PLAN EJ 2014
 

FOSTERING ADMINISTRATION­WIDE
 

ACTION ON ENVIRONMENTAL JUSTICE
 

DRAFT IMPLEMENTATION PLAN
 

Led by
 

Office of Water and Region 6
 

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 Fostering Administration‐Wide Action on Environmental Justice
 

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: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

1.0 INTRODUCTION

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations

and Low‐Income Populations” (EO 12898)−signed in 1994−calls on all federal agencies to focus

attention on, and work with other stakeholders to, eliminate or remediate the unduly high and

adverse human health or environmental effects that exist in these communities; in other words,

achieve environmental justice. EO 12898 directs each Federal Agency to “make achieving

environmental justice part of its mission by identifying and addressing, as appropriate,

disproportionately high and adverse human health or environmental effects of its programs,

policies, and activities on minority populations and low‐income populations,” including tribal

populations.

1.1 Goals

Everyone in America deserves to live, work, and play in a healthy and sustainable community. The

goal of this Implementation Plan is to facilitate the active involvement of all federal agencies in

ensuring a healthy, sustainable and green community for all people. To better achieve this goal,

EPA is leading the Administration’s effort to fully implement EO 12898. As each Agency

reinvigorates its effort to make environmental justice part of its mission, EPA will focus on helping

each Agency participate in a coordinated approach that acknowledges the disproportionately high

and adverse human health and environmental impacts on overburdened communities, while

providing access to the environmental, public health and economic benefits that Agency programs

provide. A coordinated and holistic approach is essential to ensuring that we address the full

scope of adverse human health and environmental effects in disproportionately burdened

communities, legacy pollution problems rooted in historical discrimination, and cumulative

impacts, and ensure that all communities participate in, and benefit from, the transition to a clean

energy economy.

1.2 Organizational Structure

The Office of Water (OW) and Region 6 will serve as co‐ leads on the Fostering Administration‐

Wide Action (FAWA) on EJ focus area. OW will be supported by the Office of Environmental

Justice (OEJ), the Office of Solid Waste and Emergency Response (OSWER), the Office of Federal

Activities (OFA), the Office of Civil Rights (OCR), and the Office of Congressional and

Intergovernmental Relations (OCIR). EPA recognizes that Fostering Administration‐Wide Action

requires coordination with the Council on Environmental Quality (CEQ), other federal agencies,

and EPA’s ongoing interagency activities. In addition, the Office of Federal Activities will address

the issues related to National Environmental Policy Act (NEPA), and the Office of Civil Rights will

address issues related to Title VI of the Civil Rights Act. Interagency coordination will also involve

the Interagency Working Group on Environmental Justice (IWG), which was established under EO

12898 and was reconvened in September 2010.

1 
                     

  

                         

                     

     

                          

                           

                         

                     

            

                         

     

                       

                           

                          

                         

                          

                                

                                  

               

                        

                                 

                            

                                      

                   

                               

                           

                      

                   

                            

                   

                     

                        

                           

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

2.0 IMPLEMENTATION

2.1 Strategies

EPA, in conjunction with the White House Council on Environmental Quality and Interagency

Working Group on Environmental Justice, has identified four major strategies for Fostering

Administration‐Wide Action on Environmental Justice:

 Assist other federal agencies to integrate EJ in their programs, policies, and activities.

 Work with other federal agencies to strengthen use of interagency legal tools, i.e., National

Environmental Policy Act and Title VI of the Civil Rights Act of 1964.

 Foster healthy and sustainable communities, with an emphasis on place‐based initiatives.

 Strengthen community access to federal agencies.

2.2 Activities

Strategy 1: Assist other federal agencies to integrate EJ in their missions, programs,

policies, and activities.

