout EPA Regions and
AAships.

March 2014

Office of Civil Rights and Office of Human Resources will evaluate
the data from the Management Hiring Satisfaction Survey to determine
whether there are any procedural barriers associated with the
development of vacancy announcements and outreach efforts.

June 2014

The Office of Diversity, Advisory Committee Management and
Outreach will develop a targeted outreach strategy detailing Agency-
wide outreach efforts for career developmental opportunities.

June 2014

The Office of Human Resources will launch a Learning Management
System to track Agency employees' participation in career
development activities, including trainings, details, and e-learning.

September 2014

The Office of the Director of Human Resources will develop, in
coordination with the Associate Assistant Administrator for Diversity,
Outreach and Collaboration, Director of Office of Civil Right and the
Office of General Counsel, a strategic recruitment plan and guidance
document, which will be disseminated to all supervisors in EPA.

September 2014

EPA will evaluate the effectiveness of it strategic recruitment plan and
guidance document and make necessary modifications or changes.

September 2015

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EPA Management Directive 715 Report

The Office of Human Resources will circulate a report highlighting the
career development data collected in the Learning Management
System.

September 2016

Report of Accomplishments and Modifications to Objective

Although EPA's budget constraints impacted hiring for the Senior Grades, it provided us with
the foundation to primarily focus on enhancing career development programs, which will
provide employees with the opportunity to obtain the information and develop the
competencies needed to apply, qualify, and be selected for Senior Grade positions. It is EPA's
belief that this effort will facilitate the workforce's continued growth and advancement.

In February and July 2013, the Office of Human Resources (OHR) offered Individual
Development Plan training, which provided tools for: 1) identifying individual competency
strengths and possible areas for improvement; 2) building an effective development plan; 3)
identifying your support networks; 4) identifying various development activities for to support
skill building; and 5) discovering sources to obtain honest and objective feedback.

In July 2013, the Office of Administration and Resources Management (OARM) created the
Diversity and Inclusion Advisory Committee (DIAC), a formal diversity and inclusion council
with visible leadership involvement to ensure implementation of the Diversity and Inclusion
Strategic Plan. In July 2013, the Office of Human Resources and Office of Diversity,

Advisory Committee Management and Outreach (ODACMO) collected and analyzed the
race/national origin and sex data of participants in FY 12 and first three quarters of FY 13
Successful Leader Program. The Successful Leader Program allows every new supervisor to
engage in a full year of development activities designed to enhance their skills and help them
transition successfully into their new leadership roles.

In September 2013, ODACMO provided EPA employees with the opportunity to update their
race and national origin information. By increasing the accuracy of employee race and
national origin information, this effort improved EPA's ability to determine whether barriers
exist to equal employment opportunity in the Senior Grades. In addition, ODACMO and
Shared Service Centers collaboratively created a list of diverse recruiting sources so that EPA
job announcements published on USAJobs would be sent to them. The goal is to create a
Standard Operating Procedure (SOP), which requires Shared Service Centers to provide every
EPA vacancy announcement to diverse recruiting sources. Likewise, ODACMO compiled and
posted a list of EPA's Memorandum Of Understanding with MAIs, to better leverage the MAI
partnerships.

In FY 2013, there were several initiatives implemented throughout the Agency that were
designed to better prepare the existing workforce to fill Senior Grade positions. What follows
are illustrative examples of such efforts: 1) OHR hiring managers and new hires evaluated their
satisfaction with the hiring process, including the on-boarding process; 2) the Office of the
Administrator (AO), under the guidance of the Office of Executive Services (PES), provided

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EPA Management Directive 715 Report

several detail opportunities outside AO; 3) the Region 8, Older Worker Program (OWP)
collaborated with the EEO Manager and the Emerging Leaders Network (ELN) to streamline
the Cross-Generational Communication Training to develop and launch the "Knowledge
Transfer Initiative" to share institutional knowledge within Region 8; 4) the Office of Air and
Radiation (OAR) and the Office of Radiation and Indoor Air (ORIA) sponsored a series of
seven Leadership Learning sessions for its Center Directors, including a session on "Valuing
Diversity and Inclusion; and 5)ORIA offered formal and informal opportunities, including an
internal "Leadership Coach," for its management team to learn and discuss issues related to
developing strong "leadership team."

