PLAN EJ 2014
 

RESOURCES TOOLS DEVELOPMENT
 

DRAFT IMPLEMENTATION PLAN
 

Led by
 

Office of Administration and Resources Management
 

Plan EJ 2014 is EPA’s roadmap to integrate

environmental justice (EJ) into its programs and policies.

2014 represents the 20th anniversary of the signing of

Executive Order 12898 on environmental justice.
                     

   

                             

   

Comments regarding the Resources Tools Development Draft implementation Plan can be

submitted on Regulations.gov.

For more information on Plan EJ 2014, visit the US EPA’s Office of Environmental Justice

website at: http://www.epa.gov/environmentaljustice/plan‐ej/index.html.
                       

   

                     

                        

                      

       

                             

                         

       

                     

                 

                     

                          

                             

  

                     

                   

                         

                          

                         

                           

                    

                           

                     

      

                               

                           

              

                        

                            

                               

                      

                         

                         

                             

                              

                       

                   

Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

1.0 INTRODUCTION

1.2 Goals

The Office of Administration and Resource Management’s (OARM) implementation plan has

two major components. The first component addresses the Agency’s mechanisms for providing

grants and technical assistance to support community‐based action programs. The second

component addresses workforce diversity.

Grants and Technical Assistance: OARM’s goal is to have an efficient and effective system for

delivering financial and technical assistance to communities to empower them to improve their

health and environment.

This goal includes establishing a transparent, One‐EPA approach to organizing and

implementing the Agency’s community‐based grants programs, streamlining grants processes

consistent with EPA’s fiduciary responsibilities, and providing grants management training to

communities. It also includes providing technical assistance to communities that find it difficult

to manage grants, in order to build their capacity and strengthen their ability to analyze/use

technical environmental information.

OARM’s goal furthers the Administrator’s priority of Expanding the Conversation on

Environmentalism and Working for Environmental Justice by establishing a new paradigm for

the delivery of EPA assistance to minority, low‐income and indigenous peoples to create

healthy and sustainable neighborhoods. It also responds to the Cross‐Agency Focus Area under

Plan EJ 2014 of Supporting Community‐Based Action Programs by building on the success of

ongoing EPA grants and technical assistance activities, such as the Community Action for a

Renewed Environment (CARE) Program. By aligning EPA’s grants and technical assistance

programs with the needs of citizens and community groups to achieve healthy, sustainable, and

green communities, OARM’s vision advances the Agency’s mission of protecting human health

and the environment.

The purpose of this Implementation Plan is to realize OARM’s vision over the next three years

by charting a course of action for grants and technical assistance that will be accomplished

collaboratively with communities and EPA’s grants management workforce.

Workforce Diversity: OARM’s goal is to achieve an inclusive work environment by developing

an efficient system for the outreach and recruitment of potential employees. Development of a

diversity portal, using social media tools, will be part of the system to attract qualified, diverse

applicants. OARM will also provide Agency‐wide diversity training for hiring officials.

This goal includes establishing a One‐EPA approach to consistently recruit and select, both

internally and externally, from diverse pools, the best‐qualified candidates for all positions.

The changing demographics of America mean that the public served by the EPA is also

changing. When EPA recruits and retains an inclusive workforce — one that looks like the

America it serves and where individual differences are respected, appreciated, and valued,

diversity becomes an organizational strength that contributes to achieving results.

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Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

OARM’s Office of Diversity, Outreach and Diversity (ODOC) will work with the National Program

Offices to broaden the standard outreach and recruitment efforts to attract qualified applicants

from identified groups with low inclusion rates in EPA’s workforce, in compliance with EEO

laws.

OARM’s workforce diversity goal furthers the Administrator’s priority of Expanding the

Conversation on Environmentalism and Working for Environmental Justice by establishing a new

paradigm for selecting and hiring potential employees.

1.2 Organizational Structure

Grants and Technical Assistance: As communicated by Catherine McCabe and Bharat Mathur

to the Deputy Assistant Administrators and Deputy Regional Administrators on November 5,

2010, the Agency will implement the Resources Tools Development elements for grants and

technical assistance through the existing Grants Workgroup formed under the Deputy

Administrator’s Community‐Based Coordination Project.

