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Plan EJ 2014 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Office of Environmental Justice 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
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A message from...

 

 EPA Administrator Lisa P. Jackson 

Dear Colleagues: 

Expanding the conversation on environmentalism and working for environmental 

justice are among my top priorities for our work at the U.S. Environmental Protection 

Agency. All too often, low-income, minority and tribal Americans live in the shadows of 

the worst pollution, facing disproportionate health impacts and greater obstacles to 

economic growth in communities that cannot attract businesses and new jobs. 

In 1994, President Bill Clinton issued an executive order directing all federal agencies to 

participate in a governmentwide effort to address environmental justice issues. To 

strengthen our efforts in anticipation of the 20th anniversary of that directive and to 

ensure that the EPA is setting a standard for all other agencies, I am pleased to share 

our comprehensive environmental justice strategy Plan EJ 2014. 

Plan EJ 2014 builds on the solid foundation we have established at the EPA to expand 

the conversation on environmentalism. Since my first days as Administrator, I have 

traveled the country to meet with diverse communities and listen to their concerns. 

And I am committed to making environmental justice an essential part of our decision 

making. 

Plan EJ 2014 offers a road map that will enable us to better integrate environmental 

justice and civil rights into our programs, policies and daily work. The plan focuses on 

agencywide areas critical to advancing environmental justice, including rulemaking, 

permitting, compliance and enforcement, community-based programs and our work 

with other federal agencies. It also establishes specific milestones to help us meet the 

needs of overburdened neighborhoods through our decision making, scientific analysis 

and rulemaking. 

Every American deserves clean air, water and land in the places where they live, work, 

play and learn. Through our implementation of Plan EJ 2014, the EPA will be leading by 

example in expanding the conversation on environmentalism and working for 

environmental justice – now and into the future. 

I am proud to be a part of this effort and ask you to join me as we strengthen our 

mission to protect the health of all Americans. 

Sincerely, 

Lisa P. Jackson

Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency
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Table of Contents 

EXECUTIVE SUMMARY .................................................................................. i

Cross-Agency Focus Areas ............................................................................................. i 

Tools Development Areas ........................................................................................... iv

Program Initiatives ...................................................................................................... vi

Civil Rights ................................................................................................................... vi

Conclusion ................................................................................................................... vi

1.0 INTRODUCTION ................................................................................ 1

1.1 Achieving Environmental Justice Priorities ............................................................ 2

1.2 Definition of Environmental Justice ....................................................................... 3

2.0 PLAN EJ 2014 .................................................................................... 4

2.1 Plan EJ 2014’s Organizational Structure................................................................. 5

2.2 Implementation Plans ............................................................................................ 6

2.3 Community Engagement and Stakeholder Outreach ............................................ 6

2.4 Reporting ................................................................................................................ 7

3.0 CROSS-AGENCY FOCUS AREAS ........................................................... 8

3.1 Incorporating Environmental Justice into Rulemaking .......................................... 8

3.2 Considering Environmental Justice in Permitting ................................................ 10

3.3 Advancing Environmental Justice through Compliance and Enforcement .......... 12

3.4 Supporting Community-Based Action Programs .................................................. 14

3.5 Fostering Administration-Wide Action on Environmental Justice ....................... 18

4.0 TOOLS DEVELOPMENT AREAS ......................................................... 21

4.1 Science ................................................................................................................. 21

4.2 Law ....................................................................................................................... 23

4.3 Information .......................................................................................................... 24

4.4 Resources ............................................................................................................. 25

5.0 PROGRAM INITIATIVES ................................................................... 28

6.0 CIVIL RIGHTS ................................................................................... 28

APPENDIX .................................................................................................. 29

1. Incorporating Environmental Justice into Rulemaking ......................................... 33

2. Considering Environmental Justice in Permitting.................................................. 41

3. Advancing Environmental Justice through Compliance and Enforcement ........... 56

4. Supporting Community-Based Action Programs ................................................... 78

5. Fostering Administration-Wide Action on Environmental Justice ........................ 91

6. Science Tools Development ................................................................................ 107

7. Legal Tools Development .................................................................................... 146

8. Information Tools Development ......................................................................... 150

9. Resources Tools Development ............................................................................. 159

ACRONYMS .............................................................................................. 181
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ii

Plan EJ 2014: Executive Summary i

EXECUTIVE SUMMARY 

In January 2010, Administrator Lisa P. Jackson made Expanding the 

Conversation on Environmentalism and Working for Environmental Justice 

an Agency priority. This priority was incorporated into the U.S. 

Environmental Protection Agency’s (EPA) Strategic Plan for 2011-2015. To 

implement this priority, EPA developed Plan EJ 2014 as the Agency’s 

roadmap for integrating environmental justice into its programs, policies, 

and activities. This priority recognizes that Title VI of the Civil Rights Act 

and EPA’s civil rights program is a critical component in advancing 

environmental justice. 

Plan EJ 2014, which is meant to mark the 20th anniversary of the signing of 

Executive Order 12898 on environmental justice, is EPA’s overarching 

strategy for advancing environmental justice. It seeks to: 

In July 2010, EPA introduced Plan EJ 2014 as a concept for public comment 

and initiated the development of implementation plans. This product is the 

culmination of nearly a year’s effort by EPA programs and regions, as well 

as engagement with stakeholders, to develop nine implementation plans 

with the goals, strategies, deliverables, and milestones outlined herein. 

Plan EJ 2014 has three major sections: Cross-Agency Focus Areas, Tools 

Development Areas, and Program Initiatives. The following summaries 

outline the implementation plans for Plan EJ 2014’s five cross-Agency Focus 

Areas and four Tools Development Areas. 

Cross-Agency Focus Areas 

Incorporating Environmental Justice into Rulemaking 

Goal 

To more effectively protect human health and the environment for 

overburdened populations by developing and implementing guidance on

incorporating environmental justice into EPA’s rulemaking process.

Strategies 

1. Finalize the Interim Guidance on Considering Environmental Justice 

During the Development of an Action. 

2. Facilitate and monitor implementation of guidance on incorporating 

environmental justice into rulemaking. 

3. Develop technical guidance on how to conduct environmental justice 

assessments of rulemaking activities. 

 Protect the environment and health in overburdened 

communities.

 Empower communities to take action to improve their health 

and environment. 

 Establish partnerships with local, state, tribal, and federal 

governments and organizations to achieve healthy and 

sustainable communities.
ii

Plan EJ 2014: Executive Summary 

Considering Environmental Justice in Permitting 

Goal 

To enable overburdened communities to have full and meaningful access 

to the permitting process and to develop permits that address 

environmental justice issues to the greatest extent practicable under 

existing environmental laws. 

Strategies 

1. Develop tools that will enhance the ability of overburdened 

communities to participate fully and meaningfully in the permitting 

process. 

2. Concurrent with Strategy 1, develop tools to assist permitting 

authorities to meaningfully address environmental justice in permitting 

decisions. 

3. Implement these tools at EPA and work with others to do the same. 

Advancing Environmental Justice through Compliance and 

Enforcement 

Goal 

To fully integrate consideration of environmental justice concerns into the 

planning and implementation of the Office of Enforcement and Compliance 

Assurance’s (OECA) program strategies, case targeting strategies, and 

development of remedies in enforcement actions to benefit overburdened 

communities. 

Strategies 

1. Advance environmental justice goals through selection and 

implementation of National Enforcement Initiatives. 

2. Advance environmental justice goals through targeting and 

development of compliance and enforcement actions. 

3. Enhance use of enforcement and compliance tools to advance 

environmental justice goals in regional geographic initiatives to address 

the needs of overburdened communities. 

4. Seek appropriate remedies in enforcement actions to benefit 

overburdened communities and address environmental justice 

concerns. 

5. Enhance communication with affected communities and the public 

regarding environmental justice concerns and the distribution and 

benefits of enforcement actions, as appropriate. 

Supporting Community-Based Action Programs 

Goal 

To strengthen community-based programs to engage overburdened 

communities and build partnerships that promote healthy, sustainable, and 

green communities. 

Strategies 

1. Advance environmental justice principles by building strong state and 

tribal partnerships through the National Environmental Performance 
iii

Plan EJ 2014: Executive Summary 

Partnership System (NEPPS) and the National Program Manager (NPM) 

guidance. 

2. Identify scalable and replicable elements of successful Agency 

community-based programs and align multiple EPA programs to more 

fully address the needs of overburdened communities. 

3. Promote an integrated One EPA presence to better engage 

communities in the Agency’s work to protect human health and the 

environment. 

4. Foster community-based programs modeled on the Community Action 

for a Renewed Environment (CARE) principles. 

5. Explore how EPA funding, policies, and programs can inform or help 

decision makers to maximize benefits and minimize adverse impacts 

when considering current land uses in decision making, planning, siting, 

and permitting. 

6. Promote equitable development opportunities for all communities. 

Fostering Administration-Wide Action on Environmental Justice 

Goal 

To facilitate the active involvement of all federal agencies in implementing 

Executive Order 12898 by minimizing and mitigating disproportionate, 

negative impacts while fostering environmental, public health, and 

economic benefits for overburdened communities. 

Strategies 

1. Assist other federal agencies in integrating environmental justice in 

their programs, policies, and activities. 

2. 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. 

3. Foster healthy and sustainable communities, with an emphasis on 

equitable development and place-based initiatives. 

4. Strengthen community access to federal agencies. 
iv

Plan EJ 2014: Executive Summary 

Tools Development Areas 

Science 

Goal 

To substantially support and conduct research that employs participatory 

principles and integrates social and physical sciences aimed at 

understanding and illuminating solutions to environmental and health 

inequalities among overburdened populations and communities in the 

United States. All Agency decisions will make use of the information, data, 

and analytic tools produced. 

Strategies 

1. Apply integrated transdisciplinary and community-based participatory 

research approaches with a focus on addressing multi-media, 

cumulative impacts and equity in environmental health and 

environmental conditions. 

2. Incorporate perspectives from community-based organizations and 

community leaders into EPA research agendas and engage in 

collaborative partnerships with them on science and research to 

address environmental justice. 

3. Leverage partnerships with other federal agencies on issues of 

research, policy, and action to address health disparities. 

4. Build and strengthen the technical capacity of Agency scientists on 

conducting research and related science activities in partnership with 

impacted communities and translating research results to inform 

change. 

5. Build and strengthen technical capacity of community-based 

organizations and community environmental justice and health leaders 

to address environmental health disparities and environmental 

sustainability issues. 

Law 

Goal 

To provide legal assistance to EPA policy makers and other Agency decision 

makers to advance their environmental justice objectives. 

Strategy 

Provide legal support to each Plan EJ 2014 cross-Agency Focus Area 

workgroup. 
v

Plan EJ 2014: Executive Summary 

Information 

Goal 

To develop a more integrated, comprehensive, efficient, and nationally 

consistent approach for collecting, maintaining, and using geospatial 

information relevant to potentially overburdened communities. 

Strategies 

1. Develop EPA’s GeoPlatform.

2. Develop a nationally consistent environmental justice screening tool. 

3. Incorporate appropriate elements of the environmental justice 

screening tool into the GeoPlatform. 

Resources 

Grants and Technical Assistance Goal 

To develop an efficient and effective system for delivering financial and 

technical assistance to communities to empower them to improve their 

health and environment. 

Strategies 

1. Increase transparency and efficiency in providing community-based 

grant opportunities. 

2. Improve delivery of technical assistance to communities. 

3. Strengthen grants training for communities. 

4. Improve community awareness of grant competition process. 

5. Revise grant policies that are unduly restrictive. 

6. Encourage legal and program offices to dialog on community-based 

grant opportunities. 

7. Improve timeliness of Brownfields Grant Awards. 

Workforce Diversity Goal 

To achieve an inclusive work environment by developing an efficient 

system for the outreach and recruitment of potential employees. 

Strategies 

1. Increase the diverse pool of qualified applicants. 

2. Operate under an integrated One EPA approach for recruitment and 

outreach. 
vi

Plan EJ 2014: Executive Summary 

Program Initiatives

Program Initiatives will focus on specific EPA programs. Many existing EPA 

programs actively pursue environmental justice goals or produce benefits 

for overburdened communities. Examples of such initiatives include: 

Community Engagement Initiative (Office of Solid Waste and Emergency 

Response), Urban Waters (Office of Water), National Enforcement 

Initiatives (Office of Enforcement and Compliance Assurance), Air Toxics 

Rules (Office of Air and Radiation), and the U.S. Mexico Border Program 

(Office of International and Tribal Affairs). Over the next year, EPA will 

designate at least one initiative per appropriate program for inclusion in 

Plan EJ 2014. In this way, many existing EPA initiatives can be tailored to 

better integrate environmental justice and produce greater benefits for 

overburdened communities. 

Civil Rights 

One effort already under way is implementing Administrator Jackson’s 

priority to improve EPA’s civil rights program. Complying with EPA’s 

statutory civil rights obligations is a critical part of our efforts to advance 

environmental justice. Administrator Jackson has made improving EPA’s 

civil rights program a priority. As part of this effort, EPA is pursuing long 

overdue, vigorous, robust, and effective implementation of Title VI of the 

Civil Rights Act of 1964 and other nondiscrimination statutes. EPA is 

committed to protecting people from discrimination based on race, color, 

or national origin in programs or activities that receive EPA’s financial 

assistance. 

Conclusion

Through Plan EJ 2014, EPA intends to develop a suite of tools to integrate 

environmental justice and civil rights into its programs, policies, and 

activities. It seeks to build stronger relationships with communities 

overburdened by environmental and health hazards and build partnerships 

that improve conditions in such communities. In 2014, EPA will make an 

assessment of its progress in achieving the goals of Plan EJ 2014. Based on 

this assessment, EPA will produce a report on the accomplishments, 

lessons learned, challenges, and next steps for continuing the Agency’s 

efforts to make environmental justice an integral part of every decision.
Plan EJ 2014: Overview 1

1.0 INTRODUCTION 

For far too long, many minority, low-income, tribal, and indigenous people 

in the United States have experienced higher levels of environmental 

pollution and other social and economic burdens. These overburdened 

communities1 have generally viewed environmentalism and environmental 

protection as a distant calling. These burdens have led to poorer health 

outcomes, as well as fewer financial or advocacy opportunities to pursue 

many productive activities, including “greening” their communities. 

In January 2010, U.S. Environmental Protection Agency (EPA) Administrator 

Lisa P. Jackson made Expanding the Conversation on Environmentalism and 

Working for Environmental Justice one of EPA’s priorities. The 

Administrator has directed the Agency to address the needs of 

overburdened communities by decreasing environmental burdens, 

increasing environmental benefits, and working alongside them to build 

healthy, sustainable, and green communities. This priority recognizes that 

Title VI of the Civil Rights Act and EPA’s civil rights program is a critical 

component in advancing environmental justice. The Administrator’s 

priority heralds “a new era of outreach and protection for communities 

historically underrepresented in EPA decision making” and calls for 

“include*ing] environmental justice principles in all of our decisions.”

2

February 2014 will mark the 20th anniversary of the Clinton 

Administration’s Executive Order 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations 

(EO 12898). EO 12898 calls on 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...”3 In 

recognition of this anniversary, EPA has developed Plan EJ 2014, a 

comprehensive strategy to guide the Agency in developing stronger 

relationships with communities and increasing efforts to improve the 

environmental conditions and public health in overburdened communities. 

In July 2010, EPA introduced Plan EJ 2014 as a concept for public comment 

and initiated the development of implementation plans. This product is the 

culmination of nearly a year’s effort by EPA programs and regions, as well 

as engagement with stakeholders, to develop nine implementation plans 

with the goals, strategies, deliverables, and milestones outlined herein. 

 

1

 In Plan EJ 2014, EPA uses the term “overburdened” to describe the minority, low-income, tribal, and 

indigenous populations or communities in the United States that potentially experience 

disproportionate environmental harms and risks as a result of greater vulnerability to environmental 

hazards. This increased vulnerability may be attributable to an accumulation of both negative and lack 

of positive environmental, health, economic, or social conditions within these populations or 

communities. 

2

Jackson, Lisa P., “Seven Priorities for EPA’s Future.” January 12, 2010. Available at: 

http://blog.epa.gov/administrator/2010/01/12/seven-priorities-for-epas-future/. 

3

Clinton, William J., Executive Order 12898, “Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations,” February 11, 1994, Federal Register 59, No. 32: 

7629.
Plan EJ 2014: Overview 2

1.1 Achieving Environmental Justice Priorities 

Achieving environmental justice is an integral part of EPA’s mission to 

protect human health and the environment. EPA works to ensure that all 

Americans are protected from significant risks to human health and the 

environment where they live, learn, and work, by enforcing federal laws 

protecting human health and the environment fairly and effectively and 

using the best available science. EPA also works to ensure that all parts of 

society have access to accurate information sufficient to effectively 

participate in managing human health and environmental risks. Lastly, EPA 

works to ensure that environmental protection contributes to making our 

communities and ecosystems diverse, sustainable, and economically 

productive. EPA has identified three overarching goals for its work on 

environmental justice: 

 Protect the environment and health in overburdened communities. 

 Empower communities to take action to improve their health and 

environment. 

 Establish partnerships with local, state, tribal, and federal governments 

and organizations to achieve healthy and sustainable communities. 

The Administrator’s priority on environmental justice encourages EPA to 

identify better ways to address the issues facing many minority, lowincome, tribal, and indigenous people regarding environmental and health 

concerns. To ensure environmental justice is incorporated into all 

activities, EPA has included specific language in its Fiscal Year (FY) 2011-

2015 Strategic Plan Cross-Cutting Fundamental Strategy: Working for 

Environmental Justice and Children’s Health: “Environmental justice and 

children’s health protection will be achieved when all Americans, 

regardless of age, race, economic status, or ethnicity, have access to clean 

water, clean air, and healthy communities.”4

 In addition, EPA recognizes 

that complying with its statutory obligations under Title VI of the Civil 

Rights Act of 1964 and other nondiscrimination laws is a critical part of 

integrating environmental justice in all Agency programs, policies, and 

activities. 

The Agency will use a variety of approaches to meet this commitment, 

including regulation, enforcement, research, outreach, community-based 

programs, and partnerships to protect children and disproportionately 

impacted, overburdened populations from environmental and human 

health hazards. EPA anticipates that leadership in advancing 

environmental justice and children’s health protection will inspire and 

engage a broad spectrum of partners in the public and private sector to do 

the same. The activities outlined in Plan EJ 2014 support EPA’s 

environmental justice commitments in this Cross-Cutting Fundamental 

Strategy. 

 

4

 U.S. Environmental Protection Agency, FY 2011-2015 EPA Strategic Plan: Achieving Our Vision, 

September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html. 
Plan EJ 2014: Overview 3

1.2 Definition of Environmental Justice 

EPA defines “environmental justice” as the fair treatment and meaningful 

involvement of all people regardless of race, color, national origin, or 

income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies. 5

Fair Treatment means that no group of people should bear a 

disproportionate burden of environmental harms and risks, including those 

resulting from the negative environmental consequences of industrial, 

governmental, and commercial operations or programs and policies. 

Meaningful Involvement means that: (1) potentially affected community 

members have an appropriate opportunity to participate in decisions about 

a proposed activity that will affect their environment and/or health; (2) the 

public’s contribution can influence the regulatory agency’s decision; (3) the 

concerns of all participants involved will be considered in the decisionmaking process; and (4) the decision makers seek out and facilitate the 

involvement of those potentially affected. In the Agency’s implementation 

of environmental justice, EPA has expanded the concept of fair treatment 

to include not only the consideration of how burdens are distributed across 

all populations, but also how benefits are distributed. For example, the 

Agency’s Interim Guidance on Considering Environmental Justice During the 

Development of an Action encourages the evaluation of the distribution of 

burdens by paying special attention to populations that have historically 

borne a disproportionate share of environmental harms and risk. At the 

same time, it encourages Agency staff to look at the distribution of the 

positive environmental and health consequences from our activities. 

EPA also recognizes that it has statutory obligations to comply with Title VI 

of the Civil Rights Act of 1964 and other nondiscrimination laws. Title VI 

prohibits discrimination on the basis of race, color, or national origin in all 

programs or activities receiving federal financial assistance. The Supreme 

Court has ruled that Title VI authorizes federal agencies, including EPA, to 

adopt implementing regulations that prohibit discriminatory effects as well 

as intentional discrimination. EPA has established such regulations. Title VI 

allows persons to file administrative complaints with federal departments 

and agencies alleging discrimination by financial assistance recipients. The 

Office of Civil Rights (OCR) has the responsibility within EPA to process and 

review Title VI administrative complaints.6

 In the Presidential 

Memorandum accompanying EO 12898, President Clinton pointed to civil 

rights statutes as an important tool for achieving the goals of the 

environmental justice executive order.7

 

5

 U.S. Environmental Protection Agency, Interim Guidance on Considering Environmental Justice During 

the Development of an Action. Available at: 

http://www.epa.gov/compliance/ej/resources/policy/considering-ej-in-rulemaking-guide-07-2010.pdf. 

6

For a description of EPA’s Program to Implement Title VI of the Civil Rights Act of 1964, see: 

http://www.epa.gov/civilrights/t6home.htm. 

7

Clinton, William J., Presidential Memorandum Accompanying Executive Order 12898, “Federal Actions 

to Address Environmental Justice in Minority Populations and Low-Income Populations.” Available at: 

http://www.epa.gov/environmentaljustice/resources/policy/clinton_memo_12898.pdf. 
Plan EJ 2014: Overview 4

2.0 PLAN EJ 2014 

Plan EJ 2014 is a roadmap to help EPA integrate environmental justice into 

its programs, policies, and activities. The Plan is organized into three 

sections: Cross-Agency Focus Areas, Tools Development Areas, and 

Program Initiatives. 

Cross-Agency Focus Areas address cross-cutting issues or functions that 

require work by all programs or agencies and serve to advance 

environmental justice across EPA and the federal government. They require 

a unified Agency approach toward policy and guidance development. 

Many issues also require coordination among multiple federal agencies. 

Community engagement and empowerment, with continuous input from 

communities and all stakeholders, will help shape the planning and 

implementation of Plan EJ 2014 initiatives. 

1. Cross-Agency Focus Areas 

EPA has identified five cross-Agency Focus Areas: 

 Incorporating Environmental Justice into Rulemaking. 

 Considering Environmental Justice in Permitting. 

 Advancing Environmental Justice through Compliance and 

Enforcement. 

 Supporting Community-Based Action Programs. 

 Fostering Administration-Wide Action on Environmental Justice. 

2. Tools Development Areas 

Tools Development will focus on developing the methods, mechanisms, 

and systems that support environmental justice analysis, technical 

assistance, and community work. Plan EJ 2014 has identified four areas for 

tools development: 

 Science. 

 Law. 

 Information. 

 Resources. 

3. Program Initiatives 

Program Initiatives will focus on specific EPA programs. EPA’s programs are 

designed primarily to carry out the nation’s environmental protection 

statutes, such as the Clean Air Act, Clean Water Act, and Resource 

Conservation and Recovery Act. Certain EPA programs are organized by 

media, such as air, water, and soil. Others are organized to address crossAgency functions, such as enforcement, research, and information. Under 

Plan EJ 2014, each EPA National Program Manager (NPM) will identify 

programs that benefit communities with environmental justice concerns. 
Plan EJ 2014: Overview 5

2.1 Plan EJ 2014’s Organizational Structure 

EPA’s programs and regions have assumed principal responsibility for 

leading at least one cross-Agency Focus or Tools Development Area in Plan 

EJ 2014. They have dedicated senior management and established a staff 

level workgroup to carry out this responsibility. This approach ensures that 

all program offices and regions bring their programmatic resources and 

expertise to advancing environmental justice goals. It also develops 

expertise in environmental justice throughout all Agency programs and 

regions. The table below delineates each element and its respective lead 

offices and regions. 

This organizational structure constitutes an important step for achieving 

the Agency’s environmental justice program vision that all Program Offices 

and Regions will integrate and address issues of environmental justice in 

EPA’s programs and policies as part of their day-to-day business. The 

Office of Environmental Justice (OEJ) serves as the focal point for 

facilitating that integration through building capacity, promoting 

accountability, incorporating the community’s voice, and promoting 

Agency action on critical environmental justice issues. 

PLAN EJ 2014 ELEMENT LEAD PROGRAM OFFICES AND 

REGIONS

Incorporating Environmental 

Justice in Rulemaking

Office of Chemical Safety and 

Pollution Prevention; Office of Policy;

Office of Research and Development;

Office of Environmental Justice; 

Region 9

Considering Environmental 

Justice in Permitting

Office of Air and Radiation; Office of 

General Counsel; Region 1

Advancing Environmental 

Justice through Compliance 

and Enforcement

Office of Enforcement and 

Compliance Assurance; Region 5

Supporting CommunityBased Programs

Office of Solid Waste and Emergency 

Response; Regions 2, 3, 4

Fostering AdministrationWide Action on 

Environmental Justice

Office of Water; Region 6

Science Tools Development Office of Research and Development;

Region 7

Legal Tools Development Office of General Counsel; Region 5

Information Tools 

Development

Office of Policy; Office of 

Environmental Information; Regions 

3, 8, 9, 10

Resources Tools 

Development

Office of Administration and Resource 

Management
Plan EJ 2014: Overview 6

2.2 Implementation Plans 

Each cross-Agency Focus or Tools Development Area in Plan EJ 2014 has an 

implementation plan, which is built around the following elements: goals, 

strategies, activities, deliverables, and milestones. The implementation 

plans will be used to track results and perform ongoing monitoring and 

reporting of accomplishments. These elements are defined as follows: 

 Goals: The projected state of affairs or condition that the 

implementation plan intends to achieve. 

 Strategies: Systematic action designed to achieve the stated goal. 

 Activities: Specific actions to implement the strategies identified. 

 Deliverables: Results of the activities identified, which could include 

processes, products, outputs, or changes in conditions (including 

environmental outcomes). 

 Milestones: Target dates for completion of the deliverables identified. 

In addition to supporting EPA’s current strategic plan, Plan EJ 2014 will 

align with two other important EPA and federal government initiatives: 

1. EPA’s Community-Based Coordination Project is designed to improve 

the effectiveness of EPA’s place-based community programs by 

improving management of information about EPA’s programs, 

community access to EPA resources, targeting EPA’s resources to 

communities most in need, and establishing a basis for coordinating 

this work with other federal agencies. 

2. The Federal Interagency Working Group on Environmental Justice (EJ 

IWG) was established by EO 12898 in 1994 and reconvened in 

September 2010. The EJ IWG serves as a clearing house for guidance to 

and lessons learned by federal agencies on integrating environmental 

justice into their programs. The EJ IWG will also coordinate the 

development and implementation of interagency collaborative efforts. 

2.3 Community Engagement and Stakeholder Outreach 

Plan EJ 2014 also seeks to advance the Administrator’s commitment to 

expanding the conversation on environmentalism to groups historically 

underrepresented in the environmental decision-making process. Our 

goals for stakeholder engagement are as follows: 

 To work with champions to foster greater understanding of Plan EJ 

2014’s vision, priorities, and desired outcomes among all stakeholders, 

inside and outside the Agency. 

 To obtain a broad range of stakeholder views in the development and 

implementation of Plan EJ 2014. 

 To communicate Plan EJ 2014’s vision, activities, results, and 

subsequent revisions to stakeholders, partners, and other audiences in 

a consistent and dynamic way. 
Plan EJ 2014: Overview 7

 To facilitate the development of partnerships with and among EPA’s 

stakeholders to achieve Plan EJ 2014’s goals and translate them into 

lasting results. 

Public input played a significant role in developing the elements of Plan EJ 

2014. EPA convened multiple community forums and listening sessions in 

the process of developing Plan EJ 2014. It requested that the National 

Environmental Justice Advisory Council (NEJAC) provide recommendations 

on Plan EJ 2014. EPA, along with its federal partners, plans to continue 

conducting community listening sessions and stakeholder dialogues 

throughout the country. Each implementation plan workgroup is 

responsible for developing and carrying out a community engagement and 

stakeholder outreach plan. In addition, OCR plans to issue a Limited English 

Proficiency (LEP) Order by November 2011 to ensure that all EPA programs 

and activities meet federal LEP requirements. 

2.4 Reporting 

EPA has made a commitment to provide progress reports and update the 

implementation plans. To coincide with its Strategic Plan, EPA will issue 

annual reports on Plan EJ 2014 at the end of the fiscal year. Every October, 

OEJ will coordinate posting of reports on Plan EJ 2014. These documents 

will be available on EPA’s website: 

www.epa.gov/environmentaljustice/plan-ej/index.html. 

For information on Plan EJ 2014 and how to get involved, please contact 

Charles Lee, Deputy Associate Assistant Administrator for Environmental 

Justice, 202-564-2440, Lee.Charles@epa.gov. 
Plan EJ 2014: Overview 8

3.0 CROSS-AGENCY FOCUS AREAS 

This section provides summaries of Plan EJ 2014’s five cross-Agency Focus 

Areas and their implementation plans. These areas involve issues related 

to rulemaking, permitting, enforcement, community-based action, and 

Administration-wide action. 

3.1 Incorporating Environmental Justice into Rulemaking 

Plan EJ 2014 calls upon EPA to develop and implement guidance to 

incorporate environmental justice into the fabric of its rulemaking process. 

EPA’s authority to create and enforce regulations that put our nation’s 

environmental laws into effect is one of the Agency’s most important and 

powerful tools for protecting our environment and the health of our 

people. EPA’s regulations cover a range of environmental and public health 

issues, from setting standards for clean water to controlling air pollution 

from industry and other sources. EPA’s regulatory authority combined with 

the mandates of EO 12898 charge EPA with responsibility to ensure that, as 

we develop Agency actions, we consider environmental justice issues 

during the Agency’s rulemaking process. 

EPA achieved a significant milestone in incorporating environmental justice 

into its rulemaking process by issuing the Interim Guidance on 

Incorporating Environmental Justice During the Development of an Action

(Environmental Justice in Rulemaking Guidance) in July 2010. This guidance 

calls upon Agency rule writers and decision makers to consider 

environmental justice throughout all phases of a rule’s development –

known as the Action Development Process (ADP) – from the point of its 

inception through all the stages leading to promulgation and 

implementation. EPA is also developing technical guidance to assist rule 

writers and decision makers in determining how to analyze and incorporate 

environmental justice in the Agency’s rulemaking processes.
Plan EJ 2014: Overview 9

Implementation Plan Summary 

Goal 

To more effectively protect human health and the environment for 

overburdened populations by developing and implementing guidance to 

incorporate environmental justice into EPA’s rulemaking process. 

Strategies & Activities 

Strategy 1: Finalize the Interim Guidance on 

Considering Environmental Justice During the 

Development of an Action.

Strategy 3: Develop technical guidance on how to conduct environmental 

justice assessments of rulemaking activities.

 Activity 3.1: Establish a cross-Agency Environmental Justice Technical 

Guidance Workgroup. 

 Activity 3.2: Tier the Environmental Justice Technical Guidance as a 

Tier 1 Action in the Action Development Process. 

 Activity 3.3: Develop draft technical guidance on incorporating 

environmental justice in rulemaking. 

 Activity 3.4: Conduct internal and external review of draft technical 

guidance on incorporating environmental justice in rulemaking. 

 Activity 3.5: Develop and release final technical guidance on 

incorporating environmental justice in rulemaking. 

Developing Environmental Justice Analysis for the Definition 

of Solid Waste Rule

After EPA finalized the 2008 Definition of Solid Waste (DSW) 

rule, the Agency committed to perform an expanded 

environmental justice analysis in response to concerns raised by 

citizens and other stakeholders about the rule’s potential impact 

on communities. The EPA developed an innovative methodology 

that incorporated sound science and community engagement. 

EPA began by soliciting input from the public through 

roundtables, conference calls, and webinars to get their thoughts 

on how to best conduct the analysis. The Agency identified 

potential hazards that may pose risks to communities from the 

recycling of hazardous secondary materials and the facilities that 

may take advantage of the 2008 DSW rule. The facility locations 

were then mapped against demographics of the surrounding 

communities. EPA synthesized the information and determined 

that certain population groups would be disproportionately 

impacted by the increased risk of adverse impacts under the 

2008 DSW rule. 

EPA incorporated these considerations in the revised proposed 

rule, signed June 30, 2011, to mitigate these potential adverse 

impacts, as allowed under applicable authorities. In addition, 

EPA has taken steps in implementing the DSW rule that also help 

mitigate these impacts. These steps include closely monitoring 

the facilities notifying under the rule, working with the states and 

EPA Regions to ensure they have the information they need to 

ensure compliance with the provisions of the rule, and making 

available to the public information about the facilities that have 

notified.

 Activity 1.1: Announce April closure of public 

comment period via Environmental Justice Listserv.

 Activity 1.2: Review internal and external 

comments provided during the Interim Final 

Guidance’s implementation period.

 Activity 1.3: Review documents produced by and 

interview members of EPA rule writing 

workgroups.

 Activity 1.4: Revise and release Environmental 

Justice in Rulemaking Guidance document.

Strategy 2: Facilitate and monitor implementation of 

guidance on incorporating environmental justice into 

rulemaking.

 Activity 2.1: Distribute model training 

presentations to Agency and NPM and Regionspecific regulation development and ADP trainers.

 Activity 2.2: Initiate a continuous learning effort to 

identify effective practices and lessons learned 

from the Agency’s ongoing rulemaking efforts.

 Activity 2.3: Develop and commence 

implementing a monitoring scheme to assess the 

extent to which the guidance is being applied, the 

resources being devoted to its application, and the 

effect it is having on rulemaking decisions.
Plan EJ 2014: Overview 10

3.2 Considering Environmental Justice in Permitting 

Many federal environmental statutes rely heavily on permits to deliver the 

environmental protection results that are the goal of our federal 

environmental laws. These permits play a key role in providing effective 

protection of public health and the environment in communities. Building 

upon the Agency’s efforts to incorporate environmental justice concerns in 

rules, Plan EJ 2014 calls upon EPA to consider environmental justice 

concerns during the permitting process. EPA will develop and implement 

tools to: (1) enhance the ability of overburdened communities to 

participate fully and meaningfully in the permitting process, and (2) assist 

permitting authorities to meaningfully address environmental justice issues 

in permitting decisions to the greatest extent practicable. 

To achieve our goals, the Environmental Justice Permitting Initiative will 

“identify and develop tools to support the consideration of environmental 

justice during implementation of permitting programs” to reduce 

“exposures for those at the greatest risk,” as stated in the FY 2011-2015 

EPA Strategic Plan, Cross-Cutting Fundamental Strategy: Working for 

Environmental Justice and Children’s Health.8 Initially, the Agency will 

focus on EPA-issued permits that provide the best current opportunities for 

taking environmental justice concerns into consideration. In this way, EPA 

can make short-term progress and gain valuable lessons for subsequent 

efforts. In the long term, EPA will focus on permits issued pursuant to 

federal environmental laws (i.e., federal, state, or tribal) that enable the 

Agency to address the complex issue of cumulative impacts from exposure 

to multiple sources and existing conditions. 

 

8

 U.S. Environmental Protection Agency, FY 2011-2015 EPA Strategic Plan: Achieving Our Vision, 

September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html. 
Plan EJ 2014: Overview 11

Implementation Plan Summary 

Goal 

To enable overburdened 

communities to have full and 

meaningful access to the permitting 

process and to develop permits that 

address environmental justice issues 

to the greatest extent practicable 

under existing environmental laws. 

Strategies 

Strategy 1: Develop tools that will 

enhance the ability of 

overburdened communities to 

participate fully and meaningfully 

in the permitting process. 

Strategy 2: Concurrent with 

Strategy 1, develop tools and to 

assist permitting authorities to 

meaningfully address 

environmental justice in permitting 

decisions. 

Strategy 3: Implement these tools 

at EPA and work with others to do 

the same. 

Activities 

For each strategy, EPA will 

undertake the following activities: 

Activity 1: Conduct initial internal 

research to begin to create a preliminary list of potential tools and finalize 

the implementation plan (March-June 2011, Completed). 

 Activity 1.1: Conduct an initial literature review − including a review of 

previous NEJAC papers, publications and other recommendations − to 

identify an initial list of existing and needed tools. 

 Activity 1.2: Convene a cross-Agency workgroup. 

 Activity 1.3: Review and evaluate the permitting process for a 

minimum of three federal permits with environmental justice 

considerations to use as case studies to identify existing and needed 

tools. The workgroup reviewed the permitting process for three 

federal permits and will continue to review other permits to solicit 

lessons learned and guide our next steps. 

 Activity 1.4: Coordinate overlapping strategies with other Plan EJ 2014 

elements and consider integrating and leveraging activities between 

them. 

 Activity 1.5: Issue the final implementation plan. 

Conducting Public Participation to Develop 

Permitting Tools

The Environmental Justice and Permitting 

Initiative Workgroup (Workgroup) is exploring 

ways to enable overburdened communities to 

have full and meaningful access to the 

permitting process and to ensure that the 

Agency develops permits that address 

environmental justice issues to the greatest 

extent practicable. As part of this effort, the 

Workgroup is conducting extensive public 

outreach to identify best practices and needed 

tools, such as guidance, checklists, reports, 

case studies, mapping tools, and trainings. In 

June 2011, the Workgroup conducted listening 

sessions for a host of stakeholder groups, 

including state and local governments, 

business and industry, environmental groups, 

tribes, and community groups. One listening 

session was conducted entirely in Spanish. 