Background: EPA will lead the Administration’s effort to better integrate environmental justice

into federal agency programs, policies and activities by chairing the Interagency Working Group on

Environmental Justice (EJ IWG). The Administration is dedicated to ensuring that everyone has the

opportunity to live in a healthy and sustainable community, particularly those living in

overburdened communities. As part of this Administration‐wide effort, EPA has taken the lead in

reinvigorating the EJ IWG. Under EO 12898, the EJ IWG is chaired by the EPA Administrator and

comprised of principals from other agencies. The purpose of the EJ IWG is to guide, support, and

enhance federal environmental justice and community‐based activities.

Activity #1.1: Chair and convene EJ IWG Principal, Deputy, and Senior Staff meetings.

EPA and the other federal agencies place a high priority on facilitating the integration of EJ into

federal agency programs, policies, and activities. For example, in 2010, EPA and CEQ reconvened

the EJ IWG for the first time in over a decade. White House, EJ IWG members and other federal

agency representatives expressed their commitment to meet their responsibilities under EO

12898. EPA and CEQ also hosted the first White House Environmental Justice Forum (EJ Forum).

At the Forum, EJ IWG members and other federal agency representatives reengaged with EJ

advocates about issues that are important to overburdened communities. Moving forward, EPA

will continue to lead EJ IWG meetings and events.

Activity #1.2: Chair, assist, and oversee each Agency’s effort to update or develop an EJ

Strategies.

This Administration is committed to identifying, evaluating, and reducing environmental and

human health burdens while increasing environmental and human health benefits in

overburdened communities. Accordingly, each Agency will update, or in some cases develop, an

EJ Strategy that will be responsive to the environmental and human health needs of overburdened

communities.

2 
                     

                

                         

                        

                               

                           

                   

                          

     

                 

                         

                       

                      

                          

                 

                             

                         

                         

                          

                             

                            

                                

                 

                         

                             

       

                             

                        

                      

                       

                    

                           

                            

                       

                        

                               

                         

  

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

Activity #1.3: Lead the effort to organize regional events.

EPA and other federal agencies recognize that, to successfully address the needs of overburdened

communities, federal agencies must engage EJ stakeholders in and around their communities. To

further this effort, EPA will lead the development of regional events where EJ IWG members and

other federal agency representatives will meet with EJ stakeholders to discuss and help resolve

issues that are important to communities in each region.

Activity #1.4: Develop and provide tools that help EJ and other stakeholders identify federal

information and resources.

This Administration recognizes the need to provide federal resources, contact information,

lessons‐learned, and other information to EJ stakeholders. As a result, EPA will develop

information and resource tools to promote collaboration between federal agencies and EJ

stakeholders and improve opportunities for EJ stakeholders to utilize federal resources.

Activity #1.5: Convene a group of senior attorneys from across the federal government to

promote the integration of EJ into their agencies' actions.

In partnership with the Department of Justice, the Office of General Counsel (OGC), Office of

Enforcement and Compliance Assurance (OECA) and Office of Regional Counsel (ORC) will bring

together attorneys from agencies across the federal government that have an interest in

environmental justice. We will convene monthly meetings at the staff level to share information

about legal issues the agencies have encountered and think through the role of agency attorneys

in promoting their agencies' EJ policies. We also hope to develop other forms of information‐

sharing tools. Our goal is to help EJ IWG members and other agencies with EJ interest to

understand the legal tools available to them to promote environmental justice.

Strategy 2: Work with other federal agencies to strengthen use of interagency legal

tools, i.e., National Environmental Policy Act and Title VI of Civil Rights Act of 1964

National Environmental Policy Act (NEPA)

Background: The National Environmental Policy Act (NEPA) is an important tool that can be used

to help advance the goals of environmental justice. NEPA emphasizes transparency and public

involvement and promotes better, more responsible decision‐making by the federal government.

Namely, NEPA requires federal agencies to assess and disclose environmental impacts, which

include environmental justice considerations, when proposing actions. Further, under the Clean

Air Act Section 309, EPA is mandated to review environmental impact statements, comment in

writing, and make those comments available to the public. These reviews include an assessment

of whether the requirements of Executive Order 12898 and the accompanying Presidential

Memorandum on environmental justice are considered and integrated within the NEPA process.

