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MEMORANDUM

To: Kraft Pulp Mills Docket (EPA-HQ-OAR-2012-0640)

From: Kelley Spence, Office of Air Quality Planning and Standards, 

U.S. Environmental Protection Agency 

Date: September 18, 2012

Subject: Environmental Justice Review: Kraft Pulp Mills NSPS

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.

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 the 

decision making process 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.

2.0 DEMOGRAPHICS

EPA has concluded that it is not practicable to determine whether there would be 

disproportionately high and adverse human health or environmental effects on minority, low 

income, or indigenous populations from this proposed rule as it is unknown where new facilities 

will be located. However, the Agency has reviewed the areas surrounding existing facilities 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. 

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

conducted a demographic analysis on the source category for this rulemaking. This analysis only 

gives some indication of the prevalence of subpopulations that may be exposed to air pollution 

from the sources and, therefore, would be those populations that may be expected to benefit most 

from this regulation; 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. 
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The demographic data in Table 1 shows that while most demographic categories are below or 

within 20 percent of their corresponding national averages, the African American population 

percentage within 3 miles of any source affected by this rulemaking exceeds the national average 

by 5 percentage points (18 percent versus 13 percent), or +38 percent.

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 were based on demographic information at the census 

block level, and all other demographic groups were 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 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, 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. 

 

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.
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Table 1. Summary of Demographic Analysis for Kraft Pulp Mills

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.