The Workgroup repeatedly heard about the 

need for early and meaningful public 

engagement. Its members were impressed 

and inspired by the information they received 

about Connecticut, Illinois, and Pennsylvania’s 

Enhanced/Environmental Justice Public 

Participation Policies. The Workgroup is 

drafting guidance to enhance the public 

participation process for EPA-issued 

permits and strongly encourages facilities to 

host pre-application meetings with local 

communities. The Workgroup’s hope is that 

this guidance will be used across the EPA, as 

well as by other federal agencies and states in 

their respective permit processes. 
Plan EJ 2014: Overview 12

Activity 2: Solicit initial existing and recommended tools from internal and 

external stakeholders. 

Activity 3: Create an initial list of priority tools and corresponding 

deliverables for Year 1.

Activity 4: Develop, test, and finalize priority tools for EPA-issued permits.

 Activity 4.1: Develop priority tools that need to be developed, amend 

existing tools, and identify those ready for potential immediate use at 

EPA. 

 Activity 4.2: Identify opportunities to test the draft tools through ongoing permit activities. 

 Activity 4.3: Solicit comments both internally and externally on the 

draft tools. 

 Activity 4.4: Incorporate comments and finalize tools. 

Activity 5: Determine the best format(s) or vehicle(s) to convey and 

implement the final tools (guidance, policy, rulemaking, etc.). 

Activity 6: Create a more detailed timeline for FY 2012-2014 deliverables 

for the workgroup. 

3.3 Advancing Environmental Justice through Compliance 

and Enforcement 

 EPA is committed to taking action to further ensure that our most 

overburdened communities are given particular consideration as we 

implement the Agency’s enforcement and compliance program. Through 

Plan EJ 2014, the Office of Enforcement and Compliance Assurance (OECA) 

intends to focus and accelerate our efforts to identify, assess, and address 

environmental justice concerns in these communities when developing and 

implementing OECA’s program strategies, civil and criminal enforcement 

activities, and compliance activities. Our goal for the next three years is to 

fully integrate consideration of environmental justice concerns into the 

planning and implementation of OECA’s program strategies, case targeting 

strategies, and development of remedies in enforcement actions to benefit 

these communities. We also plan to accelerate our ongoing efforts to 

communicate more effectively with these communities about our 

enforcement actions and program activities. Through these efforts, we 

hope to further advance the Agency’s environmental justice goals of fair 

treatment and meaningful involvement of communities. 

Plan EJ 2014 calls upon EPA to accelerate its ongoing efforts to give full 

consideration to environmental justice issues when developing and 

implementing its enforcement program strategies. For example, OECA 

selected National Enforcement Initiatives for FY 2011-2013 that include 

taking action against sewer overflows, Concentrated Animal Feeding 

Operations (CAFO) that discharge manure to surface or ground waters, and 

facilities that emit excessive amounts of air toxics. These types of facilities 
Plan EJ 2014: Overview 13

and pollution problems often have a disproportionate impact on minority, 

low-income, tribal, or indigenous communities. OECA and the regions, 

working with the U.S. Department of Justice (DOJ), are also pressing for 

remedies in enforcement cases that benefit communities overburdened by 

illegal pollution. OECA will also make additional efforts to provide 

information to overburdened communities about enforcement actions that 

affect those communities, and to provide meaningful opportunities for 

community input on the remedies sought in those enforcement actions.

Implementation Plan Summary 

Goal 

To fully integrate consideration of environmental 

justice concerns into the planning and 

implementation of OECA’s program strategies, case 

targeting strategies, and development of remedies 

in enforcement actions to benefit overburdened 

communities over the next three years. 

Strategies & Activities 

Strategy 1: Advance environmental justice goals 

through selection and implementation of National 

Enforcement Initiatives.

Strategy 2: Advance environmental justice goals through targeting and 

development of compliance and enforcement actions.

 Activity 2.1: Issue internal guidance requiring analysis and 

consideration of environmental justice in EPA’s compliance and 

enforcement program.

 Activity 2.2: Review OECA’s Enforcement Response Policies to 

determine whether any revisions are needed to ensure that 

environmental justice concerns are addressed in case development and 

resolution. 

 Activity 2.3: Reevaluate use of the Environmental Justice Strategic 

Enforcement Assessment Tool (EJSEAT), as appropriate, in response to 

recommendations of the NEJAC and conclusions of the EPA 

Environmental Justice Screening Committee. 

 Activity 2.4: Seek opportunities to advance environmental justice goals 

in implementing the Clean Water Act Action Plan. 

 Activity 2.5: Seek opportunities to advance environmental justice goals 

in conducting the National Enforcement Strategy for Resource 

Recovery and Conservation Act (RCRA) Corrective Action. 

Enforcing the Clean Water Act

An EPA enforcement settlement in December 2010 requires 

that the Cleveland-area Northeast Ohio Regional Sewer District 

take steps to stop the flow of untreated sewage into local 

waterways and Lake Erie. Among other requirements, the 

District is required to take several specific steps to address 

concerns in overburdened communities. For example, the 

District must reduce pollutant discharges much more quickly in 

these areas. 

In addition, several vacant lands will be transformed into green 

space and recreational areas to help capture storm water 

discharges, perhaps leading to increased property values and 

employment opportunities. Also, the District will operate a 

household hazardous waste collection center each month as a 

supplemental environmental project, providing local citizens with 

a place to properly dispose of used motor oil, paints, batteries, 

and other items that could otherwise end up in storm water 

discharges. 

 Activity 1.1: Selection of National Enforcement 

Initiatives for FY 2011-13.

 Activity 1.2: Implementation of National 

Enforcement Initiatives for FY 2011-13.

 Activity 1.3: Selection of National Enforcement 

Initiatives for FY 2014-16.
Plan EJ 2014: Overview 14

 Activity 2.6: Improve compliance at federal facilities where violations 

may impact overburdened communities. 

 Activity 2.7: Develop tools to track facilities with environmental justice 

concerns and report on enforcement actions that address 

environmental justice concerns. 

Strategy 3: Enhance use of enforcement and compliance tools to advance 

environmental justice goals in regional geographic initiatives to address 

the needs of overburdened communities.

 Activity 3.1: Regions will include use of enforcement tools as part of 

integrated problem-solving strategies that are focused on particular 

geographic areas. 

 Activity 3.2: Regions will include use of compliance assistance tools as 

part of integrated problem-solving strategies focused on particular 

geographic areas. 

Strategy 4: Seek appropriate remedies in enforcement actions to benefit 

overburdened communities and address environmental justice concerns.

 Activity 4.1: Increase efforts to address environmental justice concerns 

through use of injunctive relief, including mitigation, and Supplemental 

Environmental Projects in civil enforcement actions, as appropriate.

 Activity 4.2: Increase efforts to benefit affected communities through 

use of community service and the Crime Victims’ Rights Act in criminal 

actions. 

 Activity 4.3: Look for opportunities to work with other federal 

agencies, state and local governments, and the business community to 

complement and leverage community benefits resulting from 

enforcement activities. 

Strategy 5: Enhance communication with affected communities and the 

public regarding environmental justice concerns and the distribution and 

benefits of enforcement actions, as appropriate.

 Activity 5.1: Provide affected communities with information about 

enforcement actions and meaningful opportunities for input on 

potential environmental justice concerns and remedies to be 

implemented.

 Activity 5.2: Improve website information and other public information 

materials to explain EPA’s site cleanup enforcement processes.

 Activity 5.3: Enhance communication of the environmental justice 

benefits of EPA’s enforcement actions.

3.4 Supporting Community-Based Action Programs 

The Agency has learned that communities must be the driver for local 

solutions. However, far too many communities lack the capacity to truly 

affect environmental conditions. As a result, many low-income, minority, 

tribal, and indigenous communities continue to live in the shadows of the 

worst pollution and face some of the harshest impacts. Consequently, EPA 

has implemented numerous programs to support community 

empowerment and provide benefits that range from basic educational and 
Plan EJ 2014: Overview 15

leadership development to comprehensive approaches. These include 

financial assistance programs such as Environmental Justice, Community 

Action for a Renewed Environment (CARE), Brownfields Area-Wide 

Planning, Lead, and Tribal grants, as well as community-based programs 

such as EPA’s Local Climate and Energy, Childhood Asthma, Sustainable 

Communities and Smart Growth, Urban Waters, Superfund, and 

Brownfields programs. 

EPA’s ten regions play a leading role in implementing these programs. 

Plan EJ 2014 builds upon an Agency effort to improve the effectiveness of 

EPA’s community-based programs through better information access, 

coordination, and leveraging. EPA will build upon and leverage Agency 

efforts to promote greater coordination in the use of programs and tools 

that support community empowerment. Through these efforts, EPA will 

make the Agency’s resources more accessible to underserved communities, 

while achieving greater internal efficiency through feedback and better 

understanding of how to implement community-based programs. This 

approach will result in environmental, health, and economic improvements 

in such communities. 
Plan EJ 2014: Overview 16

Implementation Plan Summary 

Goal 

To strengthen community-based programs to engage overburdened 

communities and build partnerships that promote healthy, sustainable, and 

green communities. 

Strategies & Activities 

Strategy 1: Advance environmental justice 

principles by building strong state and tribal 

partnerships through the National Environmental 

Performance Partnership System (NEPPS) and 

National Program Manager (NPM) guidance.

Strategy 2: Identify scalable and replicable elements of successful Agency 

community-based programs and align multiple EPA programs to more 

fully address the needs of overburdened communities.

 Activity 3: Review Agency and key outside community-based 

programs, and existing evaluations of select Agency programs, to 

identify scalable and replicable program elements which encourage 

place-based solutions to environmental justice issues, strengthen and 

promote partnerships, and support healthy and sustainable 

communities. 

 Activity 4: Make recommendations on how EPA can align its 

community-based work, particularly in EPA’s regions to more fully 

address the needs of overburdened communities. 

 Activity 1: Create a workgroup to provide 

recommendations that mutually support 

community involvement, resource/data sharing, 

monitoring/tracking, and training within 

programs implemented through performance 

partnership agreements, tribal agreements, and 

work plans guided by NEPPS and NPM 

documents.

 Activity 2: Develop language for environmental 

justice principles including Title VI guidance (as 

appropriate with all Agency grants) for inclusion 

in the FY 2013 NEPPS and FY 2012 NPM 

guidance through collaboration and discussions 

with Office of Congressional and 

Intergovernmental Affairs (OCIR), Office of Civil 

Rights (OCR), Regional Offices and States.

Promoting Area-Wide Strategies for Brownfields 

Redevelopment and Community Revitalization

EPA is piloting an area-wide planning approach to brownfields in 

23 communities nationwide, recognizing that revitalization of the 

area surrounding a brownfield is just as critical to the successful 

reuse of the property as site assessment, cleanup, and 

redevelopment. Each community will receive up to $175K in 

grants and technical assistance. The pilot program will help 

further community-based partnership efforts within underserved 

or economically disadvantaged neighborhoods by confronting 

local environmental and public health challenges related to 

brownfields, while creating a planning framework to advance 

economic development and job creation.

As one example, the Ironbound Community Corporation in 

Newark, New Jersey, is building upon existing revitalization and 

redevelopment efforts to develop an area-wide plan to create 

sustainable recreational and mixed-use development in an area 

with 100 brownfields. This community is home to over 50,000 

residents and contains the remnants of a once vibrant economy, 

anchored by a large brewery that closed in the 1970s, leaving 

behind contaminated sites and deteriorating infrastructure. The 

area is economically distressed with the poverty rate as high as 

55 percent. 
Plan EJ 2014: Overview 17

Strategy 3: Promote an integrated One EPA presence to better engage 

communities in the Agency’s work to protect human health and the 

environment.

 Activity 5: Target three approaches to promote an integrated One EPA 

presence where EPA will find the best solution by working in a 

consistent and unified way. 

Strategy 4: Foster community-based programs modeled on the 

Community Action for a Renewed Environment (CARE) principles.

 Activity 6: Develop a community-based partners (CBP) program to 

create opportunities in undeserved and overburdened neighborhoods 

for collaborating with private industry, foundations, and other 

institutions to implement the CARE model. 

 Activity 7: Develop a CBP program that caters to grassroots or 

emerging community groups with little to no organizational and/or 

technical capacity. 

 Activity 8: Identify technical assistance resources, program staff, and 

regional staff available to aid overburdened communities with issues 

related to their areas of expertise. 

Strategy 5: Explore how EPA funding, policies and programs can inform 

or help local decision makers to maximize benefits and minimize adverse 

impacts from land use decision making, planning and siting.

 Activity 9: Establish a workgroup and seek stakeholder feedback to 

explore ways the Agency’s work intersects with land use decision

making, planning, and siting. 

Strategy 6: Promote equitable development opportunities for all 

communities.

 Activity 10: Promote equitable development opportunities. 
Plan EJ 2014: Overview 18

3.5 Fostering Administration-Wide Action on Environmental 

Justice 

Everyone in America deserves to live, learn, and work in a healthy and 

sustainable community. EPA seeks to facilitate the active involvement of 

all federal agencies in ensuring healthy, sustainable and green 

communities, as well as equitable development, 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 overburdened 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. 

EO 12898 also called for the establishment of an Interagency Working 

Group on Environmental Justice (EJ IWG), which is chaired by the EPA 

Administrator. EPA worked the White House Council on Environmental 

Quality (CEQ) to reconvene the IWG in September 2010. In addition, EPA 

has a number of federal partnerships established and initiatives underway 

that support a holistic approach to addressing the environmental, social, 

and economic burdens that impact communities. For example, EPA, the 

U.S. Department of Housing and Urban Development, and the U.S. 

Department of Transportation joined together to form the Partnership for 

Sustainable Communities, an unprecedented agreement to coordinate 

federal housing, transportation, and environmental investments; protect 

public health and the environment; promote equitable development; and 

help address the challenges of climate change. All federal agencies are 

responsible for considering environmental justice issues in National 

Environmental Policy Act (NEPA) environmental impact assessments and 

enforcing Title VI of the Civil Rights Act. 
Plan EJ 2014: Overview 19

Implementation Plan Summary 

Goal 

To facilitate the active involvement of all federal agencies in implementing 

EO 12898 by minimizing and mitigating disproportionate negative impacts 

while fostering environmental, public health, and economic benefits for 

overburdened communities. 

Strategies & Activities 

Strategy 1: Assist other federal 

agencies to integrate 

environmental justice in their 

missions, programs, policies, and 

activities.

 Activity 1.1: Chair and convene 

EJ IWG Principal, Deputy, and 

Senior Staff meetings. 

 Activity 1.2: Chair, assist, and 

oversee each agency’s effort to 

update or develop its 

environmental justice strategy. 

 Activity 1.3: Lead the effort to 

organize regional events. 

 Activity 1.4: Develop and 

provide tools that help 

environmental justice and other 

stakeholders identify federal 

information and resources. 

 Activity 1.5: Convene a group of 

senior attorneys from across the 

federal government to promote 

the integration of environmental 

justice into their agencies' 

actions. 

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

interagency legal tools, i.e., National Environmental Policy Act (NEPA) 

and Title VI of the Civil Rights Act of 1964.

National Environmental Policy Act 

 Activity 2.1: Articulate a consistent message about the need to 

incorporate environmental justice into NEPA implementation. 

 Activity 2.2: Enable federal NEPA practitioners to enhance 

consideration and execution of environmental justice requirements in 

NEPA implementation. 

HUD-DOT-EPA Interagency Partnership for 

Sustainable Communities

The Partnership for Sustainable Communities 

is supporting an Environmental Justice 

Showcase Communities project in Jacksonville, 

Florida. This EPA program convenes federal 

agencies, state and local government entities, 

non-governmental organizations, and other 

stakeholders to help underserved communities 

shape their neighborhoods’ futures with 

comprehensive, locally appropriate solutions.

The agencies and stakeholders will support the 

local partners as they establish a community 

health center on a cleaned-up brownfield site 

close to parks, community gardens, and other 

amenities. The area has several Superfund and 

brownfield sites and high rates of heart 

disease, cancer, diabetes, asthma, and infant 

mortality. The health center will work in 

partnership with historically black colleges and 

universities to provide training for health care 

jobs and offer educational programs on healthy 

living. The lessons learned through this and 

other Environmental Justice Showcase 

Communities pilots will help the Partnership 

better use its resources to help underserved 

communities build more sustainable 

neighborhoods with better access to 

opportunities; improved services and amenities; 

and healthier places to live, work, and play.
Plan EJ 2014: Overview 20

Title VI of the Civil Rights Act of 1964 

 Activity 2.3: Consult with DOJ to strengthen the use of Title VI of the 

Civil Rights Act of 1964 by reevaluating 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. 

Strategy 3: Foster healthy and sustainable communities, with an 

emphasis on equitable development and place-based initiatives.

 Activity 3.1: Recommend ways to enhance federal interagency 

coordination in support of healthy and sustainable communities as well 

as equitable development, in areas such as: 

o Green Jobs and Clean Energy. 

o Healthy and Sustainable Communities. 

o Climate Change and Adaptation. 

o Goods Movement. 

Strategy 4: Strengthen community access to federal agencies. 

 Activity 4.1: Conduct community needs inventory pilot. 

 Activity 4.2: Identify targeted training for communities. 

 Activity 4.3: Review results of Federal Partners Meeting. 

 Activity 4.4: Coordinate with Agency community-based coordination 

efforts. 
Plan EJ 2014: Overview 21

4.0 TOOLS DEVELOPMENT AREAS 

This section provides summaries of Plan EJ 2014’s Tools Development 

Areas and their implementation plans. These areas involve issues related 

to science, law, information, and resources. 

4.1 Science 

Under Plan EJ 2014, EPA has committed to building a 

strong scientific foundation for supporting 

environmental justice and conducting 

disproportionate impact analysis, particularly 

methods to appropriately characterize and assess 

cumulative impacts. These efforts will help to ensure 

that EPA brings the best science to decision making 

around environmental justice issues. The science and 

research activities described in Plan EJ 2014 build 

upon discussions and recommendations from EPA’s 

Science of Disproportionate Impacts Analysis 

Symposium (March 17-19, 2010) and an 

Environmental Justice Regulatory Analysis Technical 

Workshop (June 9-10, 2010). The March 2010 

Symposium was the principal event for the Agency to 

identify science needs for environmental justice and 

stimulate innovative research to meet those needs. 

Implementation Plan Summary 

Goal 

To substantially support and conduct research that employs participatory 

principles and integrates social and physical sciences aimed at 

understanding and illuminating solutions to environmental and health 

inequalities among overburdened populations and communities in the 

United States. 

Strategies & Activities 

Strategy 1: Apply integrated transdisciplinary and community-based 

participatory research approaches with a focus on addressing multimedia, cumulative impacts, and equity in environmental health and 

environmental conditions.

 Activity 1.1: Establish an Integrated Transdisciplinary Office of 

Research and Development (ORD) Research Program on Environment 

and Community Health, including the Sustainable and Healthy 

Communities Research Program. 

 Activity 1.2: Develop technical guidance, analytic methods, tools and 

data to advance the integration of environmental justice in EPA 

decision making. 

Building Scientific Capacity Among Tribal 

Environmental Professionals

EPA has a long history of supporting capacity building 

among tribal environmental professionals, primarily through 

its partnership with the Institute for Tribal Environmental 

Professionals (ITEP) at Northern Arizona University. The 

Office of Air and Radiation (OAR) has supported this 

project for over 15 years. Consistent with our trust 

responsibility to tribes, OAR works with Tribes to increase 

their capability to address their environmental concerns. 

OAR supports the training and educational efforts of ITEP 

in the areas of air quality and climate change impacts and 

adaptation planning, as well as the work of the Tribal Air 

Monitoring Support (TAMS) Center, which builds and 

strengthens the technical capacity of tribal staff. The 

TAMS Center cross-trains tribal air professionals on air 

monitoring, indoor air quality, radon and asthma. EPA is 

building on this model to develop an Environmental Justice 

Community Learning Center.
Plan EJ 2014: Overview 22

Strategy 2: Incorporate perspectives from community-based 

organizations and community leaders into EPA research agendas and 

engage in collaborative partnerships on science and research to address 

environmental justice.

 Activity 2.1: Establish a Community Engagement Initiative. 

 Activity 2.2: Re-engage with the NEJAC. 

 Activity 2.3: Support Community-Based Participatory Research (CBPR). 

Strategy 3: Leverage partnerships with other federal agencies on issues 

of research, policy and action to address environmental and health 

disparities. 

 Activity 3.1: Join the Federal Collaboration on Health Disparities. 

 Activity 3.2: Engage with President’s Task Force on Environmental 

Health Risks and Safety Risks to Children. 

Strategy 4: Build and strengthen the technical capacity of Agency 

scientists on conducting research and related science activities in 

partnership with impacted communities and translating research results 

to inform change.

 Activity 4.1: Provide training to EPA scientists on CBPR. 

 Activity 4.2: Build social science capacity within ORD. 

 Activity 4.3: Develop Environmental Justice Risk 

Management Training for the Office of Pesticide Programs 

(OPP). 

Strategy 5: Build and strengthen technical capacity of community-based 

organizations and community environmental justice and health leaders to 

address environmental health disparities and environmental 

sustainability issues.

 Activity 5.1: Build community capacity to address asthma disparities. 

 Activity 5.2: Build tribal community capacity to monitor air quality. 

 Activity 5.3: Increase citizen participation in science and decisions. 

 Activity 5.4: Establish Centers of Excellence on Environment and 

Health Disparities. 

 Activity 5.5: Build diverse environmental workforce and enhance the 

capacities of Minority Academic Institutions (MAI) to engage in 

scientific research and workforce training. 
Plan EJ 2014: Overview 23

4.2 Law 

The Office of General Counsel (OGC) is working with the programs and 

regions to identify opportunities to utilize EPA’s statutory authorities to 

advance environmental justice. Our vision is that the Agency will use law 

as a tool to advance environmental justice. OGC’s advice will help EPA to 

implement forward-leaning environmental justice policies with acceptable 

legal risk and to identify new opportunities to promote their environmental 

justice policy objectives. 

Implementation Plan Summary 

Goal 

To provide legal assistance to EPA policy makers 

and other Agency decision makers to advance 

their environmental justice objectives and 

achieve the Agency’s vision of using the law as a 

tool to advance environmental justice. 

Strategy 

OGC will accomplish its goal of providing legal 

assistance to EPA policy makers and other 

Agency decision makers to advance their 

environmental justice objectives by providing 

legal support to each cross-Agency Focus Area 

workgroup. OGC’s activities will promote a 

sound legal framework for the tools and 

programs developed by the five focus area 

workgroups. OGC will conduct this activity 

contemporaneously with the work of the five 

cross-Agency Focus Areas. 

Activities 

 Activity 1: Counseling attorneys will serve as workgroup members for 

each cross-Agency Focus Area; these attorneys are drawn from OGC 

and the Offices of Regional Counsel (ORC). 

 Activity 2: Regional Counsels and OGC Associate General Counsels will 

convene regularly to identify legal issues and develop advice in support 

of the five focus areas. 

 Activity 3: The EPA’s General Counsel will provide active oversight, 

direction, and decision making on all aspects of this initiative, in 

consultation with EPA’s Senior Leadership.

 Activity 4: OGC will convene a group of senior attorneys from across 

the federal government to promote the integration of environmental 

justice into their agencies’ actions.

Using the National Environmental Policy Act to

Address Environmental Justice

The National Environmental Policy Act (NEPA) is an important tool 

that can be used to advance the goals of environmental justice. A 

1994 Executive Order requires that all federal agencies identify and 

address disproportionately high and adverse human health or 

environmental impacts on minority, low-income and tribal 

populations. In April 2011, the Assistant Administrator of the EPA's 

Office of Enforcement and Compliance Assurance reemphasized 

those requirements in a memo urging EPA offices across the country 

to enhance efforts to consider environmental justice in fulfilling their 

NEPA responsibilities. 

EPA is required to review all Environmental Impact Statements (EIS) 

drafted by federal agencies and to make those reviews public, as 

mandated under Section 309 of the Clean Air Act. This review 

responsibility puts the EPA in a unique position to monitor how well 

Federal agencies comply with the Executive Order. Furthermore, the 

Presidential memo that transmitted the Executive Order states that 

the EPA, “shall ensure that the involved agency has fully analyzed 

environmental effects on minority communities and low-income 

communities, including human health, social, and economic effects.”
Plan EJ 2014: Overview 24

4.3 Information 

EPA’s programs and regions have developed a variety of internal screening 

tools and other Geographic Information System (GIS) applications to 

enhance environmental justice analysis and decision making to better meet 

our responsibilities to protect public health under EO 12898. These 

applications have played an important role as the Agency worked to 

integrate environmental justice into its programs, policies and activities. 

Under Plan EJ 2014, EPA is focused in an Agency-wide effort to develop a 

nationally consistent environmental justice screening tool. In addition, EPA 

is developing a suite of tools, data and services known as EPA’s 

GeoPlatform that will help coordinate and consolidate mapping activities, 

applications, and data across the Agency. The GeoPlatform will support a 

wide variety of uses across the Agency, including components of the 

nationally consistent environmental justice 

screening tool, and other data and applications that 

may be of interest to environmental justice 

stakeholders. 

Implementation Plan Summary 

Goal 

To develop a more integrated, comprehensive, 

efficient, and nationally consistent approach for 

collecting, maintaining, and using geospatial 

information relevant to overburdened 

communities. EPA will accomplish this by: (1) 

developing a common Agency-wide mapping 

platform – the GeoPlatform, (2) creating a 

nationally consistent environmental justice 

screening tool, and (3) incorporating appropriate 

elements of the screening tool into the 

GeoPlatform. 

Strategies & Activities 

Strategy 1: Develop EPA’s GeoPlatform.

 Activity 1: Develop prototype of the EPA Environmental Analyst for 

review. 

 Activity 2: Develop production release of the EPA Environmental 

Analyst. 

 Activity 3: Develop production release of the EPA GeoPlatform 

(including initial data services) for use by Environmental Analyst and 

other GeoPlatform components. 

Tools to Identify Overburdened Populations

During the BP Oil Spill Response

The dynamic nature of the BP oil spill has been a 

challenge for a range of communities along the Gulf –

from hotel operators to fishermen to local community 

leaders. During cleanup activities, EPA and other 

agencies used a variety of Geographic Information 

Systems (GIS) tools to collect information, including 

EJView and GeoPlatform.gov/gulfresponse. EPA 

developed EJView, a public mapping tool, to get a 

snapshot of environmental, health, and other social 

factors that were affecting local communities. 

GeoPlatform.gov/gulfresponse, an online tool developed 

by the National Oceanic and Atmospheric Administration,

EPA, the U.S. Coast Guard, and the U.S. Department of 

Interior, was used to gather close to real time information 

about the response effort. These tools were used to 

identify locations of overburdened communities in 

comparison to areas of waste disposal, pinpoint locations 

where oil had reached the shore, and identify locations of 

community centers where people could get assistance. 
Plan EJ 2014: Overview 25

Strategy 2: Develop a nationally consistent environmental justice 

screening tool.

 Activity 1: Hold regular staff workgroup and project steering 

committee meetings. 

 Activity 2: Develop a set of options to present to Senior Agency 

Officials. 

 Activity 3: Create a working prototype of screening tool. 

 Activity 4: Update the NEJAC on progress. 

 Activity 5: Obtain peer review and public comment on a prototype 

tool. 

 Activity 6: Revise the tool based on comments. 

Strategy 3: Incorporate appropriate elements of the screening tool into 

the GeoPlatform.

 Activity 1: Review screening tool data, methods, and requirements to 

determine which portions may be appropriate to include in the 

GeoPlatform. 

 Activity 2: Incorporate appropriate elements of the prototype 

screening tool into the GeoPlatform. 

 Activity 3: Revise GeoPlatform elements of the tool to be consistent 

with changes made to the prototype tool in response to peer review 

and public comments on screening tool. 

4.4 Resources 

Under Plan EJ 2014, the Office of Administration and Resource 

Management (OARM) focuses on two components: (1) grants and technical 

assistance to support community-based programs, and (2) workforce 

diversity. With respect to grants and technical assistance, OARM seeks to 

develop an efficient and effective system for delivering financial and 

technical assistance to communities to empower them to improve their 

health and environment. OARM’s efforts advance 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, tribal, and indigenous peoples 

to promote equitable development and create healthy and sustainable 

neighborhoods. It also responds to the cross-Agency Focus Area under 

Plan EJ 2014 of Supporting Community-Based Action Programs. With 

respect to workforce diversity, OARM seeks to achieve an inclusive work 

environment by developing an efficient system for the outreach and 

recruitment of potential employees. When EPA recruits and 

retains an inclusive workforce — one that looks like the America it 

serves — and individual differences are respected, appreciated, and 

valued, diversity becomes an organizational strength that contributes to 

achieving results. 
Plan EJ 2014: Overview 26

Implementation Plan Summary 

Grants and Technical Assistance Goal 

To develop an efficient and effective system for delivering financial and 

technical assistance to communities to empower them to improve their 

health and environment. 

Strategies & Activities 

Strategy 1: Increase transparency and efficiency in providing 

community-based grant opportunities. 

Strategy 3: Strengthen grants training for communities.

 Activity 3.1: Create umbrella, basic on-line grants training for 

communities, environmental justice-specific on-line training, and 

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

 Activity 3.2: Develop training modules. 

 Activity 3.3: Obtain informal community feedback as modules 

developed. 

 Activity 3.4: Conduct outreach to the EPA grants management 

community by providing opportunities for review of draft training 

scripts. 

Strategy 4: Improve community awareness of grant competition 

process.

 Activity 4.1: Develop and implement appropriate grant competition 

tools (e.g., listservs, webinars). 

 Activity 4.2: Obtain informal community input through 

Regional/Headquarter websites. 

 Activity 4.3: Work with region and NPMs to develop and implement 

tools. 

Community Action for a Renewed Environment 

Grant Program

The Community Action for a Renewed Environment

(CARE) program is a competitive grant program that 

provides on-the-ground support and funding to help 

revitalize and improve the health of communities in 

sustainable ways. Through CARE, various local 

organizations, including non-profits, businesses, schools 

and governments, create partnerships that create and 

implement consensus-based local solutions to reduce 

releases of pollutants and minimize people’s exposure 

to them. Through CARE, community leaders develop 

expertise in sustaining partnerships and addressing 

environmental issues, providing a strong basis for 

continued future action as other environmental threats 

emerge in the community. Since 2005, CARE has 

provided over $14.5 million in financial assistance to 80

communities in 39 states and territories. CARE offers 

two levels of financial assistance, up to $100,000 for 

Level I and up to $300,000 for Level II grants.

 Activity 1.1: Draft recommendations for improving 

community group access to EPA grant programs to be 

presented to Executive Management Committee (EMC).

 Activity 1.2: Solicit informal feedback from communities 

(e.g., CARE Program workshops).

 Activity 1.3: Conduct outreach to Regions and NPMs via 

conference calls and sharing of drafts.

Strategy 2: Improve delivery of technical assistance to 

communities.

 Activity 2.1: Develop Technical Assistance Center 

approach.

 Activity 2.2: Draft preliminary options to be presented 

to the EMC. 

 Activity 2.3: Obtain senior management guidance on 

initial concepts before obtaining informal feedback from 

communities. 

 Activity 2.4: Conduct outreach to Regions and NPMs via 

conference calls and sharing of drafts.
Plan EJ 2014: Overview 27

Strategy 5: Revise grant policies that are unduly restrictive.

 Activity 5.1: Revise Delegation 1-86 and indirect cost rate policies for 

environmental justice grants. 

 Activity 5.2: Establish simplified Indirect Cost Rate (ICR) policy.

 Activity 5.3: Obtain informal community feedback once draft ICR policy 

developed. 

 Activity 5.4: Conduct outreach to regions and NPMs by providing 

opportunity to comment on draft policy issuance. 

 Activity 5.5: Explore simplification of other policies. 

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

Counsel/Program Office dialogue on community-based grant 

opportunities.

 Activity 6.1: Conduct periodic OGC/ORC/Office of Environmental 

Justice (OEJ) meetings and OGC guidance on scope of communitybased grant authorities. 

 Activity 6.2: Obtain OGC legal guidance on scope of grant authorities. 

 Activity 6.3: Coordinate discussions with larger OGC effort on existing 

legal authorities. 

Strategy 7: Improve timeliness of Brownfields Grant Awards.

 Activity 7.1: Draft recommendations for consistent Brownfields award 

times. 

Workforce Diversity Goal 

To achieve an inclusive work environment by developing an efficient 

system for the outreach and recruitment of potential employees. 

Strategies 

Strategy 1: Increase the diverse pool of qualified applicants.

Strategy 2: Operate under a One EPA approach for recruitment and 

outreach.

Activities 

 Activity 1: Design an efficient Agency-wide outreach strategy. 

 Activity 2: Develop effective marketing materials and strategy. 

 Activity 3: Develop a National Conference Toolkit. 

 Activity 4: Develop a National Outreach Calendar. 
Plan EJ 2014: Overview 28

5.0 PROGRAM INITIATIVES 

As indicated earlier, there are many programs at EPA that actively pursue 

environmental justice goals or produce benefits for overburdened 

communities. Examples of such initiatives include: Community 

Engagement Initiative (Office of Solid Waste and Emergency Response), 

Urban Waters (Office of Water), National Enforcement Initiatives (OECA), 

Air Toxics Rules (OAR), and the U.S. Mexico Border Program (Office of 

International and Tribal Affairs). Over the next year, EPA will designate at 

least one initiative per appropriate program for inclusion in Plan EJ 2014. 

In this way, many existing EPA initiatives can be tailored to better integrate 

environmental justice into their programs and produce greater benefits for 

overburdened communities. The identified initiatives may include those 

developed to implement the Administrator’s other priorities.

6.0 CIVIL RIGHTS 

One effort already under way is implementing Administrator Jackson’s 

priority to improve EPA’s civil rights program. Complying with EPA’s 

statutory civil rights obligations is a critical part of our efforts to advance 

environmental justice. Administrator Jackson has made improving EPA’s 

civil rights program a priority. As part of this effort, EPA is pursuing long 

overdue, vigorous, robust, and effective implementation of Title VI of the 

Civil Rights Act of 1964 and other nondiscrimination statutes. EPA is 

committed to protecting people from discrimination based on race, color, 

or national origin in programs or activities that receive EPA’s financial 

assistance. In June 2011, the Administrator convened a workgroup of 

senior management to assess OCR and EPA’s overarching civil right 

program. The workgroup is charged with making recommendations to 

advance civil rights. The workgroup will look at revamping the civil rights 

office, pursuing effective and timely responses to complaints, and 

developing proactive compliance guidance and strategies. As the 

recommendations are adopted, the agency will develop implementation 

plans, take public comment and finalize the plans as part of EPA’s annual 

work plans under Plan EJ 2014. 

7.0 CONCLUSION 

Plan EJ 2014 is EPA’s roadmap for integrating environmental justice and 

civil rights into its programs, policies, and activities. Through Plan EJ 2014, 

EPA intends to develop a suite of tools to advance such integration. It 

seeks to build stronger relationships with communities overburdened by 

environmental and health hazards and build partnerships that improve 

conditions in such communities. In 2014, EPA will make an assessment of 

its progress in achieving the goals of Plan EJ 2014. Based on this 

assessment, EPA will produce a report on the accomplishments, lessons 

learned, challenges, and next steps for continuing the Agency’s efforts to 

make environmental justice an integral part of every decision. 
Plan EJ 2014: Acronyms 29

APPENDIX 

Plan EJ 2014 Implementation Plans 
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Plan EJ 2014: Appendix, Implementation Plans 33

1. Incorporating Environmental 

Justice into Rulemaking 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of Chemical Safety and Pollution Prevention, 

Office of Policy, Office of Research and Development, 

Office of Environmental Justice, and Region 9 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 34

1.0 INTRODUCTION 

Dirty air, polluted water, and contaminated land have significant effects on 

the health and economic possibilities of the people who live in 

overburdened communities. Administrator Jackson has called on the U.S. 

Environmental Protection Agency (EPA) to develop policies that have a 

measurable effect on the health and environment of overburdened 

populations and communities. The Interim Guidance on Considering 

Environmental Justice During the Development of an Action (Environmental 

Justice in Rulemaking Guidance) and the associated development of 

technical guidance for rulemaking activities, (Environmental Justice 

Technical Guidance), are important tools for answering that call. 

1.1 Goals 

The goal of this implementation plan is to more effectively protect human 

health and the environment for overburdened populations by developing 

and implementing guidance for incorporating environmental justice into 

EPA’s rulemaking process. Specifically, this implementation plan will: 

 Elevate the interim Environmental Justice in Rulemaking on the 

procedural aspects of environmental justice in rulemaking to final 

status. 