We have identified a number of activities which EPA, in concert with other federal agencies, can

take to strengthen all agencies’ abilities to incorporate environmental justice into major federal

activities.

3 
                     

                    

     

                           

                            

                       

                               

       

                        

        

                               

                       

                            

                       

  

               

                                 

                         

                          

                           

                         

                         

                               

                             

                       

                           

                               

               

                                     

               

                         

   

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

Activity #2.1: Articulate a consistent message about the need to incorporate Environmental

Justice into NEPA implementation

We will articulate a clear, consistent message about need to incorporate EJ considerations into

NEPA implementation efforts. We will reinforce the utility of NEPA as a tool to effect good

environmental decision‐making and take EJ into account through CAA Section 309 reviews. In

addition to improving internal collaboration on EJ, a clear message will enable the Agency to send

consistent messages to external stakeholders.

Activity #2.2: Enable federal NEPA practitioners to enhance consideration and execution of EJ

requirements in NEPA implementation

We will develop tools to help federal NEPA practitioners in EPA and other agencies enhance EJ

considerations in NEPA implementation by identifying and disseminating best practices in general

and in specific sectors. These tools can assist agencies in analyzing environmental impacts and

community concerns and will emphasize the benefits of having robust, agency‐specific formal

NEPA/EJ guidance.

Title VI of Civil Rights Act of 1964

Background: Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race,

color, and national origin, including matters related to language access for limited English

proficient persons, by recipients of federal financial assistance. Under EPA’s Title VI regulations,

recipients of EPA financial assistance are prohibited from, among other things, using “criteria or

methods of administering its program which have the effect of subjecting individuals to

discrimination based on their race, color, or national origin.” For example, facially‐neutral policies

or practices that result in discriminatory effects violate EPA's Title VI regulations, unless it is shown

that they are justified and that there is no less discriminatory alternative. In addition, EPA’s

regulations and Title VI prohibit intentional discrimination by recipients. Other similar laws

prohibit discrimination on the basis of age, sex, and disability by recipients of federal financial

assistance.

OCR has identified several activities that EPA, in concert with US Department of Justice (DOJ), can

take to strengthen the use of Title VI.

Activity #2.3: Consult with DOJ to strengthen the use of Title VI of the Civil Rights Act of 1964 by

re‐evaluating the approach for analyzing Title VI complaints.

Activity #2.4: Collaborate with DOJ and within EPA, to develop compliance strategies and actions

to address non‐compliance.

4 
                     

                   

   

                

                     

                      

                              

                         

                            

                             

                 

                     

                     

                                   

         

           

        

         

   

   

                   

         

                                 

                               

                     

                  

                     

                     

                  

                 

             

                     

            

                

                   

               

                   

              

                             

                     

                  

                              

                               

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

Strategy 3: Foster healthy and sustainable communities, with an emphasis on placebased initiatives

Background: Increasingly, environmentally and economically burdened communities are seeking

comprehensive solutions that address adverse human health and environmental effects while

enabling these communities to make a transition to sustainable community development. They

are calling upon federal agencies to work in a coordinated manner. Resulting efforts will improve

community access to the environmental, public health, and economic benefits that define a

healthy and sustainable community. By mobilizing the resources of all federal agencies, the EJ

IWG can foster efforts to ensure that we address adverse human health and environmental effects

in disproportionately burdened communities, including legacy pollution problems rooted in

historical discrimination and cumulative impacts, and ensure that all communities participate in,

and benefit from, the transition to a clean energy economy.

As a result of community input and the White House Forum on EJ, we identified four areas of

significant concern to disproportionately burdened communities:

 Green Jobs and Clean Energy;

 Healthy and Sustainable Communities;

 Climate Change and Adaptation; and

 Goods Movement.

Activity #3.1: Recommend ways to enhance federal interagency coordination in support of

healthy and sustainable communities.

