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December 22, 2011

The Honorable Lisa P. Jackson

Administrator

United States Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

RE: Third NACEPT Advice Letter on EPA Workforce Planning: Ensuring Diversity

Dear Administrator Jackson: 

The National Advisory Council for Environmental Policy and Technology (NACEPT) is 

working on your charge to provide advice for development of the Agency’s next Strategic 

Workforce Plan. The charge comprises the following topics: 

1. Scientific and technical competencies needed to be prepared for tomorrow’s challenges. 

2. Strategies to obtain and retain scientific and technical expertise. 

3. Strategies to attract and retain superior executive leadership talent. 

4. Leadership capabilities and culture for “One EPA”. 

5. Ensuring diversity. 

On January 31, 2011, NACEPT responded with an advice letter on the first charge question: 

scientific and technical competencies needed for the Agency to be prepared for tomorrow’s 

challenges. This was followed by a second advice letter on July 11, 2011, summarizing 

NACEPT’s recommendations addressing charge questions #2 (Strategies to obtain and retain 

scientific and technical expertise) and #4 (Leadership capabilities and culture for “One EPA”). 

This letter will provide advice on charge question #5 (Ensuring diversity). A forthcoming letter 

will address charge question #3 (Strategies to attract and retain superior executive leadership 

talent).

RECOMMENDATIONS AND RESPONSE TO THE FIFTH QUESTION IN THE 

CHARGE: ENSURING DIVERSITY

“How can EPA best ensure access to a diverse and technically astute SES applicant pool? What 

can EPA do to ensure diverse applicants selected into the SES are retained, developed and 

promoted? Given the broader concept of Diversity that EPA is espousing to (diversity in 

thinking styles, educational backgrounds, family experiences, etc.), how can EPA define and then 

track/measure diversity in this broadest sense?
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NACEPT was charged with looking at the issues of diversity and inclusion at the Agency, 

including tools and processes, and how they support the creation of a strong SES applicant pool. 

As part of the process, NACEPT analyzed current practices, systems and processes, and the 

commitment by Agency leaders. 

A full day session was held in June where Agency leaders were asked to provide the diversity 

workgroup with information about current practices covering orientation and on-boarding 

processes, engagement processes, attrition and turnover, programs for people with disabilities, 

leadership accountabilities for promoting diversity, best practices, and diversity and inclusion 

priorities. Christine Griffin, then Deputy Director of OPM, was invited to share the broader 

federal government context for developing and implementing outreach and recruiting strategies. 

Additionally, EPA’s 2010 EEO Report (MD-715) and 2011 MD-715 Action Plans and the recent 

Executive Order on Diversity and Inclusion were reviewed.

Based on a review of practices and supporting systems, the following recommendations are 

presented:

1. Update the linkage of diversity and inclusion to the strategic mission of the agency1and 

with the One EPA theme, and expand strategies to include critical stakeholder groups. 

The current focus of diversity and inclusion efforts continue to be dominated by “compliance” 

driven programs and initiatives targeted at workforce representation. Work must continue to 

ensure diversity at all levels of the organization are linked to regulatory requirements. However, 

to move the Agency to the next level of performance, greater clarity and connection of diversity 

and inclusion to the mission critical strategies and cross-cutting fundamental goals must be 

considered and embraced. 

“Our concern is that in too many places in America, the burden of pollution and environmental 

degradation falls disproportionately on low-income and minority communities – and most often, 

on the children in those communities” – Lisa Jackson, May 2009.2 

If the Agency is to successfully address these issues, a workforce that mirrors these impacted 

communities must be in place. It must be driven by a leadership team that manifests and 

embraces diversity and inclusion.

As an agency of the federal government, EPA is charged with protecting human health and the 

environment, by writing and enforcing regulations based on laws passed by Congress. Many of 

its recommendations in areas such as air quality standards, water quality and drinking water 

standards, global warming, greenhouse emissions, environmental justice, etc., require leaders 

who can build and sustain effective relations with an increasingly diverse set of policy makers. 

