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OAQPS ENVIRONMENTAL JUSTICE SUMMARY REPORT

RULE / ACTION

Kraft Pulp Mills NSPS

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 = 99

• Data Source: ICR (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. 
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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 demographic 

categories exceed 20 percent of the corresponding national average:

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

Table 1

DEMOGRAPHIC 

SUMMARY1

NEAR SOURCE 

TOTAL

% OF NEAR 

SOURCE 

TOTAL

NATIONAL TOTAL % OF NATIONAL 

TOTAL

POPULATION 757,564 312,861,256

WHITE 556,248 73% 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%

MINORITY2 201,316 27% 86,456,051 28%

HISPANIC OR LATINO3 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 15% 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 facility 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 three 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 
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Cellulose LLC (Brunswick Mill) = 11,094 (34,143 / 139,782). The area surrounding these 

facilities are predominantly minority (45%, 54% and 60% respectively) with Graphic 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 three facilities with the highest near source population totals.

Table 2

Sector Summary

Totals

# of Facilities Near Source (3 mi) 

Population

99 774,898

Top Three

Regions

4 46 245,296

6 18 80,950

10 11 239,209

States

GA 11 63,959

AL 11 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 more than one facility.

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 62% of all 

facilities, and 61% 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 facility 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. 
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 Table 3

Potential Areas of 

Concern Summary

Exceeding 20% Threshold Factor

# of Facilities Near Source (3 mi) 

Population

Sector 61 472,651 Top 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 combined 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 “facility 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 near source 

populations for all facilities notated.
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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
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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 on 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 miles 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 average proportion near facilities and the national average 

is significant.

o Table 6 indicates that 53% of facilities have a greater proportion of African Americans living 

nearby than the national average. This is not significantly different from 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 African Americans are both greater than the national average, with Table 5 indicating a 

significant difference. Furthermore, 53% of the facilities have African American populations

greater than the national average (Table 6). This suggests that the proportion of African 

American populations living near facilities is greater than the national 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 13% 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 significant.

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 facilities have people age 65 or older

populations 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 indicates that nationally, 15% of the people living within 3 miles of the facilities are living 

below the poverty line. This is 1 point, or 7%, greater than the national average of 14% in 2010.
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o Table 5 indicates that on average, 17% of the people living near a facility 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 populations 

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 (Table 6). This suggests that the 

proportion of below poverty populations living near facilities is greater than the national 

average.
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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)

H0: Average % of Population Near Sources in Category X = National % in Categyory X

H1: 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)

H0: % of Sources with Nearby Population in Category X above National Average = 50%

H1: % 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
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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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