Overview of Environmental Justice(EJ) Analysis and AnalysisConducted for the Clean PowerPlanPublic Briefing forWeAct for Environmental JusticeSeptember 17, 2014General EJ Analysis Overview►The OAQPS addresses EJ in rulemakings by using a variety ofdifferentmethods and tools of varying degrees of sophistication, depending on theavailability of information and the results of preliminary evaluations.1.Qualitative / Narrative Statements – Used when unable to quantify affected populations or impactsdue to unknown or uncertain source locations, unclassifiable areas and/or impracticable etc.•Examples: Reciprocating Internal Combustion Engines (RICE), Grain Elevators2.Demographic Proximity Analyses – Identify populations and their socioeconomic makeup within aspecified distance (i.e., 3 miles) to a facility with comparative analysis to the national averages.•Tools: EJView and EJSCREEN (ArcGIS based)•Examples: Polyvinyl Chloride (PVC), Pulp and Paper3.Risk Based Demographic Analyses – Identify the socioeconomic makeup of the population withindifferent cancer and/or noncancer risk levels due to hazardous air pollutant exposures near thefacilities subject to a specific NESHAP.•Examples: RTR analyses such as Chromium Electroplating, Secondary Lead, Wool Fiberglass4.Risk Characterization (NAAQS pollutants) – Identifypopulations susceptible and vulnerable tocriteria air pollutant health impacts in the baseline; characterize the change in risk among thesepopulations; approach first applied in the DetroitMulti-pollutant Pilot Project and subsequentlyreceived favorable peer review in the journalRisk Analysis; methods are generally consistent withthose described by Joel Schwartz in his recentAmerican Journal of Public Healtharticles.•Tools:BenMAPandCMAQ•Example: Detroit multi-pollutant pilot project; CSAPR,MATsClean Power Plan EJ Analysis►EPA conducted a qualitative EJ analysis for this rulemaking►We conducted a qualitative analysis because the EPAcannot exactlypredict how emissions from specific EGUs would change as anoutcome of the proposed rule−due to state led implementation►Overall we found that this guideline would result in regional andnational pollutant reductions►There may be some locations with more times duringthe year ofrelatively higher concentrations of pollutants−thisis due to the factthat some EGUs may become dispatched more intensively than inthe past because they become more energy efficient►We have considered the potential for such increasesand theenvironmental justice implications of such increasesAppendixDemographic Proximity Analysis►Goal: to compare demographics ofpopulations near emissions sources to thedemographics of the whole U.S.►Census blocks - smallest areas for whichdemographics are available (about 50people on average).►Issue: Which census blocks are “near”emissions sources? (currently using 3 mileradius)►General Strategy:►Choose a “proximity radius” withinwhich nearby residents may beaffected by local emissions sources.►Count “near source” populations incensus blocks whose distance fromone or more emissions sources isless than the proximity radius.►Determine the demographiccomposition (e.g., race, income, etc.)of these census blocks and comparethem to the correspondingcompositions nationally.Example: Census blocks which would be counted inthis proximity analysis are highlighted in greyPulp and Paper (Proximity Results)The demographic data in the table below shows thatwhile most demographic categories arebelow or within 10 percent of their corresponding national averages, the African Americanpopulation percentage within 3 miles of any sourceaffected by this rulemaking exceeds thenational average by 3 percentage points (15 percentversus 12 percent), or +25 percent, andthose age 65+ exceed the national average by 2 percentage points (14 percent versus 12percent) or +17 percent.6Demographic SummaryNear SourceTotal% of Near SourceTotalNational Total% of NationalTotalPopulation 2,437,688 285,339,128White 1,929,157 79% 214,539,706 75%African American 365,07715%35,043,87312%Native American 20,449 1% 2,489,515 1%Other or Multiracial 123,005 5% 33,265,937 12%Minority 508,531 21% 70,799,422 25%Hispanic or Latino 78,804 3% 39,083,760 14%Age 0-17 604,248 25% 77,245,364 27%Age 65+ 343,43914%35,491,27412%No High School Diploma 314,843 13% 36,660,464 13%Below Poverty Line 353,183 14% 37,181,029 13%3 point difference =25% above Nat’l avg.Residual Risk Decision FrameworkGoals►Limit Maximum Individual Risk (MIR) for cancer to no higher than about100 in one million(MIR is the person exposed to maximum lifetime HAPconcentrations).