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## OAQPS ENVIRONMENTAL JUSTICE **SUMMARY REPORT** 

**RULE / ACTION** Kraft Pulp Mills NSPS



## OBJECTIVE This report aids rule writers in draft ing required environmental justice preamble lang uage 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 disproportion ate 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 facilit y locations = 99

• Data Source: IC R ( Kelley Spence )



## EJ ASSESSMENT

**Meaningful Involvement**  A key element of environmental justice is ensuring that all people have an opportunity for meaningful involvement in decision

- making. Certain groups may not have participated in decision making historically because of economic (e.g., income), social (e.g., language barriers, education levels, distrust of government), and structural reasons. A critical concern is whether, and the extent to which, communities have the ability to influence the types and number of regulated activities taking place in their community, as well as the requirements, conditions, and parameters by which they must operate (e.g., permit conditions).

The EPA aims to notify and engage the public in a variety of ways. Each rule is reviewed to identify the appropriate methodology and meaningful involvement may consist of one or more of the following: notices on the EJAir website, community call discussions, fact sheets, community meetings, and/or webinars.

### 2 **Demographic Results**

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 analysis of near source populations (Table 1) reveals that the following demogra phic categories exceed 20 percent of the corresponding national average:

• African American = + 5 percentage points or + 38 %

Table 1

DEMOGRAPHIC

SUMMARY 1 NEAR SOURCE TOTAL % OF NEAR SOURCE TOTAL NATIONAL TOTAL % OF NATIONAL TOTAL

POPULATION 757,564 312,861,256 WHITE 556,248 7 3 % 226,405,205 72% AFRICAN AMERICAN 139,782 18 % 39,475,216 13% NATIVE AMERICAN 9,613 1% 3,646,995 1% OTHER OR MULTIRACIAL 51,921 7% 43,333,840 14%

MINORITY 2 201,316 27 % 86,456,051 28% HISPANIC OR LATINO 3 39,585 5% 54,181,245 17% AGE 0

- 4 50,745 7% 20,465,068 7% AGE 0

- 17 179,398 24% 75,217,176 24%

AGE 65+ 107,183 14% 40,830,262 13% NO HIGH SCHOOL DIPLOMA 71,271 9 % 32,060,510 10%

BELOW POVERTY LINE 116,904 1 5 % 43,616,850 14% >= 1.2 of National Average
Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA. 1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facilit y level total may not match this summary total. 2. The “Minority” population is the overall population minus white population. 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. All of the races noted in the table may include Hispanics.



### A facility

- level review of near source populations shows th re e areas contributing a total of 24 % to the African American sector

- wide total ; Graphic Packaging International Inc. (West Monroe Mill) = 11,580, KapStone Paper and Packaging Corp. (N. Charleston Mill) = 11,469, and GP

### 3 Cellulose LLC (Brunswick Mill) = 11,094 (34,143 / 139,782)

. T he area surrounding th ese facilit ies are predominantly minority (45%, 54% and 60% respectively) with Graph ic Packaging International Inc. (West Monroe Mill) also having a poverty rate of 21% near the source ( + 50% the national average of 14%). In the sector summary (table 2) we highlight the top three regions and states by number of facilities, and the top thre e facilities with the highest near source population totals.

Table 2

Sector Summary Totals

# of Facilities Near Source (3 mi) Population
99 774,898Top Three Regions
4 46 245,296
6 18 80,950
10 11 239,209
States

GA 11 63,959
AL 1 1 18,308
LA 8 51,554 Facilities

WA Simpson Tacoma Kraft Co. (Tacoma Mill) 72,697

OR International Paper Co. (Springfield Mill) 45,419

FL Rock

- Tenn CP LLC (Panama City Mill) 36,579

This table shows facility level totals where populations may be counted more than once if in proximity to m ore than one facilit y

.

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 1.2 times national averages for race, ethnicity and/or poverty demographic categories. 1 (The EPA acknowledges that areas with environmental justice

concerns may exist in areas below this threshold.) Analysis of this data shows 61 facilities with a near source population of 472,651 that are equal to, or exceed, this increased threshold. This is 6 2 % of all facilities, and 6 1 % of the near source population in the sector. The facility with the largest near source population in this subgroup is the Simpson Tacoma Kraft Co. (Tacoma Mill) , WA f acility with a total of 72,697 . The area surrounding this facility is comprised of 33 % minority ( + 20 % the national average of 28%)

. Table 3 provides a snapshot of the top three regions, states and facilities.

1 The demographic categories evaluated on whether they meet or exceed the threshold are: Minority Only; Hispanic Only; Poverty Only; Minority & Hispanic; Minority & Poverty; Hispanic & Poverty; Minority, Hispanic & Poverty.

