1

MEMORANDUM 

From: The Office of Air Quality Planning and Standards 

 U.S. Environmental Protection Agency 

To: Combustion Turbine NSPS Docket (EPA-HQ-OAR-2004-0490) 

Date: April, 2012 

Subject: Environmental Justice Review: Stationary Combustion Turbines 

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, 

EPA discussed the proposed rulemaking on the April 24, 2012 community call. Further stakeholder and 

public input is expected through public comment and follow-up meetings with interested stakeholders. 

2.0 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. 

To gain a better understanding of the source category and near source populations, the U.S. EPA 

conducted a demographic analysis on recent installations of combustion turbines selling >25 MW of 

power to identify any overrepresentation of minority, low income, or indigenous populations. This 

analysis only gives some indication of the prevalence of sub-populations that may be exposed to air 

pollution from the sources; 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 U.S. EPA does not have information on recent industrial applications or turbines 

smaller than 25 MW, Alaska, Hawaii, and other non-continental areas. The subset is a representation of 

areas within the country with growing electric demands that are being supplied by natural gas, and thus 

potential new facilities. 

The demographic data in Table 2.1 shows that several demographic categories exceed 20 percent of their 

corresponding national averages: 

o Other or Multiracial = +13 percentage points or +93% 

o Minority = +12 percentage points or +43% 

o Hispanic = +15 percentage points or +88% 
2

o No High School Diploma = +3 percentage points or +30% 

o Below Poverty = + 3 percentage points or +21% 

Table 2.1 Summary of Demographic Data Analysis 

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 2010 

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 sociodemographic 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 sources1234 however, not necessarily associated 

with the distance 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. 

 

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

Government Printing Office; 1995. 

2 Mohai P, Saha R. “Reassessing Racial and Socio-economic Disparities in Environmental Justice Research”. Demography. 

2006;43(2): 383–399. 

3 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. 

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

March, 2007.

POPULATION WHITE

AFRICAN

AMERICAN

NATIVE

AMERICAN

OTHER OR

MULTIRACIAL MINORITY2 HISPANIC

OR LATINO3 AGE 0 ‐ 17 AGE 65+

NO HIGH

SCHOOL

DIPLOMA

BELOW

POVERTY

LINE

6,031,599 3,621,132 737,994 61,939 1,610,534 2,410,467 1,953,393 1,365,832 668,324 805,873 1,025,534

60% 12% 1% 27% 40% 32% 23% 11% 13% 17%

312,861,256 226,405,205 39,475,216 3,646,995 43,333,840 86,456,051 54,181,245 75,217,176 40,830,262 31,914,536 43,487,509

72% 13% 1% 14% 28% 17% 24% 13% 10% 14%

Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA.

1. Racial and ethnic categories overlap and cannot be summed.

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

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

DEMOGRAPHIC

SUMMARY1

NEAR SOURCE TOTAL

% OF NEAR SOURCE TOTAL

NATIONAL TOTAL

% OF NATIONAL TOTAL