MEMORANDUM

To:		Pulp and Paper Docket (EPA-HQ-OAR-2007-0544)

From:		John Bradfield, US EPA

Date:		December 6, 2011 

Subject:	Review of Environmental Justice Impacts: Pulp and Paper 

1.0	INTRODUCTION

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes
federal executive policy on environmental justice. Its main provision
directs federal agencies, to the greatest extent practicable and
permitted by law, to make environmental justice part of their mission by
identifying and addressing, as appropriate, disproportionately high and
adverse human health or environmental effects of their programs,
policies, and activities on minority populations and low income
populations in the United States.

EPA defines “Environmental Justice” to include 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 polices.  To promote meaningful
involvement for the risk and technology review (RTR) of the NESHAP for
pulp and paper making (subpart S), EPA held public webinars ( HYPERLINK
"http://www.epa.gov/air/ej/announce.html"
www.epa.gov/air/ej/announce.html ) and hosted discussions during its
2011 Environmental Justice Conference. Stakeholder meetings were also
held with Sierra Club, Earth Justice, and with organizations that
participated in EPA Environmental Justice outreach efforts.  Further
stakeholder and public input is expected through public comment and
follow-up meetings with interested stakeholders.

DEMOGRAPHICS

EPA has determined that this proposed rule will not have
disproportionately high and adverse human health or environmental
effects on minority, low income, indigenous populations because it
increases the level of environmental protection for all affected
populations without having any disproportionately high and adverse human
health or environmental effects on any population, including any
minority, low income, or indigenous populations.

 These proposed standards may improve public health and welfare, now and
in the future, by reducing HAP emissions that may contribute to adverse
environmental and human health impacts. The reductions in HAP emissions
associated with the rule are expected to benefit all populations living
near the sources affected by this rule. 

Additionally, the Agency has reviewed this rule to determine if there is
an overrepresentation of minority, low income, or indigenous populations
near the sources such that they may currently face disproportionate
risks from pollutants that could be mitigated by this rulemaking. This
analysis only gives some indication of the prevalence of sub-populations
that may be exposed to HAP pollution from the sources affected by this
rulemaking; it does not identify the demographic characteristics of the
most highly affected individuals or communities, nor does it quantify
the level of risk faced by those individuals or communities. 

The demographic data in Table 2.1 shows that while most demographic
categories are below or within 10 percent of their corresponding
national averages, the African American population percentage within 3
miles of any source affected by this rulemaking exceeds the national
average by 3 percentage points (15 percent versus 12 percent), or +25
percent, and those age 65+ exceed the national average by 2 percentage
points (14 percent versus 12 percent) or +17 percent. 

Table 2.1 Summary of Demographic Data Analysis

Demographic Summary	Near Source Total	% of Near Source Total	National
Total	% of National Total

Population	2,437,688

285,339,128

	White	1,929,157	79%	214,539,706	75%

African American	365,077	15%	35,043,873	12%

Native American	20,449	1%	2,489,515	1%

Other or Multiracial	123,005	5%	33,265,937	12%

Minority1	508,531	21%	70,799,422	25%

Hispanic or Latino2	78,804	3%	39,083,760	14%

Age 0-17	604,248	25%	77,245,364	27%

Age 65+	343,439	14%	35,491,274	12%

No High School Diploma	314,843	13%	36,660,464	13%

Below Poverty Line	353,183	14%	37,181,029	13%

Sources: The demographics are from the U.S. Census Bureau, 2000. 
Information on the facilities is from U.S. EPA.

1The “Minorities” population is the overall population (in the first
row) minus white population (in the second row).

2The Census Bureau defines “Hispanic or Latino” as an ethnicity
rather than a racial category, Hispanics or Latinos may belong to any
race.

The analysis of demographic data used proximity-to-a-source as a
surrogate for exposure to identify those populations considered to be
living near affected sources, such that they have notable exposures to
emissions from these sources. The demographic data for this analysis
were extracted from the 2000 census data, which were provided to the EPA
by the United States Census Bureau. Distributions by race are based on
demographic information at the census block level, and all other
demographic groups are based on the extrapolation of census block group
level data to the census block level. The socio-demographic parameters
used in the analysis included the following categories: Racial (White,
African American, Native American, Other or Multiracial, and All Other
Races); Ethnicity (Hispanic); and Other (Number of people below the
poverty line, Number of people with ages between 0 and 18, Number of
people greater than or equal to 65, Number of people over age 25 without
a high school diploma). 

In determining the aggregate demographic makeup of the communities near
affected sources, the EPA focused on those census blocks within 3 miles
of affected sources and determined the demographic composition (e.g.,
race, income, etc.) of these census blocks and compared them to the
corresponding compositions nationally. The radius of 3 miles (or
approximately 5 km) is consistent with other demographic analyses
focused on areas around potential sources, however, not necessarily
associated with the distance which health risks are seen.      To the
extent that any minority, low income, or indigenous subpopulation is
disproportionately impacted by the emissions as a result of the
proximity of their homes to these sources, that subpopulation also
stands to see increased environmental and health benefit from the
emission reductions called for by this rule.

 U.S. GAO (Government Accountability Office). Demographics of People
Living Near Waste Facilities. Washington DC: Government Printing Office;
1995.

 Mohai P, Saha R. “Reassessing Racial and Socio-economic Disparities
in Environmental Justice Research”. Demography. 2006;43(2): 383–399.

 Mennis J. “Using Geographic Information Systems to Create and Analyze
Statistical Surfaces of Populations and Risk for Environmental Justice
Analysis”. Social Science Quarterly, 2002;83(1):281-297.

 Bullard RD, Mohai P, Wright B, Saha R, et al. Toxic Waste and Race at
Twenty 1987-2007. United Church of Christ. March, 2007.

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