### 4 Table 3

Potential Areas of Concern Summary Exceeding 20% Threshold Factor

# of Facilities Near Source (3 mi) Population
Sector 61 472,651Top Three Regions
4 36 188,054
6 16 76,697

10 4 153,578

States

GA 10 57,532
AL 9 10,800
LA 7 50,140 Facilities

WA Simpson Tacoma Kraft Co. (Tacoma Mill) 72,697

OR International Paper Co. (Springfield Mill) 45,419

FL Rock

- Tenn CP LLC (Panama City Mill) 36,579

Although Native American populations are factored into the minority demographic, the EPA reviews near source facility data to identify Native American populations that exceed the 1.2 threshold factor. Analysis of this data indicates 15 facilities with a co mbined Native American population of 7,269 meet or exceed this threshold in the sector. The largest Native American population (2, 575 ) is near the Simpson Tacoma Kraft Co. (Tacoma Mill) facility in Washington

. Additionally, the EPA provides a summary of “f acility clusters” (see next page). For the purposes of this report, facility clusters are formed when the study areas overlap, and a given census block can be attributed to one or more of the facilities. The following population totals are the combined nea r source populations for all facilities notated.

### 5 Cluster 1
Facilities in Cluster Facility ID Facility Name
NEI42338 Longview Fibre Paper Co. (Longview Mill)
NEI42341A Weyerhaeuser Co. (Longview Mill) Demographics Total population: 44,182 White population: 37,829 African American population: 372 Native American population: 925
Other and multi

- racial population: 5,056 Hispanic population: 4,447 Total minority population: 6,353 Population in poverty: 7,283 Population age 0 to 17: 10,397 Population age 18 to 64: 26,502 Population age 65 and up: 7,283 Number of adults 25 and over without a high school diploma: 4,083

Cluster 2
Facilities in Cluster Facility ID Facility Name
NEI33043 KPAQ

- St. Francisville
NEI46817 Georgia

- Pacific Corp. (Port Hudson Mill) Demographics Total population: 1,291 White population: 570 African American population: 695 Native American population: 4
Other and multi

- racial population: 22 Hispanic population: 20 Total minority population: 721 Population in poverty: 234 Population age 0 to 17: 365 Population age 18 to 64: 783 Population age 65 and up: 143 Number of adults 25 and over without a high school diploma: 159

### 6 Statistical Summary

The U.S. EPA provides the following statistical summary of tables 4, 5 and 6 to assist in answering the following questions:

1) On average, how much do populations living near the facilities differ from the U.S. population? 2) How often do the facilities have nearby populations greater than the national average?

While observations can be made on all demographic categories, this summary focuses o n the demographic categories of minority, Hispanic and below poverty. (Facilities with fewer than 100 residents living within 3 miles or 5 km are ignored.)

African American Population

o Table 4 indicates that nationally, 18 % of the people living within 3 mil es of the facilities are African American . This is 5 points, or 38 %
, greater than the national average of 13 % in 2010.

o Table 5 indicates that on average, 23% of the people living near a facility are African American

. The 10 point difference between the ave rage proportion near facilities and the national average is significant.

o Table 6 indicates that 5 3% of facilities have a greater proportion of African Americans living nearby than the national average. This is not significantly different from the 50% we wo uld expect if the facilities were randomly distributed across the U.S.

o Summary of the data : The national proportion (Table 4) and facility average proportion (Table 5) of African Americans are both greater than the national average, with Table 5 indicatin g a significant difference. Furthermore, 5 3% of the facilities have African American population s greater than the national average (Table 6). This suggests that the proportion of African American populations living near facilities is greater than the natio nal average, but there is a large amount of variability between individual facilities

. Age 65+ Population

o Table 4 indicates that nationally, 14 % of the people living within 3 miles of the facilities are age 65 or older . This is 1 point, or 8 %, greater than the national average of 1 3 % in 2010.

o Table 5 indicates that on average, 15 % of the people living near a facility are 65 or older . The 2 point difference between the average proportion near facilities and the national average is statistically signific ant.

o Table 6 indicates that 71 % of facilities have a greater proportion of those age 65 or older living nearby than the national average. This is significantly greater than the 50% we would expect if the facilities were randomly distributed across the U.S.

o Summary of the data : The national proportion (Table 4) and facility average proportion (Table 5) of age 65 or older are both greater than the national average, with Table 5 indicating a statistically significant difference. Furthermore, 71 % of the facili ties have people age 65 or older population s greater than the national average (Table 6). This suggests that the proportion of age 65 and older populations living near facilities is greater than the national average

. Below Poverty Population

o Table 4 indica tes that nationally, 1 5 % of the people living within 3 miles of the facilities are living b elow the poverty line. This is 1 point, or 7 %, greater than the national average of 14% in 2010.

### 7 o Table 5 indicates that on average, 17% of the people living near a f acility are living below the poverty line. The 3 point difference between the average proportion near facilities and the national average is statistically significant.

o Table 6 indicates that 71 % of facilities have a greater proportion of below poverty popu lations living nearby than the national average. This is significantly greater than the 50% we would expect if the facilities were randomly distributed across the U.S.