Taking action on climate change and improving air quality, protecting America’s waters, 

cleaning up communities and advancing sustainable development, ensuring the safety of 

chemicals and preventing pollution, along with enforcing environmental laws are very laudable 

 1 http://www.inpaws.org/EPA_Strategic_Plan.pdf

2 http://yosemite.epa.gov/opa/admpress.nsf/12a744ff56dbff8585257590004750b6/67297347ff21319a852575b60063c50b!OpenDocument
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goals but require engaging with diverse congressional leaders, state representatives, other 

agencies, private industry, citizens and environmental activists.

Therefore EPA leaders must understand that diversity and inclusion are critical to achieving 

these outcomes across diverse stakeholder groups.

2. Analyze the impact of changing demographics on the EPA’s ability to successfully 

implement its cross cutting strategies which include: expanding the conversation on 

environmentalism, working for environmental justice and children’s health, advancing 

science, research and technological innovation, strengthening state, tribal and 

international relationships, and strengthening the EPA’s workforce and capabilities.

As part of the “One EPA” framework, the organization should take a systemic approach to how 

diversity and inclusion are critical to accomplishing its cross cutting strategies. Expanding the 

conversation on environmentalism requires that leaders and staff build their cultural competence 

and skill in underserved communities so they can build effective relationships and articulate the 

value and benefits of “environmentalism” in such a way to optimize results and stakeholder 

commitment to the policy changes being recommended or implemented. 

The 2010 census results point to a very diverse youth population led by growth in the Latino / 

Hispanic population, growing immigrant communities, and a shrinking middle class.3 These 

“emerging demographic populations” have beliefs and perspectives that must be built into how 

issues are framed. And finally, creativity, problem-solving and issue resolution must be 

considered in the context of culture and background. See for example S.J. Gate’s essay on 

creativity, diversity and innovation in science and education.4 

3. Establish an EPA-wide framework for the initiative to promote diversity and inclusion 

covering leadership expectations and accountability, integration with strategic plan, crossorganizational collaboration, governance and compliance, talent management, strategic 

outreach, institutional systems analysis, risk mitigation, agency work culture and climate, 

and processes for inspecting and monitoring results. Align with President’s Executive 

Order.5

In reviewing current Agency practices, we found that regional offices and locations have a lot of 

discretion in determining what should be done and how it should be done in the area of diversity 

and inclusion. This is especially evident in some of the traditional human resource systems areas 

such as staffing, recruiting, retention and development. 

Creating an over-arching framework for diversity and inclusion allows for greater consistency, 

and more effective use of resources. This will allow the Agency to streamline processes, to more 

effectively use its limited human resources, and provide a consistent metric for measuring 

progress.

 3 http://2010.census.gov/news/releases/operations/cb11-cn125.html 4 http://php.aaas.org/programs/centers/capacity/documents/Gates_Essay.pdf

5 http://www.whitehouse.gov/the-press-office/2011/08/18/executive-order-establishing-coordinated-government-wide-initiative-prom
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The EPA-wide framework should include the following:

1. Review of the Agency’s current definition for diversity and the development of a 

definition for diversity and inclusion similar to the Department of Veteran Affairs6

2. Description of the following elements:

• Inclusive behaviors and practices for senior management

• Inclusive behaviors and practices at the individual level

• Inclusive practices that make a difference at the Agency (e.g., integration of 

inclusion into its strategic plan, ensure inclusive principles in human resource 

processes, etc.)

3. Action plans including outcomes, outcome measures, and procedures for monitoring 

progress

4. Recognition program for units, teams, and individuals who have demonstrated exemplary 

support for diversity and inclusion

5. Incorporation of other activities consistent with the President’s Executive Order (E.O. 

13583) on Diversity and Inclusion in the Federal Workforce

Diversity goes beyond programs to develop a workplace that allows all employees to perform at 

their individual best. The recent E.O. on Diversity and Inclusion in the Federal Workforce moves 

diversity beyond a valued and understood principle. The E.O. directs “...executive departments 

and agencies to develop and implement a more comprehensive, integrated and strategic focus on 

diversity and inclusion as a key component of their human resource strategies.” 

The Department of Veterans Affairs Diversity Council (VADC) has defined Diversity as “...all 

the ways in which people differ including innate characteristics (such as age, race, gender, 

ethnicity, natural origin, mental or physical disabilities, and sexual orientation) and acquired 

characteristics (such as education, socioeconomic status, religion, work experience, language, 

skills, etc.).