 Establish and commence mechanisms to facilitate and monitor 

implementation by National Program Managers (NPMs) and regional 

offices of the Environmental Justice in Rulemaking Guidance to 

maximize its effectiveness. NPMs lead the major EPA offices that are 

responsible for developing regulations protecting air, water, land, and 

ensuring chemical safety. EPA’s regional offices also develop some 

lower tier regulations and, therefore, also need to implement the 

guidance. 

 Develop technical guidance on how to conduct environmental justice 

assessments of rulemaking activities within analytical and decisionmaking frameworks used by EPA to support regulatory development 

(e.g., exposure assessment, benefit-cost analysis). 

Successful implementation of this plan will significantly advance the 

Agency’s commitment to the goals of environmental justice in EPA’s 

rulemaking work to protect human health and the environment. 

Issuing the Environmental Justice in Rulemaking Guidance as an interim 

final document in July 2010 represented a historic accomplishment, 

conveying EPA’s commitment to consider environmental justice concerns in 

the rulemaking process for the first time in EPA’s history. It represents one 

of the Agency’s most important and publically visible endeavors. The 

Environmental Justice in Rulemaking Guidance provides specific, detailed 

instructions for steps that should be taken procedurally to fulfill this 

commitment through EPA’s rule writing process, formally known as the 

Action Development Process (ADP). It provides information to rule writers 

on when during the ADP to consider environmental justice, as well as the 

Goals At-A-Glance

To more effectively 

protect human health and 

the environment for 

overburdened populations 

by developing and 

implementing guidance on 

incorporating 

environmental justice into 

EPA’s rulemaking 

process. 
Plan EJ 2014: Appendix, Implementation Plans 35

types of questions to ask. It outlines multiple steps that every EPA program 

office can take to incorporate the needs of overburdened populations and 

communities into its decision making, scientific analysis, and rule 

development. Complementary to the Environmental Justice in Rulemaking 

Guidance is the Environmental Justice Technical Guidance. This guidance 

will provide technical direction to EPA analysts to aid them in incorporating 

environmental justice into the development of risk assessment, economic 

analysis, and other scientific input and policy choices during the 

development of a rule. 

1.2 Organizational Structure 

Distinct organizational structures are being employed under each goal of 

this implementation plan: 

 Leadership for finalizing the Environmental Justice in Rulemaking 

Guidance is being provided by the Office of Chemical Safety and 

Pollution Prevention (OCSPP), which has reconvened the Agency-wide 

Environmental Justice in Rulemaking Workgroup and its Process 

Guidance Subgroup. The final guidance documents developed by the 

workgroup, and associated issues requiring senior management 

attention, are raised first with the Principals for this effort – the Deputy 

Assistant Administrators (DAAs) or Deputy Regional Administrators 

(DRAs) for OCSPP, Office of Policy (OP), Office of Enforcement and 

Compliance Assurance (OECA), Region 9; and the Associate Assistant 

Administrator for Environmental Justice – and then elevated to the 

Environmental Justice Committee (EJC) and the Executive Management 

Council (EMC) prior to being presented to the Administrator for final 

approval. 

 An Executive Steering Committee (ESC) comprised of senior executives 

from OCSPP, OP, OECA, the Office of Environmental Justice (OEJ), the 

Office of Research and Development (ORD), the Office of Air and 

Radiation (OAR), the Office of Water (OW), the Office of Solid Waste 

and Emergency Response (OSWER), and Region 9; along with the 

Associate Assistant Administrator for Environmental Justice, will 

oversee the implementation, facilitation, and monitoring efforts. 

Those efforts are expected to continue after the guidance documents 

are finalized to promote continuous learning and improvement and to 

ensure effective implementation. 

 The Environmental Justice Technical Guidance is being developed as a 

Tier 1 action under the ADP by an Agency-wide workgroup chaired by 

OP, OEJ, and ORD. As a Tier 1 action, the Administrator or her 

designee is the decision maker at each stage of the ADP.9 This 

workgroup is a subcommittee of the Environmental Justice in 

Rulemaking Workgroup. 

 

9

EPA’s regulatory development process utilizes a system of “tiering” to prioritize actions in terms of 

their potential for large and multimedia effects and ensures early involvement of key Agency personnel. 

Each regulatory action is assigned one of three tiers. Tier 1 denotes the Administrator’s Priority 

Actions, which are the few top actions that demand ongoing involvement of the Administrator and 

extensive involvement of Assistant Administrators and Regional Administrators across the Agency.
Plan EJ 2014: Appendix, Implementation Plans 36

2.0 IMPLEMENTATION 

2.1 Strategies 

Strategies to achieve the goals of this plan are specific to each goal: 

Strategy 1: Finalize the Interim Guidance on Considering Environmental 

Justice During the Development of an Action.

 Assess internal and external comments provided on the interim 

Environmental Justice in Rulemaking Guidance through Agency 

websites. 

 Evaluate documents produced by rule-writing workgroups since the 

Interim Guidance was released to assess the extent to which the 

guidance is being addressed and its effect on EPA’s rulemaking 

decisions. 

 Interview members of rule-writing workgroups, their supervisors, and 

their senior managers to assess the clarity and usefulness of the 

guidance and the burdens associated with its implementation; and 

obtain suggestions for improvement. 

 Revise the Environmental Justice in Rulemaking Guidance for 

presentation to and approval by the EMC, its EJC, and the 

Administrator. 

Strategy 2: Facilitate and monitor implementation of guidance on 

incorporating environmental justice in rulemaking.

 Work with the National Program Managers (NPM) and regions, which 

are primarily responsible for incorporating environmental justice in 

their own rulemaking efforts. 

 Provide training to rule-writing teams, their managers, and decision 

makers. 

 Initiate a continuous learning effort to identify effective practices and 

lessons learned from the NPMs’ ongoing rulemaking efforts.

 Develop and commence implementing a monitoring scheme to assess 

the extent to which the guidance is being applied, the resources being 

devoted to its application, and the effect it is having on rulemaking 

decisions. 

Strategy 3: Develop technical guidance on how to conduct 

environmental justice assessments of rulemaking activities.

 Develop draft technical guidance through an Agency-wide ADP 

workgroup. 

 Establish and conduct a peer consultation on the Draft Environmental 

Justice Technical Guidance with a special panel of EPA’s Science 

Advisory Board (SAB). 
Plan EJ 2014: Appendix, Implementation Plans 37

 Execute an outreach strategy to obtain internal and external comments 

on the Draft Environmental Justice Technical Guidance. 

 Incorporate SAB, EPA, and external comments in developing the Final 

Environmental Justice Technical Guidance for approval by the 

Administrator. 

 2.2 Activities 

The following activities are intended to carry out the strategies identified 

for this implementation plan. 

Strategy 1: Finalize the Interim Guidance on Considering Environmental 

Justice During the Development of an Action.

 Activity 1.1: Announce April closure of public comment period via the 

Environmental Justice listserv. 

o Time Frame: Completed in April 2011. 

 Activity 1.2: Review internal and external comments provided during 

the implementation period when the guidance is in interim status. 

o Time Frame: July 2011. 

 Activity 1.3: Review documents produced by and interview members 

of the EPA rule-writing workgroups. 

o Time Frame: October 2011. 

 Activity 1.4: Revise and release Final Environmental Justice Rulemaking 

Guidance document. 

o Time Frame: 

 Draft to OCSPP, OP, and OAR Principals by end of 

October 2011. 

 Draft to EJC by mid-November 2011. 

 Draft to ESC by end of November 2011. 

 Draft to Administrator by mid-December 2011. 

 Release by end of December 2011. 

Strategy 2: Facilitate and monitor implementation of guidance on 

incorporating environmental justice into rulemaking.

 Activity 2.1: Distribute model training presentations to Agency, NPM, 

and region-specific regulation development and ADP trainers. 

o Time Frame: June 2011. 

 Activity 2.2: Initiate a continuous learning effort to identify effective 

practices and lessons learned from the Agency’s ongoing rulemaking 

efforts. 

o Time Frame: September 2011. 

 Activity 2.3: Develop and commence implementing a monitoring 

scheme to assess the extent to which the guidance is being applied, the 

resources being devoted to its application, and the effect it is having on 

rulemaking decisions. 

o Time Frame: December 2011. 
Plan EJ 2014: Appendix, Implementation Plans 38

Strategy 3: Develop technical guidance on how to conduct 

environmental justice assessments of rulemaking activities.

 Activity 3.1: Establish a cross-Agency Environmental Justice Technical 

Guidance Workgroup. 

o Time Frame: Completed in February 2010. 

 Activity 3.2: Tier the Environmental Justice Technical Guidance as a 

Tier 1 Action in the ADP. 

o Time Frame: Completed in November 2010. 

 Activity 3.3: Develop draft technical guidance on incorporating 

environmental justice in rulemaking. 

o Time Frame: FY 2012. 

 Activity 3.4: Conduct internal and external review of draft technical 

guidance on incorporating environmental justice in rulemaking. 

o Time Frame: FY 2012/2013. 

 Activity 3.5: Develop and release final technical guidance on 

incorporating environmental justice in rulemaking. 

o Time Frame: FY 2013. 

2.3 Community Engagement and Stakeholder Outreach 

The following items constitute key community engagement and 

stakeholder outreach activities for this implementation plan. 

 Consultations at regularly scheduled National Environmental Justice 

Advisory Council meetings and conference calls. 

 Solicitation of internal and external comments on draft guidance 

documents via established websites. 

 Engagement of state, tribal, and local governments through consortia 

and direct contact, to the extent possible. 

 Coordination with outreach activities of other Plan EJ 2014 initiatives. 

 Technical briefings and consultation with a special panel of the EPA 

Science Advisory Board. 

 Consultations at regularly scheduled Children’s Health Protection 

Advisory Committee (CHPAC) meetings. 

 Consultations at regularly scheduled technical conferences and 

meetings. 

2.4 Adjustments 

Interim final and draft guidance documents will be revised as part of a 

process of elevating them to final status and may be subsequently revised 

based on experience and lessons learned during implementation. 
Plan EJ 2014: Appendix, Implementation Plans 39

3.0 DELIVERABLES 

ACTIVITIES DELIVERABLES MILESTONES

Develop Final 

Environmental Justice 

in Rulemaking 

Guidance.

 Report on Summarizing 

Internal and External 

Comments, Rule-Writing 

Documentation Assessment, 

and Experiences of EPA

Rule-Writers in Implementing 

Interim Final Guidance.

 October 

2011

 Draft Final Guidance on 

Considering Environmental 

Justice During the 

Development of an Action.

 November 

2011

 Final Guidance on 

Considering Environmental 

Justice During the 

Development of an Action.

 December 

2011

Facilitate and monitor 

implementation of the 

Environmental Justice 

in Rulemaking 

Guidance.

 Distribute model training 

presentations to Agency, 

NPM, and regional regulation 

development and ADP 

trainers.

 June 2011

 Initiate a continuous learning 

effort to identify effective 

practices and lessons learned 

from the Agency’s ongoing 

rulemaking efforts.

 October 

2011

 Develop and commence 

implementing a monitoring 

scheme to assess the extent 

to which the guidance is 

being applied, the resources 

being devoted to its 

application, and the effect it is 

having on rulemaking 

decisions.

 December 

2011

Develop Draft and Final 

Environmental Justice 

Technical Guidance.

 Draft Final Technical 

Guidance on Considering 

Environmental Justice During 

the Development of an 

Action.

 FY 2013
Plan EJ 2014: Appendix, Implementation Plans 40

4.0 MEASURES 

The milestones established in Section 3.0 above are the performance 

measures which will be used to track progress in implementing this plan. 

These milestones may be augmented by more detailed interim milestones 

as they are established. Implementation of the guidance documents to be 

developed under this plan may support development of future outcome 

and activity measures. 

5.0 REPORTING 

Reporting on progress in implementing this plan will take place on an 

ongoing basis when its scheduled deliverables are completed. Annual 

progress reports will be provided and updates to this implementation plan 

will be made at that time. For information, please contact Mike Burns, 

202-564-8273, Burns.Mike@epa.gov; or Kelly Maguire, 202-566-2273, 

Maguire.Kelly@epa.gov. 
Plan EJ 2014: Appendix, Implementation Plans 41

2. Considering Environmental Justice 

in Permitting 

 

 

 

 

 

September 2011 

Led by 

Office of Air and Radiation, Office of General Counsel, 

and Region 1 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 
Plan EJ 2014: Appendix, Implementation Plans 42

1.0 INTRODUCTION 

The intent of Plan EJ 2014: Considering Environmental Justice in Permitting 

(Environmental Justice Permitting Initiative) is to ensure that 

environmental justice concerns are given as full consideration as possible in 

the decision to issue a permit and the terms of the permits issued under 

existing federal environmental laws. It contemplates a focus on both U.S. 

Environmental Protection Agency (EPA)-issued permits, as well as permits 

issued pursuant to existing federal environmental laws (i.e., federal, state, 

local, or tribal). The Environmental Justice Permitting Initiative seeks to 

identify the best current opportunities for taking environmental justice 

concerns into consideration and to enable EPA to address the complex 

issue of cumulative impacts from exposure to multiple sources and existing 

conditions that are critical to the effective consideration of environmental 

justice in permitting. 

The proposed activities outlined in this implementation plan rely heavily on 

the advice and recommendations presented by the National Environmental 

Justice Advisory Council (NEJAC) from both their most recent response to 

EPA’s permitting charge and numerous relevant prior NEJAC reports. EPA 

recognizes that there has been a considerable amount of work − 

particularly on the NEJAC’s part − advocating for earlier and more effective 

public participation in the permitting process, but that these practices have 

not been widely adopted. We also recognize that although environmental 

justice can be incorporated into the permitting process in a variety of ways, 

there are significant challenges − particularly related to cumulative/multimedia impacts. We therefore seek to truly create a culture within EPA − 

and among other federal, state, local, and tribal permitting agencies – in 

which engaging on issues of environmental justice more readily translates 

into greater protections for overburdened communities. 

EPA’s implementation plan merely describes our process for the 

Environmental Justice Permitting Initiative, with a focus on activities for 

2011 and early 2012. Our proposed deliverables for this time period are a 

cohesive suite of tools for EPA-issued permits (for example, EPA guidance 

on enhanced early public participation) along with a public database of 

many other tools to serve as a resource for EPA, other federal agencies, 

states, local government, tribal governments, facilities, non-profit 

organizations, and communities. This larger database of tools will also 

serve as a starting point for our 2012-2014 activities. We are defining 

“tools” broadly to include not only guidance, but also best practices, 

templates, reports, checklists, case studies, mapping and screening tools, 

protocols, trainings, sample language, and other resources. 

Appendix A of this document contains our initial draft list of potential tools, 

but the list is neither prescriptive nor exhaustive. Over the next few years, 

we may decide not to develop some of these potential tools; similarly, we 

may decide to add new potential tools to the list as we continue to gather 

Goals At-A-Glance

To enable overburdened

communities to have full 

and meaningful access to 

the permitting process 

and to develop permits 

that address 

environmental justice 

issues to the greatest 

extent practicable under 

existing environmental 

laws.
Plan EJ 2014: Appendix, Implementation Plans 43

ideas and suggestions. Throughout the process, however, we will be 

listening to the ideas and experiences of all interested stakeholders, in 

order to leverage the successes and seize on the good work that is already 

occurring on this topic. 

1.1 Goals 

The overarching goals of this Plan are to enable overburdened 

communities to have full and meaningful access to the permitting process 

and to develop permits that address environmental justice issues to the 

greatest extent practicable. 

To achieve our goals, the Environmental Justice Permitting Initiative will 

“*i+dentify and develop tools to support the consideration of environmental 

justice during implementation of permitting programs” to reduce 

“exposures for those at the greatest risk,” as stated in the Fiscal Year (FY) 

2011-2015 EPA Strategic Plan, Cross-Cutting Fundamental Strategy: 

Working for Environmental Justice and Children’s Health (Strategic Plan).10

 

Our goals help to fulfill:

 Executive Order 12898, “Federal Actions to Address Environmental 

Justice In Minority Populations and Low-Income Populations,” which 

tasks each federal agency with “achieving environmental justice as 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 population.”11

 

 The Administrator’s priority of Expanding the Conversation on 

Environmentalism and Working for Environmental Justice, which 

heralds “a new era of outreach and protection for communities 

historically underrepresented in EPA decision making” and calls for 

“includ[ing] environmental justice principles in all of our decisions.”12 

 EPA’s mission to protect human health and the environment.

1.2 Organizational Structure 

The success of this Environmental Justice Permitting Initiative will depend 

on participation from many offices within EPA, both at Headquarters and 

the regions, as well as numerous external stakeholders (see Section 2.3, 

Community Engagement and Stakeholder Outreach). 

 

10 U.S. Environmental Protection Agency, FY 2011-2015 EPA Strategic Plan: Achieving Our Vision, 

September 30, 2010. Available at: http://www.epa.gov/planandbudget/strategicplan.html. 

11 Clinton, William J., Executive Order 12898, “Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations,” February 11, 1994, Federal Register 59, No. 32: 

7629.

12 Jackson, Lisa P., “Seven Priorities for EPA’s Future.” January 12, 2010. Available at: 

http://blog.epa.gov/administrator/2010/01/12/seven-priorities-for-epas-future/. 
Plan EJ 2014: Appendix, Implementation Plans 44

The Office of Air and Radiation has been designated the Headquarters lead. 

The Office of General Counsel has agreed to act as co-lead. Region 1 is the 

Lead Region. Staff and managers from these three offices, with guidance 

from the Office of Enforcement and Compliance Assurance/Office of 

Environmental Justice, have formed a Steering Committee to manage the 

Environmental Justice Permitting Initiative. 

The Steering Committee is chaired by the Principal Deputy Assistant 

Administrator, Office of Air and Radiation; the Associate General Counsel, 

Cross-Cutting Issues Law Office, Office of General Counsel; and the Deputy 

Regional Administrator, Region 1. 

The Environmental Justice Permitting Initiative has a small group composed 

of key senior EPA Headquarters and regional leaders (Senior Leaders) to 

provide high level recommendations as well as a cross-Agency workgroup 

of EPA Headquarters and regional staff to do the work. The workgroup 

contains staff from every EPA region, as well as staff from the Office of Air 

and Radiation, the Office of Enforcement and Compliance Assurance, the 

Office of Environmental Information, the Office of General Counsel, the 

Office of International and Tribal Affairs, the Office of Research and 

Development, the Office of Solid Waste and Remediation, and the Office of 

Water. 

Staff support for the Environmental Justice Permitting Initiative is provided 

the Office of Policy Analysis and Review, Office of Air and Radiation. 
Plan EJ 2014: Appendix, Implementation Plans 45

2.0 IMPLEMENTATION 

The strategies and activities outlined below describe the charge to the 

Environmental Justice Permitting Workgroup over the next several years. 

In the meantime, we strongly encourage offices and individuals at EPA and 

external to the Agency to continue their ongoing practice of furthering 

integration of environmental justice into the permitting process (e.g., 

regional review of state permits). Indeed, we encourage offices and 

individuals to share new issues, potential tools, and recommendations with 

the workgroup and communicate lessons learned. 

2.1 Strategies 

Strategies to achieve the goals of this implementation plan are specific to 

each goal: 

Strategy 1: Develop tools that will enhance the ability of overburdened

communities to participate fully and meaningfully in the permitting 

process. 

These tools will focus on ensuring that overburdened communities are fully 

informed about the potential impacts of permitted activities and 

understand the information they receive. In addition, we will explore ways 

of promoting regular dialogue between overburdened communities and 

the regulated facilities at all stages of the permitting process, including 

early involvement, and after a permit has been issued. 

Strategy 2: Concurrently with Strategy 1, develop tools to assist 

permitting authorities to meaningfully address environmental justice in 

permitting decisions.

These tools will focus on how environmental justice can be incorporated 

into the permitting process, including the range of potential permitting 

measures that can be used to avoid or reduce potential environmental 

justice effects. 

Strategy 3: Implement these tools at EPA and work with others to do the 

same. 

We will first focus on implementing tools related to EPA-issued permits. 

Thereafter, we will engage in supporting and encouraging other federal 

agencies, as well as state, local, and tribal permitting authorities, to 

develop environmental justice strategies for their environmental 

permitting decisions. 
Plan EJ 2014: Appendix, Implementation Plans 46

2.2 Activities 

All of the activities below support our goal to develop and implement tools 

to better enable overburdened communities to have full and meaningful 

access to the permitting process and for permits to address environmental 

justice issues to the greatest extent practicable. These tools include 

guidance, best practices, templates, reports, checklists, case studies, 

mapping and screening tools, protocols, trainings, and sample language. 

Activity 1: Conduct initial internal research to begin to create a 

preliminary list of potential tools and finalize the implementation plan

(March-June 2011, Completed).

 Activity 1.1: Conduct an initial literature review − including a review of 

previous NEJAC papers, publications, and other recommendations − to 

identify an initial list of existing and needed tools (Completed, see 

Appendix A). 

 Activity 1.2: Convene a cross-Agency workgroup. The workgroup met 

for the first time on March 7, 2011, and will carry out the proposed 

activities in this implementation plan (Completed). 

 Activity 1.3: Review and evaluate the permitting process for a 

minimum of three federal permits with environmental justice 

considerations, for use as case studies to identify existing and needed 

tools13 (Completed). The workgroup reviewed the permitting process 

for three federal permits and will continue to review other permits to 

solicit lessons learned and guide our next steps. 

 Activity 1.4: Coordinate overlapping strategies with other Plan EJ 

2014 elements and consider integrating and leveraging activities 

between them (Ongoing). 

 Activity 1.5: Issue the final implementation plan (Completed). 

Activity 2: Solicit initial existing and recommended tools from internal 

and external stakeholders (March-June 2011). 

Individual EPA programs and regions, as well as other federal agencies, 

states, local agencies, and tribal governments, have already developed and 

implemented numerous tools that consider environmental justice issues 

during the permitting process. These entities as well as community and 

advocacy groups, industry and trade organizations, and experts have firsthand experience and knowledge about the relevant issues and ideas for 

what tools are needed. Outreach to these experts provides the workgroup 

an important opportunity to gather the tools and begin to identify the most 

effective and replicable ones. 

In addition to reviewing all of the comments submitted during the formal 

public comment period (which ended Friday, April 29, 2011), the 

workgroup solicited additional comments via an external e-mail and an 

 

13 The Strategic Plan charges the Environmental Justice and Permitting Initiative to “Convene a crossAgency workgroup on the consideration of environmental justice in federal EPA permits and review, at 

a minimum, three federal permits with environmental justice considerations (by September 2011).”
Plan EJ 2014: Appendix, Implementation Plans 47

internal EPA memo focused on collecting ideas for tools and informative 

case studies. From these responses, we followed up with individuals and 

organizations to get more detailed information and comments. We also 

conducted targeted outreach to national umbrella groups via meetings, 

conference calls, and direct emails; and hosted a series of public listening 

sessions in June 2011. Finally, we set up a NEJAC Permitting Workgroup 

that has already met three times to provide guidance throughout our 

process; and we will continue to gather information from all stakeholders 

and involve them in our work. 

Activity 3: Create an initial list of priority tools and corresponding 

deliverables for Year 1 (June 2011).

Activity 4: Develop, test, and finalize priority tools for EPA-issued permits 

(June 2011-April 2012).

 Activity 4.1: Develop priority tools, amend existing tools, and identify 

those ready for potential immediate use at EPA (June-October 2011). 

 Activity 4.2: Identify opportunities to test the draft tools through 

ongoing permit activities (June-October 2011). 

 Activity 4.3: Solicit comments both internally and externally on the 

draft tools (October 2011-February 2012).

 Activity 4.4: Incorporate comments and finalize tools (April 2012).

Activity 5: Determine the best format(s) or vehicle(s) to convey and 

implement the final tools (guidance, policy, rulemaking, etc.) (December 

2011/early 2012).

Activity 6: Create a more detailed timeline for 2012-2014 deliverables 

for the workgroup (early 2012).

Per Activity 5, we intend to finalize the first suite of tools by early 2012. 

We will then focus on implementing these tools for EPA-issued permits via 

trainings and other efforts to test, revise, and institutionalize their use at 

EPA (while also looking for additional opportunities to develop more tools). 

In 2012-2014, our anticipated activities may include: 

 Implement first suite of tools via trainings at EPA. 

 Implement “train-the-trainers” seminars to help train community 

organizations and other interested entities on newly developed tools. 

 Continually review the effectiveness of the tools and trainings, update 

and revise existing tools, develop additional tools, and update and 

revise trainings. 

 Engage in supporting and encouraging other federal agencies as well as 

state, local, and tribal permitting authorities to achieve environmental 

justice goals for their permit decisions. 
Plan EJ 2014: Appendix, Implementation Plans 48

2.3 Community Engagement and Stakeholder Outreach 

The workgroup, with assistance from the Small Business Ombudsman and 

the Office of Environmental Justice, has developed a plan for early and 

continued stakeholder involvement. Our efforts will include public 

comment periods, requests for information, meetings, conference calls, 

and direct and targeted outreach to internal and external experts and 

stakeholders to seek their early and continued input. Activity 2, above, 

describes the workgroup’s efforts to date, including public listening 

sessions conducted in June 2011 and the formation of a NEJAC Permitting 

Workgroup to provide guidance throughout our process. 

Because of the states’ unique and important role in permitting, EPA has 

emphasized, and will continue to emphasize, early and ongoing outreach to 

state environmental departments to collect their success stories and 

lessons learned. EPA will work with them to identify potential 

opportunities to test draft tools (see Activity 4.2) and specifically seek out 

their comments and suggestions (see Activity 4.3). 

 EPA also welcomes comments and participation from all stakeholders and 

has already reached out to these stakeholder groups as well as others: 

 Association of State and 

Territorial Solid Waste 

Management Officials 

(ASTSWMO).

 Association of State & Interstate 

Water Pollution Control 

Administrators (ASIWPCA).

 Business organizations and trade 

associations.

 Clean Air Act Advisory Committee 

(CAAAC).

 Community advocacy groups.

 Environmental Council of the 

States (ECOS).

 Ground Water Protection Council 

(GWPC).

 Interagency Working Group on 

Environmental Justice.

 National Association of Clean Air 

Agencies (NACAA).

 National Association for Clean 

Water Agencies (NACWA).

 National Tribal Operations 

Committee (NTOC).

 North American Hazardous 

Materials Management 

Association (NAHMMA).

 Northeast Waste Management 

Officials' Association (NEWMOA).

 Other federal agencies and state, 

local, and tribal permitting 

agencies.

We will also reach out to these key stakeholder groups in the near future: 

 Asian American Native American Pacific Islanders Servicing Institutions 

(AANAPISIs). 

 Hispanic Servicing Institutions (HSIs). 

 Historical Black Colleges and Universities (HBCUs). 

 Tribal Colleges and Universities (TCUs). 
Plan EJ 2014: Appendix, Implementation Plans 49

3.0 DELIVERABLES 

ACTIVITIES DELIVERABLES MILESTONES

Activity 1.1: Conduct an initial 

literature review – including a 

review of previous NEJAC 

papers, publications, and other 

recommendations – to identify 

an initial list of existing and 

needed tools.

 See Appendix A.  Completed

Activity 1.2: Convene a crossAgency workgroup.

 The workgroup met for 

the first time on March 7, 

2011, and will continue 

to meet throughout the 

duration of this project. 

 Completed

Activity 1.3: Review and 

evaluate the permitting process 

for a minimum, of three federal 

permits with environmental 

justice considerations, for use 

as case studies to identify 

existing and needed tools.

 Identification of a 

minimum of three federal 

permits with 

environmental justice 

considerations.

 Completed

 List of existing and 

needed tools from the 

case studies.

 Completed

Activity 1.4: Coordinate 

overlapping strategies with 

other Plan EJ 2014 crossAgency elements and consider 

integrating and leveraging 

activities between them. 

 Regular meetings with 

other cross-Agency 

workgroups.

 Ongoing

Activity 1.5: Issue the final 

implementation plan. 

 Final implementation 

plan.

 Completed

Activity 2: Solicit existing and 

recommended tools from 

internal and external 

stakeholders.

 List of existing and 

needed tools from 

internal and external 

stakeholders. 

 June 2011 

Activity 3: Create an initial list 

of priority needed tools and 

corresponding deliverables for 

Year 1.

 Initial list of tools and 

corresponding 

deliverables for Year 1.

 June 2011

Activity 4.1: Develop priority 

tools, amend existing 

resources, and identify those 

ready for potential immediate 

use at EPA.

 Initial suite of draft tools.  October 

2011

Activity 4.2: Identify 

opportunities to test the draft 

tools through ongoing permit 

activities, and solicit comments 

and recommendations.

 Comments and 

recommendations based 

on our initial testing of 

the draft tools.

 October 

2011
Plan EJ 2014: Appendix, Implementation Plans 50

ACTIVITIES DELIVERABLES MILESTONES

Activity 4.3: Solicit additional 

comments both internally and 

externally.

 Additional comments.  February 

2012

Activity 4.4: Incorporate 

comments and finalize tools.

 Revised tools.  April 2012

Activity 5: Determine the best 

format(s) or vehicle(s) to 

convey and implement the 

recommendations and tools 

(finalization, policy, rulemaking, 

etc.).

 Decision on how best to 

convey and implement 

the tools.

 Early 2012

Activity 6: Create a more 

detailed timeline for 2012-2014 

deliverables for the workgroup.

More detailed timeline that 

may include:

 Implement first suite of 

tools via trainings at 

EPA.

 Implement “train-thetrainers” seminars to 

help train community 

organizations and other 

interested entities on 

newly developed tools. 

 Continually review the 

effectiveness of the tools 

and trainings, update 

and revised existing 

tools, develop additional 

tools, and update and 

revise trainings. 

 Engage in supporting 

and encouraging other 

federal agencies as well 

as state, local and tribal 

permitting authorities to 

achieve environmental 

justice goals for their 

permit decisions. 

 2012

4.0 REPORTING 

We will report annually on progress in implementing the strategies 

outlined in this implementation plan and will update, as necessary, the 

activities and deliverables outlined here. For information, please contact 

Michelle Roos, 202-573-2549, Roos.Michelle@epa.gov
Plan EJ 2014: Appendix, Implementation Plans 51

Potential Tools 

This implementation plan outlines a process by which the workgroup will 

research, solicit ideas for, prioritize, and then develop a suite of tools to 

better enable overburdened communities to have full and meaningful 

access to the permitting process and for permits to address environmental 

justice issues to the greatest extent practicable. For the first year, our 

activities will focus on developing a cohesive suite of tools most applicable 

to EPA-issued permits, and also collecting a larger set of tools for a public 

database. 

Our initial research, request for comments, meetings, conference calls, and 

one-on-one conversations have revealed this list of potential tools for EPAissued permits, but the list is neither prescriptive nor exhaustive. Over the 

next few years of the Environmental Justice and Permitting Initiative, we 

may decide not to develop some of these potential tools; similarly, we may 

decide to add new potential tools to the list as we continue to gather ideas 

and suggestions. Below is merely a draft list in the early stages of our 

multi-year process. Please note that some of the proposed tools might be 

applicable only to specific permit types (e.g., Prevention of Significant 

Deterioration [PSD], National Pollutant Discharge Elimination 

System [NPDES], Resource Recovery and Conservation Act [RCRA], etc.): 

Public Involvement/Communication 

 Environmental Justice and Permitting Enhanced Public Participation 

Guidance (potentially with a strong recommendation for preapplication public meetings). 

 Environmental Justice and Permitting Public Participation Fact Sheet 

and Website in support of the above-mentioned guidance. 

 Environmental Justice and Permitting Public Participation Outreach 

Template and Checklist in support of the above-mentioned guidance. 

 Updated and condensed guidance, best practices, and checklists for 

effective means of conducting public outreach and notification, 

potentially including: 

o Public notifications outside of newspapers (multi-media press 

releases and advertisements, use of internet and SMS, but not 

exclusive reliance on such technologies). 

o Documents written in plain language. 

o Translations of documents in appropriate languages. 

o Direct and targeted outreach to community organizations and 

institutions. 

o Making documents physically accessible and free to 

communities. 

o Proving per diem or other financial resources for community 

members to attend meetings. 

o Scheduling meetings during non-working hours. 

o Providing third party attorneys and scientists as resources for 

communities. 
Plan EJ 2014: Appendix, Implementation Plans 52

o Periodic engagement and notification throughout the 

permitting process, including when there are changes to the 

scope of the permit application or when environmental studies 

are taking place. 

o Model processes to improve information flow between the 

facility, community, and permitting authority. 

 Web-based, searchable, updated contact lists, by EPA region, of 

community organizations and tribal government and indigenous 

organizations to facilitate outreach. 

 Guidance on developing long-term communication protocols with 

specific overburdened communities that reflect the communities’

preferences for how to receive information and provide feedback into 

permitting decisions. 

 Decision tools to assist all parties in understanding the nature of 

disproportionate impacts and mitigating effects of permitting 

measures. 

 The development of an Environmental Justice Permit Social Network 

site (a one-stop shop/central point of communication run by a permit 

writer to gather all relevant background materials and better 

communicate with stakeholders – via postings and Really Simple 

Syndication [RSS] feeds). 

 Permit process descriptions of when, where, and how the public can 

get involved. 

 Guidance on translation issues. 

 Guidance for facilities on creating a real dialogue with communities 

early on in the process (potentially including identifying ways to talk 

outside of permit actions, avoiding an adversarial relationship, and 

suggestions for community benefit projects). 

 Guidance on how to communicate cumulative impacts and/or risk 

assessments to the community. 

 Guidance for EPA on providing quarterly or other regular updates to 

communities and organizations on environmental justice issues, 

responses and actions taken, and trends. 

Permit Process 

 Permit Checklist (possibly in different languages and in plain language). 

 Permit Process Flowchart (possibly including staff contact information 

per region and media office). 

 Guidance including case studies on if/when, where and how to conduct 

an environmental justice analysis or assessment and how to integrate 

these into permit conditions, mitigation actions, and/or clean-up 

activities outside of permitting. 

 Guidance on how environmental justice analyses/assessments can be 

integrated into other existing assessment requirements for permitting.

 Guidance on using existing and proposed EPA screening tools (including 

EJScreen, EJView, Community-Focused Exposure and Risk Screening 

Tool [C-FERST], Census Tract Ranking Tool for Environmental Justice 
Plan EJ 2014: Appendix, Implementation Plans 53

[CenRANK], Environmental Justice Strategic Enforcement Tool [EJSEAT], 

etc.) in the permitting process. 

 Guidance, methodology and/or tools to conduct cumulative impacts 

analysis. 

 Guidance/protocols on integrated permitting approaches, including the 

coordination of permitting actions, public comments periods, public 

notices, meetings, and hearings per facility and/or community between 

numerous permitting actions and/or across media. 

 Guidance/tools to conduct exposure-based (health effects) modeling 

and assessments, and how to integrate those results into permits. 

 Best practices, guidance, and trainings on using a variety of existing 

tools in new ways to better address environmental justice concerns 

(best available control technology [BACT]; offsets; monitoring, 

recordkeeping, and reporting; startups, shutdowns, and malfunctions 

[SSMs]; lower potential to emit; AP-42 emissions factors,14 and Clean 

Air Act Title V operating permit approvals). 

 Guidance based on lessons learned from watershed analysis processes 

(total burden analysis, cross-media effects, etc.). 

Permit Conditions – How to Integrate Environmental Justice 

into Actual Permit Conditions 

 Best practices, guidance, and trainings on developing permits to 

include issues important to local communities 

 Resources to facilitate and/or fund the placement of more fenceline 

and community-based monitors in overburdened communities. 

 Best practices, guidance, trainings, and protocols on developing permit 

conditions to better address and protect indigenous peoples’ cultural 

and subsistence resources. 

 Guidance on how to conduct traditional knowledge information 

gathering and how to integrate that into permit conditions. 

 Protocols for factoring environmental justice into permit conditions, 

regardless of the level of public participation. 

 Best practices, guidance, and trainings on minimizing issuance of 

emergency permits. 

Interagency and Government-to-Government Guidance and 

Protocols 

 Guidance, protocols, and trainings for utilizing the role of the 

Interagency Working Group for Environmental Justice to work across 

federal agencies on permits on tribal lands. 

 Guidance on how to integrate government-to-government consultation 

and environmental justice executive orders and expectations into 

permitting processes. 

 

14 An emissions factor is the formula EPA uses to calculate the emissions from key source categories. 

AP-42 is the document EPA compiles the factors into. It is used by industry and states to develop 

emissions inventories and project emissions from sources, usually in the permitting process to set 

emissions limits. 
Plan EJ 2014: Appendix, Implementation Plans 54

 Guidance on developing partnerships with states that support more 

direct collaboration with communities in the permitting process. 

 Guidance on assisting other federal agencies to integrate 

environmental justice into their environmental permitting decisions. 

 Guidance on how to conduct joint processing agreements across 

permitting authorities (including joint comment periods and hearings 

to be held, and final permits to be issued on a cooperative basis). 

Education/Training 

 Expansion of EPA environmental justice trainings, including: 

o Environmental Justice Fundamentals. 

o Environmental justice and permitting (for all media). 

o Online trainings. 

