# 1 MEMORANDUM

From: The Office of Air Qu ality 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: St ationary Combustion Turbines

1.0 INTRODUCTION

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on environmental justice. Its main pr ovision 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 hi gh and adverse human health or environmental effects of their programs, policies, and activitie s on minority populations and low income populations in the United

States.

EPA defines “Environmental Justice” to include meaningful involveme nt of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, a nd 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 publ ic 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 populati ons because it increases the level of environmental protection for all affect ed populations without havi ng any disproportionately high and adverse human health or environmental e ffects on any population, including any minority, low income, or indigenous populations.

To gain a better understanding of the source category and near s ource populations, the U.S. EPA conducted a demographic analysis on recent installa tions of combustion turbin es selling >25 MW of power to identify any overrepres entation of minority, low income , or indigenous populations. This analysis only gives some indication of the prevalen ce of sub-populations that may be exposed to air pollution from the sources; it does not identify th e demographic characteristics of the most highly affected individuals or communities, nor does it quan tify 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-cont inental areas. The subset is a representation of areas within the country with grow ing electric demands that are bei ng supplied by natural gas, and thus potential new facilities.

The demographic data in Table 2.1 shows that severa l demographic categories exceed 20 percent of their corresponding national averages:

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

o Minority = +12 percen tage 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 li ving near affected sources, such th at 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 Bure au. 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 le vel data to the census block level. The sociodemographic parameters used in th e analysis included the following ca tegories: Racial (White, African American, Native American, Other or Multiracial, and All Other Races); Ethnicit y (Hispanic); and Other (Number of people below th e poverty line, Number of people with ages between 0 and 18, Number of people greater than or equal to 65, Number of pe ople 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 1234 

# however, not necessarily associated

with the distance health risks are seen. To the extent that any minority, low income, or indigenous subpopulation is disproportionately im pacted by the emissions as a resu lt of the proximity of their homes to these sources, that subpopu lation 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 MINORITY 2 HISPANIC

OR LATINO 3 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

SUMMARY 1

NEAR SOURCE TOTAL

% OF NEAR SOURCE TOTAL

NATIONAL TOTAL

% OF NATIONAL TOTAL