EPA, in conjunction with other federal agencies, will develop a proposal to the EJ IWG for how

federal agencies can coordinate action in each of the four areas identified above to improve the

health and sustainability of disproportionately burdened communities in the implementation of

existing executive orders and administration priorities. The consideration of environmental justice

issues described shall direct engagement with stakeholder communities to obtain meaningful

input on the environmental justice implications and opportunities for interagency federal

engagement. Actions should be based on the following principles:

 Designates an EJ IWG agency to serve as lead;

 Builds on and leverages existing Administration initiatives;

 Enhances existing policies or programs to address environmental justice issues;

 Identifies data needs and success measures;

 Identifies place‐based project for coordinated action, if appropriate;

 Address issues of community access to resources and technical assistance;

 Promotes state, regional, local, and tribal partnerships; and

 Utilizes regional forums and other community outreach to inform federal actions.

Strategy 4: Strengthen Community Access to Federal Agencies

Background: In the priorities laid out for EPA by Administrator Jackson last year, she highlighted

the importance of expanding the conversation on environmentalism and working for

environmental justice. With that priority in mind, the Administrator acknowledged the

importance of reaching out to and engaging with communities. As part of this interagency focus

on environmental justice, one of our goals is to strengthen the ability of communities to access the

5 
                     

                               

                                

                           

         

         

                           

                        

                           

                                  

                         

                            

                             

                    

       

                                 

                       

                         

   

         

                           

                   

                            

                             

                              

        

                           

                   

                  

                       

                

           

           

                   

                       

                             

           

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

federal programs and the expertise that they need to realize their goals for a healthy and

sustainable way of life. In support of that goal, we will implement actions that eliminate barriers,

make connections, fill gaps, and reduce duplication so that communities are better able to access

the federal resources they need.

Activity #4.1: Community Needs Inventory Pilot

In order to determine the areas of inter‐agency cooperation that need improvement, the Regions

will select three communities of concern about which they have extensive knowledge. Each

Region will develop an inventory of the communities’ needs and identify the federal agency(ies)

that could address each need. Once that has been accomplished for all Regions, a data set of

thirty communities will be available so that the workgroup can identify trends − e.g., those three

or four federal agencies whose assistance is needed in the broadest number of communities. A

request can then be presented to the Administrator to approach those agencies through the EJ

IWG for a commitment and the development of strategies.

Activity #4.2: Targeted Training for Communities

Using the work already underway in the EJ IWG and EPA’s Office of Policy to catalog existing

federal programs and expertise relevant to communities, we will identify appropriate delivery

mechanisms, such as trainings, conferences, webinars, etc., and target them to provide needed

information to communities.

Activity #4.3: Review Federal Partners Meeting

We will review action items from the April 2010 Federal Partners Meeting, determine which

recommendations support strengthening community access to federal agencies, and determine

how to incorporate them into this implementation plan. This will result in a more robust

implementation plan in the future, and will help advance the outcomes of the Federal Partners

Meeting. This is being done in coordination with Plan EJ 2014 Community Based Action efforts.

Activity #4.4: Coordination with Agency Community‐Based Coordination Efforts

A member of this Fostering Administration‐Wide Action on EJ workgroup will participate on the

parallel workgroup under the Office of Policy’s Community‐Based Coordination Efforts Initiative’s

(CBCE) Cross‐Agency External Coordination workgroup. This person will ensure that EJ

communities’ needs are adequately addressed in each of the activities recommended and

ultimately undertaken. The CBCE Cross‐Agency External Coordination workgroup is

recommending a number of activities, including:

 Cataloguing existing community‐based efforts with interagency coordination

 Mining existing community‐based efforts with interagency coordination for best practices

 Improving community access to federal agency resources, including a website portal that

will serve as a one‐stop shop for communities to access all federal agencies according to

searchable needs and key words.

