OAQPS ENVIRONMENTAL JUSTICE ANALYTICAL TEAM REPORT

RULE / ACTION
Pulp and Paper

OBJECTIVE
This report aids rule writers in drafting required environmental justice preamble language for E.O. 12898, as well as addressing the Agency's three Final Agency Review (FAR) EJ questions:
      (1) How did your public participation process provide transparency and meaningful participation for minority, low-income, and indigenous populations, and tribes?
      (2) How did you identify and address existing and new disproportionate environmental and public health impacts on minority, low-income, and indigenous populations, and tribes?
      (3) How did actions taken under #1 and #2 impact the outcome or final decision?   

SCOPE
   * Total # of unique facility locations = 174
   * Data Source: ICR (contact Jim Hirtz)

EJ ASSESSMENT
Meaningful Involvement (FAR question #1)
To promote meaningful involvement, EPA has held public webinars (www.epa.gov/air/ej/announce.html) and held 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.

Demographic Results (FAR question #2)
      
   Method(s)
*       Proximity-to-Source: Comparative analysis of 3 mile or 5 km radius demographics to national averages. 
   Source(s)
*       CenRANK (proximity)

Proximity-to-Source 

The sector-wide analysis of near source populations reveals 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 1

A facility-level review of near source populations shows that the densely populated area surrounding the Wisconsin Paperboard Corp., WI facility is a main contributor to the African American total with 69,292, or 19%, of the total Pulp and Paper sector African American population (69,292 / 365,077). Other locations making significant contributions to the sector's total African American population are Rock-Tenn Company Mill Division Inc., OH (37,416), Newman & Company, PA (30,480) and PaperWorks Industries Inc., PA (20,630). The four areas combined make up 43% of the sector's total African American population (157,818 / 365,077). Additionally, the Wisconsin Paperboard Corp., WI area has a high percentage of people living below the poverty line at 30%, which is 17 percentage points above the national average of 13%, or +131%. In the sector summary (table 2) we highlight the top three regions and states by number of facilities, and the top three facilities with the highest near source population totals. The excel file that accompanies this report contains the near source demographic data for all facilities.
         Table 2
                                Sector Summary
                                    Totals

                                # of Facilities
                         Near Source (3 mi) Population
Sector
                                      174
                                   2,437,688
                                   Top Three
Regions
                                       
                                       

4
                                      60
                                    388,546

5
                                      43
                                   1,011,870

6
                                      19
                                    103,226

States
                                       
                                       

WI
                                      22
                                    490,785

GA
                                      16
                                    110,963

AL
                                      12
                                    22,335

Facilities
                                       
                                       

PA
NEWMAN & COMPANY
                                    230,474

WI
WISCONSIN PAPERBOARD CORP
                                    148,451

OH
ROCK-TENN COMPANY MILL DIVISION INC
                                    118,269

To evaluate potential areas of environmental justice concern, the EPA highlights the near source areas that are equal to or exceed a threshold factor of 1.25 times national averages for race, ethnicity and/or poverty demographic categories. (The EPA acknowledges that environmental justice areas may exist in areas below this threshold.) Analysis of this data shows 71 facilities with a near source population of 855,587 that are equal to, or exceed, this increased threshold. This is 41% of all facilities, and 35% of the near source population in the sector. The facility with the largest near source population in this subgroup is the Wisconsin Paperboard Corp. facility with a total of 148,451. The area surrounding this facility is comprised of 54% minority (+116% the national average of 25%), and 30% of people living below the national poverty line (+131% the national average of 13%). Table 3 provides a snapshot of the top three regions, states and facilities.
         Table 3
                      Potential Areas of Concern Summary
                          Exceeding Threshold Factor

                                # of Facilities
                         Near Source (3 mi) Population
Sector
                                      71
                                    855,587
                                   Top Three
Regions
                                       
                                       

4
                                      39
                                    275,336

6
                                      14
                                    86,064

10
                                       6
                                    110,593

States
                                       
                                       

GA
                                      11
                                    92,388

AL
                                      11
                                    15,384

LA
                                       6
                                    50,832

Facilities
                                       
                                       

WI
WISCONSIN PAPERBOARD CORP
                                    148,451

OH
ROCK-TENN COMPANY MILL DIVISION INC
                                    118,269

WA
SIMPSON TACOMA KRAFT CO LLC
                                    68,557

Additionally, the EPA provides a summary of "facility clusters." For the purposes of this report, a facility cluster is defined as an area where multiple facilities are in close proximity to each other such that the study areas overlap, and a census block can be attributed to one or more facilities. The following population totals are the combined near source populations for all facilities notated.
Facility Clusters 
   
Four facility clusters
               o       Georgia Pacific Consumer Products LP - Green Bay Broadway Mill, WI + 
      Thilmany Papers Nicolet Mill, WI +
      Green Bay Packaging Inc- Green Bay Mill, WI + 
      Georgia Pacific Consumer Products LP - Green Bay Day Street Mill, WI = 127,855 total population
      
               o       [Three] NewPage Wisconsin Systems Inc, WI + 
      NewPage Corp - Biron Mill, WI = 21,999
      

Three facility cluster
               o       Longview Fibre paper & Packaging Inc., WA +
   Weyerhaeuser Co., WA +
   North Pacific Paper Corporation (NORPAC) (Longview Mill), WA = 43,329

Two facility clusters (Seven areas - see excel file)
                                       

Charge to Project Lead (FAR question #3)
How did actions taken under [FAR questions] #1 and #2 impact the outcome or final decision? 

                                       