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PART 1-4: Senior Executive Service

STATEMENT OF
CONDITION THAT WAS
A TRIGGER FOR A
POTENTIAL BARRIER:

Provide a brief narrative
describing the condition at
issue. How was the
condition recognized as a
potential barrier?

EPA has not acquired adequate applicant flow data to conduct
a comprehensive analysis of the Senior Executive Service
(SES) workforce.

BARRIER ANALYSIS:

Provide a description of the
steps taken and data
analyzed to determine cause
of the condition.

In the 4th quarter of FY 2011, EPA's Executive Resources
Division (ERD) successfully launched its first system to collect
applicant flow data related to external applicants for SES
vacancies. Presently, when selections are made, retrospective
analyses of applicant flow data related to determinations on
best qualified candidates for the vacancies is conducted and
reported.

This year, for the first time, partial external SES applicant flow
data was collected and categorized by race/national origin and
sex. However, this data was not included in this report,
because the appropriate feeder pool was not collected.

STATEMENT OF
IDENTIFIED BARRIER:

Provide a succinct statement
of EPA policy, procedure or
practice that has been
determined to be the barrier
of the undesired condition.

At this time, it is not possible to identify if there is a specific
hiring or promotion process policy, practice, or procedure that
may be impacting the representation of any group in the SES.
However, EPA will collect and analyze internal applicant flow
data for the SES in FY 2014.

OBJECTIVE:

State the alternative or
revised Agency policy,
procedure or practice to be
implemented to correct the
undesired condition.

EPA will work to continue its efforts to enhance its automated
data capture capabilities for internal SES hires.

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RESPONSIBLE
OFFICIAL:

Director of Office of Civil Rights

Associate Assistant Administrator for Diversity, Outreach and
Collaboration

Director of Human Resources
Deputy Civil Rights Officials

DATE OBJECTIVE
INITIATED:

October 1, 2013

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2016

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

Analyze and, if necessary, modify procedures for capturing data.

Completed
November 2013

The Office of Human Resources will develop a process for collecting
internal SES applicant flow data in accordance with the requirements
of MD-715.

March 2014

The Office of Human Resources will launch a Learning Management
System to track Agency employees' participation in career
development activities, including trainings, details, and e-learning.

September 2014

The Office of Human Resources will collect internal Senior Executive
Service applicant flow data in accordance with the requirements of
MD-715.

September 2014

The Office of the Director of Human Resources will develop, in
coordination with the Director of the Office of Diversity, Advisory
Committee Management and Outreach, Director of Office of Civil
Rights and the Office of General Counsel, a strategic recruitment plan

September 2014

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EPA Management Directive 715 Report

and guidance document, which will be disseminated to all supervisors
in EPA.

The Office of Human Resources will circulate a report highlighting
employees' participation in training and/or career development
opportunities collected in the Learning Management System.

September 2016

The Office of Human Resources will circulate a report highlighting the
career development data collected in the Learning Management
System.

September 2016

Report of Accomplishments and Modifications to Objective

In FY 2013, EPA is pleased to report that it collected partial external applicant flow data
categorized by race/national origin and sex for SES vacancies for the first time. Over 4000
applications were received in response to vacancies posted through USAJOBS. The total
application rate has doubled since last year, which was the first time that EPA utilized an
electronic application process for external applications.

EPA has modified its objectives related to the SES for FY 2014. In particular, EPA will
establish a process for collecting internal SES applicant flow data in accordance with the
requirements of MD-715. In addition, EPA will develop the Learning Management System to
track employee participation in career development opportunities, including trainings, details,
and e-learning during FY 2014.

Thereafter, a report will be circulated which highlights the data collected in the Learning
Management System. EPA anticipates that the enhancement of its SES applicant flow data
collection process, and system to track participation rates in supervisory training will further
its ability to examine whether barriers to equal employment opportunity exist.

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EPA Management Directive 715 Report

PART 1-5: Individuals with Targeted Disabilities

STATEMENT OF
CONDITION THAT WAS
A TRIGGER FOR A
POTENTIAL BARRIER:

Provide a brief narrative
describing the condition at
issue.

How was the condition
recognized as a potential
barrier?