6 
                     

       

                   

                          

                     

                        

                  

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

2.3 Community Engagement and Stakeholder Partnership Plan

Community engagement and stakeholder partnership activities are integrated into the different

strategies and activities of this Implementation Plan. Many strategies and activities of this plan

resulted from community dialogues and the National Environmental Justice Advisory Council’s

(NEJAC) advice and recommendations. In addition, we will coordinate our community outreach

and stakeholder involvement efforts with the Office of Environmental Justice.

7 
                     

   

                        

     

       

         

   

   

     

       

       

         

         

         

   

       

         

   

               

       

       

       

           

     

   

             

     

       

       

       

          

         

       

           

   

       

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

3.0 DELIVERABLES

Goal #1: Assist other federal agencies to better integrate EJ into Agency programs,

policies and activities.

ACTIVITY DELIVERABLES MILESTONES

Activity #1.1: Chair and convene  Chair annual Principals/Deputies  By the end of 2011

EJ IWG Principal, Deputy, and meetings. Senior Staff meetings

 Chair Senior Staff meetings/calls.  Monthly

Activity #1.2: Chair, assist and

oversee each Agency’s effort to

update or develop an EJ Strategies

 Oversee the finalization of each

Agency’s EJ Strategy.

 By the end of 2011

Activity #1.3: Lead the effort to

organize regional events

 Hold at least one event in each EPA

region, or in appropriate equivalent.

 By the end of 2011

Activity #1.4: Develop and provide  Publish a draft Federal EJ Directory and  By the end of 2011

tools that help EJ and other draft Federal Resource Guide.

stakeholders identify federal

information and resources  Review EPA’s EJ IWG website

 Update EPA’s EJ IWG website.

 Annually

 As appropriate

Activity #1.5: Convene a group of

senior attorneys from across the

Administration in order to

promote the integration of EJ into

their agencies' actions

 Conduct meetings on regular basis  As appropriate

8 
                     

                         

                             

     

       

     

       

           

   

             

                 

           

  

       

      

   

      

     

        

     

           

         

         

           

         

           

       

      

   

           

             

         

      

             

             

              

   

        

  

             

         

           

     

       

       

   

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

Strategy 2: Work with other federal agencies to strengthen use of interagency legal

tools, i.e., National Environmental Policy Act and Title VI of Civil Rights Act of 1964

ACTIVITY DELIVERABLES MILESTONES

Activity #2.1: Articulate a Issue a directive to NEPA reviewers March 31, 2011

consistent message about the emphasizing environmental justice,

need to incorporate reinforcing the utility of NEPA through CAA

environmental justice into NEPA Section 309 reviews as a tool to effect good

implementation decisions and take into account EJ

considerations.

 Stakeholder outreach: Work with

Regional managers. Post on web.

Engage with federal agencies to identify

unique or “best practices.” Develop

information on “best practices” for

implementing EJ requirements in the NEPA

process and post on the internet.

 Stakeholder outreach: Work with EPA EJ

experts and Regional NEPA

practitioners. Share with NEJAC.

September 30, 2011

Activity #2.2: Enable federal

NEPA practitioners to enhance

consideration and execution of

EJ requirements in NEPA

implementation

Work with the Interagency Working Group,

CEQ, federal agencies, NEJAC) to urge that

all federal agencies with NEPA

responsibilities have robust agency‐

specific guidance in place setting forth a

process to meaningfully consider EJ in the

NEPA EIS process. EPA will identify and

disseminate examples/components of

June 30, 2011

strong guidance

 Stakeholder outreach: EJ IWG, CEQ,

NEJAC

Develop a best practices tool for regulators

to analyze specific environmental impacts

and identify typical community concerns for

a particular sector

 Stakeholder outreach: Work with

affected regions, communities, Federal

and state regulators

September 31, 2011

9 
                     

         

         

           

       

     

         

         

     

         

         

         

   

     

         

       

   

           

             

         

   

           

         

       

       

         

         

  

                 

  

   

             

   

       

               

           

         

   

           

           

   

       

     

     

   