The VADC Charter as well as others has identified inclusion as the engine that puts diversity to 

work. Inclusion behaviors and practices are operative at the individual, leadership and 

organizational levels. Therefore, the Agency’s Diversity Program must contain not only a 

definition for diversity but also an action plan that embraces and encourages inclusion.

The Administrator’s recent reaffirmation of equal opportunity and diversity in the work place 

and urging to cultivate an inclusive environment in the work environment provide the direction 

for the vector for the Agency to move forward. The President’s E.O. provides the guidance and 

direction for diversity and inclusion in the federal workforce. This recommendation outlines a 

framework for implementing the strategy and measuring progress of diversity and inclusion at 

EPA. Additional information on a sample framework is included in the addendum.

 6 http://www.diversity.va.gov/council/files/charter.pdf
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4. Strengthen the pipeline of talent for SES level positions, particularly among minorities:

Even with the progress EPA 

has made to expand the 

pipeline for potential SES 

applicants, there is still the 

question of how to ensure 

that there are enough 

trained individuals from 

underrepresented minorities 

in the pipeline for existing 

positions as well as for the 

new types of jobs EPA has 

envisioned for the future 

described in our first 

workforce letter. It is not 

enough to assume that this 

pool has already been hired 

but is simply waiting for transfer for promotion; rather, EPA should take the proactive stance that 

this pipeline needs to keep developing and see to it that there are programs available that can 

provide trained and diverse personnel on a continual basis. 7

There are a number of actions that the EPA can take to enhance the pipeline in the short-term. 

These actions include the following:

• Diversity SWOT Analysis – Perform a SWOT analysis to provide insight into the strengths, 

weaknesses, opportunities and threats of diversity and inclusion efforts within the Agency.

• Leadership Accountability – Make it a requirement that diversity and inclusion be a part of 

every leader’s annual performance management process with clear actions and metrics for 

measuring progress. 

• Diversity and Inclusion Analytics - Adopt a dashboard to monitor progress in achieving 

Agency-wide objectives, including:

o Diversity in applicant pools.

o Workforce representation trends (e.g., year over year progress in areas of 

underutilization).

o Participation of minorities and women in HR programs (e.g., development, training, 

mentoring, etc.). Link to requirements and recommendations in MD-715 reports.

• Strengthen focus on pipeline by focusing on “Placements of women and minorities against 

opportunities” in areas of underutilization (e.g., SES level and professional levels).

 7 Charts adapted from EPA Office of Civil Rights 2010 data.
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• Selection Pool and Interview Panel Diversity - Make it a priority that women and minorities 

be represented in selection pools and interview panels (“Rooney Rule”). Managers should be 

held accountable via the annual performance management process for ensuring parity and 

transparency in all selection processes.

• Education (e.g., Inclusion, Harassment Prevention, Unconscious bias) - Make it mandatory 

that all EPA employees participate in an annual harassment prevention education program. 

Require all leaders to do a self assessment on personal inclusive behavior and lead a

discussion with their team on personal and team behavior.

• Outreach - Enhance Agency outreach to ensure that more Hispanic and Latino candidates are 

in the candidate pools. Strengthen the Limited English Proficiency Program (LEP) to 

provide meaningful access by stakeholders with limited English proficiency.

• Employee Resource Group Engagement - Solicit feedback and input from employee resource 

groups (Affinity Groups) to assist in strategy and outreach programs in targeted 

communities.

• Resource Allocation – Establish a central diversity budget to focus on carrying out these 

programs and strategies.

• Recruiting Firms - Consider using firms specialized in recruiting minorities and other groups 

currently under-represented in the Agency.

Additionally, work with higher education to address the pipeline issue involving higher 

education:

• By creating or enhancing relevant programs at minority-serving institutions.

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• By linking minority institutions with non-minority institutions that already have achieved 

excellence in key program areas for joint training through partnerships.

• By encouraging existing institutions that have achieved excellence in key program areas to 

recruit minority candidates more successfully through incentives and assistance.9

Ideally, all three of these strategies would be deployed in different programs to test and gather 

data about which are most effective. In the current funding environment, however, it is likely to 

be difficult to create new programs from scratch if existing universities already have suitable 

programs. In that case, linkages are helpful and have been used in the past. 