Data comparisons between FY 2012 and FY 2013 indicate that
EPA workforce decreased by 71,053 (5.8%) employees, which
included a decrease in the total number of individuals with
targeted disabilities within EPA.

BARRIER ANALYSIS:

Provide a description of the
steps taken and data
analyzed to determine cause
of the condition.

EPA completed Part J of this report and noted that the total
number of individuals with targeted disabilities in EPA
workforce declined from 227 in FY 2012 to 201 in FY 2013. In
other words, the percentage of individuals with targeted
disabilities declined by 11.45% from FY 2012 to FY 2013.
Additionally, the total number of qualified individuals with a
reportable disability declined by 7.25% from FY 2012 to FY
2013.

As indicated in Table Bl, EPA lost 28 permanent employees,
who were individuals with targeted disabilities; however their
reasons for departing from Agency employment are unknown.
To identify their motivation for departing from EPA
employment, the exit interview form and process will be
updated in FY 2014. A concern identified in some Action
Plans was that budgetary constraints due to the sequestration,
furloughs, the government shutdown, and the reduced numbers
of FTEs greatly limited the hiring capabilities of managers.

EPA's National Disability Program Manager and Special
Emphasis Program Managers in the Disability Action Council,
Regions and AAships identified, through their MD 715 Action
Plans, possible attitudinal or institutional barriers that may be
causing the number of individuals with targeted disabilities to
be declining. These submissions demonstrated that there are
perceived attitudinal barriers, and that all Agency managers

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EPA Management Directive 715 Report



may not have adequate knowledge or awareness to use
Schedule A hiring authorities under 5 CFR 213.3102(u) or
adequate knowledge about the Workforce Recruitment Program
for College Students with Disabilities. In FY 2014, EPA has
numerous planned activities to address these barriers through:
1) improved training for hiring managers and human resource
specialists; 2) enhanced recruitment and outreach strategies;
and 3) the creation of a committee to address hiring,
advancement, and retention of people with targeted disabilities.

STATEMENT OF
IDENTIFIED BARRIER:

Provide a succinct statement
of EPA policy, procedure or
practice that has been
determined to be the barrier
of the undesired condition.

At this time, it is not possible to identify a specific policy,
practice or procedure which may be causing any of the
identified lower than expected participation rates. But, the data
suggests that EPA should more closely examine: 1) the
uniform use and training on Schedule A and 5 CFR
213.3102(u); 2) the availability of training programs on
Schedule A and 5 CFR 213.3102(u); 3) the gathering of
applicant flow data to the extent it is possible.

OBJECTIVE:

State the alternative or
revised Agency policy,
procedure or practice to be
implemented to correct the
undesired condition.

EPA will continue its analysis of the retention and selection
rates of individuals with targeted disabilities to determine
whether an agency policy, practice or procedure is causing the
identified triggers and work towards collecting applicant flow
data on people with targeted disabilities.

RESPONSIBLE
OFFICIAL:

Director of Office of Civil Rights

Director of Office of Diversity, Advisory Committee

Management and Outreach

Director of Human Resources

Deputy Civil Rights Officials

DATE OBJECTIVE
INITIATED:

February 15, 2011

TARGET DATE FOR
COMPLETION OF
OBJECTIVE:

September 30, 2014

PLANNED ACTIVITIES TOWARD COMPLETION OF
OBJECTIVE:

TARGET DATE
(Must be specific)

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EPA Management Directive 715 Report

The Disability Program Manager developed a training toolkit which
included: 1) the definition of disability and targeted disabilities; 2)
ABCs of Schedule A for hiring managers, HR professionals and
disability program managers; 3) the Workforce Recruitment Program
(WRP) for Students with Disabilities; 4) the Computer /Electronic
Accommodation Program (CAP), which provides assistive
technological accommodations in the workplace for people with
disabilities; and 5) disability law with federal focus based on the
Americans with Disabilities Act Amendments Act of 2008 (ADAAA).

Completed
January 2013

The Office of Human Resources will implement its plan to market the
creation and benefits of individual development plans to employees and
supervisors.

Completed
February 2013

Provide Agency-wide Special Emphasis Program Managers training on
how to provide briefings and brown-bag luncheons to managers on the
Workforce Recruitment Plan and Schedule A hiring authority in the
Regions and at Headquarters.