 Community-based trainings, resources, and websites, including: 

o Permitting processes (for all media). 

o Preparing public comments. 

o Environmental justice assessment or screening tools. 

o Leadership development. 

o Job skills relevant to local industry and facility needs. 

o Advanced legal training on major statues. 

 A network of EPA experts accessible to the public, hotline of experts, 

and/or on-line question-and-answer (Q&A) portal on issues of 

importance to environmental justice and permitting. 

 Technical assistance resources. 

 A collective learning forum and regular national conference call(s) for 

EPA staff and managers responding to specific permit challenges. 

“Outside” of Traditional Permitting

 Guidance and trainings on using resources and programs outside of 

permitting including: 

o Helping communities develop and adopt community-specific, 

comprehensive environmental justice plans. 

o Community Action for a Renewed Environment (CARE). 

o Encouraging the creation of Supplemental Environmental 

Project (SEP)-like mitigation projects (diesel retrofits, off-site 

street sweeping, tree planting, landscaping, public playgrounds 

and green spaces, etc.). 

o Good Neighbor/Environmental Benefit Agreements. 

o Performance Partnership Agreements. 

o Memoranda of Agreement/Understanding involving EPA, 

communities, facilities; and state, local, or tribal governments. 

o Increasing and maintaining active listening, engagement, and 

follow-up with communities outside of permitting actions. 

o Creating plain language summaries of proposed or existing 

permit-related regulations that have a greater impact on 

overburdened communities, and/or a plain language guide for 
Plan EJ 2014: Appendix, Implementation Plans 55

rulemaking with the purpose of educating citizens on how to 

influence the rulemaking process in a meaningful way. 

Cross-Cutting/Other 

 Environmental justice and permitting e-Library (i.e., an 

online/searchable database of tools organized by key features to serve 

as a resource to permit writers and the public looking for tools and 

ideas that have been used successfully and could be replicated). 

 Guidance, trainings, and other resources on making better use of other 

EPA roles, such as oversight, in which EPA affects how other permitting 

authorities implement federal permitting requirements. 

 General and comprehensive guidance on how to incorporate 

environmental justice into all aspects of permitting. 
Plan EJ 2014: Appendix, Implementation Plans 56

3. Advancing Environmental Justice 

through Compliance and Enforcement 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of Enforcement and Compliance Assurance 

and Region 5 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 
Plan EJ 2014: Appendix, Implementation Plans 57

1.0 INTRODUCTION 

This implementation plan sets forth goals, strategies, and activities to 

advance environmental justice through compliance and enforcement, 

under the U.S. Environmental Protection Agency (EPA)’s Plan EJ 2014. It 

was developed by the Office of Enforcement and Compliance Assurance 

(OECA) and EPA Region 5, as Lead Region for OECA for Fiscal Year (FY) 

2011-13, in consultation with all EPA regions, the Office of Environmental 

Justice, and the Office of General Counsel. 

1.1 Goals 

OECA and the EPA regions, in collaboration with other EPA offices and the 

U.S. Department of Justice (DOJ), are committed to taking action to further 

ensure that our most overburdened communities are given particular 

consideration as we implement the Agency’s enforcement and compliance 

program. Through this implementation plan, we intend to focus and 

accelerate our efforts to identify, assess, and address environmental justice 

concerns in these communities when developing and implementing OECA’s 

program strategies, civil and criminal enforcement activities, and 

compliance activities. 

Our goal for the next three years is to fully integrate consideration of 

environmental justice concerns into the planning and implementation of 

OECA’s program strategies, case targeting strategies, and development of 

remedies in enforcement actions to benefit these communities. We also 

plan to accelerate our ongoing efforts to communicate more effectively 

with these communities about our enforcement actions and program 

activities. Through these efforts, we hope to further advance the Agency’s 

environmental justice goals of fair treatment and meaningful involvement, 

and to help address environmental justice concerns in overburdened 

communities. 

1.2 Organizational Structure 

OECA and Region 5 (as OECA Lead Region) share responsibility for 

developing this implementation plan. This work is co-chaired by OECA’s

Principal Deputy Assistant Administrator and Region 5’s Deputy Regional 

Administrator. The co-chairs called upon OECA’s standing Environmental 

Justice Council, consisting of the Directors and/or Deputy Directors of all 

OECA offices, the Lead Region Enforcement and Environmental Justice 

Manager, and supporting staff to develop this plan. The Associate General 

Counsel, Cross-Cutting Issues Law Office, Office of General Counsel, 

participates regularly in the OECA Environmental Justice Council meetings 

and has been of invaluable assistance in developing this plan. 

Goals At-A-Glance

To fully integrate 

consideration of 

environmental justice 

concerns into the planning 

and implementation of 

OECA’s program 

strategies, case targeting 

strategies, and 

development of remedies 

in enforcement actions to 

benefit overburdened 

communities. 
Plan EJ 2014: Appendix, Implementation Plans 58

OECA and regional managers conducted an open discussion of this plan at 

the January 26, 2011, Senior Enforcement Managers meeting in New 

Orleans, Louisiana. Following that discussion, the draft plan was revised to 

incorporate agreed-upon modifications and additions. OECA and all EPA 

regions will use this implementation plan as a dynamic document, making 

improvements as we learn through experience in implementation. 
Plan EJ 2014: Appendix, Implementation Plans 59

2.0 IMPLEMENTATION 

2.1 Strategies 

OECA has five major strategies for Advancing Environmental Justice 

through Compliance and Enforcement: 

 Advance environmental justice goals through selection and 

implementation of National Enforcement Initiatives. 

 Advance environmental justice goals through targeting and 

development of compliance and enforcement actions. 

 Enhance use of enforcement and compliance tools to advance 

environmental justice goals in regional geographic initiatives to address 

the needs of overburdened communities. 

 Seek appropriate remedies in enforcement actions to benefit 

overburdened communities and address environmental justice 

concerns. 

 Enhance communication with affected communities and the public 

regarding environmental justice concerns and the distribution and 

benefits of enforcement actions, as appropriate. 

2.2 Activities 

Strategy 1: Advance environmental justice goals through selection and 

implementation of National Enforcement Initiatives.

Background. Every three years, OECA selects a limited number of high 

priority national environmental and compliance problems to address 

through concentrated, nationwide enforcement efforts. In selecting these 

areas of focus, OECA looks for important environmental and public health 

problems that are caused, at least in part, by widespread failure of 

regulated sectors to comply with federal environmental laws, where it

believes that a concentrated federal enforcement effort can make a 

difference in correcting violations and reducing pollution. OECA and the 

regions solicited input from state agencies to identify potential areas of 

focus, and sought public comment on the final list of proposed candidates. 

The selected areas of focus are called “National Enforcement Initiatives.”

OECA has been, and continues to be, committed to taking environmental 

justice factors into consideration when it selects and implements these 

National Enforcement Initiatives. One of OECA’s primary program goals is 

to aggressively go after pollution problems that make a difference to 

communities, and we place a high priority on benefits to overburdened 

communities in selecting our National Enforcement Initiatives. 
Plan EJ 2014: Appendix, Implementation Plans 60

 Activity 1.1: Selection of National Enforcement Initiatives for FY 2011-

13. In 2010, OECA selected the following six National Enforcement 

Initiatives for implementation in FY 2011-2013 after input from the 

public, states, and tribes: 

o Keeping raw sewage and contaminated stormwater out of our 

nation’s waters.

o Preventing animal waste from Concentrated Animal Feeding 

Operations (CAFO) from contaminating surface and ground 

waters. 

o Cutting toxic air pollution that affects communities’ health.

o Reducing widespread air pollution from the largest sources, 

especially the coal-fired utility, cement, glass, and acid sectors. 

o Reducing pollution from mineral processing operations. 

o Assuring energy extraction sector compliance with 

environmental laws. 

In selecting these areas of focus, OECA gave significant weight to problems 

that affect overburdened communities. For example, raw sewage 

discharges from municipal sewer systems often affect poor and minority 

communities by contaminating urban waters or causing sewage backups 

into their homes. CAFOs are often located near poor rural communities, 

and animal waste that gets into ground water can contaminate nearby 

residents’ drinking water supplies. Toxic air pollution can affect the health 

of poor and minority communities that often are located closest to 

industrial facilities with toxic air emissions. Widespread air pollution from 

coal-fired power plants and other industries can travel long distances and 

contributes to respiratory illnesses, such as asthma, that afflict poor and 

minority populations and children. Large mineral processing facilities, 

which can cause significant contamination of ground and surface waters 

with hazardous waste, are often located near poor and minority 

communities. Energy extraction activities, which often occur on or near 

tribal lands in the west, can cause air or water pollution problems that 

affect tribal communities. 

 Activity 1.2: Implementation of National Enforcement Initiatives for FY 

2011-13. OECA will look for opportunities to address environmental 

justice concerns as it implements the Agency’s National Enforcement 

Initiatives for FY 2011-13. A “Strategy Implementation Team,” 

consisting of OECA Headquarters and regional representatives, is 

responsible for developing implementation strategies and performance 

measures for each of the National Enforcement Initiatives. Each 

initiative’s strategy will consider how environmental justice concerns 

can be addressed in carrying out its activities, e.g., by giving priority in 

case selection to overburdened communities affected by the pollution 

problems we seek to address in each of the initiatives. In developing 

remedies in our enforcement cases for the initiatives, we will seek 

judicial and administrative remedies that will reduce or eliminate 

pollution that may have a disproportionate effect on minority, lowincome, tribal and indigenous populations (see further discussion 
Plan EJ 2014: Appendix, Implementation Plans 61

under Strategy 4 below). As of the date of the publication of this plan, 

OECA has finalized the National Enforcement Initiative strategies and 

measures. 

 Activity 1.3: Selection of National Enforcement Initiatives for FY 2014-

16. In 2013, OECA will call for nominations for the FY 2014-2016 

National Enforcement Initiatives, with emphasis on those with 

potential opportunities for addressing environmental justice concerns, 

and will then select the new initiatives. As we have done previously, 

OECA will solicit state input and public comment on the proposed FY 

2014-2016 initiatives before they are selected. 

Strategy 2: Advance environmental justice goals through targeting and 

development of compliance and enforcement actions.

EPA will continue to place a high priority on addressing environmental 

justice concerns as it develops the specific targeting and case selection 

strategies for both National Enforcement Initiative cases and the many 

other enforcement cases that EPA brings in FY 2011-13. As discussed 

above, the Strategic Implementation Teams (SITs) for each National 

Enforcement Initiative will identify opportunities to protect and benefit 

overburdened communities when selecting and developing specific cases. 

For example, when selecting specific CAFO facilities for enforcement 

action, priority may be given to facilities that are affecting or threatening 

the drinking water supplies of poor rural communities. 

EPA will also give specific consideration and priority to environmental 

justice concerns and overburdened communities when selecting 

enforcement actions to address other important compliance problems, 

regardless of whether they are part of a National Enforcement Initiative. 

For example, in selecting enforcement actions to address violations of 

drinking water standards, we will give high priority to addressing violations 

at water supply systems that serve poor and tribal communities, as well as 

children, one of the most vulnerable populations. 

 Activity 2.1: Issue internal guidance requiring analysis and 

consideration of environmental justice in EPA’s compliance and 

enforcement program. EPA’s enforcement program is already giving 

significant consideration to environmental justice concerns in selecting 

enforcement areas of focus and targets. For example, as described 

above, environmental justice considerations played a significant role in 

our selection of national compliance problems to address through 

National Enforcement Initiatives. To ensure that EPA enforcement staff 

and managers consistently and effectively consider environmental 

justice concerns in all their work under EPA’s national compliance and 

enforcement program, OECA will issue national guidance in 2011 to 

reinforce, guide, and accelerate these efforts. 

The Agency’s national guidance will direct EPA’s compliance and 

enforcement staff and managers to consider and give significant weight 
Plan EJ 2014: Appendix, Implementation Plans 62

to environmental justice concerns when they select compliance 

problems to focus on, select specific civil or criminal enforcement case 

targets, and develop and conduct civil litigation or criminal 

prosecution. Given limited resources, EPA managers must make many 

strategic choices as they decide which problems to focus on and how to 

address them. Protection of the public health is OECA’s highest 

priority, and protection of the health of overburdened communities is 

especially important. While OECA cannot address every problem with 

our limited resources, we can ensure that we consider and give 

significant weight to the protection of overburdened communities as 

we make strategic choices. 

For example, in carrying out our National Enforcement Initiative to 

address pollution of underground or surface water caused by CAFOs, 

EPA must make strategic choices about which watershed areas to focus 

on and which particular CAFOs to inspect. A number of factors are 

considered in that decision-making process, e.g., the relative severity 

of the environmental and public health problems, the degree to which 

facilities are known or suspected to have violations that are 

contributing to the problem, and the degree to which enforcement 

action is likely to be an effective and appropriate tool to correct that 

problem. Environmental justice concerns should be considered and 

given significant weight in making this decision. For example, if there is 

a poor or minority overburdened community whose drinking water 

supply is contaminated or at risk of contamination from a nearby CAFO, 

that factor weighs in favor of selecting that CAFO as one of our 

enforcement case targets. 

To ensure that all EPA enforcement personnel consider and address 

environmental justice concerns early in the enforcement process, the 

Agency, in consultation with DOJ, is revising its internal Model 

Litigation Report guidance to call for increased analysis and discussion 

of environmental justice considerations in civil case referrals that EPA 

sends to DOJ. In addition, EPA will issue guidance calling for analysis 

and discussion of environmental justice considerations in the requests 

for prosecutorial assistance that the Agency provides to DOJ. These 

guidances will be issued in 2011. 

In order to implement the direction to consider environmental justice 

concerns in selecting and conducting enforcement cases, case teams 

will need guidance on how to identify areas of potential environmental 

justice concern. EPA has developed a number of screening tools to 

assist in identifying areas of potential environmental justice concern. 

These include the online mapping tool “EJ View” (formerly known as 

the Environmental Justice Geographic Assessment Tool, or EJGAT), 

which uses demographic, environmental, health, and facility-level 

information to assist in identifying areas with potential environmental 

justice concerns. OECA has also developed a screening tool called the 

Environmental Justice Strategic Enforcement Assessment Tool 
Plan EJ 2014: Appendix, Implementation Plans 63

(EJSEAT), which uses these same categories of data to assist in 

identifying areas of potential environmental justice concern that may 

be appropriate for enforcement action to address the effects of 

noncompliance on overburdened communities. A number of EPA’s 

regions have also developed their own analytic tools and methods for 

this purpose. 

With all of these screening tools, it is important to remember that they 

can only provide a starting point for analysis and decision making as to 

whether a community has environmental justice concerns or whether 

any enforcement action is appropriate. “Ground truthing” is needed 

before drawing any conclusions regarding any particular community or 

environmental compliance problem, and, as described above, a 

number of other important factors must be taken into consideration 

when deciding whether and where to take enforcement actions. 

In addition to OECA’s efforts to develop screening tools for use in the 

enforcement and compliance program, the Agency’s Information Tools 

Development Workgroup is undertaking a larger effort to develop 

guidance on identifying areas of potential environmental justice 

concern as a separate effort under EPA’s Plan EJ 2014. It will be 

important to ensure that OECA’s guidance to enforcement case teams 

is consistent with the approach(es) developed by the Agency-wide 

Environmental Justice Screening Committee. Therefore, upon 

completion of the Screening Committee’s work, OECA will review its 

guidance to ensure that it is consistent with the final Agency decisions 

based on the Environmental Justice Screening Committee’s work.

 Activity 2.2: Review OECA’s Enforcement Response Policies to 

determine whether any revisions are needed to ensure that 

environmental justice concerns are addressed in case development and 

resolution. OECA will review its Enforcement Response Policies for the 

various statutory and regulatory programs to assess whether any 

revisions are needed to ensure environmental justice concerns are 

addressed. A plan for the review will be developed by June 30, 2011.

 Activity 2.3: Reevaluate use of EJSEAT, as appropriate, in response to 

recommendations of the NEJAC and conclusions of the EPA 

Environmental Justice Screening Committee. EPA’s National 

Environmental Justice Advisory Council (NEJAC) thoroughly reviewed 

OECA’s screening tool, EJSEAT, and provided technical and policy 

recommendations to improve this tool in May 2010. OECA responded 

to and discussed the NEJAC’s recommendations at the NEJAC meeting 

in July 2010, and is implementing some of its technical 

recommendations. Many of the NEJAC’s recommendations raised 

policy issues that have broad application and implications for all of the 

Agency’s environmental justice work. To ensure Agency-wide 

consistency, OECA will await the outcome of the Environmental Justice 

Screening Committee’s work before making final decisions on the 
Plan EJ 2014: Appendix, Implementation Plans 64

NEJAC’s policy recommendations. However, as OECA and the regions 

continue to use EJSEAT pending the outcome of the Environmental 

Justice Screening Committee’s work, the OECA Environmental Justice 

Council will assess whether additional changes to EJSEAT 

recommended by the NEJAC’s review of the tool should be made on an 

interim basis. 

 Activity 2.4: Seek opportunities to advance environmental justice goals 

in implementing the Clean Water Act Action Plan. OECA and the Office 

of Water (OW) have developed a Clean Water Act Action Plan to 

revamp the Agency’s permitting, compliance and enforcement 

programs so that we more effectively focus our limited resources on

addressing the most important environmental and public health 

problems facing the nation. Many of these problems 

disproportionately affect poor and minority communities. For 

example, urban waters pollution is most likely to affect the health and 

welfare of poor communities located along urban waterways. As 

OECA, OW, and the regions develop and implement new strategies and 

plans under the Clean Water Act Action Plan, we will identify specific 

opportunities to address environmental justice concerns. 

Many of the opportunities to address environmental justice concerns in 

implementation of the Clean Water Act Action Plan will come through the 

development of targeting strategies and specific case selection. The Clean 

Water Act Action Plan also offers other opportunities to address 

environmental justice concerns, such as our increased attention with state 

agencies, to the relationship between effective permitting and 

enforcement in assuring compliance with the Clean Water Act. Often, the 

concerns that are raised to EPA by overburdened communities relate to the 

effectiveness of the permit regulating a particular facility, which is an 

essential underpinning for effective compliance and enforcement. 

 Activity 2.5: Seek opportunities to advance environmental justice 

goals in conducting the National Enforcement Strategy for RCRA 

Corrective Action. OECA’s Corrective Action program has set an 

aspirational goal of achieving remedy construction at 95 percent of 

3,747 RCRA facilities by the year 2020. The National Enforcement 

Strategy for Corrective Action (NESCA) provides direction to the 

regions, and guidance to states, for assessing, targeting, and 

prioritizing the EPA-lead Corrective Action facilities to help meet the 

2020 Corrective Action goal. EPA regions are encouraged to focus 

attention on identifying and addressing disproportionate effects that 

RCRA facilities needing corrective action may have on adjacent or 

nearby overburdened populations. 

NESCA identifies a variety of mapping tools that regions, states, and 

communities can use to view and identify environmental justice concerns. 

Each EPA regional office is developing a RCRA Corrective Action 2020 

strategy. As part of these strategies, the regions should identify what tools 

they plan to use to address environmental justice concerns in their 

prioritization. To assist regions with addressing environmental justice 
Plan EJ 2014: Appendix, Implementation Plans 65

concerns, OECA provided each region with a list of all potential facilities. 

OECA used EJSEAT to screen and prioritize each facility on these lists of 

facilities. The regions will assess their 2020 Corrective Action Universe to 

ensure consideration of environmental justice and provide updated RCRA 

Corrective Action 2020 strategies in the Spring of 2011. 

 Activity 2.6: Improve compliance at federal facilities where violations 

may affect overburdened communities. Where federal facilities are 

located adjacent to or nearby overburdened communities, illegal 

pollution or hazardous waste contamination can have a 

disproportionate effect on those communities. As part of Plan EJ 2014, 

OECA, together with Federal Facility Program Managers in each EPA 

region, will accelerate efforts to identify communities with these types 

of problems and take enforcement action to ensure that federal 

facilities comply with the law and address pollution problems that 

affect the communities. In FY 2011 OECA will use EJSEAT and other 

tools and information to identify overburdened communities located 

near federal facilities that have significant violations of federal 

environmental laws. These facilities will be given priority in regional 

targeting efforts for compliance and enforcement. 

 Activity 2.7: Develop tools to identify and track facilities located in 

areas with potential environmental justice concerns, and report on 

enforcement actions that address environmental justice concerns. To 

ensure the success of Activities 2.1-2.6, it will be important to ensure 

that environmental justice screening information is available to case 

teams, and to track the enforcement and compliance activities that we 

implement under this Plan. Therefore, in 2011, OECA will develop and 

implement technical programming for the Integrated Compliance 

Information System (ICIS) database, an internal tracking system, to 

allow for automated reporting on OECA regional and Headquarters 

review of EPA civil enforcement cases for potential environmental 

justice concern. OECA is in the process of developing this capacity and 

will determine in 2011 whether the reporting mechanism in ICIS is 

adequate for its needs. 

To support OECA’s program efforts to improve tracking and reporting of 

environmental justice aspects of EPA criminal enforcement case work, 

OECA will in 2011 analyze its current docket of investigations for potential 

environmental justice concerns, and will revise its internal Criminal Case 

Reporting System (CCRS) to capture information concerning potential 

environmental justice concerns in criminal enforcement investigations and 

prosecutions. OECA will consider environmental justice data, along with 

other criminal case tiering information. 
Plan EJ 2014: Appendix, Implementation Plans 66

Strategy 3: Enhance use of enforcement and compliance tools to advance 

environmental justice goals in regional geographic initiatives to address 

the needs of overburdened communities.

EPA regions have developed and continue to develop integrated strategies 

to focus on particular geographic areas in their regions with overburdened 

communities that are disproportionately affected by environmental 

problems. Beginning in 2008, for example, each region identified a 

“Showcase Community” to focus efforts to address environmental justice 

concerns. The regions used integrated strategies for this purpose that 

considered the full range of EPA’s tools, and a number of these projects 

include use of enforcement and compliance assurance tools. Under this 

strategy, the regions will ensure that they use their enforcement and 

compliance assistance tools effectively to identify and address 

environmental and public health problems in areas of environmental 

justice concern that are caused or made worse by violations of federal 

environmental laws. For example, EPA Regions 3, 4, and 5 are leading a 

geographic enforcement initiative focused on Huntington Port, which was 

selected in part because screening analysis results indicated a high 

potential for environmental justice concerns. This initiative incorporates 

enforcement and compliance assistance to reduce pollution and increase 

compliance. It also includes workshops to build the community’s capacity 

to help ensure long-term protection of the environment and public health. 

 Activity 3.1: Regions will include use of enforcement tools as part of 

integrated problem-solving strategies that are focused on particular 

geographic areas. OECA and the regions, together with state and other 

agencies as appropriate, will evaluate facility compliance in 

overburdened communities selected for strategic focus. These 

evaluations should be targeted using the best available data and 

methods in light of the overall objectives of EPA’s enforcement and 

compliance assurance work. In this way, community-focused initiatives 

can complement the national enforcement initiatives and other sectorbased and program-specific enforcement activities, meeting OECA’s 

goal of strategically using limited enforcement resources to address the 

most significant issues first. 

OECA and the regions will tailor compliance evaluation and enforcement 

actions as part of integrated strategies to maximize EPA’s ability to gain 

environmental and public health benefits in overburdened communities. 

For example, this could include use of multi-media inspections or process 

inspections to comprehensively address potential impacts from violations 

at a given facility. 

 Activity 3.2: Regions will include use of compliance assistance tools as 

part of integrated problem-solving strategies focused on particular 

geographic areas. OECA and the regions will consider and use 

compliance assistance activities to effectively reach large numbers of 

small sources with environmental violations that have significant local 

impacts on overburdened communities. Compliance assistance tools, 

such as counseling, online resource centers, fact sheets, guides, 
Plan EJ 2014: Appendix, Implementation Plans 67

training, and monitoring, are particularly appropriate, at least as initial 

compliance efforts, when widespread violations are found among small 

businesses, which often have limited resources and less ability than 

major industrial facilities to understand and comply with the 

requirements of federal environmental regulations. The EPA and states 

have often been successful in improving small businesses’ compliance 

with environmental regulations through focused outreach and 

education efforts. 

Strategy 4: Seek appropriate remedies in enforcement actions to benefit 

overburdened communities and address environmental justice concerns.

 Activity 4.1: Increase efforts to address environmental justice concerns 

through use of injunctive relief, including mitigation, and Supplemental 

Environmental Projects in civil enforcement actions, as appropriate. 

OECA, the EPA regions, and DOJ are jointly heightening their focus in 

civil enforcement cases on potential options to obtain meaningful 

environmental and public health benefits to specific overburdened 

communities affected by violations of federal environmental laws. 

These efforts go beyond traditional injunctive relief to stop illegal 

pollution, to mitigate the environmental and public health harm caused 

by illegal pollution and, where appropriate and agreed to by 

defendants, to include Supplemental Environmental Projects (SEPs) 

that provide benefits to communities. For example, in a case involving 

illegal discharges of pollutants from a facility that damaged a tribal 

fishing area, the relief ordered (in addition to stopping the illegal 

discharges) included restocking the fishing ground. EPA has also been 

successful in obtaining SEPs from defendants to retrofit diesel school 

buses, to reduce the air pollution that children are exposed to. We will 

continue and accelerate these types of efforts to reduce pollution 

burdens that have a disproportionate impact on minority, low-income, 

tribal and indigenous populations. 

 Activity 4.2: Increase efforts to benefit affected communities through 

use of community service and the Crime Victims’ Rights Act in criminal 

actions. OECA will work with DOJ to (1) explore innovative uses of 

criminal sentencing options, e.g., community service or environmental 

compliance plans, and (2) take into account information obtained 

pursuant to the Crime Victims Rights Act when developing 

environmental crimes case resolutions (e.g., restitution). 

 Activity 4.3: Look for opportunities to work with other federal 

agencies, state and local governments, and the business community to 

complement and leverage community benefits resulting from 

enforcement activities. In addition to the benefits that can be obtained 

for overburdened communities through judicial and administrative 

enforcement actions, there may be other, parallel opportunities to 

obtain additional benefits for the community through cooperation with 

other federal agencies, state or local governments, or the business 

community. For example, the U.S. Department of Housing and Urban 
Plan EJ 2014: Appendix, Implementation Plans 68

Development (HUD) may be able to provide housing assistance or 

other community benefits in a “brownfields” area where EPA has taken 

enforcement action to clean up environmental contamination. 

State or local governments may have projects or grant funding that can be 

used to improve the community’s infrastructure or environment in an area 

that is also the focus of EPA compliance or enforcement action. In 

situations where air emissions from individual or multiple industrial 

facilities continue to adversely affect community health despite their 

compliance with emission limitations, some businesses may be willing to 

take voluntary action to further reduce the emissions that adversely affect 

the community. Examples of such voluntary actions include: a health clinic 

established and operated together with local, state, and community 

members; a household hazardous waste collection drive; a local company 

voluntarily agreeing to post compliance monitoring information directly on 

a public website, to allow community members to check on compliance; 

and “good neighbor agreements” between local companies and 

communities to address facility effects not regulated by a permit or other 

law. 

EPA will identify specific opportunities, in cases or regional geographic 

initiatives, to work with other federal agencies, state and local 

governments, and the business community to complement and leverage 

benefits resulting from enforcement activities. EPA will document and 

share recommendations and best practices for taking action on these 

opportunities. 

Strategy 5: Enhance communication with affected communities and the 

public regarding environmental justice concerns and the distribution and 

benefits of enforcement actions, as appropriate.

OECA and the EPA regions with DOJ will increase their efforts to 

communicate with affected communities and the public about 

enforcement strategies and actions that may affect overburdened 

communities. EPA recognizes that communities have a legitimate need to 

be informed and to understand the federal government’s enforcement 

activities to protect their environment and public health, and to have their 

voices heard when solutions are being considered to redress 

environmental and health problems caused by violations of federal 

environmental laws that affect their community. As OECA implements 

these strategies for Plan EJ 2014, we commit to increase outreach to 

communities and to provide more information about environmental and 

public health problems caused by failure to comply with federal 

environmental laws, efforts to address those problems, and available 

judicial and administrative solutions to those problems that can address 

the communities’ concerns and needs.

At the same time, it is important for communities to understand the 

legitimate and essential need to protect the confidentiality of enforcement 
Plan EJ 2014: Appendix, Implementation Plans 69

activity when a case is under development and in settlement negotiations. 

This is essential to assure that effective enforcement, and its ultimate 

benefits for the community, will not be undermined and adversely affected 

by premature disclosure of confidential enforcement information. While 

this consideration will necessarily limit the amount and kind of information 

that EPA is able to share with the community at various stages of 

enforcement activity, we are committed to sharing as much information as 

possible, to enable communities to be informed and to have their voices 

heard in the determination of appropriate resolutions for violations of 

federal environmental laws that affect them. 

While increased communication efforts are important, it is no less 

important to receive input from communities on potential violations. OECA 

will continue to invite tips and complaints, including through such means as 

EPA’s on-line reporting badge and the EPA fugitives web page. 

 Activity 5.1: Provide affected communities with information about 

enforcement actions and meaningful opportunities for input on 

potential environmental justice concerns and remedies to be 

implemented. As OECA and the regions develop and implement our 

enforcement actions, we will seek to identify communities with 

environmental justice concerns that could benefit from enhanced 

communication and consultation regarding enforcement activities, and 

provide the communities with additional information (consistent with 

the confidentiality requirements needed to protect the integrity of 

enforcement actions). As appropriate, OECA and the regions will also 

provide opportunities for communities to provide input on 

environmental justice concerns and remedies to be sought in 

enforcement actions that affect their communities. This information 

will be provided through EPA’s website, local information repositories, 

and other appropriate means.

 Activity 5.2: Improve website information and other public information 

materials to explain EPA’s site cleanup enforcement processes. OECA 

and the regions recognize that the Agency’s enforcement processes 

concerning hazardous waste site cleanup that affect communities with 

potential environmental justice concerns, are often complicated and 

can be difficult for the public to understand and to follow. To increase 

communities’ ability to understand our enforcement processes, we will 

coordinate across EPA offices to maximize website information on 

cleanup enforcement at specific sites, develop and make available fact 

sheets to better explain EPA’s cleanup enforcement process, and 

prepare for internal EPA use a compendium of “best practices” that will 

encourage and facilitate EPA employees’ efforts to make cleanup 

enforcement information more available to the public. 

 Activity 5.3: Enhance communication of the environmental justice 

benefits of EPA’s enforcement actions. EPA’s enforcement actions 

frequently provide significant benefits to overburdened communities, 

including reduction of air or water pollution, cleanup of toxic and 

hazardous waste, and additional community benefits such as diesel bus 
Plan EJ 2014: Appendix, Implementation Plans 70

retrofits and other benefits made available through SEPs. However, 

the community is best able to appreciate these benefits when they 

have good information about these actions. Therefore, OECA and the 

regions will accelerate efforts to communicate, through press releases, 

EPA’s website, and other means, the benefits of our enforcement 

actions for overburdened communities. To ensure nationwide 

consistency in this effort, we will issue internal guidance for this 

purpose in 2011. 
Plan EJ 2014: Appendix, Implementation Plans 71

3.0 DELIVERABLES 

Strategy 1: Advance environmental justice goals through selection and 

implementation of National Enforcement Initiatives. 

Strategy 2: Advance environmental justice goals through targeting and 

development of compliance and enforcement actions. 

ACTIVITY DELIVERABLES MILESTONES

Activity 2.1: Issue internal 

guidance calling for analysis 

and consideration of 

environmental justice in 

EPA’s compliance and 

enforcement program, 

including using available tools 

and approaches to identify 

areas of potential 

environmental justice 

concern.

 Issue guidance to EPA 

managers and staff that 

calls for consideration of 

environmental justice in 

EPA’s compliance and 

enforcement program.

 April 30, 

2011

 Revise Model Litigation 

Report Guidance to call for 

increased analysis and 

discussion of environmental 

justice in judicial referrals.

 Draft by 

June 30, 

2011; Final 

by Sept. 30, 

2011

 Consider environmental 

justice data, along with 

criminal case tiering 

information.

 Ongoing

 Issue guidance calling for 

discussion of environmental 

justice issues in requests for 

prosecutorial assistance. 

 August 31, 

2011

ACTIVITIES DELIVERABLES MILESTONES

Activity 1.1: Consider 

environmental justice in 

selecting National 

Enforcement Initiatives 

(NEIs) for FY 2011-13.

 Selection of National 

Enforcement Initiatives for 

FY 2011-13. 

 Completed 

Activity 1.2: Advance 

environmental justice goals 

through implementation of 

NEIs.

 Strategic Implementation 

Team (SIT) strategies to 

include opportunities to 

advance environmental 

justice goals. 

 April 30, 

2011

Activity 1.3: Consider 

environmental justice in 

nominating and selecting 

National Enforcement 

Initiatives for FY 2014-16. 

 Call for nominations for FY 

2014-16 NEIs to include 

request to identify 

opportunities to advance 

environmental justice goals.

 In 2013
Plan EJ 2014: Appendix, Implementation Plans 72

ACTIVITY DELIVERABLES MILESTONES

Activity 2.2: Review 

OECA’s Enforcement 

Response Policies to 

determine whether any 

revisions are needed to 

ensure that environmental 

justice concerns are 

addressed in case 

development and resolution.

 Develop a plan and 

timetable for review of 

Enforcement Response 

Policies. 

 June 30, 

2011

Activity 2.3: Re-evaluate 

use of EJSEAT, as 

appropriate, in response to 

recommendations of the 

NEJAC and conclusions of 

the EPA Environmental 

Justice Screening 

Committee.

 Finalize implementation of 

the NEJAC technical 

recommendations for 

EJSEAT already accepted. 

 June 30, 

2011 

 Reconsider and finalize 

response to the NEJAC 

recommendations on 

EJSEAT following issuance 

of final work product by 

Environmental Justice 

Screening Committee (to 

ensure consistency).

 Within 180 

days 

following 

issuance of 

final work 

product of 

Environmen

tal Justice 

Screening 

Committee

Activity 2.4: Seek 

opportunities to advance 

environmental justice goals in 

implementing the Clean 

Water Action Plan.

 As EPA develops and 

implements new strategies 

and plans under the Clean 

Water Act Action Plan, we 

will identify specific 

opportunities to address 

environmental justice 

concerns. 

 Ongoing

Activity 2.5: Seek 

opportunities to advance 

environmental justice goals in 

conducting the National 

Enforcement Strategy for 

RCRA Corrective Action.

 Screen all facilities in the 

2020 Corrective universe 

that are subject to the 

National Enforcement 

Strategy for RCRA 

Corrective Action for 

potential environmental 

justice concerns. 

 Completed

 Identify as priorities for 

enforcement, Corrective 

Action sites using the 

potential for environmental 

justice concerns as a factor. 

 Ongoing
Plan EJ 2014: Appendix, Implementation Plans 73

ACTIVITY DELIVERABLES MILESTONES

Activity 2.6: Improve 

compliance at federal 

facilities where violations may 

affect overburdened

communities.

 Use EJSEAT to identify 

overburdened communities 

located near federal 

facilities. Identify those that 

have significant 

environmental violations for 

priority consideration by 

regional federal facility 

program targeting efforts, for 

compliance assistance and 

potential enforcement. 

 Ongoing

Activity 2.7: Develop 

tracking and reporting tools 

on potential environmental 

justice concerns and results 

in enforcement actions.

 Develop and implement 

technical/programming 

requirements for the ICIS 

database.

 Ongoing; 

Draft

guidance by 

March 30, 

2012

 Develop reporting guidance.  Ongoing

 Revise the Criminal Case 

Reporting System (CCRS) 

to capture information 

concerning potential 

environmental justice 

concerns in criminal 

enforcement investigations 

and prosecutions. 

 Ongoing

Strategy 3: Enhance use of enforcement and compliance tools to advance 

environmental justice goals in regional geographic initiatives to address the 

needs of overburdened communities. 

ACTIVITY DELIVERABLES MILESTONES

Activity 3.1: Regions will 

include use of enforcement 

tools as part of integrated 

problem-solving strategies 

that are focused on particular 

geographic areas. 

 Regions will be asked to 

include enforcement efforts 

(e.g., through targeting and 

inspections) when applying 

integrated problem-solving 

strategies in selected 

geographic areas with 

environmental justice

concerns. For example, 

some regions incorporated 

such an approach into their 

Environmental Justice

Showcase Community 

projects.

 Ongoing

 Document accomplishments 

and future plans for including 

enforcement in these 

geographic initiatives. 

 December

31, 2011
Plan EJ 2014: Appendix, Implementation Plans 74

ACTIVITY DELIVERABLES MILESTONES

Activity 3.2: Regions will 

include use of compliance 

assistance tools as part of

integrated problem-solving 

strategies (e.g., as applied in 

the Showcase Communities), 

that are focused on particular 

geographic areas. 

 Regions will be asked to 

evaluate appropriate 

compliance assistance tools 

when applying integrated 

problem-solving strategies in 

selected geographic areas 

with environmental justice

concerns. For example, 

some regions incorporated 

such an approach into their 

Environmental Justice

Showcase Community 

projects.

