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 hi gher 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 l iving 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 Sp rings 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% multiraci al (vs. 3.9% for the entire city ).

The area close to the plant is also poor er 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 c ity) 48.9% of working age population earns less than $25,000 /yr ( vs. 24.1% for the entire c ity) 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 residen ts living with three miles of the plant, theiraverage income, and percent of people of color. The study ranked Martin Drake as the 26th worst

performing plant in the nation in terms of environmental justice based on the facts that it emitted a yearly

ave rage 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 disproportion ate 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 r esearch from yet another credible source shows that within a one

- mile radius of the Martin Drake plant the popu lation 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 Just ice

- 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 add ressing, 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 [NE PA].” We point out here the environmental injustice of this aging plant's continued operation.

Low

- income populations within a th ree

- mile radius are directly affected by the continued operation of an outdated and environmentally hazardous Martin Drake c oal 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 fig ht 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 matt er.

Respectfully Submitted,

Sam Masias, Nicole Rosa, Jacquie OstromSources



### ● 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. Marti n Drake Power Plant. http://www.sourcewatch.org/index.php/Martin_Drake_Power_Plant

. 

### ● EPA Enforcement & Compliance History Online (ECHO), Detailed Facility Report for Martin Dra ke, 11/15/12. Particularly section on Demographic Profile of Surrounding Area. www.epa

echo.gov/cgi

- bin/get1cReport.cgi?tool=echo&IDNumber=110009559637

. 

### ● EP A, 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, Sta tistics 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 pop ulation, 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 Compariso n. 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&featty pe=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. Ta ble 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, Geograp hic 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

- Springs

Colorado.html



### Bounding from N, E, S, W (Clockwise) Population Median Household Income Unemployment Residents below the Poverty L evel (US Census Bureau) Motor City, Ramona, S. 8 th 

### (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%