
MEMORANDUM


DATE:	January 3, 2012
SUBJECT:	Environmental Justice Review: Secondary Aluminum RTR
FROM:	Rochelle Boyd, US EPA
TO:		Secondary Aluminum RTR Docket


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.
2.0 DEMOGRAPHICS
The EPA has determined that this proposed rule will not have disproportionately high and adverse human health or environmental effects on minority, low income or 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 limiting HAP emissions that may contribute to adverse environmental and human health impacts. The control of HAP emissions associated with the rule is 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 major source demographic analysis shows that while most demographic categories are below or within 10 percent of their corresponding national averages, the African American percentage within 3 miles of any source affected by this rulemaking exceeds the national average by 3 percentage points (16 percent versus 13 percent), or +23 percent. The area source sector-wide analysis of near source populations reveals that several demographic categories exceed 10 percent of their corresponding national averages: Minority by +16 percentage points (44% vs. 28%), or +57%; Hispanic or Latino by +17 percentage points (34% vs. 17%), or +100%; Without a High School Diploma by +6 percentage points (16% vs. 10%), or +60%, and; Below National Poverty Line: +7 percentage points (21% vs. 14%), or +50%. 

        Table 2.1 Summary of Demographic Data Analysis (Major Sources)


         Table 2.2 Summary of Demographic Data Analysis (Area Sources)


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 with ages 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 at 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 benefits from the emission reductions called for by this rule.