 Ongoing

 Document accomplishments 

and future plans for including 

compliance assistance in 

these geographic initiatives. 

 December

31, 2011

Strategy 4: Seek appropriate remedies in enforcement actions to benefit 

overburdened communities and address environmental justice concerns. 

ACTIVITY DELIVERABLES MILESTONES

Activity 4.1: Increase efforts 

to address environmental 

justice concerns through use 

of injunctive relief, including 

mitigation, and SEPs in civil 

enforcement actions.

 On case-specific basis, 

coordinate with DOJ on 

potential options in judicial 

cases for injunctive relief, 

including mitigation, and 

SEPs that will deliver 

substantial and meaningful 

environmental benefits to 

specific environmental 

justice communities.

 Ongoing

 Assess opportunities for 

increasing environmental 

justice benefits in remedies 

in administrative actions.

 Ongoing

Activity 4.2: Increase efforts 

to benefit overburdened

communities through use of 

community service and the 

Crime Victims’ Rights Act 

(CVRA) in criminal actions.

 Work with DOJ to (1) 

explore innovative uses of 

criminal sentencing options, 

e.g., community service 

and/or environmental 

compliance plans, and (2)

take into account information 

obtained pursuant to the 

CVRA when developing 

environmental crimes case 

resolutions (e.g., restitution).

 Ongoing

 Provide comments on the 

DOJ/Attorney General’s 

CVRA Guidelines.

 Completed
Plan EJ 2014: Appendix, Implementation Plans 75

ACTIVITY DELIVERABLES MILESTONES

 Coordinate with DOJ in their 

implementation of CVRA 

guidelines for federal 

environmental prosecutions.

 Ongoing

 Evaluate use of restitution, 

community service, and 

CVRA in federal 

environmental prosecutions, 

and issue guidance to 

investigators.

 Ongoing

Activity 4.3: Look for 

opportunities to work with 

other federal agencies, state 

and local governments, and 

the business community to 

complement and leverage 

community benefits resulting 

from enforcement activities.

 Identify specific 

opportunities, in cases or 

regional geographic 

initiatives, to work with other 

federal agencies, state and 

local governments, and the 

business community to 

complement and leverage 

benefits resulting from 

enforcement activities.

 Ongoing

 Document and share 

recommendations and best 

practices for taking action on 

these opportunities. 

 December

31, 2011

Strategy 5: Enhance communications with affected communities and the 

public regarding environmental justice concerns and the distribution and 

benefits of enforcement actions, as appropriate.

ACTIVITY DELIVERABLES MILESTONES

Activity 5.1: Provide 

affected communities with 

information about 

enforcement actions and 

meaningful opportunities for 

input on potential 

environmental justice 

concerns and remedies to be 

sought, as appropriate. 

 Identify communities where 

enhanced communication 

and consultation regarding 

enforcement matters is 

appropriate. 

 Ongoing

 Provide communities with 

information about 

enforcement actions and 

meaningful opportunities for 

input on potential 

environmental justice 

concerns and remedies to be 

sought, as appropriate

 Ongoing

Activity 5.2: Improve 

website information on 

cleanup enforcement, 

develop fact sheets to better 

explain the cleanup 

enforcement process, and 

prepare a compendium of 

best practices.

 Coordinate across EPA 

offices to maximize website 

information on cleanup 

enforcement at specific sites.

 Ongoing

 Participate in the 

development of fact sheets 

that explain the cleanup 

enforcement process. 

 Ongoing
Plan EJ 2014: Appendix, Implementation Plans 76

ACTIVITY DELIVERABLES MILESTONES

 Prepare compendium of best 

practices. 

 December

31, 2011

Activity 5.3: Enhance 

communication of 

environmental justice 

benefits of EPA’s 

enforcement actions.

 Develop policy on 

communicating in press 

releases and similar 

statements the 

environmental justice 

benefits of EPA’s 

enforcement actions. 

 August 31, 

2011
Plan EJ 2014: Appendix, Implementation Plans 77

4.0 REPORTING 

OECA will report annually on progress in implementing the strategies 

outlined in this implementation plan, and will update as necessary, the 

activities and deliverables outlined here. For information, please contact 

Loan Nguyen, 202-564-4041, Nguyen.Loan@epa.gov; or Eileen Deamer, 

312-886-1728, Deamer.Eileen@epa.gov. 
Plan EJ 2014: Appendix, Implementation Plans 78

4. Supporting Community-Based 

Action Programs 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 September 2011 

Led by

Office of Solid Waste and Emergency Response, 

and Regions 2, 3, and 4 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 79

1.0 INTRODUCTION 

For over forty years, the U.S. Environmental Protection Agency (EPA)’s top 

priority has been protecting human health and the environment. The 

Agency has learned that communities must be the driver for local solutions. 

Consequently, EPA has implemented numerous programs that support 

community empowerment and provide community benefits at all levels, 

from basic educational and leadership development to comprehensive 

approaches to achieving healthy, sustainable, and green communities. 

These efforts include financial assistance programs such as Environmental 

Justice, Community Action for a Renewed Environment (CARE), Brownfields 

Area-Wide Planning, and Tribal grants. They also include other place-based 

programs such as EPA’s Local Climate and Energy, Childhood Asthma, 

Sustainable Communities and Smart Growth, Urban Waters, Superfund, 

and Brownfields programs. EPA undertakes these programs in 

collaboration with other federal agencies, state, tribal, and local 

governments, and multiple stakeholders. Significantly, EPA’s ten regions 

play a leading role in implementing these programs. 

While communities continue to impress EPA with their dedication, their 

innovative ideas, and most importantly their ability to bring real change to 

their communities, we realize that far too many communities still lack the 

capacity to affect environmental conditions. Many minority low-income, 

tribal, and indigenous communities continue to live in the shadows of the 

worst pollution and face some of the harshest effects. 

 

The Plan EJ 2014 Supporting Community-Based Action Programs 

implementation plan builds upon an Agency effort to improve the 

effectiveness of EPA’s place-based community programs through better 

information access, coordination, and leveraging. Through this process, 

EPA hopes to make “community” an organizing principle for our work. To 

implement this principle, EPA is currently doing the difficult foundational 

work of internally aligning and coordinating its programs. The resulting 

foundation will enable EPA, particularly its regions, to more effectively 

expand partnerships, build local capacity, and foster health and economic 

benefits in overburdened communities, as well as aligning EPA programs 

and investments with those of other federal agencies, state, local, and 

tribal governments, and other stakeholders. 

1.1 Goals 

EPA will strengthen community-based programs to engage overburdened 

communities and build partnerships that promote healthy, sustainable, and 

green communities. 

To accomplish this goal, EPA will build upon and leverage Agency efforts to 

promote greater coordination in the use of programs and tools that 

support community empowerment. EPA will pursue this goal at all levels, 

Goals At-A-Glance

To strengthen communitybased programs to 

engage overburdened 

communities and build 

partnerships that promote 

healthy, sustainable, and 

green communities.
Plan EJ 2014: Appendix, Implementation Plans 80

from basic educational and leadership development to comprehensive 

approaches to achieving healthy, sustainable, and green communities. 

Through these efforts, EPA will make the Agency’s resources more 

accessible to underserved communities, while achieving greater internal 

efficiency through feedback and better understanding of implementing 

community-based programs. This approach will result in environmental, 

health, and economic improvements in such communities. 

1.2 Organizational Structure 

The Office of Solid Waste and Emergency Response (OSWER) and regions 2, 

3, and 4 are responsible for designing and implementing the Plan EJ 2014 

Supporting Community-Based Action Programs focus area. They will be 

supported by the Office of Water (OW), the Office of Air and Radiation 

(OAR), the Office of Policy (OP), the Office of Enforcement and Compliance 

Assurance (OECA), the Office of Environmental Justice (OEJ), the Office of 

the Chief Financial Officer (OCFO), and Regions 1, 6, and 10. 

The EPA recognizes that Supporting Community-Based Action Programs is 

cross-cutting in nature and requires the participation of all EPA programs 

and regions. This integrated One EPA approach enables the Agency to 

better engage and empower communities and other stakeholders, 

particularly those who have been historically under-represented, in order 

to support and advance environmental protection and foster 

environmental, health, and economic benefits for all communities. 
Plan EJ 2014: Appendix, Implementation Plans 81

2.0 IMPLEMENTATION 

2.1 Strategies 

EPA will employ six strategies in the Supporting Community-Based Action 

Programs Implementation Plan that are tied to the larger Plan EJ 2014 

goals and Agency priorities. 

1. Advance environmental justice principles by building strong state and 

tribal partnerships through the National Environmental Performance 

Partnership System (NEPPS) and National Program Manager (NPM) 

guidance. 

2. Identify scalable and replicable elements of successful Agency 

community-based programs and align multiple EPA programs to more 

fully address the needs of overburdened communities. 

3. Promote an integrated One EPA presence to better engage 

communities in the Agency’s work to protect human health and the 

environment. 

4. Foster community-based programs modeled on the Community Action 

for a Renewed Environment (CARE) principles. 

5. Explore how EPA funding, policies, and programs can inform or help 

decision makers to maximize benefits and minimize adverse impacts 

when considering current land uses in decision making, planning, siting, 

and permitting. 

6. Promote equitable development opportunities for all communities. 

2.2 Activities 

This section describes the ten major activities EPA will undertake to 

implement these strategies to support community-based programs. 

Strategy 1: Advance environmental justice principles by building strong 

state and tribal partnerships through the National Environmental 

Performance Partnership System (NEPPS) and National Program 

Manager (NPM) guidance

This effort will advance the Administrator’s priorities on environmental 

justice and children’s health through state, tribal, and grant work plans. 

EPA regions will work with states and tribes to advance environmental 

justice by improving environmental conditions and public health in 

overburdened communities. 

EPA has established a workgroup and schedule a series of meetings to hold 

discussions. The workgroup will make recommendations and develop 

appropriate language to incorporate environmental justice principles and 

Title VI to better protect overburdened communities. This effort will 

demonstrate how the Agency can positively affect overburdened 
Plan EJ 2014: Appendix, Implementation Plans 82

communities through its partnerships, agreements, work plans and grants 

that are governed by NEPPS and NPM guidance principles. 

The workgroup will promote state and tribal engagement with affected 

communities in their discussions and decision-making processes. The 

workgroup has identified two key activities to address as part of its effort 

to advance environmental justice through NEPPS and NPM guidance: 

 Activity 1: Provide recommendations that mutually support 

community involvement; resource and data sharing; and monitoring, 

tracking, and training within programs implemented through 

performance partnership agreements, tribal agreements, and work 

plans guided by NEPPS and NPM documents. 

o Address specific issues and identify barriers within current 

practices to incorporating environmental justice principles into 

NEPPS and NPM process. 

o Develop recommendations on how to best integrate 

environmental justice principles into state and tribal grant 

work plans. 

o Promote state and tribal involvement in environmental justice 

discussions, reviews, and decision making to incorporate 

environmental justice principles into the NEPPS and NPM 

processes. 

o Coordinate with NEPPS and NPM efforts, exploring current 

regional practices and lessons learned to develop language for 

environmental justice guidance on community-based programs 

for inclusion in the annual NPM and NEPPS guidance. 

o Identify Agency programs to pilot the inclusion of 

environmental justice principles into negotiated work plans 

and tribal agreements. 

o Incorporate lessons learned from pilot demonstrations of 

environmental justice in negotiated work plans and tribal 

agreements into NPM and NEPPS annual guidance. 

 Activity 2: Develop language for environmental justice principles 

including Title VI guidance (as appropriate with all Agency grants) for 

inclusion in the FY 2013 NEPPS and FY 2012 NPM guidance through 

collaboration and discussions with Office of Congressional and 

Intergovernmental Relations (OCIR), Office of Civil Rights (OCR), 

regional offices, and states. 

o Consult Agency legal resources for guidance in integrating 

environmental justice considerations and Title VI guidance 

through NEPPS and NPM guidance documents. 

o Review language from Performance Partnership Agreements 

(PPAs), Performance Partnership Grants (PPGs), and grants of 

Agency and state programs being implemented under NEPPS 

and NPM guidance.
Plan EJ 2014: Appendix, Implementation Plans 83

Strategy 2: Identify scalable and replicable elements of successful Agency 

community-based programs and align multiple EPA programs to more 

fully address the needs of overburdened communities.

EPA has achieved great success with community-based programs that help 

build capacity to address critical issues affecting overburdened 

populations. In order to help Agency community-based programs learn 

from experience, this workgroup will engage both headquarters and 

regional offices regarding their successes and lessons learned with 

community-based programs. The workgroup will also review Office of 

Policy’s (OP) list of 26 existing Agency community-based programs and 

existing evaluations of select Agency EJ programs to identify effective 

programmatic elements of successful place-based programs that help to 

support healthy and sustainable communities. 

This is part of EPA’s efforts to improve the effectiveness of its communitybased programs through better information access, coordination, and 

leveraging. This effort focuses on making “community” an organizing 

principle of our work, increasing community access to our programs, and 

improving environmental protection and the quality of life at the 

community level. The workgroup has identified two key activities to 

improve EPA’s community-based efforts to produce tangible results in 

overburdened communities. 

 Activity 3: Review Agency and key outside community-based 

programs, and existing evaluations of select Agency programs, to 

identify scalable and replicable program elements which encourage 

place-based solutions to environmental justice issues, strengthen and 

promote partnerships, and support healthy and sustainable 

communities. 

 Activity 4: Make recommendations on how EPA can align its 

community-based programs, particularly in EPA’s regions to more fully 

address the needs of overburdened communities. 

Strategy 3: Promote an integrated One EPA presence to better engage 

communities in the Agency’s work to protect human health and the 

environment. 

The organizational structure of EPA presents a challenge for many 

communities that are addressing multiple environmental issues. The 

reality is that most Americans see EPA as a single entity. More and more 

communities are seeking comprehensive environmental solutions that cut 

across individual media programs. We will find the best solutions when we 

work consistently in a unified way. What we can achieve as One EPA to 

assure a clean and healthy environment for all is far greater than the 

results of multiple uncoordinated efforts. One EPA is a mindset that values 

alignment – investing our time and energy to define together the outcomes 

we want and how to get there. It entails our persistent search for more 

integrated ways of reaching solutions that better protect the environment. 

This involves headquarters and regions working together to target areas of 

concerns. 
Plan EJ 2014: Appendix, Implementation Plans 84

The workgroup has identified the following key activity to address as part 

of its effort to promote a One EPA presence. 

 Activity 5: Target three approaches to promote an integrated One EPA 

presence where EPA will find the best solution by working in a 

consistent and unified way. 

EPA will identify opportunities to present an integrated One EPA 

presence through: 

1. Conferences and listening sessions. 

2. Communication and outreach to better engage communities. 

3. Capacity building through workforce development and job 

training. 

Strategy 4: Foster community-based programs modeled on Community 

Action for a Renewed Environment (CARE) principles.

The CARE program was developed from lessons learned from EPA 

community-based programs (e.g., Brownfields, Environmental Justice, 

Community-Based Environmental Protection, etc.) and advice from the 

2004 NEJAC to “initiate community-based, collaborative, multi-media, risk 

reduction pilot projects.”15 The CARE principles will be applied to a One 

EPA approach toward testing regional approaches for joint planning and 

non-EPA funding of community partnerships. These partnerships will 

engage private industry, businesses, foundations, universities and 

community colleges, and other groups. 

The workgroup has identified the following three key activities to address 

as part of its effort to foster community-based programs modeled on CARE 

principles: 

 Activity 6: Develop a community-based partners (CBP) initiative for 

opportunities in underserved and environmentally overburdened 

neighborhoods to collaborate with federal agencies, private industry, 

foundations, and other institutions to implement the CARE principles. 

o In developing the CBP program, EPA will assess and implement 

ways by which the Agency can better act as a conduit to bring 

together underserved communities with federal agencies, 

private industry, businesses, foundations, universities, and 

other institutions. 

 Activity 7: Develop a CBP program that caters to grassroots or 

emerging community groups with little to no organizational or 

technical capacity. 

o This second type of CBP program will address Agency concerns 

in reaching out to those community groups who have been 

unsuccessful in competing for government grants. 

 

15 National Environmental Justice Advisory Council, Ensuring Risk Reduction in Communities with 

Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts, December 2004. Available at: 

http://www.epa.gov/compliance/ej/resources/publications/nejac/nejac-cum-risk-rpt-122104.pdf. 
Plan EJ 2014: Appendix, Implementation Plans 85

 Activity 8: Identify technical assistance resources, program staff, and 

regional staff available to aid overburdened communities with issues 

related to their areas of expertise. 

Strategy 5: Explore how EPA funding, policies, and programs can inform 

or help decision makers to maximize benefits and minimize adverse 

impacts when considering current land uses in decision making, planning, 

siting, and permitting.

EPA is aware of communities concerns about land use planning. To 

respond to these concerns, EPA will explore how our programs affect land 

use planning, siting, and decision making in overburdened communities. 

While land use planning is usually a local government responsibility, EPA 

can provide interested jurisdictions with information on best practices 

regarding policies and approaches that can benefit all community 

stakeholders and minimize adverse impacts. 

Building upon its work with the interagency Partnership for Sustainable 

Communities, EPA can support a broad discussion forum to explore how 

interested jurisdictions might better address the issues of overburdened 

communities when making local land use decisions. Due to the crosscutting nature of land use planning and its effect on communities, EPA will 

work collaboratively with state agencies that, subsequently, will work with 

communities and other stakeholders to identify issues and opportunities. 

EPA has identified the following activity to implement its effort to examine 

land use decision making, planning, and siting in underserved and 

overburdened communities: 

 Activity 9: Establish a workgroup and seek stakeholder feedback to 

explore ways the Agency’s work intersects with land use decision 

making, planning, and siting. 

o This workgroup will produce information discussing 

environmental concerns that may affect land use planning, 

siting, and permitting decisions. This workgroup will be 

comprised of select EPA offices, and state, local, and tribal 

governments. The workgroup will also develop a 

complementary training course for stakeholders with the goal 

of increasing awareness of land-use decision making, and its 

effect on communities. 
Plan EJ 2014: Appendix, Implementation Plans 86

Strategy 6: Promote equitable development opportunities for all 

communities.

EPA has a range of financing and technical assistance vehicles in place that 

communities might be able to tap if they had basic, understandable 

information about how to do so. However, ensuring equitable access to 

them can be a formidable challenge for communities and organizations 

unfamiliar with EPA’s processes for both distributing and leveraging these 

resources. Therefore, EPA needs to foster a climate in which more 

equitable development opportunities can be realized, by providing tailored 

information on financing and related tools and strategies, including 

outreach to agencies whose complementary tools could be given a greater 

community focus. 

 Activity 10: Promote equitable development opportunities. 

o This workgroup will conduct research on existing financing 

vehicles; prepare an analysis (that will integrate existing Office 

of the Chief Financial Officer (OCFO)/Environmental Financial 

Advisory Board (EFAB) tools, as appropriate); produce an “EPA 

Agency-wide Financing and Technical Assistance Vehicle: 

Strategies to Apply Them to Support Equitable Community 

Development” and post on the web; and prepare an outreach 

memorandum to other key agencies, to encourage application 

of their tools in ways that promote equitable development.

2.3 Community Engagement and Stakeholder Outreach 

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 NEJAC advice and recommendations. 

In addition, we will coordinate our community outreach and stakeholder 

involvement efforts with OEJ. 
Plan EJ 2014: Appendix, Implementation Plans 87

3.0 DELIVERABLES 

The table below provides a list of activities to be completed with 

deliverables and associated milestones. 

ACTIVITIES DELIVERABLES MILESTONES

Activity 1: 

Recommendations on 

advancing 

environmental justice 

principles in work 

plans and agreements.

 Necessary expertise identified for 

developing recommendations.

 June 30, 

2011 

 Recommendations on how to best 

integrate NEPPS principles into 

state, tribal, and grant work plans.

 September 

30, 2011

 Agency programs to pilot the 

inclusion of environmental justice

into negotiated work plans and 

tribal agreements identified.

 September 

30, 2012

Activity 2: 

Development of 

appropriate language 

for incorporating 

environmental justice 

principles in work 

plans and agreements.

 The Office of General Counsel 

(OGC) guidance on 

environmental justice and Title VI 

language.

 June 30, 

2011

 Proposed language on 

environmental justice including 

Title VI guidance for communitybased (CB) programs for FY 2013 

NEPPS guidance and FY 2012 

NPM guidance developed.

 September 

30, 2012

Activity 3: List of 

scalable and replicable 

elements of CB 

programs.

 Workgroup established to 

coordinate with OP and look at 

Agency and outside CB 

programs.

 March 31, 

2011

 List of scalable and replicable CB 

program elements developed.

 October 28, 

2011

Activity 4: 

Recommendations on 

aligning Agency CB 

programs.

 Recommendations on aligning 

Agency CB programs.

 December 

31, 2011

Activity 5: Target 

three approaches to 

promote an integrated 

One EPA presence.

 Conferences and listening 

sessions

 July 1, 

2011

 Communication and outreach to 

better engage communities.

 July 29, 

2011

 Capacity building through 

workforce development and job 

training.

 December 

31, 2011
Plan EJ 2014: Appendix, Implementation Plans 88

Activity 6: Develop 

and implement CBP 

program based on the 

CARE model.

 Communities with the established 

framework in place to implement 

this program identified by EPA 

regional offices.

 August 

2011

 Select communities and engage 

partnership opportunities.

 September 

2011

 Preliminary program initiated.

 Lessons learned from selected 

communities developed.

 June 2012

Activity 7: Develop 

and implement CBP 

program for grassroots 

or emerging 

community groups.

 Develop a process to select 

communities.

 December 

2011

 Preliminary program initiated.  January 

2012

 Lessons learned from selected 

communities developed.

 January 

2013

Activity 8: Identify 

resources available to 

underserved 

communities.

 Identify areas of need.  September 

2011

 Reach out to offices and regions 

to identify resources and staff.

 October 

2011

 Develop a list and a system for 

updating the list.

 May 2012

Activity 9: Explore 

how EPA funding, 

policies, and programs 

can inform and help 

local decision makers 

to maximize benefits 

and minimize adverse

effects from land use 

decision making, 

planning, and siting.

 Establish a workgroup.  May 2011

 Set up a series of meetings to 

begin looking at intersection of 

Agency work and land use 

planning.

 March 2011

 Develop an outreach strategy to 

get stakeholder feedback.

 June 2011

 Develop training course for 

stakeholders.

 December 

2011

 Develop a tool to showcase 

findings

 December 

2011

Activity 10: Promote 

equitable development 

opportunities.

 Conduct research on financing 

vehicles.

 August 1, 

2011

 Prepare the Analysis (which will 

integrate existing OCFO and 

EFAB tools as appropriate). 

 September 

30, 2011

 Produce an “EPA Agency-wide 

Financing and Technical 

Assistance Vehicle: Strategies to 

Apply Them to Support Equitable 

Community Development” 

and post on the web.

 December 

31, 2011

 Prepare an outreach 

memorandum to other key 

agencies, to encourage 

application of their tools in ways 

that promote equitable 

development.

 December 

31, 2011
Plan EJ 2014: Appendix, Implementation Plans 89

4.0 REPORTING 

Progress reports on this implementation plan will be generated annually. 

The planned deliverables and milestones for each of the activities are 

described in Section 3.0. Each of the offices responsible will further refine 

and develop the activities during the process of implementation. For 

information, please contact Pat Carey, 202-566-0199, Carey.Pat@epa.gov. 
Plan EJ 2014: Appendix, Implementation Plans 90

Community-Based Programs, Projects, and Investments 

(2009-10)

1. Community Action for a Renewed Environment (Leads: OW and OAR) 

OAR 

2. Community-Based Childhood Asthma Program 

3. Local Climate and Energy Program (Climate Showcase Communities) 

4. EPA School Monitoring Initiative 

OSWER 

5. Brownfields – Training, Technical Assistance Grants, including Technical 

Assistance to Brownfields Communities (TAB) grants 

6. Targeted Brownfields Assessment 

7. Superfund Job Training Initiative 

8. Superfund Redevelopment Initiative 

9. Superfund Community Technical Assistance Grants 

10. Brownfields Sustainability Pilots 

11. Brownfields Assessment, Cleanup, and RLF Grants, including 

Brownfields Area-Wide Planning Pilots 

12. Superfund Technical Assistance Services for Communities (TASC) 

Program 

13. Environmental Workforce Development and Job Training Grants 

14. Partnership for Sustainable Communities Brownfields Pilots (2010) 

15. RE-Powering Feasibility Studies 

16. Brownfields and Land Revitalization Technical Support Centers 

OW

17. Five Star Restoration Grants Program 

18. Lead in Schools Program 

29. Urban Waters Initiative 

20. Stormwater/Sanitary Sewer Overflow (SSO)/Combined Sewer Overflow 

(CSO) permits 

Office of Chemical Safety and Pollution Prevention (OCSPP) 

21. Community-Based Lead Grant Program 

22. Tribal Lead Grant Program 

OP

23. Smart Growth Program 

Office Indian Affairs (OIA) 

24. Indian Environmental General Assistance Program 

OECA 

25. Environmental Justice Showcase Communities 

26. Environmental Justice Small Grants Program 
Plan EJ 2014: Appendix, Implementation Plans 91

5. Fostering Administration-Wide 

Action on Environmental Justice 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of Water and Region 6

U.S. Environmental Protection Agency 

Washington, D.C. 20460 
Plan EJ 2014: Appendix, Implementation Plans 92

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, it called for federal agencies to 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.16

 

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, as well as equitable 

development, for all people. To better achieve this goal, the U.S. 

Environmental Protection Agency (EPA) is leading the Administration’s 

effort to fully implement EO 12898. As each federal agency reinvigorates 

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

on helping each federal 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 of EPA’s 

programs. 

A coordinated and holistic approach is essential to ensure that we address 

the full scope of adverse human health and environmental effects in 

overburdened communities, legacy pollution problems rooted in historical 

discrimination, and cumulative impacts; and to 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 for the 

Fostering Administration-Wide Action on Environmental Justice crossAgency 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). 

 

16 Clinton, William J., Executive Order 12898, “Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations,” February 11, 1994, Federal Register 59, No. 32: 

7629.

Goals At-A-Glance

To facilitate the active 

involvement of all federal 

agencies in implementing 

EO 12898 by minimizing 

and mitigating 

disproportionate, negative 

impacts while fostering 

environmental, public 

health, and economic 

benefits for overburdened 

communities.
Plan EJ 2014: Appendix, Implementation Plans 93

EPA recognizes that Fostering Administration-Wide Action requires 

coordination with the White House Council on Environmental Quality 

(CEQ), other federal agencies, and EPA’s ongoing interagency activities. In 

addition, the OFA will address the issues related to the National 

Environmental Policy Act (NEPA), and the OCR will address issues related to 

Title VI of the Civil Rights Act of 1964. Interagency coordination will also 

involve the Federal Interagency Working Group on Environmental Justice 

(EJ IWG), which was established under EO 12898 and was reconvened in 

September 2010. 
Plan EJ 2014: Appendix, Implementation Plans 94

2.0 IMPLEMENTATION 

2.1 Strategies 

EPA, in conjunction with the White House CEQ and the EJ IWG, has 

identified four major strategies for Fostering Administration-Wide Action 

on Environmental Justice:

 Assist other federal agencies to integrate environmental justice in their 

programs, policies, and activities. 

 Work with other federal agencies to strengthen use of interagency 

legal tools, such as NEPA and Title VI of the Civil Rights Act of 1964. 

 Foster healthy and sustainable communities, with an emphasis on 

equitable development and place-based initiatives. 

 Strengthen community access to federal agencies. 

2.2 Activities 

The following activities are intended to carry out the strategies identified 

for this implementation plan. 

Strategy 1: Assist other federal agencies to integrate environmental 

justice in their missions, programs, policies, and activities.

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

justice into federal agency programs, policies, and activities by chairing the 

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 Administrationwide 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. 

The following five activities will be conducted to implement this strategy: 

 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 environmental justice 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. 

The 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 Forum on Environmental Justice. At the Forum, EJ IWG 

members and other federal agency representatives reengaged with 

environmental justice advocates about issues that are important to 

overburdened communities. Moving forward, EPA will continue to lead 

EJ IWG meetings and events. 
Plan EJ 2014: Appendix, Implementation Plans 95

 Activity 1.2: Chair, assist, and oversee each federal agency’s effort to 

update or develop its environmental justice strategy. 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 federal agency will update, or in some 

cases develop, an environmental justice strategy that will be 

responsive to the environmental and human health needs of 

overburdened communities.

 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 

environmental justice 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 environmental justice stakeholders to discuss and help 

resolve issues that are important to communities in each region. 

 Activity 1.4: Develop and provide tools that help environmental justice 

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 

environmental justice stakeholders. As a result, EPA will develop 

information and resource tools to promote collaboration between 

federal agencies and environmental justice stakeholders and improve 

opportunities for environmental justice stakeholders to utilize federal 

resources. 

 Activity 1.5: Convene a group of senior attorneys from across the 

federal government to promote the integration of environmental 

justice into their agencies' actions. In partnership with the U.S. 

Department of Justice (DOJ), EPA’s Office of General Counsel (OGC), 

the Office of Enforcement and Compliance Assurance (OECA), and the 

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' environmental justice policies. We also hope 

to develop other forms of information-sharing tools. Our goal is to 

help EJ IWG members and other agencies with environmental justice 

interest to understand the legal tools available to them to promote 

environmental justice. 
Plan EJ 2014: Appendix, Implementation Plans 96

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

interagency legal tools, such as the National Environmental Policy Act and 

Title VI of the Civil Rights Act of 1964.

National Environmental Policy Act (NEPA) 

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 

(CAA) Section 309, EPA is mandated to review Environmental Impact 

Statements (EIS), comment in writing, and make those comments available 

to the public. These reviews include an assessment of whether the 

requirements of EO 12898 and the accompanying Presidential 

Memorandum on environmental justice are considered and integrated 

within the NEPA process. We have identified a number of activities that 

EPA, in concert with other federal agencies, can take to strengthen all 

agencies’ abilities to incorporate environmental justice into major federal 

activities. 

 Activity 2.1: Articulate a consistent message about the need to 

incorporate environmental justice into NEPA implementation efforts.

We will articulate a clear, consistent message about need to 

incorporate environmental justice considerations into NEPA 

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

to effect good environmental decision making and take environmental 

justice into account through CAA Section 309 reviews. In addition to 

improving internal collaboration on environmental justice, 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 environmental justice requirements in 

NEPA implementation efforts. We will develop tools to help federal 

NEPA practitioners in EPA and other agencies enhance environmental 

justice considerations in NEPA implementation efforts 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-specific environmental justice guidance. 

Title VI of Civil Rights Act of 1964 

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 
Plan EJ 2014: Appendix, Implementation Plans 97

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 two activities that EPA, in concert with 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.

Strategy 3: Foster healthy and sustainable communities, with an 

emphasis on equitable development and place-based initiatives.

Increasingly, environmentally and economically burdened communities are 

seeking comprehensive solutions that address adverse human health and 

environmental effects, as well as health disparities, while enabling these 

communities to make a transition to sustainable community development. 

Communities 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 overburdened 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 

Environmental Justice, the EJ IWG identified four areas of significant 

concern to overburdened communities: 

 Green Jobs and Clean Energy. 

 Healthy and Sustainable Communities. 

 Climate Change and Adaptation. 

 Goods Movement. 

The following activity will be conducted to implement Strategy 3. 

 Activity 3.1: Recommend ways to enhance federal interagency 

coordination in support of healthy and sustainable communities as well 

as equitable development. EPA, in conjunction with other federal 
Plan EJ 2014: Appendix, Implementation Plans 98

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 overburdened 

communities in the implementation of existing executive orders and 

administration priorities. Federal agencies will make community 

engagement an important part of our efforts to identify environmental 

justice issues and opportunities for interagency collaboration. Actions 

should be based on the following principles: 

o Designate an EJ IWG agency to serve as lead. 

o Build on and leverages existing Administration initiatives. 

o Enhance existing policies or programs to address 

environmental justice issues. 

o Identify data needs and success measures. 

o Identifies place-based project for coordinated action, if 

appropriate. 

o Address issues of community access to resources and technical 

assistance. 

o Promote state, regional, local, and tribal partnerships. 

o Utilize regional forums and other community outreach to 

inform federal actions. 

Strategy 4: Strengthen Community Access to Federal Agencies. 

In the priorities outlined by Administrator Lisa 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 EPA’s goals is to strengthen the 

ability of communities to access the 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, EPA 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 interagency cooperation that need improvement, the EPA 

regions will select three communities of concern about which they 

have extensive knowledge. Each EPA region will develop an inventory 

of the communities’ already-identified needs and then 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 EJ IWG can identify trends − for example, those 

three or four federal agencies whose assistance is needed in the 

broadest number of communities. The product of this internal EPA 

analysis will be a request to the Administrator to approach those 

agencies through the EJ IWG for a commitment and the development 

of strategies. 
Plan EJ 2014: Appendix, Implementation Plans 99

 Activity 4.2: Targeted Training for Communities. EPA will identify 

appropriate delivery mechanisms to convey information to 

communities on existing federal programs and expertise relevant to 

them. This information will be based on the work already underway in 

the EJ IWG and EPA’s Office of Policy (OP) to catalog existing federal 

programs and expertise. Potential delivery mechanisms include 

trainings, conferences, and webinars. 

 Activity 4.3: Review Federal Partners Meeting. EPA 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 

Environmental Justice Workgroup will participate on the parallel 

workgroup under the OP’s Community-Based Coordination Efforts 

(CBCE) Initiative’s cross-Agency External Coordination Workgroup. This 

person will ensure that environmental justice 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: 

o Cataloguing existing community-based efforts with interagency 

coordination. 

o 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. 

 
Plan EJ 2014: Appendix, Implementation Plans 100

2.3 Community Engagement and Stakeholder Plan 

Community engagement and stakeholder partnership activities are 

integrated into the different strategies and activities of this 

implementation plan. Many of the strategies and activities in 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 OEJ. 
Plan EJ 2014: Appendix, Implementation Plans 101

3.0 DELIVERABLES 

Strategy 1: Assist other federal agencies to better integrate environmental 

justice into agency programs, policies, and activities. 

ACTIVITY DELIVERABLES MILESTONES

Activity 1.1: Chair and 

convene EJ IWG 

Principal, Deputy, and 

Senior Staff meetings.

 Chair annual 

Principals/Deputies 

meetings. 

 By the end of 

2011

 Chair Senior Staff 

meetings/calls.

 Monthly

Activity 1.2: Chair, 

assist, and oversee 

each federal agency’s 

effort to update or 

develop its 

environmental justice 

strategy.

 Oversee the 

finalization of each 

Agency’s 

environmental justice 

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 tools that 

help environmental 

justice and other 

stakeholders identify 

federal information and 

resources.

 Publish a draft 

Federal 

Environmental 

Justice Directory and 

draft Federal 

Resource Guide.

 By the end of 

2011

 Review EPA’s EJ 

IWG website.

 Annually

 Update EPA’s EJ 

IWG website.

 As appropriate

Activity 1.5: Convene 

a group of senior 

attorneys from across 

the Administration in 

order to promote the 

integration of 

environmental justice

into their agencies' 

actions.

 Conduct meetings on 

regular basis.

 As appropriate
Plan EJ 2014: Appendix, Implementation Plans 102

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 consistent message 

about the need to 

incorporate 

environmental justice 

into NEPA 

implementation.

Issue a directive to NEPA 

reviewers emphasizing 

environmental justice, 

reinforcing the utility of NEPA 

through CAA Section 309 

reviews as a tool to effect 

good decisions and take into 

account environmental justice 

considerations. 

 Stakeholder outreach: 

Work with regional 

managers. Post on web.

March 31, 2011

Activity 2.2: Enable 

federal NEPA 

practitioners to 

enhance consideration 

and execution of 

environmental justice 

requirements in NEPA 

implementation.

Engage with federal agencies 

to identify unique or “best 

practices.” Develop 

information on “best practices” 

for implementing 

environmental justice 

requirements in the NEPA 

process and post on the 

internet.

 Stakeholder outreach: 

Work with EPA 

environmental justice 

experts and regional 

NEPA practitioners. 

Share with the NEJAC.

September 30, 

2011

Work with the EJ IWG, White 

House CEQ, federal agencies, 

and the NEJAC to urge that all 

federal agencies with NEPA 

responsibilities have robust 

agency-specific guidance in 

place setting forth a process to 

meaningfully consider 

environmental justice in the 

NEPA EIS process. EPA will 

identify and disseminate 

examples/components of 

strong guidance.

 Stakeholder outreach: EJ 

IWG, White House CEQ, 

NEJAC.

June 30, 2011

Develop a best practices tool 

for regulators to analyze 

specific environmental impacts 

and identify typical community 

concerns for a particular 

sector.

September 31, 

2011
Plan EJ 2014: Appendix, Implementation Plans 103

ACTIVITY DELIVERABLES MILESTONES

 Stakeholder outreach: 

Work with affected 

regions, communities, and 

federal and state 

regulators.