►Protect the greatest number of persons to less thanone in one millionlifetime cancer risk.Step One►Determine what additional emission standards are neededto achieve“acceptable risk” of approximately100 in one millioncancer risk or less,including uncertainty and without consideration of costs.Step Two►Set standard to provide “ample margin of safety" considering all healthinformation and all other relevant factors (including chronic noncancerrisks, potential acute impacts of concern, costs/feasibility).7Risk and Technology Review (RTR)Risk-based Demographic Analyses►Identify the socioeconomic makeup of the populationwith significant cancer ornoncancer risks due to HAP exposures near the facilities subject to a specificNESHAP (case by case basis).Secondary lead smelting source category example:►Populations living around the 14 secondary lead smelters in the U.S. are a higherpercent minority than the nation as a whole►Baseline cancer risks•Of the 84,000 people currently exposed to cancer risks greater than one in a million from secondary leadsmelting emissions, about 40% are minorities (the general minority population nationwide is about 25% of thetotal population)•Compared to the national population, this at-risk group is also a higher percent Hispanic *(56% versus 14%)and a higher percent below the poverty level (22% versus 13%)►Baseline noncancer risks•The analysis estimates that 200 people live in areas near 3 secondary lead smelters that may currentlyexperience ambient lead concentrations above the National Ambient Air Quality Standard (NAAQS)–However, only 7% of this group is comprised of minority populations►After implementation of the proposed controls:•Proposed controls will result in nearly 60,000 fewer people exposed to cancer risks greater than one in a millionand no one experiencing ambient levels above the NAAQS, thus providing benefits to a population which has ahigher percent minorities than the national average8Characterizing Risk from NAAQS Pollutants►National Ambient Air Quality Standards are set to protect public health,including the health of at-risk populations, with an adequate margin ofsafety.►Recent NAAQS reviews identified children, older adults, persons with pre-existing diseasesand/or persons of lower social economic status (SES) as “at-risk” populations.►We use exposure factors and concentration-responsefunctions that characterize risk amongthese specific populations, to the extent that relevant information is available.►We can assess the health risks from criteria pollutants on susceptible andvulnerable populations in support of the NAAQS as wellas those rules thathelp implement the NAAQS.►For rules designed to help implement the NAAQS, EJ anddistributionalassessments generally try to answer two key questions:1.What is the baseline distribution of air pollutionrisk by race, ethnicity andincome?2.To what extent does the rule deliver air quality improvements among suchpopulations?9Example Criteria Pollutant Distributional Assessment:Cross-State Air Pollution RuleAmong populations living in countiesatgreatest risk*of air pollutionAmong populations living inall othercounties10*95thpercentileThe Cross-State Rule reduces the mortality burden the greatestamong highly susceptible populations, irrespective of raceThe Office of Transportation and Air Quality (OTAQ)►Regulatory office establishing emission standards and certificationfor:►Motor vehicles►Nonroad engines►Locomotive, ship, and airplane engines►OTAQ programs also include►Voluntary retrofit programs (National Clean DieselCampaign)►SmartWay Transport Partnership recognition programfor carriers and shippersthat reduce emissions11Environmental Justice in the Office ofTransportation and Air Quality (OTAQ)►Over last 10-15 years, hundreds of health studies on near-road airpollution have been published.►In the 2009 American Housing Survey, 17% of U.S. housing unitswere within 300 feet of a highway with 4 or more lanes, railroad, orairport.►Over 20 million homes►Populations living near roads, rail yards, and marine ports, plusschools near major roads are disproportionately nonwhite and lowerin income.12OTAQ Rulemaking Analysis Examples►Literature reviews►Statistical analyses usinggeographic informationsystems (GIS)►Demographic analyses of U.S.government databases►2000 and 2010 Census►American Housing Survey(Census Bureau)►Common Core of Data (Dept.of Ed.)►Air quality modeling►Roadways►Rail yards►Ports (example shown)►AirportsDiesel PM Concentration Around Port of Baltimore, MDLocomotive / Marine Rule Analysis