This issue has come up previously from a few institutions. It has been
discussed with the EPA Grants Officer at the last two FDP (Federal
Demonstration Partnership) meetings  The Council of Governmental Relations
(COGR) is also in the
process of talking with EPA about this form.  The form should not apply to
EPA research grants, but
the EPA Grants Officer said their legal office has decided to required it
for all awards.

Here are a couple of suggestions for completing the form:
The EPA EEO Officer in Region IX (California) was called and asked how it
should be completed.  Under Part III, the campus can acknowledged that
complaints had been filed and list the EEO/AA Director's telephone number
and General Counsel's phone number for further information.  You do not
need to list any of the complaints.

Other responses to questions III and IV are to attach the DOL EEO-6 Form.
 The EPA Grants Officer told COGR that the EPA form is similar to the Dept.
of Education or the Dept. of Labor's EEO-6.  COGR's suggestion is to
attached the EEO-6 to this submission.  Some institutions are filling out
the form by stating in questions III and IV that this information has
previously been submitted to EEOC/OFCCP and they can get it from those
agencies.

 On Part VII, "Population Characteristics", you can say "Not Applicable",
although some campuses are trying to fill out Part VII.  It really doesn't
apply to research grants.