1

Pio Pico Energy Center

Proposed PSD Permit No. SD 11-01

Environmental Justice Analysis

June 2012

Introduction

Executive Order 12898, entitled “Federal Actions To Address Environmental Justice in 

Minority Populations and Low-Income Populations,” states in relevant part 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.” Section 1-101 of Exec. Order 12898, 59 Fed. Reg. 7629, (Feb. 16, 1994). 

“Federal agencies are required to implement this order consistent with, and to the extent 

permitted by, existing law.” Id. at 7632. Based on this Executive Order, the EPA’s 

Environmental Appeals Board (EAB) has held that environmental justice issues must be 

considered in connection with the issuance of federal Clean Air Act (CAA) Prevention of 

Significant Deterioration (PSD) permits issued by EPA Regional Offices and states acting under 

delegations of Federal authority. See, e.g., In re Prairie State Generating Company, 13 E.A.D. 

1, 123 (EAB 2006); In re Knauf Fiber Glass, GmbH, 8 E.A.D. 121, 174-75 (EAB 1999) (“Knauf 

I”). EPA Regional Offices or their delegates in the states have for several years incorporated 

environmental justice considerations into their review of applications for PSD permits. The EAB 

reinforced the importance of completing an environmental justice analysis in a recent opinion 

discussed further below. See In re: Shell Gulf of Mexico, Inc. and Shell Offshore, Inc., OCS 

Appeal Nos. 10-1 to 10-4, Slip Op. at 63-4 (EAB December 30, 2010) (“Shell II”).

EPA determined that there may be minority or low-income populations potentially 

affected by its proposed action on the Pio Pico Energy Center (PPEC or Project) PSD permit 

application, and determined that it would be appropriate to prepare an Environmental Justice 

Analysis for this action. EPA therefore prepared this Environmental Justice Analysis.

For purposes of the Executive Order on environmental justice, EPA has recognized that 

compliance with the applicable National Ambient Air Quality Standards (NAAQS) is 

emblematic of achieving a level of public health protection that demonstrates that EPA’s 

issuance of a PSD permit for a proposed facility will not have disproportionately high and 

adverse human health or environmental effects on minority populations and low-income 

populations. See, e.g., Shell II., slip op. at 74; In re Shell Offshore Inc., 13 E.A.D. 357, 404-5 

(EAB 2007) (“Shell I”); In re Knauf Fiber Glass, GmbH, 9 E.A.D 1, 15-17 (EAB 2000) (“Knauf 

II”); In re AES Puerto Rico, L.P., 8 E.A.D. 324, 351 (EAB 1999). This is because the NAAQS 

are health-based standards, designed to protect public health with an adequate margin of safety, 

including sensitive populations such as children, the elderly, and asthmatics. As the EAB 

recently observed, “[i]n the context of an environmental justice analysis, compliance with the 

NAAQS is emblematic of achieving a level of public health protection that, based on the level of 

protection afforded by the NAAQS, demonstrates that minority or low-income populations will 

not experience disproportionately high and adverse human health or environmental effects due to 

exposure to relevant criteria pollutants.” Shell II, Slip Op. at 73.
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The studies assessed by EPA in setting NAAQS and the integration of the scientific 

evidence presented therein have undergone extensive critical review by EPA, the Clean Air 

Scientific Advisory Committee (CASAC), and the public. See e.g., Primary National Ambient 

Air Quality Standards for Nitrogen Dioxide, Final Rule, 75 Fed. Reg. 6474, 6478 Feb. 9, 2010. 

“The rigor of the review makes these studies, and their integrative assessment, the most reliable 

source of scientific information on which to base decisions on the NAAQS.” Id. When setting 

the NAAQS, “[t]he Administrator’s final decisions draw upon scientific information and analysis 

related to health effects, population exposures, and risks; judgments about the appropriate 

response to the range of uncertainties that are inherent in scientific evidence and analyses; and 

comment received from CASAC and the public.” Id. at 6483. In light of these characteristics of 

the process for setting the standards, the EAB generally “relies on and defers to the Agency’s 

cumulative expertise when upholding a permit issuer’s environmental justice analysis based on a 

proposed facility’s compliance with the relevant NAAQS in a PSD appeal.” Shell II, Slip Op. at 

74. The NAAQS are also the underpinning for the State Implementation Plan process, which 

requires states to adopt rules and programs that will reduce emissions causing air pollution.

