To: Adam Clark, Carl Daly, Monica Morales - US EPA Region 8

1595 Wynkoop St. (8P-AR)

Denver, CO 80202-1129

(303) 312-7104

From: City of Colorado Springs Residents

Sam Masias, Jacquie Ostrom, Nicole Rosa

Date: January 27, 2016

Subject: Environmental Justice Considerations of the Martin Drake Coal Fired Power Plant 

We have studied the demographics of the community surrounding the Martin Drake coal fired 

power plant in the heart of Colorado Springs downtown and we find a higher percentage of minority 

population, lower education levels and high levels of poverty than that compared with the population of 

the entire city. In addition the health impacts of this plant are being disproportionately visited upon the 

78,101 people living within a three mile radius of it (the distance usually studied for increased pollution 

impacts).

Census statistics show the people living within a one-mile radius the Drake plant, represent a 

higher percentage of minority population than Colorado Springs as a whole. This area is 

16.8% Hispanic origin (versus 12% for the entire city) 

7.2% African American (vs. 6% for the entire city) 

2% American Indian (vs. .9% for the entire city), and

7.3% multiracial (vs. 3.9% for the entire city). 

The area close to the plant is also poorer and less educated. Within one-mile of the Martin Drake plant 

the community is: 

29.4% below the poverty level (vs. 8.7% for the entire city) 

48.9% of working age population earns less than $25,000 /yr (vs. 24.1% for the entire city) 

20.1% have no high school diploma (9.1% for the entire city).

Within a three-mile radius of the Martin Drake plant the population is: 

14.5% Hispanic origin (12% for the entire city), 

25.2% are below the poverty level (8.7% for the entire city), 

36% of working age residents earn <less than $25,000 per year (vs. 24.1% for the city), 

15% have no high school diploma (vs. 9.1% for the entire city).

In an NAACP report that came out in late 2012, the Martin Drake plant was listed as one of 75 

plants that received an “F” grade for social justice when being evaluated for environmental justice 

performance of coal fired power plants that generate over 100 MW of power each year. The evaluation 

considered SO2 and NOx emissions, the number of residents living with three miles of the plant, their 
average income, and percent of people of color. The study ranked Martin Drake as the 26th worstperforming plant in the nation in terms of environmental justice based on the facts that it emitted a yearly 

average of 7,658 tons of SO2 and 4,192 tons of NOx and that the community of 78,101 people who live 

within three miles of the plant and have an average income of $20,905 and is comprised of 26.6% people 

of color.

This population is experiencing disproportionate deadly and costly health impacts. The Clear Air 

Task Force, using well-established and extensively peer-reviewed methodology approved by the US 

EPA’s Science Advisory Board and the National Academy of Sciences, reported in 2010 on power plant 

pollution assessed death and disease caused by coal fired power plants. Using that same methodology, 

the Clean Air Task Force estimates that the Martin Drake plant caused 8 deaths, 13 heart attacks 160 

asthma attacks, 8 asthma ER visits, 6 hospital admissions and 6 cases of chronic bronchitis a year, at an 

estimated cost of $65 million per year (2010 dollars).

Our additional recent research from yet another credible source shows that within a one-mile 

radius of the Martin Drake plant the population of 6,940 are 24.2% below the poverty level (vs. 8.7% for 

the whole community) and 13.2% are unemployed (vs. 5.2% for the whole community). Additional detail 

concerning this data can be found in the table below. 

According to the EPA Document titled "Environmental Justice - Guidance Under the National 

Environmental Policy Act" published by the Council on Environmental Quality, by Executive Order it is 

required that “each Federal agency shall make achieving environmental justice part of its mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of its programs, policies, and activities on minority populations and low-income 

populations.” The President has emphasized the importance of this mandate by stating that “each Federal 

agency shall analyze the environmental effects, including human health, economic and social effects, of 

Federal actions, including effects on minority communities and low-income communities, when such 

analysis is required by [NEPA].” We point out here the environmental injustice of this aging plant's 

continued operation.

Low-income populations within a three-mile radius are directly affected by the continued 

operation of an outdated and environmentally hazardous Martin Drake coal plant. These are citizens who 

are struggling with day to day economic survival who don't have the resources to know what's happening 

to them or why they have associated health issues with their lungs and hearts and don't have the time or 

energy to fight the polluting plant so very close to their homes. By definition the EPA is required to 

examine the Martin Drake plant through the lens of Environmental Justice in order to protect these 

citizens. Thank you for your consideration of this important matter.

Respectfully Submitted,

Sam Masias,

Nicole Rosa,

Jacquie Ostrom
Sources

● NAACP, Little Village Environmental Justice Organization, Indigenous Environmental Network 

and Adrian Wilson. “Coal Blooded: Putting Profits Before People.” NAACP, 2012. Web. 

December 2012 http://www.naacp.org/pages/coal-blooded1.