The Grants Workgroup is co‐chaired by the Director, Office of Grants and Debarment (OGD),

OARM, and the Director, Financial Policy and Planning Staff, Office of Financial Management

(OFM), Office of the Chief Financial Officer (OCFO). It includes the following seven Subgroups:

 Healthy Communities Coordinated Grants Subgroup: Office of Air and Radiation (OAR) and

Region 9 (Co‐Chairs)

 Technical Assistance Subgroup: Office of Environmental Justice (OEJ) (Chair)

 Training Subgroup: OCFO (Chair)

 Competition Subgroup: OGD (Chair)

 Internal Policies Subgroup: OGD (Chair)

 Legal Issues Subgroup: OEJ and OGC (Co‐Chairs)

 Timely Award Subgroup: OGD and Office of Solid Waste and Emergency Response (OSWER)

(Co‐Chairs)

The Grants Workgroup has broad representation from Headquarters and Regional offices.

Workforce Diversity: OARM’s ODOC will be establishing a cross‐Agency task force, the

Outreach and Recruitment Task Force, with representatives from National Program Offices and

Regional Offices to develop a national strategy to attract a diverse pool of qualified applicants

by May 13, 2011.

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Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

2.0 IMPLEMENTATION

2.1 Strategies

Grants and Technical Assistance: Under the framework of the Community‐Based Coordination

Project, the Grants Workgroup has the following charges:

 Improve community access to information about available grants and application processes

 Design streamlined grants processes, grants bundling, and other approaches that ensure

quality awards while reducing transaction costs to communities seeking assistance

 Design efficient and effective approaches to provide technical assistance to communities

that find it difficult to manage grants

 Coordinate with related ongoing grants streamlining efforts

To accomplish these charges, the Workgroup has established seven strategies:

Strategy 1: Increase Transparency and Efficiency in Providing Community‐Based Grant

Opportunities

Strategy 2: Improve Delivery of Technical Assistance to Communities

Strategy 3: Strengthen Grants Training for Communities

Strategy 4: Improve Community Awareness of Grant Competition Process

Strategy 5: Revise Grant Policies that are Unduly Restrictive

Strategy 6: Encourage OGC/ORC/Program Office Dialog on Community‐Based Grant

Opportunities

Strategy 7: Improve timeliness of Brownfields Grant Awards

Workforce Diversity: The Outreach and Recruitment Task Force will have the following charge:

 Increase the diverse pool of qualified applicants

 Operate under a One‐EPA approach for recruitment and outreach

2.2 Activities

Grants and Technical Assistance: To implement these seven strategies, the Grants Workgroup

has identified a set of priority activities. OGD is responsible for overseeing the Workgroup’s

progress in completing these tasks.

Strategy 1: Increase Transparency and Efficiency in Providing Community­Based

Grant Opportunities

 Draft recommendations for improving community group access to EPA grant programs to

be presented to Executive Management Committee (EMC) in March 2011

 Soliciting informal feedback from communities (e.g., CARE Program workshops)

 Conducting outreach to Regions and National Program Managers (NPMs) via conference

calls and sharing of drafts.

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Plan EJ 2014: Resources Tools Development	 Draft Implementation Plan, March 1, 2011

Strategy 2: Improve Delivery of Technical Assistance to Communities

	 Develop Technical Assistance Center approach

	 Preliminary draft options to be presented to the EMC in March 2011

	 Need senior management guidance on initial concepts before obtaining informal feedback

from communities

	 Will conduct outreach to Regions and NPMs via conference calls and sharing of drafts

Strategy 3: Strengthen Grants Training for Communities

	 Create umbrella, basic on‐line grant training for communities, EJ‐specific on‐line training,

and program‐specific training (e.g., CARE, Urban Waters)

	 Training modules in place by December 2011

	 Will obtain informal community feedback as modules developed

	 Will conduct outreach to EPA grants management community by providing opportunities

for review of draft training scripts

Strategy 4: Improve Community Awareness of Grant Competition Process

 Develop and implement appropriate grant competition tools (e.g., listservs, webinars)