Completed
July 2013

The Office of Human Resources and Office of Diversity Advisory
Committee Management Office will collect and analyze the individuals
with targeted disabilities data of participants in FY 12 and first three
quarters of FY 13 Successful Leader Program.

Completed
July 2013

The Office of Human Resources will carefully track EPA's use of
Schedule A appointing authorities for hiring individuals with targeted
disabilities.

Completed
September 2013

The Office of Civil Rights will provide training to management and
Agency LORACs throughout EPA on using the toolkit as well as on
facilitating requests for reasonable accommodation for applicants and
employees with disabilities.

Completed
September 2013

In an effort to improve the accuracy of data on individuals with
disabilities, the Office of Diversity, Advisory Committee Management
and Outreach will provide all employees the opportunity to update their
disability status.

Completed
December 2013

The Office of Civil Rights and Office of Diversity, Advisory
Committee Management and Outreach will continue to conduct

Completed

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EPA Management Directive 715 Report

assessments on whether there are attitudinal barriers to selection and
promotion opportunities by holding a series of at least 5 separate
listening sessions throughout EPA with disability constituency
groups. This may also include meetings with Disability Special
Emphasis Program groups, EEO leaders, Local Accommodation
Coordinators, Union officials, and other managers and employees.

December 2013

The Office of Human Resources and Office of Civil Rights will
analyze: 1) the uniform use and training on Schedule A and 5 CFR
213.3102(u); 2) the availability of training programs on Schedule A use
and requirement for applicants and managers; and 3) the gathering of
applicant flow data to the extent it is possible.

February 2014

Support a "One Great Place to Work Initiative" committing EPA to
foster a work environment that nurtures and advances the talents, drive,
and interests of all employees. This campaign is built around three
principal areas: Supportive Work Environments, Professional
Development, and Benefits and Amenities.

March 2014

The Office of Diversity, Advisory Committee Management and
Outreach will compile a list of disability recruiting sources for Shared
Service Centers to send copies of EPA job announcements published on
USAJobs.

March 2014

The Office of Human Resources will update the exit interview form and
process to track the motivation for employees' departure from Agency
employment.

March 2014

EPA will announce a numerical goal for each Region and AAship and
for EPA overall for the hiring of individuals with targeted disabilities
consistent with Executive Order 13548.

April 2014

Establish a diversity committee to address hiring, advancement, and
retention of people with targeted disabilities.

April 2014

Report of Accomplishments and Modifications to Objective

This year, due to budgetary constraints, there were limited opportunities to hire new employees
which affected the Agency's ability to achieve its goal for individuals with targeted disabilities
to represent 2% of EPA's total workforce.

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EPA Management Directive 715 Report

Nonetheless, in FY 2013, the Equal Employment Opportunity (EEO) Officers and Program
Management Officers (PMOs) worked with the National Disability Program Manager, Regions
and AAships through their MD 715 Action Plans to identify possible attitudinal or institutional
barriers that may be causing the representation of People with Targeted Disabilities (PWTD) in
EPA's workforce to decline. Specifically, several EPA Regions and AAships conducted
disability listening sessions including Disability Action Council, OAR, OCFO, Regions 4, 7
and 9 to discuss attitudes and potential barriers to equal employment opportunity.

At such sessions, several managers explained that their failure to utilize Schedule A hiring
authority was due to budgetary constraints, which resulted in: 1) the hiring pause which halted
hiring efforts; 2) the furloughs caused by the government sequestration which impacted office
budgets; 3) a lack of available Full-Time Employee Equivalents (FTEs) which prohibited their
office from hiring interns and permanent employees. A few managers thought that hiring
people with disabilities would interfere with Merit System Protection Board (MSPB)
regulations.

In addition, the Office of Civil Rights (OCR) and Office of Diversity, Advisory Committee
Management and Outreach (ODACMO) met with Disability Special Emphasis Program
groups, EEO leaders, Local Accommodation Coordinators and Union officials, to better assess
the attitudinal barriers to selection. In these listening sessions, the participants reiterated their
beliefs that many EPA managers and human resource specialists may not: 1) have adequate
knowledge of the Schedule A hiring authorities under 5 CFR 213.3102(u); 2) know how to
specifically use Schedule A hiring authorities; 3) know about the Persons with Disabilities and
Schedule A (u) and 213.3102 Workforce Recruitment Program online database; and 4) know
the benefits of hiring individuals with disabilities.

