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:
MESSAGE
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…