Activity 2.3: Develop 

a plan of action, in 

consultation with DOJ, 

which will outline how 

EPA will re-evaluate the 

approach for analyzing 

Title VI complaints.

Convene stakeholder dialogue 

to discuss the re-evaluation of 

the approach for analyzing 

Title VI complaints.

 Stakeholder Outreach: 

Work with EPA; DOJ; 

state agencies; 

businesses; and civil 

rights, environmental 

justice, community, and 

other experts.

June 30, 2011

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 to hold 

stakeholder dialogues to 

discuss the development of 

compliance strategies and 

actions to address noncompliance.

 Stakeholder Outreach: 

Work with EPA, DOJ, and 

other federal agencies. 

November 30, 

2011
Plan EJ 2014: Appendix, Implementation Plans 104

Strategy 3: Foster Healthy and Sustainable Communities, with emphasis on 

equitable development and place-based 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 

overburdened communities in 

the implementation of existing 

executive orders and 

administration priorities, in the 

at least two of the following 

four areas:

 Clean Jobs and Clean 

Energy.

 Healthy and Sustainable 

Communities.

 Climate Change and 

Adaptation.

 Goods Movement.

September 30, 

2012

Strategy 4: Strengthen Community Access to Federal Agencies. 

ACTIVITY DELIVERABLES MILESTONES

Activity 4.1:

Community Needs 

Inventory Pilot.

Inventory of three Region 6 

environmental justice 

communities' needs and 

corresponding federal 

agencies.

April 30, 2011

Inventory of 27 remaining 

regional environmental justice 

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 the EJ 

IWG.

By May 31, 

2012

Activity 4.2: Targeted 

Training for 

Communities.

 Assessment of program 

cataloging results in the 

EJ IWG and OP efforts.

 Identification of best 

delivery mechanisms to 

reach communities.

By September 

30, 2011
Plan EJ 2014: Appendix, Implementation Plans 105

ACTIVITY DELIVERABLES MILESTONES

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 

Agency CBCE Initiative.

Draft options paper for 

Executive Management 

Council (EMC) review.

By February 15, 

2011

Form workgroups to 

implement selected actions.

To be 

determined
Plan EJ 2014: Appendix, Implementation Plans 106

4.0 REPORTING 

Progress reports on this implementation plan will be made annually. The 

planned deliverables and milestones for each of the activities are described 

above. Each of the offices responsible will further refine and develop the 

activities 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.

 
Plan EJ 2014: Appendix, Implementation Plans 107

6. Science Tools Development 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of Research and Development 

And Region 7

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 108

1.0 INTRODUCTION 

Under Plan EJ 2014, the U.S. Environmental Protection Agency (EPA) has 

committed to building a strong scientific foundation for supporting 

environmental justice and conducting disproportionate impact analysis, 

particularly methods to appropriately characterize and assess cumulative 

impacts. These efforts will help to ensure that EPA brings the best science 

to decision making around environmental justice issues. 

This Science Tools Development Implementation Plan discusses 

overarching goals, strategies, and activities, including a science and 

research agenda for the Agency. The science and research activities 

described in this plan build upon discussions and recommendations from 

“Strengthening Environmental Justice and Decision Making: A Symposium 

on the Science of Disproportionate Environmental Health Impacts” (March 

17-19, 2010) and the workshop on “Analytical Methods for Assessing the 

Environmental Justice Implications of Environmental Regulations” (June 9-

10, 2010). The March 2010 Symposium was the principal event for the 

Agency to identify science needs for environmental justice and stimulate 

ideas for innovative research to meet those needs. 

1.1 Goals 

Our goal is that, within five years, EPA will substantially support and 

conduct research that employs participatory principles and integrates 

social and physical sciences aimed at understanding and illuminating 

solutions to environmental and health inequalities among overburdened 

populations and communities in the United States. This goal supports our 

vision that all Agency decisions will make use of the information, data, and 

analytic tools produced. Our goal has two specific elements: 

1. Improve the scientific basis for environmental regulatory and policy 

decisions in order to ensure that everyone enjoys the same degree of 

protection from environmental and health hazards and equal access to 

the decision-making process to have a healthy environment in which to 

live, learn, and work. 

2. In order to increase the relevance of science to policy making, 

transform how EPA formulates, designs, prioritizes, conducts, and 

fosters more citizen participatory, inclusive, co-production of 

knowledge, and collaborative processes within the scientific research 

enterprise. 

Goals At-A-Glance

To substantially support 

and conduct research that 

employs participatory 

principles and integrates 

social and physical 

sciences aimed at 

understanding and 

illuminating solutions to 

environmental and health 

inequalities among 

overburdened populations 

and communities in the 

United States. 
Plan EJ 2014: Appendix, Implementation Plans 109

1.2 Strategies 

We have five major strategies to achieve our goals. 

1. Apply integrated transdisciplinary and community-based participatory 

research approaches with a focus on addressing multi-media, 

cumulative impacts and equity in environmental health and 

environmental conditions. 

2. Create mechanisms to incorporate perspectives from communitybased organizations and community leaders into EPA’s research 

agendas and engage in collaborative partnerships with them on science 

and research to address environmental justice. 

3. Leverage partnerships with other federal agencies on issues of 

research, policy, and action to address health disparities. 

4. Build and strengthen the technical capacity of Agency scientists on 

conducting research in partnership with impacted communities and 

translating research results to inform change. 

5. Build and strengthen technical capacity of community-based 

organizations and community environmental justice and health leaders 

to address environmental health disparities and environmental 

sustainability issues. 

1.3 Discussion 

Multiple aspects of the physical environment in which we live, learn, work, 

and play can put certain groups of people “at higher risk.” Also, individuals 

and groups may experience disadvantages related to their gender, 

lifestage, socioeconomic status, race, ethnicity, disability, education, 

geographic location, or other characteristics historically linked to 

discrimination or exclusion. This complex interaction between the physical 

environment and other conditions of social disadvantage contributes to 

known social disparities in environmental health outcomes. 

Since 1994, as stated in the Executive Order 12898 (EO 12898), it has been 

incumbent upon all federal agencies including EPA to identify and address 

disproportionately high and adverse human health or environmental 

effects on minority and low-income populations that may result from their 

programs, policies, and activities. The concept of disproportionate 

environmental health impacts and burdens refers to the finding that some 

populations systematically experience higher levels of risks and impacts 

than the general population. (Brulle and Pellow 2006) This perspective 

recognizes that multiple factors, including social, psychosocial, economic, 

physical, chemical, and biological determinants may contribute to 

disproportionately high and adverse human health or environmental 

impacts. 
Plan EJ 2014: Appendix, Implementation Plans 110

The importance of science in environmental decision making at EPA 

emphasizes the need for data and information that is sound and 

defensible, reproducible, and informative. For environmental justice 

stakeholders, it is even more important that the science underlying EPA’s 

decisions appropriately accounts for the multiple exposures to chemical 

stressors and cumulative impacts from multiple exposures that they 

experience in their communities. Further, the social and real world context 

in which exposures to environmental contaminants occur also needs to be 

explicitly considered and reflected in EPA’s scientific research and analysis 

as emerging evidence demonstrates that social context may enhance the 

toxic effects of both single and multiple environmental contaminant 

exposures. Such considerations require new models for assessing the 

toxicity of environmental hazards, advanced methods for analyzing 

complex interactions between multiple stressors, and enhanced access to 

community-level wisdom and resources. 

These emerging needs indicate that new ways of conducting scientific 

inquiry to inform environmental decision are needed at EPA. Such 

expansion and advancement of EPA’s scientific agenda, methods, models, 

research inquiry approaches, and information resources is necessary for 

the Agency to adequately address environmental justice stakeholder’s 

concerns about environment, sustainability, and health inequalities. These 

advancements take on additional importance when viewed in the context 

of the Agency’s mandate to achieve environmental justice as required by 

EO 12898, and its ability to effectively contribute towards Healthy People 

2020’s overarching goals to achieve health equity, eliminate health

disparities, improve the health of all groups, and create social and physical 

environments that promote good health for all.17

 

Conversely, health and environment status can influence, for example, the 

social and institutional arrangements, which can lead to both negative and 

positive outcomes cumulatively impacting the health of a community. The 

cumulative impact has greater and farther-reaching consequences than any 

one factor or event alone; this is particularly evident among vulnerable 

low-income and underserved populations. In order to determine the 

positive and negative health and environmental impacts during some of 

the social processes described above, the scientific research requires both 

quantitative and qualitative approaches. 

The goals, strategies, and activities for this implementation plan build upon 

the science recommendations articulated at the March 2010 symposium, 

Strengthening Environmental Justice Research and Decision- Making: A 

Symposium on the Science of Disproportionate Environmental Health 

Impacts, and the subsequent “100-Day Challenge” Report developed by the 

Agency in response to recommendations generated from the symposium. 

 

17 Healthy People is a set of goals and objectives with 10-year targets designed to guide national health 

promotion and disease prevention efforts to improve the health of all people in the United States. 
Plan EJ 2014: Appendix, Implementation Plans 111

A consistent theme throughout the March 2010 symposium was the 

linkages between science and policy. These discussions were framed 

within the context of identifying research and scientific needs that are 

necessary to ensure that environmental justice concerns and social 

disparities in environmental health are incorporated in EPA’s decisions for 

the purpose of advancing EPA policy on environmental justice. Several 

conceptual frameworks have been published in the last few years that 

relate environmental justice and health disparities to upstream, structural 

determinants of health (CSDH 2008; Gee and Payne-Sturges 2004; Krieger 

2001; Habermann and Gouveia 2008; Morello-Frosch 2002; Morello-Frosch 

and Shenassa 2006; Schulz et al 2002; Wakefield and Baxter 2010). 

Symposium participants suggested several actions that EPA and other 

federal agencies take in order to reduce data gaps in the area of 

environmental justice, overcome limitations in the theories and methods 

for conducting research on environmental health disparities and 

particularly research supported by the federal government, and overcome 

limitations in practice of risk assessment at EPA. The science 

recommendations from environmental justice advocates and other 

stakeholders are captured in Appendix C.
Plan EJ 2014: Appendix, Implementation Plans 112

1.4 Organizational Structure 

The specific science and research actions described in Section 2.0 were 

developed through a cross-Agency workgroup for the Agency’s 100-Day 

Report follow-up to the March 2010 Symposium. Representation on the 

workgroup included the Office of Air and Radiation (OAR), the Office of 

Chemical Safety and Pollution Prevention (OCSPP), the Office of Policy (OP), 

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

Water (OW), the Office of Research and Development (ORD), and Regions 

6, 7, 8, and 10. Region 7 serves as ORD’s Lead Region. 

Going forward, ORD, as lead for the Science Tools Development 

Implementation Plan, proposes to establish a more permanent structure 

within ORD, which we are planning to name the Environment Health and 

Society Workgroup. This workgroup will serve as ORD science experts and 

points of contact on environmental justice, environmental disparities, and 

disproportionate impacts science issues. ORD’s National Center for 

Environmental Research (NCER) and the Office of Science Policy (OSP) will 

jointly sponsor and co-chair this new workgroup. The co-chairs will also 

lead the Plan EJ 2014 Science Tools Development Workgroup and monitor 

the Science Implementation Plan for Plan EJ 2014. ORD is considering reconstituting the intra-agency group on science for the 100-Day Report to 

serve as the Plan EJ 20114 Science Group. ORD will coordinate with all the 

Plan EJ 2014 implementation workgroups to ascertain how current 

activities can be better tailored or leveraged to address Plan EJ 2014 

workgroups' science needs under the five strategies (listed in Section 1.2) 

and to identify future science activities. 
Plan EJ 2014: Appendix, Implementation Plans 113

2.0 IMPLEMENTATION 

Below we describe several major science and research activities under the 

five strategies. These activities will be carried out with existing resources, 

provided these resources remain available. 

2.1 Activities 

Strategy 1: Apply integrated transdisciplinary and community-based 

participatory research approaches with a focus on addressing multimedia, cumulative impacts and equity in environmental health and 

environmental conditions.

Activity 1.1: Establish an Integrated Transdisciplinary ORD Research 

Program on Environment and Community Health – Sustainable and Healthy 

Communities Research Program. 

The new Administration at EPA and in particular in ORD recognizes that 

fragmented research programs cannot solve 21st century environmental 

challenges including disparities in environmental health. ORD is leading the 

way by integrating 12 research programs that were mostly media-specific 

into four transdisciplinary programs aligned with EPA’s new Strategic Plan. 

As part of this re-structuring, ORD is fully establishing and supporting a new 

integrated transdisciplinary research program on environment and 

community health known as “Sustainable and Healthy Communities.” This 

program seeks to adopt a more holistic view of environment and health as 

its conceptual framework, take on research projects that address many of 

the topics raised at the Symposium, and conduct research in a manner 

consistent with principles of community-based participatory research. 

Both ORD intramural and extramural resources from existing human 

health, land, sustainability, and ecosystems research programs would be 

directed to support this new program. For this new research program to 

be successful, implementation of many of the recommended actions on 

capacity building within ORD and incorporating community perspectives is 

critical. 

As part of the new Sustainable and Healthy Communities Research 

Program (SHCRP), EPA’s new Science to Achieve Research (STAR) grant 

solicitations are being considered to support tribal community 

environmental health research and to establish Centers of Excellence on 

Environment and Health Disparities to examine the joint impacts of social 

and physical environmental conditions, processes and systems on health in 

collaboration with the National Institutes of Health’s (NIH) National Center 

on Minority Health and Health Disparities (NCMHD). 
Plan EJ 2014: Appendix, Implementation Plans 114

Benefits to EPA Stakeholder Communities 

 ORD’s new research program is responsive to suggestions from 

stakeholders to create and institute a new scientific research approach 

that develops a more holistic understanding of the environmental and 

health. This approach will also integrate perspectives from community 

residents and leaders, community-based non-governmental 

organizations (NGOs), and community health and environmental 

quality advocates in the development of EPA’s scientific research 

agendas, as well as in data collection, conduct of risk and exposure 

assessments, and risk management decisions. 

 The hallmark of the integrated proposed transdisciplinary approach is 

“systems thinking,” which seeks to understand the complex 

interactions between social, natural, and built environmental systems, 

conditions and policies that impact human health and well-being. To 

explicitly address environmental justice concerns, this program will 

need to direct its attention to how these complex interactions result in 

unequal environmental health conditions or disproportionate impacts 

among (diverse) disadvantaged population groups, communities, 

neighborhoods and individuals. 

 Anticipated outcomes of this program include new information and 

tools to support more holistic environmental decision making at 

national, regional, state, tribal, and local levels. It is anticipated that 

this program will also inform strategies for alleviating systemic drivers 

of racial and socio-economic disparities in environmental health 

outcomes and access to healthy environments. 

Impacts on EPA Programs and Activities 

 The Assistant Administrator for ORD announced the re-structuring of 

ORD’s 12 media-specific research programs into four integrated 

programs in Fall 2010. The Sustainable and Healthy Communities 

Research Program is an important part of this effort. This new program 

is currently in the early stages of organizing and development. Input 

from EPA program offices will be sought in early 2011. Then in late 

spring, input from outside stakeholders will be solicited. Bringing 

together diversity of disciplines to plan and implement integrated 

research programs will make EPA more effective at developing 

sustainable solutions to complex, 21st century environmental 

problems. It will create a culture where different disciplines are 

encouraged to find innovative solutions and will make EPA’s research 

more timely, relevant and responsive to the short-, medium- and 

longer-term needs of our partners and stakeholders. Several external 

advisory committees continue to recommend this approach. 
Plan EJ 2014: Appendix, Implementation Plans 115

Timeframe 

 Establish and fully support a Sustainable and Healthy Communities 

Research Program (Fiscal Year [FY] 2011). 

 Incorporate ideas and concerns from stakeholders and representatives 

from disproportionately impacted communities and populations (FY 

2011). 

 Issue joint Request for Applications (RFA) or other funding mechanisms 

to collaborate with NIH National Institute on Minority Health and 

Health Disparities to establish Centers of Excellence on Environment 

and Health Disparities (FY 2012). 

Activity 1.2: Develop technical guidance, analytic methods, tools and data 

to advance the integration of environmental justice in EPA’s decision 

making. 

EPA’s regulatory decision making is informed by scientific data and analysis. 

To facilitate the process of using scientific data, EPA scientists and decision 

makers, as well as communities, community advocates and other 

stakeholders, require consistent and systematic guidance on how to 

conduct these analyses. They also depend on scientifically valid tools and 

methods, as well as information communicated by environmental data. 

While the guidance, methods, tools, and data for advancing environmental 

health protection has been an area of significant investment by EPA, these 

tools of the trade have not been fully adapted or developed to specifically 

address environmental justice issues. 

EPA’s commitment to integrating environmental justice in all of its 

decisions, policies, and programs has resulted in investments to develop 

technical guidance, analytic methods, tools, and data. For example, EPA is 

in the process of developing guidance entitled “Technical Guidance for 

Incorporating Environmental Justice into Rulemaking Activities” through 

Plan EJ 2014’s Incorporating Environmental Justice into Rulemaking

Implementation Plan. This document is expected to aid EPA staff and 

managers in incorporating environmental justice into EPA’s analytical 

frameworks such as risk assessment, and economic analysis, and other 

scientific and policy assessments. 

EPA’s OAR is piloting several kinds of analyses that are useful in informing 

managers about the potential environmental justice implications of air 

rulemakings. OAR is evaluating and testing several analytical approaches 

including: (1) proximity-based socio-demographic analyses, which highlight 

the characteristics of those living closest to sources of air pollution; (2) 

exposure and health risk modeling that breaks out data based on sociodemographic characteristics (e.g., race, income); and (3) benefits mapping 

that shows the distribution of benefits of a regulation to various sociodemographic groups. OAR expects to learn from their experiences in using 

these approaches. OAR will revise its methods accordingly, as it seeks to 

do a better of job of identifying rules that may present environmental 

justice concerns and to understand more fully the implications of air rules 
Plan EJ 2014: Appendix, Implementation Plans 116

on overburdened populations. OAR’s experiences will help to inform the 

overall Agency effort to develop the technical guidance. 

ORD plans to evaluate existing tools developed by ORD scientists with 

respect to appropriateness and ease of use for lay experts in communities. 

To improve access to Agency tools, ORD plans to work with stakeholders to 

develop a series of free regionally-based trainings on EPA’s information and 

assessment tools. ORD also plans to partner with EPA regional offices, 

other federal agencies, and consortia of environmental justice and 

community health non-profits and community-based organizations to host 

community-based tools workshops and Regional Tools Summits. There will 

be a specific focus on tools to evaluate environmental justice and health 

disparities policies and programs. 

ORD proposes to continue to develop cumulative risk/impact assessment 

techniques and analytics, tools, and mapping methods that can be applied 

at multiple geographic scales. For example, ORD has committed $8 million 

in research investment through STAR grants on cumulative risk assessment 

methods that incorporate community social contexts (non-chemical 

stressors) and indicators of population vulnerability (see 

http://www.epa.gov/ncer/cumulativerisk). The Agency will ensure 

research results from these new STAR grants on cumulative risks, and 

chemical and non-chemical stressors are well disseminated and used by 

EPA program offices. 

ORD’s Office of the Science Advisor (OSA) and the National Exposure 

Research Laboratory (NERL) have launched an initiative to develop a webbased cumulative risk assessment tool, the Community Cumulative 

Assessment Tool (CAAT). This tool will enable a more complete and 

thorough evaluation and understanding of physiological and socioeconomic 

stressors that result in cumulative impacts in U.S. communities and 

populations. This broader framework for decision making leads to 

inherently more sustainable outcomes as a result of a more complete 

understanding of the factors constituting and contributing to risk in 

identified populations. 

The CCAT is designed to implement a multi-media approach to cumulative 

risks in communities facing environmental justice issues; and will leverage 

datasets, research, and certain Geographic Information System (GIS) 

capabilities that were developed for C-FERST in the Communities and 

Cumulative Risk Research Program in ORD. The CCAT will also reflect the 

cumulative impact considerations outlined in the “Technical Guidance for 

Incorporating Environmental Justice into Rulemaking Activities” and 

provide insight on environmental justice to the Risk Assessment Forum 

(RAF) Technical Panel developing the EPA Cumulative Risk Assessment 

(CRA) Guidelines. The project is directly responsive to the recognition that 

vulnerability and health disparities are interrelated and must be studied 

within the risk assessment paradigm. The developers of the CCAT will 

engage with environmental justice and community-based stakeholders to 
Plan EJ 2014: Appendix, Implementation Plans 117

inform the development of the CCAT and related agency cumulative risk 

assessment guidelines. This approach purposely builds skills among EPA 

scientists to design research and risk assessment protocols informed by 

collaboration with affected communities. 

At the March 2010 Symposium, participants requested EPA to develop 

easy-to-use GIS tools. ORD’s National Atlas of Ecosystem Services is 

developing an Urban Atlas, which will include high-resolution mapping for 

100-250 populated areas selected along several gradients of concern (e.g., 

size, location, demographics, and environmental and health condition). It 

will feature selected small towns and rural communities, including rural 

Tribal lands. By mapping the current availability of “green” infrastructure 

and applying existing models for pollutant removal, water storage, and 

other functions, ORD’s National Atlas will estimate the extent to which 

ecosystem services contribute to the basic needs of populated places. 

Additionally, the Atlas will reveal under-served areas where 

management to enhance specific ecosystem services would benefit 

community health and well-being. This local component of the 

Atlas will include demographic mapping to identify overburdened 

sub-populations that may benefit disproportionately from “green” 

infrastructure and/or are disproportionately underserved. The 

Atlas will permit stratification of urban and other populated areas 

to develop separate estimates of ecosystem services for 

communities identified as socially vulnerable. Additionally, it will 

incorporate accessible health data to map aspects of population 

susceptibility to diminished or degraded services. EPA is 

conducting this project in collaboration with multiple federal 

agencies, including the U.S. Forest Service, the U.S. Geological 

Survey, and the Centers for Disease Control and Prevention, as well 

as academic and other educational organizations. EPA regions and 

ORD’s Human Health Research Program are interacting with 

communities to identify priority issues and build capacity for 

working with mapping tools to inform risk evaluation and 

management decisions. 

EPA’s ORD is also developing an Environmental Quality Index tool for 

measuring county level environmental quality, which will increase 

understanding about how multiple stressors simultaneously contribute to 

health disparities in minority, low-income, tribal, and indigenous 

populations. 
Plan EJ 2014: Appendix, Implementation Plans 118

Benefits to EPA Stakeholder Communities 

 The development of guidance, methods, tools, and data to advance the 

integration of environmental justice into EPA’s decision-making 

processes is responsive to several comments provided by stakeholders. 

For example, these activities address suggestions that EPA consider the 

areas of policy, capacity building, and promoting healthy and 

sustainable communities. These stakeholder comments recommend 

EPA to: (1) develop analytic and assessment tools and data collection 

approaches that can be used by community health advocates and 

environmental justice groups; (2) adopt multi-media cross-program 

approaches to addressing cumulative environmental exposures in 

stakeholder communities, as well as restructuring risk assessment to 

better account for multiple stressors; (3) increase community capacity 

to assess their environment; (4) develop a more holistic understanding 

of environment and health; and (5) integrate environmental justice in 

all its decisions. Better integration of environmental justice into EPA’s 

decisions directly benefits communities impacted by EPA’s regulatory 

activities. The overarching goal of developing these tools of the trade 

is to aid EPA staff to develop regulatory options that fully protect the 

health and environment of all people, as well as help communities to 

better understand their environmental problems.

 Community-based “stakeholders” will benefit from CCAT through 

access to improved information that integrates their own 

understanding of local conditions with data drawn from EPA’s

databases. Depending upon application, benefits may include 

improved capacity to collaborate with Agency experts, identify 

priorities, and pursue risk reduction strategies to improve public health 

and the environment.

 Key outcomes of the Urban Atlas will be to inform community 

members and decision makers as to how natural resources are critical 

community assets, and how their absence or degradation may be 

contributing to cumulative burdens on human health and well-being. 

Furthermore, the integrated, multi-media approach of the Urban Atlas 

will provide information on the co-benefits accrued to the community 

when applying ecosystem services to mitigate specific environmental 

contaminants or other priority health risks. 

Impacts on EPA programs and activities 

 These actions are also responsive to several core focus areas of EPA’s 

Plan EJ 2014 and the principles on environmental justice articulated in 

EPA’s Strategic Plan for 2011-2015. It is also responsive to the 

mandate in EO 12898 which requires that EPA identify and address 

disproportionately high and adverse human health or environmental 

effects of its policies, programs and activities on minority, low income, 

and tribal populations.

 Results produced by the new research grants on cumulative risks and 

impacts will demonstrate successful approaches to incorporating 

community knowledge into the development of such tools and the 
Plan EJ 2014: Appendix, Implementation Plans 119

application of qualitative approaches and social science methods into 

cumulative impact assessments. EPA’s programs will benefit from the 

development of the CCAT through engaging with stakeholders to 

address the community-based assessment of cumulative risks with 

environmental justice concerns. 

 Intensive engagement with environmental justice stakeholders will 

improve the incorporation of these issues in the design of the CRA

Guidelines. The CCAT will improve the capacity of EPA regional risk 

assessors to assist communities in understanding the complexity of 

risk, and provide the means by which to identify priorities. Also the 

CRA-EJ software will assist programs in implementing the planned 

“Technical Guidance for Incorporating Environmental Justice into 

Rulemaking Activities” by facilitating a step-by-step approach to 

evaluating cumulative risks and impacts. More broadly the CRA 

Guidelines will affect risk-based decision making across the full range of 

EPA’s programs, nationally, regionally, and more locally. The CCAT is a 

project under the RAF CRA Technical Panel, and will directly 

incorporate environmental justice into CRA and thus introduce 

environmental justice risk-based considerations throughout EPA’s

policies and decision making. 

 The process for developing these tools, data, methods, and guidance 

will lead to innovative approaches and tools for incorporating 

environmental justice concerns in EPA’s regulatory and policy decision 

making. Other innovations include identifying research needs and data 

gaps on topics such as environmental public health indicators to assess 

disparities, equity impact assessment methods, metrics to assess 

inequities in risk assessments to support rule making, and policy and 

program evaluation. ORD plans to bridge these data gaps through both 

intramural and extramural research programs. 

 Initial community interaction for the development of the Urban Atlas 

will proceed through EPA’s existing initiatives such as the CARE and 

Environmental Justice Showcase Communities programs and the 

EPA/U.S. Department of Housing and Urban Development (HUD)/U.S. 

Department of Transportation (DOT) Partnership for Sustainable 

Communities, and their EPA liaisons. Information about ecosystem 

services will expand options for improving community health and wellbeing, and clarify economic and other trade-offs involved in alternate 

environmental mitigation and remediation decisions. The selection of 

focal areas along several gradients is designed to facilitate the 

application of observed linkages between community welfare and 

ecosystem services to additional populated places of concern to EPA. 
Plan EJ 2014: Appendix, Implementation Plans 120

Timeframe 

 Develop final draft of technical guidance by FY 2013. 

 Develop and refine screening tools that identify air rules that raise 

potential environmental justice concerns (FY 2011). 

 Determine the analytical tools are most appropriate for particular types 

of air rulemaking (FY 2011-12). 

 Identify any additional analytical tools that may be needed to better 

understand the environmental justice implications of air rulemakings 

(FY 2011-12). 

 Host community-based tools workshop(s) and Regional Tools Summits 

with focus on environmental justice and health disparities, to solicit 

recommendations and inform EPA’s actions on tools under Plan EJ 

2014 (FY 2012-13). 

 Develop final Environmental Quality Index (Long term). 

 Beta test a prototype of the CCAT in early 2012.

 Complete first phase of the Urban Atlas will be completed in FY 2013; 

incorporate additional populated areas will begin in FY 2012 and FY 

2013, contingent upon funding. 

Strategy 2: Incorporate perspectives from community-based 

organizations and community leaders into EPA research agendas and 

engage in collaborative partnerships on science and research to address 

environmental justice.

A few initiatives are highlighted here to better engage with communities in 

EPA science activities and implementation of regulatory programs. 

Activity 2.1: Establish Community Engagement Initiative. 

OSWER has launched the Community Engagement Initiative (CEI), 

www.epa.gov/oswer/engagementinitiative/, which is designed to enhance 

OSWER and regional offices' engagement with local communities and 

stakeholders (e.g., state and local governments, tribes, academia, private 

industry, other federal agencies, non-profit organizations) to help them 

meaningfully participate in government decisions on land cleanup, 

emergency preparedness and response, and the management of hazardous 

substances and waste. 

Activity 2.2: Re-engage with National Environmental Justice Advisory 

Committee. 

ORD intends to establish a health and research workgroup or 

subcommittee within National Environmental Justice Advisory Committee 

(NEJAC) to advise the EPA Administrator and ORD in the area of scientific 

research, health impacts, and environmental risks and exposures that 

directly relate to environmental justice. An initial task of the workgroup 

will be to advise ORD on the development of the Sustainable and Health 

Communities Research Program. 
Plan EJ 2014: Appendix, Implementation Plans 121

Activity 2.3: Support Community-based Participatory Research. 

Participatory research methods will be integrated into the new ORD 

research program on Sustainable and Healthy Communities and new 

extramural research solicitations to support CBPR are under consideration. 

A significant feature of the Sustainable and Health Communities Research 

program will be community and regional based projects. Applying 

participatory research methods will be the hallmark of this new program 

within ORD. Community-based participatory research (CBPR) fosters more 

complete understandings of the existing interactions between 

environmental conditions, human health and ecosystems. Researchers, 

practitioners, community members, and funding institutions have 

increasingly recognized the importance of comprehensive, holistic, and 

participatory approaches to environmental research and later stages of 

intervention. For EPA, applying CBPR in its scientific research and program 

planning promises to lead to more appropriate solutions for the persistent 

and uneven social disparities in health as well as access to clean and safe 

environments. 

Benefits to EPA Stakeholder Communities 

 These actions are in agreement with suggestions from environmental 

justice stakeholders to integrate perspectives from community 

residents and community leaders in the development of the EPA’s 

scientific research agendas as well as in data collection. 

 OSWER’s CEI will include direct outreach to state and local 

governments, tribes, academia, private industry, other federal 

agencies, and non-profit organizations. The CEI is designed to help 

stakeholders have meaning participation in EPA’s decisions on land 

cleanup, emergency preparedness and response, and the management 

of hazardous substances and waste. It will also improve OSWER efforts 

to protect human health and the environment through site cleanups 

and other risk reduction activities. 

 Re-establishing a NEJAC health and research workgroup or 

subcommittee would provide a critically needed formal mechanism for 

environmental justice stakeholders, community-based organizations to 

provide input and feedback into the EPA/ORD research initiatives. 

Presently, ORD lacks any mechanism for public input into its research 

agenda. If concerns about environmental and health inequalities are 

not “on the table” they will be not be addressed by the EPA research 

enterprise. However it must be recognized that a NEJAC subcommittee 

cannot be the only approach for soliciting the contribution of 

environmental justice stakeholders. ORD will need to identify 

additional approaches for soliciting input and collaborating with 

environmental justice stakeholders (e.g., through regional outreach, 

the Regionally Applied Research Effort (RARE) program, and partnering 

with EPA program offices and other federal agencies). Creating formal 

mechanisms for receiving stakeholder input assures that community 

wisdom, perspectives and values are duly considered and 

accommodated in the development of ORD’s new program. Moreover, 
Plan EJ 2014: Appendix, Implementation Plans 122

such mechanisms assure that the results of this program, which 

subsequently influence decision making at EPA, also consider robust 

community input. 

Impacts on EPA programs and activities 

 Nearly all of OSWER programs and activities will be impacted by the 

various CEI actions. The CEI is designed to enhance OSWER and 

regional offices' engagement with local communities and stakeholders, 

and to help them meaningfully participate in government decisions on 

land cleanup, emergency preparedness and response, and the 

management of hazardous substances and waste. 

 The first task for this NEJAC workgroup could be to advise ORD on 

developing the Sustainable and Healthy Communities Research 

Program initiative, which is currently being discussed. Since this 

research program is in its early stages of development, engaging a 

NEJAC workgroup now could be extremely beneficial to ORD to help set 

the course, identify critical research questions that should be 

addressed and how best to solicit input and potential partnerships with 

community-based organization and environmental justice leaders such 

as hosting public forums on the Sustainable Community Environments 

and Public Health research program. 

Timeframe 

 Each of the CEI actions has defined deliverables and timeline for their 

completion. Nearly all of the actions have significant deliverables due 

in FY 2011. 

 Incorporate ideas and concerns from stakeholders and representatives 

from disproportionately impacted communities and populations (FY 

2011). 

 Establish a NEJAC workgroup on research by FY 2012.

 Issue joint RFA or other funding mechanism to collaborate with NIH 

National Institute Minority Health and Health Disparities to establish 

national research Centers of Excellence on Environment and Health 

Disparities (FY 2012). 

Strategy 3: Leverage partnerships with other federal agencies on issues 

of research, policy, and action to address environmental and health 

disparities. 

Environmental justice and related concerns for health inequalities are 

complex and multi-dimensional. Solutions to these societal problems 

require intersectoral and intergovernmental actions. Environmental justice 

is not solely EPA’s responsibility, just as health disparities cannot be seen 

solely as a U.S. Department of Health and Human Services problem. At 

present, governmental approaches to promoting and managing health and 

it determinants, namely the environment, are fragmented. Symposium 

participants recognized in order to achieve environmental justice, a multistakeholder, multi-system approach is required. Within federal agencies, 

we need to strengthen federal interagency collaboration to improve 
Plan EJ 2014: Appendix, Implementation Plans 123

research that can impact environmental and health practice, programs, and 

policy and formulate solutions for communities. 

Activity 3.1: Join the Federal Collaboration on Health Disparities. 

EPA’s ORD will actively participate on the interagency Federal Collaboration 

on Health Disparities Research (FCHDR) and represent EPA on the Executive 

Steering Committee (http://minorityhealth.hhs.gov/fchdr/). The Executive 

Committee of the FCHDR was created to bring together selected agency 

representatives to seek practical solutions to advance health disparities 

research, and foster greater federal coordination, collaboration, and 

communication around the elimination of health disparities. 

Federal departments represented on the Executive committee include: 

 U.S. Department of Education 

 National Institute on Disability and Rehabilitation Research 

 U.S. Department of Housing and Urban Development 

 U.S. Department of Justice 

 U.S. Department of Veterans Affairs 

 U.S. Environmental Protection Agency 

 National Science Foundation 

 U.S. Department of Health and Human Services (HHS), Centers for 

Disease Control and Prevention 

 HHS, Health Resources and Services Administration 

 HHS, National Institute for Minority Health and Health Disparities 

 HHS, Office of Minority Health 

The FCHDR’s goal is to ensure that health disparities research is conducted 

as an integrated and inclusive field of study, rather than as an aggregate of 

independent research activities occurring in separate research domains. 

FCHDR members will work together to explore needs and opportunities for 

pooling scientific expertise and resources to conduct, translate, and 

disseminate research most needed to accelerate the elimination of health 

disparities. 

FCHDR goals and strategies are to: 

1. Identify health disparities challenges including the scientific and 

practical evidence most relevant to underpinning future policy and 

action. 

2. Increase and maintain awareness about federal government efforts 

and opportunities to address health disparities. 

3. Determine how evidence can be translated into practice to address 

health disparities and promote innovation. 

4. Advise on possible objectives and measures for future research, 

building on the successes and experiences of health disparities experts. 

5. Publish reports that will contribute to the development of the FCHDR 

strategic vision and plan. 
Plan EJ 2014: Appendix, Implementation Plans 124

Activity 3.2: Engage with President’s Task Force on Environmental Health 

Risks and Safety Risks to Children. 

EPA’s OAR, the Office of Children’s Health Protection (OCHP), ORD, and 

others are collaborating and participating with other federal agencies on 

the newly re-established President’s Task Force on Environmental Health 

Risks and Safety Risks to Children. One focal area of their work is on 

asthma disparities among minority and disadvantaged children. In early 

December 2010, a Federal Workshop on Asthma Disparities was held in 

Washington, D.C., to foster interagency coordination on development and 

implementation of a detailed Federal Action Plan to address asthma 

disparities. 

Benefits to EPA Stakeholder Communities 

 More coordinated federal approach to research, policy, and action to 

address environmental justice health disparities. 

Impact on EPA programs and activities 

 EPA’s participation in these three federal initiatives will identify and 

create opportunities to combine resources to tackle issues of 

disparities in health and access to clean environments; and will 

increase access and exposure of all EPA offices, including ORD, to nontraditional EPA disciplines such as social science and concepts such as 

social determinants of health. 

Timeframe 

 ORD’s participation with the federal collaboration is ongoing. 

 Participation with other federal agencies on the President’s Task Force 

on Environmental Health Risks and Safety Risks to Children to work on 

asthma disparities among minority and disadvantaged children that can 

be addressed through interagency coordination on development and 

implementation of a detailed Federal Action Plan (FY 2011- 2015). 

Strategy 4: Build and strengthen the technical capacity of EPA scientists 

on conducting research and related science activities in partnership with 

impacted communities and translating research results to inform change.