In FY 2013, EPA accomplished several planned activities that make knowledge of disability
issues and tools more easily accessible to managers which might impact the triggers identified
above. Specifically, in January 2013, the Disability Program Manager developed a training
toolkit which included: 1) the definition of disability and targeted disabilities; 2) ABCs of
Schedule A for hiring managers, human resources specialists, and disability program
managers; 3) the Workforce Recruitment Program (WRP) for Students with Disabilities; 4) the
Computer/Electronic Accommodation Program (CAP), which provides assistive technological
accommodations in the workplace for people with disabilities; and 5) provisions of the
disability law with federal focus based on the Rehabilitation Act of 1973 and the Americans
with Disabilities Act Amendments Act of 2008 (ADAAA).

In 2013, the Office of Human Resources (OHR) implemented a 2013 Memorandum of
Understanding Partnership with Gallaudet University, an educational institute for the hearing
impaired, through which OHR and Office of Administration and Resources Management
(OARM) coordinated and organized the placement of 14 hearing impaired student volunteers
at EPA's Headquarters Program Offices during the 2012-2013 school year.

In April 2013, the Office of Diversity, Advisory Committee Management and Outreach
(ODACMO) Disability Representative provided mock interview training for Gallaudet

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EPA Management Directive 715 Report

University students. In July 2013, ODACMO provided a workshop to Gallaudet University
students on job applications, career etiquette and expectations in the work place.

In July 2013, EPA Special Emphasis Program Managers (SEPM) also received training on
how to provide briefings and brown-bag luncheons to managers on the WRP and Schedule A
hiring authority in the Regions and at headquarters. The goal of these sessions was to equip
managers and supervisors with the capacity to locate and hire highly qualified college students
with disabilities in all academic fields and disciplines.

In September 2013, the ODACMO compiled a list of disability recruiting sources for Shared
Service Centers, who thereafter, distributed all vacancy announcements to organizations that
support the employment of PWTD. This targeted recruited effort resulted in Region 9 hiring
21% of their 2013 new hires through Schedule A.

Throughout 2013, the NRAC and Assistant Reasonable Accommodation Coordinator (ARAC)
provided training to management and Agency LRAC on using the toolkit as well as on
facilitating requests for reasonable accommodation. The NRAC conducted a total of 36
training sessions on EPA's Reasonable Accommodation Policy and Procedures, and Section
508. The training sessions were attended by managers/supervisors and employees and focused
on managers'/supervisors' use of the toolkit as well as on facilitating requests for reasonable
accommodation.

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EPA Management Directive 715 Report

EEOCFORM
715-01
PART J

U.S. Equal Employment Opportunity Commission
FEDERAL AGENCY ANNUAL
EEO PROGRAM STATUS REPORT
Special Program Plan for the Recruitment, Hiring, and Advancement
of Individuals With Targeted Disabilities

PARTI
Department or
Agency
Information

1. Agency

1. US Environmental Protection Agency

la. 2nd

Level

Component

l.a. N/A

lb. 3rd
Level or
lower

lb. N/A

PART II

Employment
Trend and
Special
Recruitment for

Individuals
With Targeted
Disabilities

Enter
Actual
Number at
the ...

Start 9-30-2012

End 9-30-2013

Net Change

Number

%

Number

%

Number

Rate of Change

Total Work
Force

18,055

100.00%

17,002

100.00%

-1053

-5.83

Reportable
Disability

1,158

6.41%

1,074

6.32%

-84

-7.25

Targeted
Disability*

227

1.26%

201

1.18%

-26

-11.45

* If the rate of change for persons with targeted disabilities is not equal to or
greater than the rate of change for the total workforce, a barrier analysis should be
conducted (see below). Please see Part 19.