One example is a current Memorandum of Understanding between EPA and Vermont Law 

School that has the goal of improving the flow of information between EPA and minority 

communities. So far several law students from North Carolina Central University, a historically 

black college, have attended the summer session on environmental law at Vermont Law School 

in the Agency's first organized effort to train more lawyers to handle environmental justice issues

 8 http://meldi.snre.umich.edu/diversity_initiative/Diversity+Programs+and+Initiatives 9 http://www.environmentaldiversity.org/people.html
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in minority and low-income communities, which bear a disproportionate amount of health and 

environmental impacts from pollution.10

Sincerely,

/Signed/

Dr. James H. Johnson, Jr.

Chair

Addendum: Sample Framework for Diversity and Inclusion Initiative

Charts of EPA Feeder Pools

cc: Bob Perciasepe, Deputy Administrator

Craig E. Hooks, Assistant Administrator, OARM

Cynthia D. Jones-Jackson, Acting Director, OFACMO

NACEPT Members

 10http://www.vermontlaw.edu/News_and_Events/News/2010_News_Archive/EPA_Minority_Fellows_Kick_Off_Environmental_Law_Outreach

_Program_at_VLS.htm
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ADDENDUM

A SAMPLE FRAMEWORK FOR DIVERSITY AND INCLUSION INITIATIVE

The framework is intended to be an “Agency-wide” framework for managing a diversity and 

inclusion initiative. It should be examined against the Agency’s mission critical strategies for 

effectiveness. 

The strategy should be guided by principles focused on ways to enhance representation at all levels, 

meet regulatory requirements and to consolidate efforts, streamline processes, and strengthen senior 

leadership accountability and commitment.

Element of 

Initiative

Key Components Expected Outcomes Element Owner

Leadership • Build a leadership “mindset” that understands 

and is committed to diversity and inclusion

• Hold Agency leaders accountable for results 

and actions

• Develop a clear case for diversity (including 

definition)

• Clarify expectations and accountability (roles, 

responsibilities and relationships)

• Reinforce relationship to the “One EPA” 

strategy

SES Leaders held accountable for 

diversity and inclusion; Human 

Resource Officers (HROs) and Equal 

Employment Opportunity (EEO) 

Officers provide support.

Diversity and inclusion results 

become a component of performance 

evaluation and development plans

Leaders role modeling the behaviors 

that are required 

EPA 

Administrator 

and Senior 

Leadership 

Team

Integration with 

EPA Strategic 

Plan

• Identify critical diversity and inclusion levers

• Understand implications on cross cutting 

strategies

• Build into human capital plans and workforce 

/ stakeholder development strategies

Leaders understand how diversity 

and inclusion can be a competitive 

advantage in relationships with 

stakeholder groups and in achieving 

goals outlined in the strategic plan.

• Mindset

• Guiding Principles

EPA 

Administrator 

and Senior 

Leadership 

Team

Governance and 

Compliance

• Align action with Presidential EO and seek 

ways to eliminate redundant functions.

• Use MD-715 as the tool for identifying and 

eliminating barriers, examining gaps and for 

building workforce improvement strategies

• Ensure effective implementation of Executive 

Orders: 13171 (Hispanic employment), 

13518 (Veterans), 13548 (Individuals with 

Disabilities employed in FG), 13163 

(Increasing Opportunities for People with 

Disabilities in FG), 13078 (Employment of 

Adults with Disabilities)

Build on the work that is already 

underway in the Agency to address 

gaps.

Institute strategies for consolidation 

and integration of compliance efforts 

through use of technology and crossorganizational teaming.

Increase people with disabilities 

hiring.

Increased rigor in developing and 

implementing MD-715 Action Plans 

by Senior Management annually

Human 

Resource 

Officers (HROs), 

EEO Officers

Office of 

Diversity, 

Outreach and 

Collaboration 

(ODOC)

Office of Civil 

Rights (OCR)

Cross 

Organizational 

Collaboration

• Identify opportunities to “team” and / or 

collaborate with other federal agencies

o Best practices

o Sharing resources

o Engaging other Federal Agencies 

(OPM, etc.)