 Tools in place by October 2011

 Obtaining informal community input through Regional/HQ websites

 Will work with Regions and NPMs to develop and implement tools

Strategy 5: Revise Grant Policies that are Unduly Restrictive

	 Revise Delegation 1‐86 and indirect cost rate policies

	 Temporarily revised delegation issued November 2010

	 Simplified Indirect Cost Rate (ICR) policy in place by October 2011

	 Will obtain informal community feedback once draft ICR policy developed

	 Will conduct outreach to Regions and NPMs by providing opportunity to comment on draft

policy issuance

	 Will explore simplification of other policies

Strategy 6: Encourage Office of General Counsel/Office of Regional Counsel/Program

Office Dialog on Community­Based Grant Opportunities

	 Conduct periodic OGC/ORC/OEJ meetings and OGC guidance on scope of community‐based

grant authorities

	 First OGC/ORC/OEJ call held 01/05/11

	 Next OGC/ORC/OEJ call scheduled for 2/2/11

	 Awaiting OGC legal guidance on scope of grant authorities

	 Discussions must be coordinated with larger OGC effort on existing legal authorities

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Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

Strategy 7: Improve timeliness of Brownfields Grant Awards

 Draft recommendations for consistent Brownfields award times to be issued 1/31/11

 Draft recommendations will be shared with EPA’s Grants Management Officers (GMOs) and

OSWER and finalized by May 2011

 This is primarily an internal Agency process issue

The Workgroup anticipates that it will complete all of these priority activities by the end of

2011. It recommends that the Agency codify Workgroup accomplishments in a consolidated

Grants Policy approved by senior Agency management. No additional Full Time Employee (FTE)

will be required to complete agreed‐upon tasks. As described above, each Subgroup under the

Grants Workgroup will conduct appropriate community/stakeholder outreach.

Workforce Diversity: To meet its goals, the Outreach and Recruitment Task Force has

identified four priority activities. OARM’s ODOC is responsible for overseeing the Workgroup’s

progress in completing these tasks.

Activity 1: Design an efficient Agency‐wide outreach strategy by June 24, 2011

Activity 2: Develop effective marketing materials and strategy July 29, 2011

Activity 3: Develop a National Conference Toolkit by August 19, 2011

Activity 4: Develop a National Outreach Calendar by August 19, 2011

OARM will also provide Agency‐wide diversity training for hiring officials.

2.3 Community Engagement and Stakeholder Partnership Plan

Grants and Technical Assistance: As noted in Section 2.2, the Grants Workgroup is seeking

informal feedback from communities in developing revisions to policies, procedures and

organizational structures. More formal community feedback (e.g., feedback from the National

Environmental Justice Advisory Council (NEJAC)) may be required for certain activities, including

the development/selection of options under Strategies 1 and 2. As Workgroup activities

proceed, OARM will consult with OEJ to determine the need for formal community feedback.

2.4 Adjustments

Grants and Technical Assistance: OGD will carefully monitor and evaluate the impact of revised

policy and procedures in FY 2012. If the Agency and communities are not realizing the desired

outcomes, OGD and the Workgroup make necessary adjustments in FY 2013 to reach the

desired outcomes.

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Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

3.0 DELIVERABLES

3.1 Schedule of Deliverables

Grants and Technical Assistance: Appendix A contains a draft schedule of deliverables along

with associated performance measures.

Workforce Diversity: OARM’s ODOC is in the process of soliciting proposals from contractors

for diversity training. It is anticipated that the Task Force will complete all of these priority

activities by the end of 2011.

3.2 Measures

Grants and Technical Assistance: See Appendix B.

Workforce Diversity: Measures will be developed in a collaborative manner once the Task

Force is convened.

3.3 Reporting

Grants and Technical Assistance: The Grants Workgroup will provide quarterly progress

updates as part of the Community‐Based Coordination Project. OARM will submit an annual

progress report at the end of each fiscal year as required by Plan EJ 2014. For information,

please contact: Howard Corcoran, 202‐564‐1903, corcoran.howard@epa.gov.