1. Total Number of Applications Received
From Persons With Targeted Disabilities
during the reporting period.

Data not available

2. Total Number of Selections of Individuals
with Targeted Disabilities during the
reporting period.

Data not available

PART III Participation Rates In Agency Employment Programs

Other
Employment/
Personnel
Programs

TOTAL

Reportable
Disability

Targeted
Disability

Not Identifiec

No Disability

#

%

#

%

#

%

#

%

3. Competitive
Promotions

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

4. Non-

Competitive

Promotions

755

63

8.34%

15

1.99%

19

2.52%

673

89.14%

5. Employee Career Develoj

Dment Programs - No Data Available

5.a. Grades 5 -
12

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

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EPA Management Directive 715 Report

EEOCFORM
715-01
PART J

U.S. Equal Employment Opportunity Commission
FEDERAL AGENCY ANNUAL
EEO PROGRAM STATUS REPORT
Special Program Plan for the Recruitment, Hiring, and Advancement
of Individuals With Targeted Disabilities

5.b. Grades 13 -
14

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

5.c. Grade
15/SES

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

6. Employee Recognition and Awards

6.a. Time-Off
Awards (Total
hrs awarded)

122,312

6927

5.66%

1,117

0.9%

1760

1.43%

113,625

92.89%

6.b. Cash
Awards (total
$$$ awarded)

2,294,631

152,525

6.65%

23734

1.03%

28410

1.24%

2,113,696

92.1%

6.c. Quality-
Step Increase

297

7

2.36%

0

0%

4

1.35%

286

96.30%

Part IV

Please see Form 1-5.













Identification and
Elimination of
Barriers



















Part V



















Goals for
Targeted
Disabilities

Hiring Goals - EPA has established a goal to reach 2.0% representation in the total
workforce for persons with targeted disabilities by the end of FY 2015. In order to
reach this 2.0% goal, EPA will need to hire approximately 139 individuals with
targeted disabilities. Therefore, efforts will be taken as outlined in Part 1-5 to
substantially increase the number of employees with targeted disabilities.

Retention Goals - To improve its retention of individuals with targeted disabilities
in the workforce, the exit interview form and process will be updated to track their
motivation for departing from EPA employment by March 2014. In addition, a
diversity committee will be established to focus on the retention and advancement
of individuals with targeted disabilities by April 2014.

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EPA Management Directive 715 Report

PART K: Best Practices Summary

EPA considers the following to be noteworthy best practices of our Agency:

>	The establishment of Deputy Civil Rights Officials (DCROs) within each regional office
and assistant administrator's office to serve as that office's primary point of
accountability for effectively implementing the civil rights programs within their
respective organizations, and providing senior level involvement in the development of
national EEO strategies and policies.

>	The formation of the Transgender Workgroup to develop a guidance document on
transgender inclusion in the workplace.

>	The development of a comprehensive listing of EPA Memoranda of Understanding with
MAI's to better leverage the MAI partnerships.

>	The creation of an electronic repository of EPA mentorship programs.

>	The implementation of a plan to market the creation and benefits of individual
development plans to employees and supervisors.

>	The implementation of a 2013 Memorandum of Understanding Partnership with
Gallaudet University, an educational institute for the hearing impaired, through which
OHR and OARM coordinated and organized the placement of 14 hearing impaired
student volunteers at EPA's Headquarters Program Offices during the 2012-2013 school
year.

>	The formation of the Diversity and Inclusion Advisory Committee (DIAC). This is a
standing committee of the Executive Management Committee that provides senior
leadership oversight, counsel, and recommendations concerning EPA's diversity and
inclusion efforts. DIAC, which is comprised of officials from ODACMO, 2 EEO
Officers, the Special Emphasis Program Managers (SEPMs), Regional representatives
and headquarters officials, intends to meet quarterly to address the effectiveness of EPA's
efforts to expand senior leadership diversity.

>	The compilation a list of disability recruiting sources for Shared Service Centers, who
thereafter, distributed all vacancy announcements to organizations that support the
employment of PWTD. This targeted recruited effort resulted in Region 9 hiring 21% of
their 2013 new hires through Schedule A.

>	The implementation of training courses throughout the regions and AAships on the
following topics: 1) the reasonable accommodation request process; 2) the interactive

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EPA Management Directive 715 Report

process; 3) the importance of maintaining confidentiality and providing accommodations
in a timely manner; and 4) union negotiated procedures.

> The development and issuance of a Section 508 training course attended by 270

managers/supervisors and 149 employees, which was offered in Regions 1, 2, 4, 5, 6, 8,
10, as well as the OEI Program Office.

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