Along with efforts to increase technical capacity in communities, EPA needs 

to build up its capacity to work with communities in order for real progress 

to be made. Several recommendations from the Symposium address this 

issue and call for EPA to: 

 Train EPA staff on effective outreach and dialog with communities; 

 Develop capacity within the Agency. 

 Provide training for EPA risk assessors and managers on community 

engagement. 

 Consider using qualitative approaches in risk assessment. 

 Establish multi-disciplinary teams to work on issues. 

 Encourage multidisciplinary teams in environmental health research. 

 Explore approaches for interacting with communities that can build 

collective efficacy and social capital. 
Plan EJ 2014: Appendix, Implementation Plans 125

 Support participation of communities as equal partners in research; 

include them as equal partners in the co-production of knowledge. 

 Include community representatives and perspectives in the design of 

studies/research. 

Social science disciplines like social epidemiology indicate that EPA needs 

to look more at upstream factors – social processes that ultimately process 

the disparities in risks and health outcomes. 

Activity 4.1: Provide training to EPA scientists on CBPR. 

Both ORD and OSWER intend to provide training to scientists on principles 

of community-based participatory research, health disparities, and 

environmental justice. Both offices will look for opportunities to 

collaborate on providing training for staff. For example, OSWER’s 

Community Involvement and Program Initiatives Branch (CIPIB) sponsors a 

Community Involvement University (CIU) to provide training courses for 

Superfund Program Community Involvement Coordinators (CIC) and other 

EPA and EPA-affiliated staff. Participants are provided with the necessary 

skills, techniques, and practices to engage the community in the Superfund 

process. CIU offers a variety of courses each year at regional offices and at 

national conferences or training events. These courses could be offered to 

ORD scientists and modified to address community-engagement in more of 

the research context. 

In order to design appropriate capacity training program, ORD will first 

evaluate current understanding and research capacity of ORD sciences 

regarding principles of community-based participatory research, health 

disparities, and environmental justice. ORD will then design and 

implement training for its staff. 

Activity 4.2: Build Social Science Capacity within ORD. 

The National Center for Environmental Research (NCER) is developing an 

ORD research agenda for behavioral and social sciences as they impact and 

affect environmental protection as well as the evolution of environmental 

policy. Environmental justice consideration will be critical to this research 

agenda. ORD will conduct Individual and focus group interviews of 

behavioral and social science experts to solicit their thoughts and identify 

the most relevant current research as well as known gaps in four areas: 

behavioral economics, decision theory, management science, and risk 

perception. Following the expert interview, NCER will host a workshop 

with the scientific leaders identified through the interview phase (30-50 

people). 

NCER plans to establish a cooperative agreement with a professional 

society concerned with applying the social science research to 

contemporary environmental health issues. This effort is intended to help 

ORD devise approaches and methods for truly incorporating the social 
Plan EJ 2014: Appendix, Implementation Plans 126

sciences into its research and assessment activities. Activities under the 

cooperative agreement could include: 

 Providing training to ORD staff on incorporating qualitative approaches 

and social science methods into cumulative impact assessments. 

 Developing approaches to incorporate community knowledge in such 

tools for cumulative impact assessments. 

 Offering webinars and training to cultivate analytical skills among ORD 

staff to examine the social and economic systems that create 

cumulative adverse environmental impacts in communities. 

Activity 4.3: Develop Environmental Justice Risk Management Training for 

OPP. 

The Office of Pesticide Programs (OPP) has created a new training module 

as a part of its regular staff training program to ensure that environmental 

justice and sensitive population considerations are fully incorporated and 

more clearly characterized in the pesticide risk assessment process. The 

training module consists of two components: (1) addressing general 

background on environmental justice, and (2) integrating environmental 

justice considerations through OPP risk management to address 

environmental justice issues identified by the risk assessments. 

Benefits to EPA Stakeholder Communities 

 Impacted communities and environmental justice leaders should see 

improved interactions with Agency scientists. 

 The goal of OPP’s training is to provide the tools to better identify 

potential environmental justice issues. Enhanced risk assessment 

methodologies will result from a closer and more focused look at the 

toxicity and exposure patterns specific to each pesticide and pesticide 

use that could present a disproportionate risk. Areas now considered 

in pesticide risk assessment (hazard assessment, dietary exposure, 

occupational and resident exposure, incident data) will be considered 

through an environmental justice lens. 

Impact on EPA programs and activities 

 We anticipate that the capacity of Agency scientists to conduct 

research in partnership with impacted communities, to understand and 

employ social science methods in environmental research, and 

translate research results to inform change will be greatly improved. 

This will help ORD’s Sustainable and Healthy Communities Research 

Program meet its objectives. 

 The OPP training program will improve how environmental justice is 

incorporated by risk managers. This training is expected to influence 

pesticide registration and re-registration decisions to more robustly 

incorporate environmental justice considerations. To date, 10 training 

sessions on the first component and a total of 160 OPP staff completed 

the training. 
Plan EJ 2014: Appendix, Implementation Plans 127

Timeframe 

 Host scientist to scientist workshop on behavioral and social sciences 

(late FY 2011). 

 Design a research capacity training program for ORD scientists, which 

could include self-paced training on community-based and 

participatory research CBPR offered by Michigan Public Health Training 

Center and joint courses through OSWER’s Community Involvement 

University (FY 2012–2013). 

 Complete the new OPP module on risk management training by early 

FY 2012. The goal will be to have 100 percent of risk assessors and 

managers trained by the end of FY 2012. 

Strategy 5: Build and strengthen technical capacity of community-based 

organizations and community environmental justice and health leaders to 

address environmental health disparities and environmental 

sustainability issues.

Community capacity has been defined as “a set of dynamic community 

traits, resources, and associational patterns that can be brought to bear for 

community-building and community health improvement” (Norton et al 

2002). “Community capacity building activities” are those designed to 

increase community capacity and emphasize (1) assets and empowerment 

(versus disease and deficiency); (2) the role of bottom-up, communitydetermined processes and agendas (versus top-down/externally 

determined ones); and (3) the processes for developing community 

competence. 

The commissioned paper on community-capacity presented at the March 

2010 Symposium identified important domains of action to strengthen 

community capacity, including leadership, participation, skills, resources, 

social and organizational networks, sense of community and understanding 

of community history, community power, community values, community 

cohesion, language capacity, and community information. 

(See http://www.epa.gov/ncer/events/calendar/2010/mar17/papers.html) 

In addressing all of these domains, strategies for enhancing community 

capacity may include training and technology transfer, technical assistance, 

community-based participatory research, empowerment approaches, 

community organizing, and social action. Commissioned paper authors 

noted that capacity-building strategies that give more control to 

communities (e.g., CBPR, empowerment, and community organizing) may 

more fully address the fundamental causes of environmental disparities 

than more agency controlled processes (e.g., training and technical 

assistance). 

(See 

http://www.epa.gov/ncer/events/calendar/2010/mar17/presentations/fre

udenberg.pdf) 
Plan EJ 2014: Appendix, Implementation Plans 128

These community-driven strategies are more labor and resource intensive 

and require a higher level of commitment from communities, researchers, 

and agencies, as well as a new set of capabilities on the part of Agency 

personnel with regard to the skills needed to, for example, facilitate 

meetings, communicate clearly, and create an atmosphere of inquiry and 

trust. 

In order to more effectively reduce disparate environmental exposure and 

engage the public in making environmental policy decisions, the EPA must 

engage relevant constituencies in participation processes early, provide 

these constituencies with the resources and information that can 

contribute to effective participation, and ensure that the outcomes reflect 

participation. Specifically, helping communities develop the capacities to 

create, access, use, and interpret scientific information and changing 

Agency practices to better incorporate community voices in scientific 

activities and decisions will be a key and proper task for EPA. EPA, 

therefore, proposes the following actions to establish programs and 

provide federal government support to increase technical and scientific 

capacity in communities. 

Activity 5.1: Build Awareness and Community Capacity to Address Asthma 

Disparities. 

In response to the growing asthma problem where minority, low-income, 

tribal, and indigenous populations are disproportionately affected, EPA’s 

OAR established the Asthma Program to promote scientific understanding 

of environmental asthma triggers and ways to manage them. The program 

collaborates with partners to support research and educate the public 

about asthma and ways to manage environmental triggers. Partners 

include government agencies, universities and research centers, the health 

care community, nonprofit organizations, and community programs. Major 

program activities center around the Communities in Action for Asthma 

Friendly Environments initiative, and include support for real time peer-topeer learning, technology transfer and resources for community-based 

asthma programs through an online network 

(www.AsthmaCommunityNetwork.org), “pacing” events (National Asthma 

Forum, regional events and webinars), and support to non-profit 

organizations focused on health care provider training, improving school 

environments and raising public awareness about asthma (see also 

Supporting Community-Based Action Programs, Strategy 2, Activity 3). 

Activity 5.2: Build Tribal Community Capacity to Monitor Air Quality. 

OAR has a long history of supporting capacity building among tribal 

environmental professionals, primarily through its partnership with the 

Institute for Tribal Environmental Professionals (ITEP) at Northern Arizona 

University, which OAR has supported for over 15 years. Consistent with 

our trust responsibility to tribes, OAR works with tribes to increase their 

capability to address their environmental concerns. OAR supports the 

training and educational efforts of ITEP in the areas of air quality and 
Plan EJ 2014: Appendix, Implementation Plans 129

climate change impacts and adaptation planning, as well as the work of the 

Tribal Air Monitoring Support (TAMS) Center, which builds and strengthens 

the technical capacity of tribal staff. The TAMS Center cross-trains tribal air 

professionals on air monitoring, indoor air quality, radon, and asthma (see 

also Supporting Community-Based Action Programs, Strategy 2). 

Activity 5.3: Increase Citizen Participation in Science and Decisions. 

ORD proposes to create a program, in partnership with other governmental 

agencies, private non-profits, professional societies, and private 

foundations, to develop the capacity of community leaders to understand 

the role of science in decision making and influence the decision-making 

process and on the use of data and other information to document 

disparities and concerns in their communities. 

Activity 5.4: Establish Centers of Excellence on Environment and Health 

Disparities. 

Several new extramural research solicitations are under consideration to 

fund research that address specific research needs and topics raised at the 

March 2010 Symposium and that fully employ CBPR approaches such as 

establishing Centers of Excellence on Environment and Health Disparities. 

The aim for these Centers will be to examine the joint impacts of social and 

physical environmental conditions and processes on health, link with 

community health clinics to increase their capacity to address occupational 

and environmental health concerns of their constituents, and design policy 

solutions to ameliorate and prevent disparities. 

Activity 5.5: Build diverse environmental workforce and enhancing the 

capacities of Minority Academic Institutions (MAI) to engage in scientific 

research and workforce training 

The National Center for Environmental Research’s (NCER) Fellowship 

Program is implementing several initiatives to strengthen EPA’s efforts to 

encourage and support environmental justice research among the next 

generation of environmental scientists and engineers. For example, 

Environmental justice research topics are highlighted in the STAR 

Fellowships RFA and environmental justice considerations have been 

included as review criteria under "Broader Societal Impacts" for all 

fellowship applications. 

As part of the Greater Research Opportunities (GRO) fellowship, NCER has 

a goal of enhancing capacity at academic institutions that are not well 

funded for environmental research capacity, including HBCUs. ORD 

considers ineligible those institutions identified as receiving more than $35 

million in annual federal research. NCER has increased resources allotted 

to the GRO program to increase GRO funded students, which can enhance 

our efforts in this area. 

OSWER will support research through the Faculty and Student Teams 

(FaST) Program, a cooperative effort between the U.S. Department of 
Plan EJ 2014: Appendix, Implementation Plans 130

Energy (DOE) Office of Science and the National Science Foundation (NSF). 

Faculty from colleges and universities with limited research facilities and 

those institutions serving populations, women and minorities 

underrepresented in the fields of science, engineering, and technology are 

encouraged to apply for the FaST program. The FaST program will support 

a team comprised of one faculty member and two to three undergraduate 

students. The program provides hands-on research opportunities in the 

DOE or EPA national laboratories during the summer. The faculty member 

identifies a mutually beneficial research area amenable to collaboration by 

the faculty member and the laboratory scientist. 

The EPA Region 6 University-Community Partnerships initiative will 

facilitate and nurture a partnership between universities and community 

groups to increase overburdened communities’ capacity to address their 

environmental challenges through technical assistance. Memorandums of 

Understanding (MOU) are in place between EPA Region 6 and the 

University of Texas El Paso (UTEP) and EPA Region 6, EPA’s Office of Water 

and Texas A&M Kingsville. 

Within the federal government, EPA has been a leader in the use of 

collaborative approaches to accomplish strategic goals and objectives. 

Learning from this rich experience can help the Agency realize the full 

potential of collaborative processes and accelerate environmental 

progress. The ability to collaborate effectively with MAIs will become more 

important as the growing complexity of environmental problems will 

require diverse approaches to developing innovative solutions. Failure to 

tap into MAIs represents a missed opportunity for advancing 

environmental protection and stewardship. For example, MAIs in the 

Southeast and the Southwest could be leveraged for strategic projects 

targeting climate change impacts and adaptation, and engaging 

populations that are vulnerable to climate change. 

Benefits to EPA Stakeholder Communities 

 These capacity-building actions can help the public to address 

environmental health issues and to allow them to effectively 

participate in environmental health decision making and will increased 

confidence that concerns about the power dynamics between 

academic, government researchers, and communities will be taken 

seriously. 

 Actions undertaken by the Asthma Program will equip stakeholder 

communities and organizations to assess, organize and sustainably 

deploy community resources to reduce or eliminate exposure to 

asthma triggers, and improve health outcomes and the quality of life 

for people with asthma. The actions help support and strengthen the 

capacity of health care and environmental professionals, schools, and 

community-based organizations to develop comprehensive asthma 

care strategies in partnership with impacted communities and to 

spread their results to accelerate improvements across the national 

asthma care landscape. 
Plan EJ 2014: Appendix, Implementation Plans 131

 Through the partnership with ITEP, tribes are better able to fashion 

their own responses to environmental issues including climate change, 

and have a better understanding of how they can effectively 

participate in the environmental decision making of federal, state and 

local regulatory agencies. 

 Research through the proposed Centers of Excellence will be specially 

aimed at benefiting disadvantaged, undeserved, and environmentally 

overburdened communities or groups. 

 Requiring NCER fellowship applicants to consider and explain the 

environmental justice implications of their research will help develop a 

new generation of environmental scientists, engineers, and policy 

makers who are cognizant of environmental justice -related issues that 

can arise in research and thus adjust approaches accordingly to 

promote broad environmental protection. 

 Increasing the reach of the GRO program will promote research and 

training at Minority Serving Institutions (MSIs), which may have special 

expertise on environmental justice matters. 

 Through the Region 6 partnerships with University of Texas and Texas 

A&M Kingsville, EPA will increase knowledge about best approaches for 

community–university partnerships. 

Impact on EPA programs and activities 

 The Communities in Action initiative and the online Network, Asthma 

Community Network will surface important, field-tested community 

strategies that the Asthma Program will use to bolster the Agency’s 

national asthma education and outreach efforts. 

 When tribal perspectives are effectively communicated, EPA is more 

cognizant of Tribal issues and is able to make more informed and 

responsive decisions concerning its rules, programs and policies. As 

tribes take more responsibility for implementing air programs, EPA may 

be able to reduce some of its implementation efforts. 

 The proposed research-oriented activities will help institute program 

development and strategic institutional change within EPA. The goal is 

to increase democratization in the conduct of and community access to 

EPA/ORD research. The proposed activities will produce: (1) consistent 

and validated principles of community engagement in research for ORD 

and EPA programs; (2) improved science and research results that are 

more relevant to environmental problems faced by the public and 

more effectively translated to inform policy change and intervention; 

and (3) inclusion of environmental justice considerations as review 

criteria that serve as a model for other competition-based EPA 

programs. These results will promote a culture that considers 

environmental justice implications in all agencies funding actions and 

activities. 

 The process of increasing the reach of the GRO program will translate 

into stronger outreach to MSIs and highlight the critical role MSIs play 

in the nation's research and development enterprise to solve pressing 

environmental protection challenges. 
Plan EJ 2014: Appendix, Implementation Plans 132

 The intent of Region 6’s existing MOU’s are to: (1) improve the quality 

of environmental science and technical education; (2) increase the 

relevance of UTEP research projects to EPA’s environmental and public 

health mission; and (3) increase number of culturally diverse students 

electing to pursue graduate study and research careers in areas 

including science, engineering, and mathematics. It is expected that 

UTEP‘s capacity to develop environmental specialists for potential EPA 

employment will be significantly enhanced while important 

contributions will be made to EPA’s overall research and 

developmental programs. 

Timeframe 

 Support and grow an online community network of stakeholders that 

serves as a real time resource for mentoring and collaboration to 

support community asthma management programs (FY 2011 and 

ongoing). 

 Develop web-based tools that facilitate collaboration, problem solving, 

and learning among leaders of asthma programs (FY 2011 and 

ongoing). 

 Facilitate knowledge transfer among stakeholders through EPA 

sponsorship of “pacing” events, including the National Asthma Forum, 

regional events and webinars for community-based asthma programs 

(FY 2011 and ongoing). 

 Train health care professionals to improve their ability to integrate the 

assessment of environmental factors into a comprehensive, culturally 

appropriate asthma care plan, based on national standards of care (FY 

2011 and ongoing). 

 Continue funding for ITEP and the TAMS Center (ongoing). 

 Continue OAR involvement in developing ITEP’s curriculum and 

training, and oversight of the TAMS Center (ongoing). 

 Institute a pilot program on “meet the decision makers” on 

environmental health and environmental justice that would 

accommodate up to 15 community leaders (FY 2013). 

 Issue joint RFA or other funding mechanism to collaborate with NIH 

National Institute Minority Health and Health Disparities to establish 

national research Centers of Excellence on Environment and Health 

Disparities (FY 2012). 

 Highlight Environmental Justice Research topics in the STAR 

Fellowships RFA (ongoing). 
Plan EJ 2014: Appendix, Implementation Plans 133

2.2 Community Engagement and Stakeholder Partnership 

Plan 

Community outreach and engagement plans are integrated into the 

individual science actions described above. The most significant science 

actions that will include community outreach and partnerships are ORD’s 

Sustainable and Health Communities Research Program, OSWER’s 

Community Engagement Initiative and the extramural research funding 

under consideration. 
Plan EJ 2014: Appendix, Implementation Plans 134

3.0 DELIVERABLES 

Strategy 1: Apply integrated transdisciplinary and community-based 

participatory research approaches with a focus on addressing multi-media, 

cumulative impacts, and equity in environmental health and environmental 

conditions.

ACTIVITIES DELIVERABLES MILESTONES

Activity 1.1: Establish 

an Integrated 

Transdisciplinary ORD 

Research Program on 

Environment and 

Community Health –

Sustainable and Healthy 

Communities Research 

Program.

 Research program framework 

developed (ORD - SHCRP 

Team).

 February 

2011

 Regional listening sessions to 

gather input from 

communities. Incorporate 

ideas and concerns from 

stakeholders and 

representatives from 

disproportionately impacted 

communities and populations 

(ORD - SHCRP Team).

 Spring 2011

 RFA to support Extramural 

research on Tribal 

Community Health (ORD –

NCER).

 FY 2012

 RFA to support Extramural 

research to support Centers 

of Excellence on Environment 

and Health Disparities (ORD 

– NCER).

 FY 2012

Activity 1.2: Develop 

technical guidance, 

analytic methods, tools 

and data to advance the 

integration of 

environmental justice in 

EPA decision making.

 Environmental Justice 

Technical Guide (ORD, OEJ, 

OP).

 FY 2013

 Community Cumulative 

Assessment Tool (CCAT) 

(ORD - NERL and OSA).

 Early FY2012

 Environmental Quality Index 

Tool (ORD – NHEERL).

 Long-term

 Regional Tools Summits 

(ORD - OSP and SHCRP 

Team).

 FY 2012 –

2013

 Environmental justice 

screening tools for air rules 

(OAR).

 FY 2011 –

2012

 Urban Atlas (ORD –

NHEERL).

 First phase

complete FY13
Plan EJ 2014: Appendix, Implementation Plans 135

Strategy 2: Incorporate perspectives from community-based organizations 

and community leaders into the EPA’s research agendas and engaging in 

collaborative partnerships on science and research to address 

environmental justice.

ACTIVITIES DELIVERABLES MILESTONES

Activity 2.1: Establish 

Community Engagement 

Initiative (OSWER).

 Conduct training of OSWER 

staff on CBPR (OSWER).

 Ongoing

Activity 2.2: Re-engage 

National Environmental 

Justice Advisory 

Committee.

 Establish a research 

workgroup under NEJAC to 

advise ORD on the 

development of the 

Sustainable and Health 

Communities Research 

Program (ORD - NCER and 

OSP; OEJ).

 FY 2012

Activity 2.3: Support 

Community-Based 

Participatory Research.

 RFA to support extramural 

research on Tribal 

Community (ORD-NCER).

 FY 2012

 RFA to fund Extramural 

research to support Centers 

of Excellence on Environment 

and Health Disparities (ORD 

– NCER).

 FY 2012

 Regional listening sessions to 

gather input from 

communities. Incorporate 

ideas and concerns from 

stakeholders and 

representatives from 

disproportionately impacted 

communities and populations 

(ORD - Rick Linthurst and 

SHCRP Team).

 Spring 2011
Plan EJ 2014: Appendix, Implementation Plans 136

Strategy 3: Leverage partnerships with other federal agencies on issues of 

research, policy and action to address environmental and health 

disparities. 

ACTIVITIES DELIVERABLES MILESTONES

Activity 3.1: Join the 

Federal Collaboration on 

Health Disparities.

 Potential collaboration on 

research funding with sister 

federal agencies; better 

coordination of research 

needs on health disparities 

across federal government 

(ORD).

 Ongoing

Activity 3.2: Engage 

with President’s Task 

Force on Environmental 

Health Risks and Safety 

Risks to Children.

 Federal Action Plan to 

address asthma disparities 

(OCHP, ORD, OAR).

 FY 2011-

2015

Strategy 4: Build and strengthen the technical capacity of EPA scientists on 

conducting research and related science activities in partnership with 

impacted communities and translating research results to inform change.

ACTIVITIES DELIVERABLES MILESTONES

Activity 4.1: Provide 

training to EPA 

scientists on CBPR.

 Survey ORD scientists’ needs 

and awareness about 

CBPR(ORD - OSP and 

NCER).

 FY 2012 –

2013

 Develop a training plan for 

ORD scientists (ORD - OSP 

and NCER).

 FY 2012 –

2013

 Collaborate with OSWER to 

modify and offer courses 

under the Community 

Involvement University (ORD 

and OSWER).

 FY 2012 –

2013

Activity 4.2: Build 

Social Science 

Capacity within ORD.

 Host scientist to science 

workshop on behavioral and 

social sciences (ORD-NCER).

 FY 2011 –

2012

 An ORD research agenda for 

behavioral and social sciences 

(ORD-NCER).

 FY 2012 –

2013

 Cooperative Agreement with a 

Social Science professional 

society (ORD- NCER).

 FY 2012 –

2013
Plan EJ 2014: Appendix, Implementation Plans 137

ACTIVITIES DELIVERABLES MILESTONES

Activity 4.3: Develop 

Environmental Justice 

Risk Management 

Training for OPP.

 Training module to ensure 

environmental justice and 

sensitive population 

considerations are fully 

incorporated and more clearly 

integrated throughout OPP risk 

management processes 

(OPP).

 By early 

FY2012

 100% of OPP risk assessors 

and managers properly trained 

on environmental justice in risk 

management (OPP).

 End of 

FY2012

Strategy 5: Build and strengthen technical capacity of community-based 

organizations and community environmental justice and health leaders to 

address environmental health disparities and environmental sustainability 

issues.

ACTIVITIES DELIVERABLES MILESTONES

Activity 5.1: Build 

Community Capacity to 

Address Asthma 

Disparities.

 Establish an online community 

network available to 

stakeholders as a year-round 

resource for mentoring and 

collaboration and designed to 

support community asthma 

management programs (OAR).

 FY 2011 and 

ongoing

 Develop web-based tools that 

facilitate collaboration, problem 

solving, and learning among 

leaders of asthma programs 

(OAR).

 FY 2011 and 

ongoing

 Hosting the National Asthma 

Forum and Awards Program 

and regional pacing events for 

community-based programs 

(OAR).

 FY 2011 and 

ongoing

 Train health care 

professionals, to improve their 

ability to integrate the 

assessment of environmental 

factors into a comprehensive, 

culturally appropriate asthma 

care plan, based on national 

standards of care (OAR).

 FY 2011 and 

ongoing
Plan EJ 2014: Appendix, Implementation Plans 138

ACTIVITIES DELIVERABLES MILESTONES

Activity 5.2: Build 

Tribal Community 

Capacity to Monitor Air 

Quality.

 Continue funding for ITEP and 

the TAMS Center (OAR).

 Ongoing

Activity 5.3: Increase 

Citizen Participation in 

Science and Decisions.

 Cooperative agreement to 

support a citizen scientist 

fellowship program – a meet 

the decision makers” on 

environmental health and 

environmental justice (ORDNCER).

 FY 2013

Activity 5.4: Establish 

Centers of Excellence 

on Environment and 

Health Disparities.

 RFA to support Extramural 

research to support Centers of 

Excellence on Environment 

and Health Disparities (ORD –

NCER)

 FY 2012

Activity 5.5: Build 

diverse environmental 

workforce and 

enhancing the 

capacities of MAI to 

engage in scientific 

research and workforce

training.

 Highlight environmental justice 

research topics in the STAR 

Fellowships RFA. Include 

environmental justice 

considerations as review 

criteria under "Broader Societal 

Impacts" for all fellowship 

applications (ORD-NCR)

 Completed

and ongoing

 Support research through the 

FaST Program and provide 

university faculty and students 

to have hands-on research 

opportunities in DOE or EPA 

national laboratories (OSWER)

 Ongoing

 Establish a UniversityCommunity Partnerships 

initiative to provide technical 

assistance to local community 

groups and increase number of 

culturally diverse students 

electing to pursue graduate 

study and research careers 

(Region 6).

 To be 

determined 

(TBD)
Plan EJ 2014: Appendix, Implementation Plans 139

4.0 REPORTING 

There is no overall reporting plan for the science activities at this time. 

However, program reporting may occur by the individual program offices 

responsible for each activity. For information, please contact Devon PayneSturges, 703-347-8055, Payne-Sturges.Devon@epa.gov; or Chris Saint, 202-

564-9839, Saint.Chris@epa.gov. 
Plan EJ 2014: Appendix, Implementation Plans 140

APPENDIX 

Appendix A: References 

Brulle RJ and Pellow DN (2006). Environmental Justice: Human Health and 

Environmental Inequalities. Annual Review of Public Health. Vol 27: pp 103-

24.

CSDH (2008). Closing the gap in a generation: health equity through action 

on the social determinants of health. Final Report of the Commission on 

Social Determinants of Health. Geneva, World Health Organization. 

Gee GC and Payne-Sturges DC. 2004. Environmental Health Disparities: A 

Framework Integrating Psychosocial and Environmental Concepts. 

Environmental Health Perspectives. VOLUME 11, NUMBER 17. pp1645 –

1653.

Habermann M and Gouveia N. 2008. Environmental Justice: an ecossocial 

health approach. Rev Saúde Pública 42(6). Pp 1 – 7.

Krieger N. 2001. Theories for social epidemiology in the 21st century: an 

ecosocial perspective. International Journal of Epidemiology. Vol 30: pp 

668- 677. 

Morello-Frosch RA. 2002. Discrimination and the political economy of 

environmental inequality. Environment and Planning C: Government and 

Policy. Volume 20, pages 477 – 496 

Morello-Frosch R. and Shenassa ED. 2006. The Environmental “Riskscape” 

and Social Inequality: Implications for Explaining Maternal and Child Health 

Disparities. Environmental Health Perspectives. VOLUME 114. NUMBER 8. 

Pp. 1150 – 1153. 

Norton B, Mcleroy K, Burdine J, Felix M, and Dorsey A. 2002. Community 

capacity: Concept, theory and methods, in DiClemente R, Crosby R, Kegler 

M, eds. Emerging Theories in Health Promotion Practice and Research. San 

Francisco: Jossey-Bass. 

Schulz AJ, Williams DR, Israel BA, Lempert LB. 2002. Racial and Spatial 

Relations as Fundamental Determinants of Health in Detroit. The Milbank 

Quarterly, Vol. 80, No. 4. Pp 677-707. 

Wakefield S.E.L. and Baxter J. 2010. Linking Health Inequality and 

Environmental Justice: Articulating a Precautionary Framework for 

Research and Action. ENVIRONMENTAL JUSTICE. Volume 3, Number 3. pp 

95- 102.
Plan EJ 2014: Appendix, Implementation Plans 141

Appendix B: Recommendations from the Science of 

Disproportionate Impacts Analysis Symposium 

(Washington, DC, March 17-19, 2010) 

Symposium participants recommended several actions to reduce research 

or data gaps, overcome limitations in the theories and methods for 

conducting environmental research, particularly research supported by 

federal government, and limitations in practice of risk assessment. The 

science recommendations are described below. The first sentence is a 

summary statement meant to capture the main points of the individual 

recommendations from the Symposium that follow, including 

recommendations from the Environmental Justice-Caucus letter that was 

sent to Lisa Garcia, Senior Advisor to EPA Administrator for Environmental 

Justice. 

1. Create and institute a new scientific research approach to develop 

more holistic understanding of environment and health. One of the 

potential outcomes of this new framework is to inform environmental 

policies related to environmental justice and address environmental 

health disparities. Several recommendations from the symposium point to 

EPA to adopt a more holistic view of the environment and the impacts on 

population health: “*the+ EPA/ORD’s research agenda needs to be 

reframed, inequality and inequity needs to be a part of the discussion [and 

research]; there needs to be a shift to not only look at risks and exposures, 

but to consider root and fundamental causes, need to start where it 

(inequality) begins; [the] EPA likes to start the analysis and research at a 

level that does not address the history and root causes of health endpoints, 

risks and exposures; analyze the environment in a broader context, 

evaluate the interaction between the social and the physical environments; 

a better framework is needed for combining physical and psychosocial 

science in research and practice; use social determinants of health and 

health disparities research framework to conduct research on cumulative 

impacts/risks; encourage multidisciplinary teams in environmental health 

research; develop the science of interactive effects; social science 

disciplines like social epidemiology indicate that [the] EPA needs to look 

more at upstream factors – social processes that ultimately process the 

disparities in risks and health outcomes; develop measures for the social 

environment; test the validity of available vulnerability indices and tools; 

encourage multidisciplinary approach to research and analysis; address the 

role of institutionalized racism in poor community environmental health; 

encourage the consideration of environmental justice in land use planning; 

and conduct research with direct policy implications - not research for the 

sake of research.”

Further, the Environmental Justice-Caucus participants recommend that 

“*the+ EPA should develop a plan to ensure incorporation of the concept of 

vulnerability, particularly its social and cultural aspects in the Agency’s 
Plan EJ 2014: Appendix, Implementation Plans 142

research agendas” and “... in consultation with environmental justice 

constituencies, incorporate community principles in its funding guidelines 

for research in environmental health and planned and existing actions that 

adversely impact public health and quality of life.”

2. Integrate perspectives from decision makers such as community 

residents, community leaders, community-based NGOs and community 

health and environmental quality advocates in the development of EPA’s 

scientific research agendas as well as in data collection, conduct of 

exposure/risk assessments and risk management decisions. 

A common recommendation articulated in both the Environmental JusticeCaucus letter and through discussions the Symposium is the need to 

incorporate community perspectives in the development of EPA’s 

science/research agendas and in the conduct of exposure/risk assessments. 

Signatories to the Environmental Justice-Caucus letter recommend that 

“*the+ EPA and other publicly funded research require the expertise of 

environmental justice communities in the research design, 

implementation, recommendations and programmatic design that may 

result from the research” and “*the+ EPA should develop a plan to ensure 

incorporation of the concept of vulnerability, particularly its social and 

cultural aspects in the Agency’s research agendas.” Related 

recommendations from the Symposium state “include community 

representatives and perspectives in the design of studies/research; 

communities would like to be involved as [the] EPA sets its research 

priorities and agenda as well as the regulatory agenda and priorities; and 

there needs to be a research workgroup formed within the NEJAC.” 

Although the following recommendations from the Symposium stem from 

discussions on regulatory actions and capacity building, they also suggest 

that EPA/ORD needs to approach its research planning and its 

contributions to the development of Agency risk assessment guidance 

differently: “create effective mechanisms to listen to community concerns; 

develop culturally competent outreach processes. Hire local community 

folks with cultural expertise and community knowledge; and improve 

incorporation of exposure information for smaller communities and 

population groups in national risk assessments.”

3. Create EPA funding mechanisms for community-based participatory 

research (CBPR) and transdisciplinary research, with a specific focus on 

studies that will benefit disadvantaged, undeserved, and environmentally 

overburdened communities or groups. The Environmental Justice-Caucus 

letter states that “affected communities need to be involved in the conduct 

of research to insure that that results are disseminated in an effective and 

understandable manner and that research recommendations are reviewed 

by the community.” Similar recommendations were made at the 

Symposium including “support/fund community originated and owned 

research; increase support/funding for community based participatory 

research; support participation of communities as equal partners in 

research; include them as equal partners in the co-production of 
Plan EJ 2014: Appendix, Implementation Plans 143

knowledge; include community representatives and perspectives in the 

design of studies/research.”

Further, Environmental Justice-Caucus letter recommends that EPA should 

also “develop a set of guidelines for federal environmental health research 

that would require community participation with binding ethical and Title 

VI guidelines for federally funded researchers in [environmental justice] 

communities and tribal nations.” This is consistent with comments raised at 

the symposium encouraging “federal funders of University researchers to 

address the unequal power dynamic that often arises between Universities 

and impacted communities that are subject of environmental and public 

health research.”

4. Collaborate with other federal government agencies on research, 

policy-making and other kinds of actions to address environmental health 

disparities. Many comments were made about the need to strengthen 

interagency efforts: “to address *environmental justice], need interagency 

collaboration; government approach to promoting and managing health is 

fragmented; agencies need to work together to formulate solutions for 

communities; other agencies should integrate [environmental justice] in all 

their activities.”

5. Enhance the capacities of Minority Academic Institutions (MAI) to 

engage in scientific research and workforce training. For instance, help 

MAI institutions to provide training opportunities for minority students in 

relevant scientific disciplines. Several statements were made at the 

Symposium that there was a lack of diversity in the academic institutions 

represented at the meeting and as presenters. HBCUs need to be involved 

in this new and expanded area of research on environmental health 

disparities. 

6. Develop and implement a multi-media approach to cumulative 

contamination exposures in environmental justice communities. 

Restructure risks assessment practice to better account for multistressors that cumulatively impact community and population health and 

recognize that the concepts that vulnerability and health disparities are 

interrelated. These recommendations from the Environmental JusticeCaucus letter echo many of the concerns and other recommendations 

raised at the Symposium on the topic of cumulative impacts. Comments 

from the Symposium include “communities see their environment as a 

whole not pieces; [the] EPA needs to address the issue of non-concordance 

between risk assessment results and community experience; vulnerability 

should be an integral part of cumulative risk assessment even it must be 

analyzed using qualitative measures; incorporate social vulnerabilities and 

cultural risks in risk assessments and cumulative risks/impact assessments; 

incorporate background risk in risk assessment; consider using qualitative 

approaches in risk assessment; adopt a quality of life approach; risk 

assessment should move away from individual lifestyles to one that 

considers the social context; focus on health and well-being as opposed to 
Plan EJ 2014: Appendix, Implementation Plans 144

risk, illness and death; [the] EPA should recognize that stressors in 

communities that are unaccounted for are not considered in risk 

assessments; adopt a systems approach to risk assessment and decision 

making; and [the] EPA should use information on cumulative impacts in all 

its decisions.”

7. Establish programs and provide federal government support to 

increase technical and scientific capacity in communities. This capacity 

building can help the public to address environmental health issues and 

to allow them to effectively participate in environmental health decision 

making. The Environmental Justice- – Caucus letter recommends that 

“grant/funding programs be expanded to provide support directly to 

[environmental justice] communities, [environmental justice] organizations 

and networks, Tribes and Native organizations to assess and act on 

*environmental justice+ issues.” Additionally Symposium participants 

advocated that “*the+ EPA include community-based organizations, leaders 

and residents in the co-production of knowledge and the scientific bases 

for environmental decision making; make resources available to develop 

technical skills of community leaders on science and decisions; develop 

technical expertise within the communities; and commit resources to 

develop networks and centers/consortia with universities to support 

community groups with technical matters and participation in decision 

making.” 

8. Develop analytic and assessment tools, and data collection approaches 

that could be used by community health advocates and environmental 

justice groups. Availability of appropriate tools and training on use of such 

tools would also help increase technical capacity of communities. For 

example recommendations include “work with local governments to 

provide access to data sources; influence their [local governments] data 

collection approaches; develop mapping tools that communities can use; 

encourage community engagement in the collection of data by 

government; explore the approach of using communities to collect data to 

overcome limitations of government data such as privacy issues and poor 

geospatial resolution; and develop zoning maps that are accessible to 

communities; regional councils of government can provide accurate city 

level data for community research.”