### o Summary of the data : The national proportion (Table 4) and facility average proportion (Table 5) of people below the poverty line are both greater than the national average, with Table 5 indicating a statistically significant difference. Furthermore, 71 % of the facilities have a below poverty population greater than the national average (Tab le 6). This suggests that the proportion of below poverty populations living near facilities is greater than the national
average



### .

### 8 Table 4 - Threshold Factor

POPULATION WHITE AFRICAN
AMERICAN NATIVE
AMERICAN OTHER OR
MULTIRACIAL MINORITY HISPANIC
OR LATINO AGE 0 - 4 AGE 0 - 17 AGE 65+ NO HIGH
SCHOOL
DIPLOMA BELOW
POVERTY

757,564 556,248 139,782 9,613 51,921 201,316 39,585 50,745 179,398 107,183 71,271 116,904 73% 18% 1% 7% 27% 5% 7% 24% 14% 9% 15% 312,861,256 226,405,205 39,475,216 3,646,995 43,333,840 86,456,051 54,181,245 20,465,068 75,217,176 40,830,262 32,060,510 43,616,850 72% 13% 1% 14% 28% 17% 7% 24% 13% 10% 14% >= 1.2 of National Average 1% 46% 9% -51% -4% -70% -2% 8% -8% 11%

Table 5 - Hypothesis Test 1 (Average Population Variance)

H 0 : Average % of Population Near Sources in Category X = National % in Categyory X
H 1 : Average % of Population Near Sources in Category X ≠ National % in Categyory X

WHITE AFRICAN
AMERICAN NATIVE
AMERICAN OTHER OR
MULTIRACIAL MINORITY HISPANIC
OR LATINO AGE 0 - 4 AGE 0 - 17 AGE 65+ NO HIGH
SCHOOL
DIPLOMA BELOW
POVERTY

72% 23% 1% 4% 28% 3% 6% 24% 15% 11% 17% 2.409% 2.465% 0.142% 0.307% 2.409% 0.381% 0.149% 0.425% 0.402% 0.430% 0.597%
-0.1067 4.1860 -1.8494 -31.9510 0.1067 -36.3037 -74.1366 -0.7674 5.5545 2.5967 5.8682 0.9153 < 0.0001 0.0675 < 0.0001 0.9153 < 0.0001 < 0.0001 0.4447 < 0.0001 0.0109 < 0.0001

Table 6 - Hypothesis Test 2 (Occurrence)

H 0 : % of Sources with Nearby Population in Category X above National Average = 50%
H 1 : % of Sources with Nearby Population in Category X above National Average ≠ 50%

WHITE AFRICAN
AMERICAN NATIVE
AMERICAN OTHER OR
MULTIRACIAL MINORITY HISPANIC
OR LATINO AGE 0 - 4 AGE 0 - 17 AGE 65+ NO HIGH
SCHOOL
DIPLOMA BELOW
POVERTY

57% 53% 19% 1% 43% 1% 44% 49% 71% 55% 71% 5.049% 5.093% 3.984% 1.036% 5.049% 1.036% 5.063% 5.102% 4.639% 5.075% 4.639%
1.4443 0.6136 -7.8446 -47.2467 -1.4443 -47.2467 -1.2344 -0.2042 4.4909 1.0262 4.4909 0.1519 0.5410 < 0.0001 < 0.0001 0.1519 < 0.0001 0.2201 0.8387 < 0.0001 0.3074 < 0.0001

STATISTICAL SIGNIFICANCE LEVEL No Significance (P >= 0.05) Marginal Significance (0.01 <= P < 0.05) Moderate Significance (0.001 <= P < 0.01) Strong Significance (P =< 0.001) DEMOGRAPHIC

SUMMARY

NEAR SOURCE TOTAL % OF NEAR SOURCE TOTAL
NATIONAL TOTAL % OF NATIONAL TOTAL

STATISTIC

AVERAGE % NEAR FACILITIES
STANDARD DEVIATION
T STATISTIC

P-VALUE

STATISTIC

% FACILITIES > NATIONAL AVG
STANDARD DEVIATION
T STATISTIC

P-VALUE

### 9 72%

13%

1% 14% 28%

17%

7% 24%

13% 10% 14% 87%

15%

1% 17% 33%

21%

8% 29%

16%
12% 17% 73%

18%

1% 7% 27%

5% 7% 24%

14%

9% 15% 72%

23%

1% 4% 28%

3% 6% 24%

15%

11% 17%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

WHITE AFRICAN AMERICAN NATIVE AMERICAN OTHER OR MULTIRACIAL MINORITY HISPANIC OR LATINO AGE 0

- 4 AGE 0

- 17 AGE 65+ NO HIGH SCHOOL DIPLOMA BELOW POVERTY LINE 

## Percentage Comparisons by Demographic Category

NATIONAL % NATIONAL % X 120% SOURCE CATEGORY TOTAL % SOURCE CATEGORY AVERAGE %

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