● Conrad Schneider and Jonathan Banks, Clean Air Task Force. “The Toll from Coal, An Updated 

Assessment of Death and Disease from America’s Dirtiest Energy Source.” September 2010.

● SourceWatch. Coal Issues. Martin Drake Power Plant. 

http://www.sourcewatch.org/index.php/Martin_Drake_Power_Plant.

● EPA Enforcement & Compliance History Online (ECHO), Detailed Facility Report for Martin 

Drake, 11/15/12. Particularly section on Demographic Profile of Surrounding Area. www.epaecho.gov/cgi-bin/get1cReport.cgi?tool=echo&IDNumber=110009559637.

● EPA, EJ View, Statistics represent residential population, by 2000 census block group, within a 1 

mile buffer of feature of interest (Martin Drake). December 6, 2012. 

http://oaspub.epa.gov/envjust/env_just_ejv.get_geom?report_type=html&census_type=bg2k&p_cal

ler=self&coords=-104.831360,38.822450&feattype=point&radius=1.0

● EPA, EJ View, Statistics represent residential population, by 2000 census block group, within a 3 

mile buffer of feature of interest (Martin Drake). 

http://oaspub.epa.gov/envjust/env_just_ejv.get_geom?report_type=html&census_type=bg2k&p_cal

ler=self&coords=-104.831360,38.822450&feattype=point&radius=3.0.

● EPA, EJ View, Statistics represent residential population, by 2000 census block group, within a 5 

mile buffer of feature o f interest (Martin Drake). December 6, 2012. 

http://oaspub.epa.gov/envjust/env_just_ejv.get_geom?report_type=html&census_type=bg2k&p_cal

ler=self&coords=-104.831360,38.822450&feattype=point&radius=5.0.

● EPA, Environmental Justice, EJ View, County and State Comparison. 

11/24/12.http://oaspub.epa.gov/envjust/demog_report_2_ejv.doCountyStateComp. 

http://oaspub.epa.govenvjust/env_just_ejv.get_geom?report_type=html&census_type=bg2k&p_call

er=self&

● EPA Toxic Release Inventory (TRI), Envirofacts Report for Martin Drake, 11/15/12. 

http://oaspub.epa.gov/enviro/tris_control.tris_print?tris_id=80903MRTND700SC.

● EPA, EJ Screening Level Tool, Tier I Report for Martin Drake. December 6, 2012. 

http://ofmpub.epa.gov/envjust/ej_prioritization_report_ejv.get_report?fac_uin=110009559637&p_r

ace=25.57&p_engltw=3.7&p_income=9.26.

● EPA, EJView Census 2010 Summary Report. December 6, 2012. 

http://epamap14.epa.gov/ejmap/demog2010report.aspx?coords=-

104.83136,38.82245&feattype=point&radius=.5.

● EPA, EJView ACS Summary Report. December 6, 2012. 

http://epamap14.epa.gov/ejmap/acsreport.aspx?coords=-

104.83136,38.82245&feattype=point&radius=.5.

● U.S. Bureau of the Census, Census 2000. Table DP-1 Profile of General Demographic 

Characteristics: 2000, Geographic area: El Paso County, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-2 Profile of Selected Social Characteristics: 

2000, Geographic area: El Paso County, Colorado.
● U.S. Bureau of the Census, Census 2000. Table DP-3 Profile of Selected Economic 

Characteristics: 2000, Geographic area: El Paso County, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-4 Profile of Selected Housing Characteristics: 

2000, Geographic area: El Paso County, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-1 Profile of General Demographic 

Characteristics: 2000, Geographic area: Colorado Springs, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-2 Profile of Selected Social Characteristics: 

2000, Geographic area: Colorado Springs, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-3 Profile of Selected Economic 

Characteristics: 2000, Geographic area: Colorado Springs, Colorado.

● U.S. Bureau of the Census, Census 2000. Table DP-4 Profile of Selected Housing Characteristics: 

2000, Geographic area: Colorado Springs, Colorado.

● City Data in table below at http://www.city-data.com/income/income-Colorado-SpringsColorado.html

Bounding 

from N, E, S, W (Clockwise)

Population Median 

Household 

Income

Unemployment Residents below the 

Poverty Level

(US Census Bureau)

Motor City, Ramona, S. 8th

(SE of Drake) 1,121 $37,431 11.1% 12.3%

Cimarron, I-25, Motor City, 

S. 8th St.

(W. of Drake) 963 $49,552 11.0% 16.0%

Ramona, Woodburn, 

Cheyenne Rd, 8th St. 

(SW of Drake) 1,946 $52,872 11.0% 16.0%

Boulder, Wahsatch, 

Cimarron, I-25 

(NE of Drake) 730 $9,816 18.8% 31.8%

Cimarron, Wahsatch, I-25 

(E. of Drake) 1,059 $22,972 18.8% 43.5%

Average / Summary: 5,819 $29,669 13.2% 24.2%