9. Build capacities and skills among EPA/ORD staff and scientists to 

conduct research and other science related activities in equal partnership 

with impacted communities. This step must include diversifying EPA’s 

technical and scientific expertise in the social sciences. Concomitant with 

efforts to increase technical capacity in communities, EPA/ORD needs to 

build up its capacity to work with communities in order for real progress to 

be made. Several recommendations from the Symposium address this 

issue: “train EPA staff on effective outreach and dialog with communities; 

develop capacity within the agency; provide training for EPA risk assessors 

and managers on community engagement; consider using qualitative 

approaches in risk assessment; multi-disciplinary teams are needed to work 
Plan EJ 2014: Appendix, Implementation Plans 145

on issues; encourage multidisciplinary teams in environmental health 

research; social science disciplines like social epidemiology indicate that 

EPA needs to look more at upstream factors – social processes that 

ultimately process the disparities in risks and health outcomes; explore 

approaches for interacting with communities that can build collective 

efficacy and social capital; support participation of communities as equal 

partners in research; include them as equal partners in the co-production 

of knowledge; and include community representatives and perspectives in 

the design of studies/research.”

10. EPA and other agencies should integrate environmental justice in all 

EPA activities, including policy making, regulatory actions, research and 

public outreach. An important place for intervention for environmental 

justice is regulation and rule-making. Example recommendations from the 

Symposium on the use of science and information to address 

environmental justice concerns in decision making include “develop 

measures of environmental health disparities to monitor temporal and 

spatial trends in disparities, and also whether environmental regulation is 

effective; stratify research data by race and income to better analyze 

disparate impacts; account for differences in the effect of lead on 

hypertension which is more pronounced in chronically stressed individuals 

in regulatory assessments and policies; develop tools for equity 

assessment; test the validity of available vulnerability indices and tools; 

base decisions on good science that passes the tests of reliability, 

repeatability and peer review; good data are legally defensible; and present 

policy choices and equity impacts to Administrator as a standard 

consideration in decision making.”
Plan EJ 2014: Appendix, Implementation Plans 146

7. Legal Tools Development 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of General Counsel

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 147

1.0 INTRODUCTION 

Plan EJ 2014 established a road map to help the U.S. Environmental 

Protection Agency (EPA) integrate environmental justice into its programs. 

The Plan outlined five cross-Agency focus areas. The five focus areas are: 

1. Incorporating Environmental Justice into Rulemaking. 

2. Considering Environmental Justice Concerns in EPA’s Permitting 

Process. 

3. Accelerating Compliance and Enforcement Initiatives. 

4. Supporting Community-Based Action Programs. 

5. Fostering Administrative-Wide Action on Environmental Justice. 

In addition, Plan EJ 2014 identifies four tools to support the cross-Agency 

efforts. One of the tools relates to identifying opportunities to use existing 

legal authorities to advance environmental justice. The Office of General 

Counsel (OGC) has been assigned primary responsibility for this tool. This 

implementation plan discusses the goal, strategy, and activities associated 

with the development and dissemination of information about EPA’s 

environmental justice-related legal authorities. 

1.1 Goals 

The goal of this Initiative is to provide legal assistance to EPA policy makers 

and other Agency decision makers to advance their environmental justice 

objectives. Our vision is that the Agency will use law as a tool to advance 

environmental justice. By providing advice on EPA’s discretionary legal 

authorities to advance environmental justice, OGC will support the five 

cross-Agency focus areas. In particular, OGC’s advice will help EPA officials

to (1) implement forward-leaning environmental justice policies with 

acceptable legal risk; and (2) identify new opportunities to promote their 

environmental justice policy objectives. This initiative will advance 

Administrator Lisa Jackson’s environmental justice priority, her 

commitment to the rule of law, and EPA’s overarching mission to protect 

human health and the environment. 

1.2 Organizational Structure 

OGC will give leadership to Plan EJ 2014’s focus areas by helping EPA to 

integrate environmental justice into its day-to-day business. As the chief 

legal adviser to the EPA, OGC provides ongoing legal support for Agency 

rules and policies, case-by-case decisions (such as permits and response 

actions), and legislation, which includes all of Plan EJ 2014’s elements. 

OGC’s practice areas include all of the Agency’s programs (i.e., land, air, 

water, etc.), as well as cross-cutting law areas that including environmental 

justice, tribal law, and civil rights. OGC regularly interfaces with all the EPA 

program offices and regions, as well as EPA’s ten Offices of Regional 

Counsel. 

Goals At-A-Glance

To provide legal 

assistance to EPA policy 

makers and other Agency 

decision makers to 

advance their 

environmental justice 

objectives.
Plan EJ 2014: Appendix, Implementation Plans 148

2.0 IMPLEMENTATION 

2.1 Strategies 

OGC will accomplish its goal of providing legal assistance to EPA policy 

makers and other Agency decision makers to advance their environmental 

justice objectives by providing legal support to each cross-Agency focus 

area workgroup. 

OGC’s activities will promote a sound legal framework for the tools and 

programs developed by the five focus area workgroups. We will use the 

resources of OGC and the Offices of Regional Counsel, both at the staff and 

senior leadership levels, to develop our advice to Plan EJ 2014’s 

workgroups. The persons primarily responsible for coordinating the 

development and communication of this advice will be the counseling 

attorneys assigned to each workgroup, in collaboration with senior Agency 

attorneys and the General Counsel. OGC will conduct this activity 

contemporaneously with the work of the five cross-Agency focus areas. 

OGC will participate in the stakeholder outreach implemented by each 

focus area that we serve. 

2.2 Activities 

OGC will provide legal support to each cross-Agency focus area workgroup 

through the following activities: 

 Activity 1: Counseling attorneys will serve as workgroup members for 

each cross-Agency focus area. These attorneys are drawn from OGC 

and its regional offices. 

 Activity 2: Regional Counsels and OGC Associate General Counsels will 

convene regularly to identify legal issues and develop advice in support 

of the five focus areas. 

 Activity 3: The General Counsel will provide active oversight, direction, 

and decision making on all aspects of Plan EJ 2014, in consultation with 

the EPA’s Senior Leadership.

 Activity 4: OGC will convene a group of senior attorneys from across 

the federal government to promote the integration of environmental 

justice into their agencies’ actions. 

2.3 Community Engagement and Stakeholder Outreach 

OGC will participate in the stakeholder outreach implemented by each 

focus area that we serve. 

2.4 Adjustments 

The Office of General Counsel might adjust this implementation plan after a 

period of implementation. 
Plan EJ 2014: Appendix, Implementation Plans 149

3.0 DELIVERABLES 

This portion of the implementation plan incorporates by reference the 

deliverables, schedules, measures, and reports identified in the 

implementation plans for the five cross-Agency focus areas. For 

information, please contact David Coursen, 202-564-0781, 

Coursen.David@epa.gov. 
Plan EJ 2014: Appendix, Implementation Plans 150

8. Information Tools Development 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by 

Office of Policy and Office of Environmental Information

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 151

1.0 INTRODUCTION 

In 1994, Executive Order 12898 (EO 12898) mandated that each federal 

agency make achieving environmental justice part of its mission by 

identifying and addressing disproportionately high and adverse human 

health or environmental effects of its programs, policies, and activities on 

minority, low-income, tribal, and indigenous populations. In implementing 

EO 12898, EPA programs and regions have developed a variety of internal 

environmental justice screening tools and other Geographic Information 

Systems (GIS) applications. These applications, such as the Environmental 

Justice Strategic Enforcement Assessment Tool (EJSEAT), EJView, and 

others, have played an important role as the Agency worked to integrate 

environmental justice into its programs, policies, and activities. Senior EPA 

leadership has been asked to focus on developing a nationally consistent 

environmental justice screening tool in order to better meet the Agency’s

responsibilities of protecting public health under EO 12898 and our goals 

under Plan EJ 2014. 

In addition, EPA is developing a suite of tools, data, and services known as 

EPA’s GeoPlatform that will help coordinate and consolidate mapping 

activities, applications, and data across the Agency. The GeoPlatform will 

support a wide variety of uses across the Agency, including components of 

the nationally consistent environmental justice screening tool, and other 

data and applications that may be of interest to environmental justice 

stakeholders. 

1.1 Goal 

The goal of this implementation plan is to develop a more integrated, 

comprehensive, efficient, and nationally consistent approach for collecting, 

maintaining, and using geospatial information relevant to overburdened 

communities. EPA will accomplish this goal by: (1) developing a common 

Agency-wide mapping platform – the GeoPlatform, (2) creating a nationally 

consistent environmental justice screening tool, and (3) incorporating 

appropriate elements of the screening tool into the GeoPlatform. 

1.2 Organizational Structure 

The Office of Environmental Information (OEI) has the lead on the 

GeoPlatform, and the Office of Policy (OP) has the lead on the nationally 

consistent screening tool. 

The development of EPA’s GeoPlatform is being led by OEI, with oversight 

from the Agency’s GIS Workgroup Steering Committee (comprised of 

representation from six regions), the Office of Research and Development 

(ORD), the Office of Chemical Safety and Pollution Prevention (OCSPP), the 

Office of Water (OW), and the EPA Quality and Information Council (QIC). 

The QIC is the Agency’s decision making body for addressing enterprisewide technology issues and developing policies to guide EPA decision 

Goal At-A-Glance

To develop a more 

integrated, 

comprehensive, efficient, 

and nationally consistent 

approach for collecting, 

maintaining, and using 

geospatial information 

relevant to overburdened

communities. 
Plan EJ 2014: Appendix, Implementation Plans 152

makers in the area of information technology and information 

management within the framework of OEI. The QIC is comprised of Senior 

Executive Service-level managers from Agency program and regional 

offices, and is chaired by the Agency’s Chief Information Officer (CIO).

Development of the nationally consistent environmental justice screening 

tool is led by OP and is overseen by a steering committee comprised of 

Assistant Administrators or their designees from OP, the Office of 

Environmental Justice (OEJ), ORD, OEI, and Regions 7, 8, and 9. In addition, 

a staff level workgroup meets regularly and has participation from nearly 

every program office and region across EPA. 
Plan EJ 2014: Appendix, Implementation Plans 153

2.0 IMPLEMENTATION 

2.1 Strategies 

The following three major strategies have been identified as critical 

components of the Information Tools Development Implementation Plan:

 Develop EPA’s GeoPlatform.

 Develop a nationally consistent environmental justice screening tool. 

 Incorporate appropriate elements of the screening tool into the 

GeoPlatform 

2.2 Activities 

Strategy 1: Develop EPA’s GeoPlatform

EPA’s GeoPlatform consists of a suite of tools, data and services that will 

support a wide variety of uses across the Agency. The GeoPlatform is an 

Agency initiative that will serve environmental justice, but also other 

important areas such as enforcement and community-based work. The 

GeoPlatform will eventually be applied for additional uses, and will provide 

access to a wide range of EPA and stakeholder data pertaining to 

environmental exposure and risk, ecological condition, public health, 

demographic data, and boundary/administrative information, as needed by 

EPA programs. 

The next several paragraphs describe the GeoPlatform. An understanding 

of the structure and philosophy behind the platform is important to seeing 

how it will serve environmental justice practitioners. EPA’s GeoPlatform 

project strives to coordinate activities, applications, and data across the 

Agency. We seek to ensure that the opportunity for re-use is maintained 

and that data and information is documented and available across the 

Agency, to states and tribes, and to our other stakeholder communities. 

Our vision is that ultimately everyone has the ability to conduct relevant 

geospatial analysis in their area of interest using common data, tools, and 

techniques. 
Plan EJ 2014: Appendix, Implementation Plans 154

The GeoPlatform concept consists of three primary tiers – Applications, 

Services, and Data – plus a governance tier (see Figure 1 for the EPA 

GeoPlatform conceptual architecture). Details on each tier are provided 

below: 

Data Tier: The Data components of the EPA GeoPlatform include a wide 

range of geospatial data needed for EPA programmatic purposes. Some of 

this data is originated and maintained by the Agency, but most of the data 

needed is sourced from other public or private sector organizations. Data 

components already identified as core sources to be integrated into the 

GeoPlatform are the Integrated Geospatial Database (IGD), currently 

managed by the OEI/the Office of Information Analysis and Access (OIAA); 

the Facility Registry System (FRS), currently managed by OEI/OIC; program 

specific databases such as the Toxics Release Inventory (TRI) and 

Brownfields, currently managed by the individual program offices; and 

externally held geospatial data services, such as for transportation 

networks, land use, land cover, and Census data, which come from a 

variety of public and private sources. The key to organizing data assets 

spread across these different offerings lies in metadata management. The 

Agency’s “Geospatial Data Gateway” (GDG, http://geogateway.epa.gov) 

application will continue to be used for metadata management. 

Figure 1: Conceptual Architecture for the EPA GeoPlatform
Plan EJ 2014: Appendix, Implementation Plans 155

Services Tier: Standardizing our geospatial data management at the Agency 

is of critical importance, however, we must also consider the mechanisms 

through which we provide Agency staff and other stakeholders access to 

different datasets housed in this enterprise. From a technical perspective, 

the most effective and re-usable way to broker this access is through open 

standards compliant web services. One of the most important components 

of the EPA GeoPlatform, then, will be a comprehensive web services tier 

that will help ensure that all relevant geospatial data and analytical 

components are as widely accessible as possible throughout the enterprise. 

Geospatial data access and some geoanalytical services (e.g., buffer and 

proximity searches) are being developed to leverage our internal data 

stores. Additionally, through catalog services and our application tier 

(Environmental Analyst, EPA Portal, etc.), we will be able to leverage 

services offered by external public and private providers. 

Applications Tier: As part of the EPA GeoPlatform “Release 1” offering, 

three central applications will be developed and made available for 

Agency-wide use: Environmental Analyst, the EPA Geospatial Portal, and 

EPA Earth. Environmental Analyst will be the primary tool initially intended 

for environmental justice practitioners. Environmental Analyst is an EPA 

custom version of the forthcoming ESRI commercial web application 

Community Analyst (http://communityanalyst.esri.com). Environmental 

Analyst will feature an interface designed for EPA staff to easily access and 

leverage a wide range of geospatial data to carry out their specific tasks. 

This represents a major opportunity to consolidate a number of different 

internal Program and regional geospatial web applications into a single 

one, and a significant portion of the GeoPlatform effort will be dedicated to 

outreach and development of opportunities for organizations to have their 

data, analytical and reporting requirements integrated into this central 

application. 

 Activity 1.1: Prototype of EPA Environmental Analyst for review. 

 Activity 1.2: Production release of the EPA Environmental Analyst. 

 Activity 1.3: Production release of the EPA GeoPlatform (including 

initial data services) for use by Environmental Analyst and other 

GeoPlatform components. 

Strategy 2: Develop the nationally consistent environmental justice 

screening tool.

EPA is now taking the next step in creating a nationally consistent 

environmental justice screening tool to help identify communities living 

with the greatest potential for negative environmental and health effects. 

The purpose of the screening tool will be to provide, for locations across 

the United States, a comprehensive and nationally consistent tool for 

presenting available environmental and demographic data. 

The tool will aid decision makers in assessing policy and actions to be taken 

by EPA, in accordance with, and pursuant to, applicable law. The tool will 

serve as a national baseline screening tool, which can then be 
Plan EJ 2014: Appendix, Implementation Plans 156

supplemented with additional information and on-the-ground experience 

to help identify overburdened communities that may warrant additional 

investigation by EPA to help reduce risk and improve public health. OP is 

leading a cross-Agency team to identify relevant data and develop 

appropriate methods that would serve as the basis of the nationally 

consistent screening tool. As a result of this effort, increased consistency 

of data and methods will be brought to environmental justice screening 

work across EPA. 

 Activity 2.1: Hold regular staff workgroup and project steering 

committee meetings. 

 Activity 2.2: Develop a set of options to present to Senior Agency 

Officials. 

 Activity 2.3: Create a working prototype of screening tool. 

 Activity 2.4: Update the National Environmental Justice Advisory 

Council on progress. 

 Activity 2.5: Obtain peer review and public comment on a prototype 

tool. 

 Activity 2.6: Revise the tool based on comments. 

Strategy 3: Incorporate appropriate elements of the screening tool into 

the GeoPlatform.

The development of the GeoPlatform and the concurrent creation of a 

nationally consistent environmental justice screening tool provide an 

opportunity for the two efforts to reinforce and enhance each other. As 

both projects continue to evolve, EPA will be watching for opportunities for 

them to work together. Making consistent data and screening methods 

available to users of the GeoPlatform would go a long way towards 

furthering the Agency’s work in environmental justice. 

 Activity 3.1: Review screening tool data, methods, and requirements to 

determine which portions may be appropriate to include in the 

GeoPlatform. 

 Activity 3.2: Incorporate appropriate elements of the prototype 

screening tool into the GeoPlatform. 

 Activity 3.3: Revise GeoPlatform elements of the tool to be consistent 

with changes made to the prototype tool in response to peer review 

and public comments on screening tool. 

2.3 Adjustments 

Adjustments to the environmental justice screening approach may be 

made after public comment, after peer review, and in response to feedback 

from early users. Any required adjustments to the EPA GeoPlatform 

datasets or the Environmental Analyst application will also be made to 

support changes made to the environmental justice screening approach. 
Plan EJ 2014: Appendix, Implementation Plans 157

3.0 DELIVERABLES 

ACTIVITIES DELIVERABLES MILESTONE

Strategy 1: Develop the EPA’s GeoPlatform.

Activity 1.1 Prototype of EPA Environmental Analyst for 

review.

Fiscal Year 

(FY) 2011 Q4

Activity 1.2 Production release of EPA Environmental 

Analyst.

FY 2012 Q1

Activity 1.3 Production release of EPA GeoPlatform 

(including initial data services) for use by 

Environmental Analyst and other 

GeoPlatform components.

FY 2012 Q1

Strategy 2: Develop the nationally consistent environmental justice 

screening tool.

Activity 2.1 Hold regular staff workgroup and project 

steering committee meetings.

Ongoing

Activity 2.2 Develop a set of options to present to Senior 

Agency Officials.

FY 2011 Q3

Activity 2.3 Create a working prototype of screening tool. FY 2012 Q2

Activity 2.4 Update the National Environmental Justice 

Advisory Council on progress.

TBD

Activity 2.5 Obtain peer review and public comment on a 

prototype tool.

TBD

Activity 2.6 Revise the tool based on comments. TBD

Strategy 3: Incorporate appropriate elements of the screening tool into the 

GeoPlatform.

Activity 3.1 Review screening tool data, methods, and 

requirements to determine which portions 

may be appropriate to include in the 

GeoPlatform.

Begin FY 2011 

Q4 & continue 

on a monthly 

basis

Activity 3.2 Incorporate appropriate elements of the 

prototype screening tool into the 

GeoPlatform.

TBD

Activity 3.3 Revise GeoPlatform elements of the tool to 

be consistent with changes made to the 

prototype tool in response to peer review and 

public comments on screening tool.

TBD
Plan EJ 2014: Appendix, Implementation Plans 158

4.0 REPORTING 

Progress reports on this implementation plan will be made annually. For 

information, please contact: Glynis Hill, 202-564-1139, hill.glynis@epa.gov, 

Jerry Johnston, 202-564-3175, johnston.jerry@epa.gov, or Kim Balassiano, 

202-566-0709, balassiano.kim@epa.gov . 
Plan EJ 2014: Appendix, Implementation Plans 159

9. Resources Tools Development 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

September 2011 

Led by

Office of Administration and Resources Management

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

 
Plan EJ 2014: Appendix, Implementation Plans 160

1.0 INTRODUCTION 

1.1 Goals 

The U.S. Environmental Protection Agency (U.S. EPA)'s Office of 

Administration and Resource Management (OARM)’s 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. The goals of each are discussed below. 

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, integrated One EPA approach 

to organizing and implementing the Agency’s community-based grants 

programs, streamlining grants processes consistent with the 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 and 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, tribal, 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 all communities to achieve healthy, 

sustainable, green, and equitable development, 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. 

Goals At-A-Glance

To develop an efficient 

and effective system for 

delivering financial and 

technical assistance to 

communities to empower 

them to improve their 

health and environment.
Plan EJ 2014: Appendix, Implementation Plans 161

This goal includes establishing an integrated 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 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. 

OARM’s Office of Diversity, Outreach, and Collaboration (ODOC), in 

conjunction with in collaboration with the Office of Human Resources 

(OHR) and the Office of Civil Rights (OCR), will work with the EPA national 

program offices and regions 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 Equal 

Employment Opportunity (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 the Deputy 

Assistant Administrator, Office of Enforcement and Compliance Assurance 

the Deputy Regional Administrator, Region 5, 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, the Office of Grants 

and Debarment (OGD), OARM; and the Director, Financial Policy and 

Planning Staff, the Office of Financial Management (OFM), the 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 Office of General Counsel (OGC) (CoChairs). 

 Timely Award Subgroup: OGD and Office of Solid Waste and Emergency 

Response (OSWER) (Co-Chairs). 
Plan EJ 2014: Appendix, Implementation Plans 162

The Grants Workgroup has broad representation from EPA 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. 
Plan EJ 2014: Appendix, Implementation Plans 163

2.0 IMPLEMENTATION 

2.1 Strategies 

Grants and Technical Assistance: Under the framework of the CommunityBased 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/Office of Regional Counsel (ORC)/Program 

Office Dialogue 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 an integrated One EPA approach for recruitment and 

outreach. 
Plan EJ 2014: Appendix, Implementation Plans 164

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 

Community-Based Grant Opportunities. 

 Activity 1.1: Draft recommendations for improving community group 

access to EPA grant programs to be presented to Executive 

Management Committee (EMC) in March 2011. 

 Activity 1.2: Solicit informal feedback from communities (e.g., CARE 

Program workshops). 

 Activity 1.3: Conduct outreach to regions and National Program 

Managers (NPMs) via conference calls and sharing of drafts. 

Strategy 2: Improve Delivery of Technical Assistance to Communities.

 Activity 2.1: Develop Technical Assistance Center approach. 

 Activity 2.2: Preliminary draft options to be presented to the EMC in 

March 2011. 

 Activity 2.3: Obtain senior management guidance on initial concepts 

before obtaining informal feedback from communities. 

 Activity 2.4: Conduct outreach to regions and NPMs via conference 

calls and sharing of drafts. 

Strategy 3: Strengthen Grants Training for Communities.

 Activity 3.1: Create umbrella, basic on-line grants training for 

communities, environmental justice-specific on-line training, and 

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

 Activity 3.2: Develop training modules by December 2011. 

 Activity 3.3: Obtain informal community feedback as modules 

developed. 

 Activity 3.4: 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.

 Activity 4.1: Develop and implement appropriate grant competition

tools (e.g., listservs, webinars). Tools will be in place by October 2011. 

 Activity 4.2: Obtain informal community input through 

Regional/Headquarters websites. 

 Activity 4.3: Work with regions and NPMs to develop and implement 

tools. 

Strategy 5: Revise Grant Policies that are Unduly Restrictive.

 Activity 5.1: Revise Delegation 1-86 and indirect cost rate policies for 

environmental justice grants by the end of 2011. Temporarily revised 

delegation policies were issued in November 2010. 
Plan EJ 2014: Appendix, Implementation Plans 165

 Activity 5.2: Establish simplified Indirect Cost Rate (ICR) policy by 

October 2011. 

 Activity 5.3: Obtain informal community feedback once draft ICR policy 

developed. 

 Activity 5.4: Conduct outreach to regions and NPMs by providing 

opportunity to comment on draft policy issuance. 

 Activity 5.5: Explore simplification of other policies. 

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

Counsel/Program Office Dialogue on Community-Based Grant 

Opportunities.

 Activity 6.1: Conduct periodic OGC/ORC/OEJ meetings and OGC 

guidance on scope of community-based grant authorities. 

OGC/ORC/OEJ calls were conducted on January 5, 2011, and February 

2, 2011. 

 Activity 6.2: Obtain OGC legal guidance on scope of grant authorities. 

 Activity 6.3: Coordinate discussions with larger OGC effort on existing 

legal authorities. 

Strategy 7: Improve timeliness of Brownfields Grant Awards.

 Activity 7.1: Develop recommendations for consistent Brownfields 

award times by August 2011. Draft recommendations will be shared 

with the EPA’s Grants Management Officers (GMOs) and OSWER. 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 and 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 

January 2012. 

 Activity 2: Develop effective marketing materials and strategy by 

January 2012. 

 Activity 3: Develop a National Conference Toolkit by January 2012. 

 Activity 4: Develop a National Outreach Calendar by January 2012. 

OARM will also provide Agency-wide diversity training for hiring officials. 
Plan EJ 2014: Appendix, Implementation Plans 166

2.3 Community Engagement and Stakeholder Outreach 

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 (for example, feedback from the National 

Environmental Justice Advisory Council [NEJAC]) may be required for 

certain activities, including the development and 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 effect of revised policy and procedures in Fiscal Year (FY) 2012. If the 

Agency and communities are not realizing the desired outcomes, OGD and 

the workgroup will make necessary adjustments in FY 2013 to reach the 

desired outcomes. 
Plan EJ 2014: Appendix, Implementation Plans 167

3.0 DELIVERABLES 

3.1 Schedule of Deliverables

Grants and Technical Assistance: Appendix B 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 

Outreach and Recruitment Task Force will initiate 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. 
Plan EJ 2014: Appendix, Implementation Plans 168

4.0 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 FY 

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 Outreach and Recruitment Task Force is convened. For 

information, please contact Antoinette Powell-Dickson, 202-566-0738, 

Powell-Dickson.Antoinette@epa.gov. 

 
Plan EJ 2014: Appendix, Implementation Plans 

178

Appendix B: Table of Deliverables and Measures 

Strategy Number Q2 FY 2011 Q3 FY 2011 Q4 FY 

2011 Q1 FY 2012 Q2 FY 2012 Q3 FY 2012 Q4 FY 2012

Q1 FY2013 - 

FY 2014 Measures

Strategy 1: Increase 

Transparency & 

Efficiency in Providing 

Community-Based 

Grant Opportunities.

Brief EMC on 

draft options 

for improving 

grant delivery 

system.

Refine 

reform 

options 

based on 

EMC and 

community 

feedback.

Finalize 

reform 

options.

Begin 

implementation

Continue 

implementation

Continue 

implementation

Continue 

implement

ation.

Conduct 

evaluation 

and make 

necessary 

adjustments.

Reduction in 

regional workload; 

Increase in 

community grant 

applications.

Strategy 2: Improve 

Delivery of Technical 

Assistance to 

Communities.

Brief EMC on 

preliminary 

draft options.

Refine 

reform 

options 

based on 

EMC and 

community 

feedback.

Finalize 

reform 

options.

Begin drafting 

of grant or 

contract 

RFP(s).

Issue RFP(s). RFP period 

closes.

Evaluate 

application

s an make 

selections 

for service 

provider(s)

Monitor 

service 

provider(s), 

conduct 

evaluation, 

and make 

necessary 

adjustments.

Compliance with 

performance 

measures in 

grant/contract 

workplan(s); 

Degree of 

utilization by 

regions and 

Communities; 

Geographic 

distribution of 

outreach activities.

Strategy 3:

Strengthen Grants 

Training for 

Communities.

Complete 

development

of draft 

umbrella and 

environmental 

justice on-line 

training.

Obtain 

community 

& EPA 

feedback; 

initiate 

programspecific 

trainings.

Evaluate 

feedback; 

continue 

to develop 

programspecific 

training.

Complete all 

training.

Roll-out 

training to 

communities.

Provide 

training.

Provide 

training.

Conduct 

evaluation of 

training and 

make 

necessary 

adjustments.

Community 

satisfaction as 

measured by 

customer 

feedback.

Strategy 4:

Improve Community 

Awareness of Grant 

Competition Process.

Seek input 

from EPA 

grants 

community 

via 

regional/HQ 

websites.

Evaluate 

community 

feedback;

Obtain EPA 

feedback. 

Evaluate 

feedback; 

finalize 

competitio

n tools.

Roll-out 

competition 

tools to 

communities.

Promote use of 

tools.

Promote use of 

tools.

Evaluation 

of 

effectiven

ess of 

tools.

Tools 

adjusted 

based on 

results of 

evaluation.

Number of, and 

participation in, 

webinars; 

Increase in 

applications from 

new organizations 

(OEJ). 
Plan EJ 2014: Appendix, Implementation Plans 

179

Strategy Number Q2 FY 2011 Q3 FY 2011 Q4 FY 2011 Q1 FY 2012 Q2 FY 2012 Q3 FY 2012 Q4 FY 2012 Q1 FY2013 - 

FY 2014 Measures

Strategy 5:

Revise grant policies that 

are unduly restrictive. 

Inform 

programs of 

temporary 

revised 

version of 

Delegation 1-

86.

Issue final 

revised 

version of 

Delegation 1-

86.

Assess need 

for additional 

changes to 

delegation 

and make 

adjustments 

as 

necessary.

Increase in 

number of 

single-statute 

awards.

Strategy 5: 

Revise grant policies that 

are unduly restrictive.

Draft policy to 

simplify 

indirect cost 

rules; solicit 

feedback on 

changes to 

other policies.

Issue draft 

revision to 

indirect 

cost 

policies and 

other 

identified 

policies.

Issue final 

revised 

indirect 

cost rate 

policy/other 

revised 

policies.

Implement. Continue to 

implement.

Continue to 

implement.

Continue to 

implement.

Conduct 

evaluation 

and make 

necessary 

adjustments.

Number of 

communities 

that take 

advantage of 

simplified 

indirect cost 

rates.

Strategy 6: Encourage 

OEJ-OGC/ORC-Program 

Office Dialogue on 

Community-Based Grant 

Issues.

Hold kick-off 

meeting to 

clarify roles 

and 

responsibilitie

s for eligibility 

reviews.

Second 

quarterly 

meeting.

Quarterly 

meeting.

Quarterly 

meeting.

Quarterly 

meeting.

Quarterly 

meeting.

Quarterly 

meeting.

Conduct 

evaluation 

and make 

necessary 

adjustments.

Increase in 

timeliness of 

Program 

Office/ 

OGC/ORC 

eligibility 

reviews.

Strategy 6:

Encourage OEJOGC/ORC –Program 

Office Dialogue on 

Community-Based Grant 

Issues. 

Schedule for 

issuance of 

OGC 

guidance on 

the scope of 

existing grant 

authorities to 

be 

determined.

Reduction in 

number of 

legally 

ineligible 

grant 

applications.

Strategy 7: Improve 

Timeliness of Brownfields 

Grant Awards. Develop draft 

approach.

Consult 

with HQ/ 

Regional 

Program & 

Grants 

Offices.

Finalize 

strategy 

and begin 

to 

implement.

Implement. Continue to 

implement.

Continue to 

implement.

Continue to 

implement.

Conduct 

evaluation 

and make 

necessary 

adjustments.

Reduction in 

award times 

across grants 

offices.
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181

Plan EJ 2014: Acronyms 

ACRONYMS 

AANAPISIs Asian American Native American Pacific Islanders Servicing 

Institutions 

ADP Action Development Process 

Agency U.S. Environmental Protection Agency 

ASIWPCA Association of State and Interstate Water Pollution Control 

Administrators 

ASTSWMO Association of State and Territorial Solid Waste 

Management Officials 

BACT Best Available Control Technology 

C-FERST Community-Focused Exposure and Risk Screening Tool 

CAA Clean Air Act 

CAAAC Clean Air Act Advisory Committee 

CAFO Concentrated Animal Feeding Operation 

CARE Community Action for a Renewed Environment 

CB Community-based 

CBCE Community-based coordination efforts (initiative) 

CBP Community-based partners (program) 

CBPR Community-Based Participatory Research

CCRS Criminal Case Reporting System 

CEI Community Engagement Initiative 

CenRANK Census Tract Ranking Tool for Environmental Justice 

CEQ White House Council on Environmental Quality

CHPAC Children’s Health Protection Advisory Committee

CIC Community Involvement Coordinator 

CIO Chief Information Officer 

CIPIB Community Involvement and Program Initiatives Branch 

CIU Community Involvement University 

CRA Cumulative Risk Assessment 

CSO Combined Sewer Overflow 

CVRA Crime Victims’ Rights Act

DAA Deputy Assistant Administrator 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice
182

Plan EJ 2014: Acronyms 

DOT U.S. Department of Transportation 

DRA Deputy Regional Administrator 

DSW Definition of Solid Waste (rule) 

ECOS Environmental Council of the States 

EEO Equal Employment Opportunity 

EFAB Environmental Financial Advisory Board 

EIS Environmental Impact Statement 

EJ IWG Federal Interagency Working Group on Environmental 

Justice 

EJC Environmental Justice Committee 

EJGAT Environmental Justice Geographic Assessment Tool 

EJSEAT Environmental Justice Strategic Enforcement Assessment 

Tool 

EMC Executive Management Council 

EO 12898 Executive Order 12898 (on environmental justice) 

EPA U.S. Environmental Protection Agency 

ESC Executive Steering Committee 

FaST Faculty and Student Teams (Program) 

FCHDR Federal Collaboration on Health Disparities Research 

FRS Facility Registry System 

FY Fiscal Year 

GDG Geospatial Data Gateway

GIS Geospatial Information System 

GMO Grants Management Officers 

GRO Greater Research Opportunities (fellowship) 

GWPC Ground Water Protection Council 

HBCUs Historical Black Colleges and Universities 

HHS U.S. Department of Health and Human Services 

HSIs Hispanic Servicing Institutions 

HUD U.S. Department of Housing and Urban Development 

ICIS Integrated Compliance Information System 

ICR Indirect Cost Rate 

IGD Integrated Geospatial Database 

ITEP Tribal Environmental Professionals 
183

Plan EJ 2014: Acronyms 

LEP Limited English Proficiency

MAI Minority Academic Institutions

MOU Memorandum of Understanding 

MSI Minority Serving Institution 

NACAA National Association of Clean Air Agencies, comprised of 

the State and Territorial Air Pollution Program 

Administrators and the Association of Local Air Pollution 

Control Officials 

NACWA National Association for Clean Water Agencies 

NAHMMA North American Hazardous Materials Management 

Association 

NCER National Center for Environmental Research 

NCMHD National Center on Minority Health and Health Disparities 

NEI National Enforcement Initiative 

NEJAC National Environmental Justice Advisory Council 

NEPA National Environmental Policy Act 

NEPPS National Environmental Performance Partnership System 

NERL National Exposure Research Laboratory 

NESCA National Enforcement Strategy for Corrective Action 

NEWMOA Northeast Waste Management Officials' Association 

NGO Non-governmental organization 

NHEERL National Health and Environmental Effects Research 

Laboratory 

NIH National Institutes of Health 

NPM National Program Manager 

NSF National Science Foundation 

NTOC National Tribal Operations Committee 

OAR Office of Air and Radiation 

OARM Office of Administration and Resource Management 

OCFO Office of the Chief Financial Officer 

OCHP Office of Children’s Health Protection 

OCIR Office of Congressional and Intergovernmental Affairs 

OCR Office of Civil Rights

OCSPP Office of Chemical Safety and Pollution Prevention 

ODOC Office of Diversity, Outreach and Collaboration 
184

Plan EJ 2014: Acronyms 

OECA Office of Enforcement and Compliance Assurance 

OEI Office of Environmental Information 

OEJ Office of Environmental Justice 

OFA Office of Federal Activities 

OFM Office of Financial Management 

OGC Office of General Counsel 

OGD Office of Grants and Debarment 

OHR Office of Human Resources

OIA Office Indian Affairs 

OIAA Office of Information Analysis and Access 

OP Office of Policy

OPP Office of Pesticide Programs 

ORC Office of Regional Counsel 

ORD Office of Research and Development 

OSA Office of the Science Advisor 

OSP Office of Science Policy 

OSWER Office of Solid Waste and Emergency Response 

OW Office of Water

PPA Performance Partnership Agreement 

PPG Performance Partnership Grants 

Q&A Question-and-Answer 

QIC Quality and Information Council

RAF Risk Assessment Forum 

RARE Regional Applied Research Effort Program 

RCRA Resource Conservation and Recovery Act 

RFA Request for Applications 

RFP Request for proposal 

RSS Really Simple Syndication 

SAB Science Advisory Board 

SEP Supplemental Environmental Project 

SHCRP Sustainable and Healthy Communities Research Program 

SIT Strategic Implementation Team 

SSMs Startups, Shutdowns, and Malfunctions 

SSO Sanitary Sewer Overflow 
185

Plan EJ 2014: Acronyms 

STAR Science to Achieve Research (grant) 

TAB Technical Assistance to Brownfields Communities (grant) 

TAMS Tribal Air Monitoring Support (Center)

TASC Technical Assistance Services for Communities (program) 

TBD To be determined 

TCUs Tribal Colleges and Universities 

TRI Toxics Release Inventory 

UTEP University of Texas El Paso 
For more information on Plan EJ 2014, visit the U.S. Environmental Protection Agency’s Office of 

Environmental Justice website at: http://www.epa.gov/environmentaljustice/plan-ej/