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

ACTIVITY DELIVERABLES MILESTONES

Activity #2.3: Develop a plan of Convene stakeholder dialogue to discuss June 30, 2011

action, in consultation with DOJ, the re‐evaluation of the approach for

which will outline how EPA will re‐ analyzing Title VI complaints

evaluate the approach for

analyzing Title VI complaints  Stakeholder Outreach: Work with EPA,

DOJ, civil rights, environmental justice,

community, state agency, business and

other experts

Activity #2.4: Collaborate with

DOJ, and EPA, to develop

compliance strategies and actions

to address non‐compliance

Develop a comprehensive plan of action

that will outline how EPA will implement

this approach

 Stakeholder Outreach: Work with EPA

and DOJ

September 30, 2011

Convene EPA, DOJ, and other federal

agencies stakeholder dialogue to discuss

the development of compliance strategies

and actions to address non‐compliance

 Stakeholder Outreach: Work with EPA,

DOJ, and other federal agencies

November 30, 2011

Goal #3: Foster Healthy and Sustainable Communities, with emphasis on place­based

initiatives

ACTIVITY DELIVERABLES MILESTONES

Activity #3.1: Recommend ways

by which the EJ IWG can enhance

interagency coordination in

support of healthy and

sustainable communities

Develop proposal to EJ IWG for how federal

agencies can coordinate action to improve

the health and sustainability of

disproportionately burdened communities

in the implementation of existing executive

orders and administration priorities, in the

following four areas:

 Clean Jobs and Clean Energy

 Healthy and Sustainable Communities

 Climate Change and Adaptation

 Goods Movement

September 30, 2011

10 
                     

           

                 

       

   

           

     

  

     

             

     

     

     

             

         

       

     

     

     

   

         

           

     

     

   

   

               

         

                            

                                    

                      

                 

   

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

Strategy 4: Strengthen Community Access to Federal Agencies

ACTIVITY DELIVERABLES MILESTONES

Activity #4.1: Community Needs

Inventory Pilot

Inventory of three Region 6 EJ communities'

needs and corresponding federal agencies

April 30, 2011

Inventory of 27 remaining Regions EJ

communities' needs and corresponding

Federal Agencies

By June 15, 2011

Analysis of commonalities and trends By December 31, 2011

Recommendations made to Administrator

to take to IWG

By May 31, 2012

Activity #4.2: Targeted Training

for Communities

 Assessment of program cataloging

results in IWG and OP efforts.

 Identification of best delivery

mechanisms to reach communities

By September 30, 2011

Activity #4.3: Review Federal

Partners Meeting

Recommendations

Identification of recommendations from the

April 2010 Federal Partners Meeting to

determine which to incorporate.

By June, 2011

Activity #4.4: Coordination with Draft Options paper for EMC review By February 15, 2011

Agency Community‐Based

Coordination Efforts Initiative Form workgroups to implement selected

actions

TBD

3.1 Reports

Progress reports on this Implementation Plan will be made annually. The planned deliverables and

milestones for each of the activities described above are set forth in the tables. Each of the offices

responsible will further refined and developed during the process of implementation. For

information, please contact: Sherri White, 202‐564‐2462, white.sherri@epa.gov or Alice Walker,

202‐529‐7534, walker.alice@epa.gov.

11 
                     

             

           

          

       

       

         

         

           

               

               

           

           

           

                 

         

Plan EJ 2014: Fostering Administration‐Wide Action Draft Implementation Plan, March 1, 2011

4.0 APPENDICES

Acronyms

CBCE – Community Based Coordination Efforts Initiative

CEQ – Council on Environmental Quality

DOJ – Department of Justice

EJ – Environmental Justice

EO – Executive Order

EPA – Environmental Protection Agency

IWG – Interagency Working Group

NEPA – National Environmental Policy Act

OECA – Office of Enforcement and Compliance Assurance

OCIR – Office of Congressional and Intergovernmental Relations

OCR – Office of Civil Rights

OFA – Office of Federal Activities

OGC – Office of General Counsel

OSWER – Office of Solid Waste and Emergency Response

OW – Office of Water

12