"The Synergy of Conservation and Civil Rights: No Community Left Behind."
1. Recently the Department of the Interior, Office of Civil Rights, sent a memo to all Bureau Directors, asking for national policies implemented by the bureaus on other power driven motor vehicles (OPDMDs) and service animals. As we know, there have been several changes in the ADA, requiring public entities to allow OPDMDs as reasonable modifications (subject to exeptions/assessment factors), and also limiting service animals to dogs and miniature horses. The ADA does not apply to Federally Conducted programs, but the DOI Office of Civil Rights is looking at possibly harmonizing the DOI policies with the ADA. The Refuges Office would be responsible for any FWS policies on OPDMDs and service animals, and would have the information for DOI. Our recent policy memo on OPDMDs went to the State fish and wildlife agencies. We shared a copy of that memo with the Department, anyway, even though it didn't address Federally Conducted Accessibility.
2. We recently initiated a desk civil rights review of more than 70 new recipients of the Coastal Impact Assistance Program (CIAP). These are mostly local government units in coastal regions of the USA, especially in the Southeast and Pacific. There are no Regional Office responsibilities; CIAP, as I understand it, is handled via a CIAP branch in WSFR and State Coordinators. The checklist of civil rights information that we sent them is similar to the information that we ask of the State fish and wildlife agencies. The CIAP recipient responses are due in late September. We gave them the option of showing that they have been subject to a CR review by another Federal agency within the past 3 years. If they send us a review report dated within 3 years, we will defer to that Federal agency's civil rights compliance monitoring.
3. Recently, the DOI Office of Civil Rights sponsored a forum on tracking Federal financial assistance online. That includes tracking grant moneys to subrecipients as well as recipients. We learned from this forum, and also from complaint handling, that these Internet-based systems may be inadequate to accurately assess the precise FWS moneys going from FWS to a recipient and then to a subrecipient. A more accurate method is to ask our prime recipients to identify FWS financial assistance given to the subrecipient in question. We used that method to establish our jurisdiction on a Title VI/Environmental Justice case in Texas. Currently, WSFR has a very extensive database of our grant recipients. Grant experts here in WSFR mentioned that recent legislation requires a listing of both recipients and subrecipients per agency.
4. The Inter-agency Working Group on Environmental Justice, Title VI Committee, just sent each agency an informal survey on complaint and compliance activities where both Title VI and Environmental Justice are jointly involved. Here in FWS, we just listed the one Title VI/EJ case; the close working relationship between the Title VI program and the EJ program; the EJ and Title VI aspects of our State complaince reviews; our active involvement with the EJ IWG; and that FWS adheres to the DOI EJ Plan that has a specific section for Title VI. Our survey will go to the DOI Office of Civil Rights for consolidation of the DOI bureau responses. The DOI OCR may allow us to send it directly to DOJ, since I am on the EJ IWG Title VI Committee, and helped prepare the survey.
Last updated: August 9, 2012
Wildlife and Sport Fish Restoration Program