Ensure cost effective and efficient 

ways of delivering tools, processes 

and services to support diversity and 

inclusion

Enhance flexibility and customer 

service by promoting crossorganizational teaming, education 

and communications

EPA 

Administrator

and Senior 

Leadership 

Team

OPM

ODOC

HROs and EEO 

Officers
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Element of 

Initiative

Key Components Expected Outcomes Element Owner

Talent 

Management

• Build a compelling reason to work with EPA 

that resonates with Millennials and emerging 

leaders

• Focus efforts on building the pipeline of 

diverse talent, especially in the Hispanic 

population.

Understand why certain populations are 

underrepresented in SES positions. Analyze 

turnover by demographic groups.

Develop a “One EPA” strategy for sourcing 

talent (National Outreach Program).

• Understand feeder pools

• Explore creative solutions such as 

Vermont NCCU collaboration

• Focus on creative solutions 

(partnerships, linkage to strategic 

plan, engagement of operating 

management)

• Enhance OnBoarding (goals, 

tracking, feedback, linkage to 

survey)

Improvement in workforce 

representation of underserved 

minorities especially SES level.

More targeted and integrated 

sourcing strategy.

Continued strengthening of the 

executive OnBoarding process (SES) 

Reinforced commitment to the EPA 

Emerging Leaders Network

HROs

EEO Officers

ODOC

Culture and 

Organization 

Climate

• Address any workplace or satisfaction issues 

that may impact satisfaction and engagement 

of the workforce.

o Generational diversity

o Employee Resource Groups

o Demographic analysis of 

retention, satisfaction

o Work flexibility

o Accessibility

• Ensure that process for raising issues and 

concerns about work place issues 

(discrimination, harassment, and retaliation) 

are effective and being used. 

Goal is lower turnover rates for high 

talent employees, increased 

satisfaction levels, and greater worklife integration

Continued use of employee resource 

groups to provide input and feedback 

on work place issues.

Timely intervention, investigation and 

decisions, and effective Alternative 

Dispute Resolution (ADR) for charges 

of discrimination, inappropriate 

behavior, and retaliation

HROs

EEO Officers

ODOC

OCR

Strategic 

Outreach

• Strengthen relationships with key diversity 

organizations, particularly those focused on 

Hispanic /Latino; African American and other 

underrepresented minorities. 

• Build more inclusive strategies for working 

with increasingly diverse stakeholder groups 

(businesses, communities, activists, 

government officials.

More effective relationships with 

employees, regulators, communities, 

tribes, etc.

EPA 

Administrator 

and Senior 

Leadership 

Team

Office of Human 

Resources

ODOC

OCR
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Element of 

Initiative

Key Components Expected Outcomes Element Owner

Institutional 

Barriers and 

Systems

Examine barriers that are created in recruiting, 

staffing, and hiring processes Shift to a centralized 

resume management system, align with OPM 

office or use same tool

• Monitor applicant flow data to assess 

the level of diversity in pools

Eliminate policies and procedures that may 

unintentionally make it more difficult to attract and 

retain diverse talent.

• For example, only hiring the first 50 

applicants that apply

• Lack of coordination of regional offices 

on prospective employees

• Policies that make it difficult for people 

with disabilities to apply

Evaluate diversity and workplace best practices 

from other federal agencies / businesses to 

improve efficiency / effectiveness

Institutional barriers that create an 

impediment to building a more 

diverse and inclusive workforce are 

minimized or eliminated.

HROs, EEO

Officers

ODOC

Office of 

Civil Rights

Office of General 

Counsel

Monitoring and 

Measurement

Set specific goals and targets for Agency directors 

and leaders to achieve in carrying out this initiative

Leaders are held accountable for 

implementing the specific actions 

identified in this initiative.

EPA 

Administrator 

and Senior 

Leadership 

Team 
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Based on EPA Office of Civil Rights 2010 Data
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Based on EPA Office of Civil Rights 2010 Data
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NOTICE

This letter is the product of the National Advisory Council for Environmental Policy and 

Technology (NACEPT), an advisory committee created under the Federal Advisory Committee 

Act. NACEPT provides independent advice and recommendations on environmental policy, 

technology, and management issues to the Administrator and other officials of the U.S. 

Environmental Protection Agency (EPA). The recommendations in this letter reflect the opinions 

and views of NACEPT, and not necessarily the views or opinions of the U.S. EPA.

NACEPT’s reports and advice letters are posted on the EPA website at 

http://www.epa.gov/ofacmo/nacept.