EPA staff have received notice that the Agency will now require prospective grant recipients to complete a "Civil Rights form" before receiving an award, apparently as a result of a "new interpretation" by EPA civil rights lawyers of what the constitution requires of the State.
The staff were told:
The grants office is no longer making awards without a copy of the Civil Rights form (4700-4). In the past, the grants office could make an award without the form and simply term and condition the agreement. They could also use a completed form for multiple awards for the same recipient in a given year. They can no longer do this. The Civil Rights form must be completed by the applicant before a grant award can be made. Therefore, the grants office is asking that the form be submitted with the other forms and certifications (application, lobbying and assurances) in the funding recommendation.
The form itself asks questions - that is, stakes out new conditions - including, among others:
List all civil rights lawsuits and administrative complaints pending against the applicant/recipient that allege discrimination based on race, color, national origin, sex, age, or disability.
Does the applicant/recipient maintain demographic data on the race, color, national origin, sex, age, or handicap of the population it serves?
Does the applicant/recipient have a policy/procedure for providing access to services for persons with limited English proficiency?
In short, "civil rights" lawsuits are now much more likely to also be used as a tool to bully the ever-expanding universe having staked their claim to taxpayer funding in the form of EPA-style government contracting. Nice place you got here, running various pointy-headed compliance workshops, feeding off the beast that is the Superfund black hole, etc. Sure be a shame if a civil rights lawsuit or two were filed...
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