Workforce Diversity: Reporting will be developed in a collaborative manner once the Task

Force is convened. For information, please contact: Antoinette Powell‐Dickson, 202‐566‐0738,

powell‐dickson.antoinette@epa.gov.

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Plan EJ 2014: Resources Tools Development Draft Implementation Plan, March 1, 2011

4.0 APPENDICES

Appendix A: Acronyms

CARE ‐ Community Action for a Renewed Environment

EMC ‐ Executive Management Committee

GMO ‐ Grants Management Officers

NEJAC ‐ National Environmental Justice Advisory Council

NPM ‐ National Program Managers

OARM ‐ Office of Administration and Resource Management

OAR ‐ Office of Air and Radiation

OCFO ‐ Office of the Chief Financial Officer

OCHP ‐ Office of Children’s Health Protection

OCSPP ‐ Office of Chemical Safety and Pollution Prevention

ODOC – Office of Diversity, Outreach and Collaboration

OEJ ‐ Office of Environmental Justice

OFM ‐ Office of Financial Management

ORC ‐ Office of Regional Counsel

OGC ‐ Office of General Counsel

OGD ‐ Office of Grants and Debarment

Appendix B: Table of Deliverables and Measures

See Pages 8‐9.

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Strategy Number Q2 FY11 Q3FY11 Q4FY11 Q1FY12 Q2FY12 Q3FY12 Q4FY12 

Strategy 1: Brief EMC on Refine Finalize Begin Continue Continue Continue 

Increase draft options reform reform implementation implementation implementation implementation 

Transparency & for improving options options 

Efficiency in grant delivery based on Providing system EMC and Community‐ community Based Grant feedback OpportunitiesStrategy 2: Brief EMC on Refine Finalize Begin drafting Issue RFP(s) RFP closes Evaluate Improve Delivery preliminary reform reform of grant or applications an of Technical draft options options options contract RFP(s) make selections 

Assistance to based on for service 

Communities EMC and

communityfeedback

provider(s) 

Strategy 3: Complete Obtain Evaluate Complete all Roll‐out Provide training Provide training 

Strengthen development community feedback; training training to Grants Training of draft & EPA continue to communities 

for Communities umbrella and

EJ on‐linetraining

feedback;initiateprogram‐specifictrainings

developprogram‐specifictrainng

Strategy 4: Seek input Evaluate Evaluate Roll‐out Promote use of Promote use of Evaluation of 

Improve from EPA community feedback; competition tools tools effectiveness of 

Community grants feedback; finalize tools to tools Awareness of community Obtain EPA competition communities 

Grants via feedback tools 

Competition Regional/HQ 

Process websites 
Strategy Number Q2FY11 Q3FY11 Q4FY11 Q1FY12 Q2FY12 Q3FY12 Q4FY12 Q

Strategy 5: Inform Issue final A

Revise Grant programs of revised version f

Policies that are temporary of Delegation 

unduly restrictive revised

version ofDelegation 1‐86

1‐86 

Strategy 5: Draft policy to Issue draft Issue final Implement Continue to Continue to Continue to 

Revise Grant simplify revision to revised implement implement implement 

Policies that are indirect cost indirect indirect 

unduly restrictive rules; solicit

feedback onchanges toother policies

costpoliciesand otheridentifiedpolicies

cost ratepolicy/otherrevisedpolicies

Strategy 6: Hold kick‐off Second Quarterly Quarterly Quarterly Quarterly Quarterly 

Encourage OEJ‐ meeting to quarterly meeting meeting meeting meeting meeting 

OGC/ORC‐Program clarify roles meeting 

Office Dialog on and Community‐Based responsibilities Grant Issues for eligibility

reviews

Strategy 6: Schedule for 

Encourage OEJ‐ issuance of OGC/ORC – OGC guidance 

Program Office on the scope 

Dialog on of existing

Community‐Based grant

Grant Issues authorities to

be determined

Strategy 7:ImproveTimeliness ofBrownfields GrantAwards

Develop draftapproach

Consultwith HQ/RegionalProgram &GrantsOffices

Finalizestrategyand begintoimplement

Implement Continue to

implement

Continue to

implement

Continue toimplement