Pursuant to Clean Air Act section 165(a)(3), construction of a major emitting facility may 

not commence until the owner or operator of such facility demonstrates, among other things, that 

the facility will not cause or contribute to air pollution in excess of any NAAQS applicable to the 

PSD permit decision. 42 U.S.C. § 7475(a)(3); see also 40 C.F.R. §§ 52.21(k), 52.21(i)(2). With 

respect to the proposed PSD permit for the PPEC, EPA would regulate emissions affecting the 

following NAAQS: nitrogen dioxide (NO2) (1-hr and annual average), particulate matter 2.5 μm 

in diameter and smaller (PM2.5) (24-hr and annual), and particulate matter 10 micrometers (μm) 

in diameter and smaller (PM10) (24-hr). Several pollutants do not trigger PSD review as the 

Project’s potential emissions fall below the significant emissions rate for these pollutants,

including lead (Pb), sulfur dioxide (SO2), and carbon monoxide (CO)

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. EPA has determined that 

the proposed facility’s projected emissions will not cause or contribute to a violation of the 

applicable NAAQS. EPA has determined that compliance with the applicable NAAQS is 

sufficient to satisfy the Executive Order as to the pollutants regulated under the PSD program. 

Project Description and Regulatory Framework

Pio Pico Energy Center, LLC has applied to EPA Region 9 for authorization under the 

CAA PSD permitting program to construct a new power plant that will generate 300 megawatts 

(MW) of electricity using natural gas. The plant will be located in San Diego County, 

California, within the San Diego Air Pollution Control District (SDAPCD or District). The 

District is located within the San Diego air basin. The District’s jurisdiction begins in the south 

at the U.S./Mexico border and extends north to the Orange County line, east to the Riverside

County line, and west to the Pacific Ocean.

Under the CAA, new sources of pollutants for an area that has been designated 

attainment or unclassifiable are regulated under the PSD program. In addition, certain other 

 

1

The Project is not expected to emit lead. The Project’s potential SO2 emissions are estimated to be 4.1 tons per 

year (tpy), which is well below the 40 tpy significant emissions rate for SO2, and the Project’s potential CO 

emissions are estimated to be 96.4 tpy, below the 100 tpy significant emissions rate for CO. See 40 C.F.R. §§ 

52.21(b)(23)(i); 52.21(j)(2); 52.21(m)(1). 
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pollutants for which no NAAQS have been set are subject to regulation with a defined

applicability threshold under the PSD regulations. Within the District’s boundaries, the 

pollutants regulated under the PSD program and for which the proposed Project is either a major 

source or has the potential to emit in significant amounts include NO2, total particulate matter 

(PM), PM10, PM2.5, and greenhouse gases (GHG). These pollutants are addressed by the PSD 

permit for the Project. The emissions of other air pollutants from the proposed Project, including 

the pollutants for which the area is not meeting the NAAQS (and precursors that lead to the 

formation of such pollutants), are regulated by the District. The District implements the 

Nonattainment New Source Review (NNSR) permitting program for this area as required under 

the Clean Air Act and 40 CFR 51.160 to 51.165. The District is currently designated as an 

unclassified ozone non-attainment area under the 1997 0.080 parts per million (ppm) 8-Hour 

Ozone NAAQS Standard.

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 The non-attainment pollutants subject to non-attainment NSR 

permitting by the District include nitrogen oxides (NOx) and volatile organic carbons (VOC) as 

ozone precursors. However, PPEC will not be a major source of any nonattainment pollutant, 

and therefore requirements of nonattainment NSR, including Lowest Achievable Emission Rate 

(LAER) and emission offsets, do not apply to the Project. 3 Instead, the minor NSR permit 

issued by SDAPCD addresses both attainment and nonattainment pollutants, and on May 4, 

2012, the District issued a Final Determination of Compliance (FDOC) for the Project to address 

applicable NSR SIP requirements as well as other local permitting requirements. Also, the 

California Energy Commission (CEC) must issue a license to authorize construction of proposed 

power plants over 50 MW in size. The District and CEC approval processes are separate from 

EPA’s PSD permitting process.

The proposed Project will be comprised of three General Electric (GE) LMS100 natural 

gas-fired combustion turbine-generators (CTGs) with a total net generating capacity of 

approximately 100 megawatts each (MW, gross). The Project will be supplying peaking energy 

to San Diego Gas and Electric (SDG&E) under a 20-year purchase agreement. The GE LMS100 

natural gas-fired turbines were developed specifically for producing peak demand electrical 

needs, allowing the facility to meet and respond to variable demands. To meet Best Available 

Control Technology (BACT) requirements under the PSD permitting program, add-on pollution 

control technologies for the Project will include a selective catalytic reduction (SCR) system and 

water injection to reduce NOx emissions. The Project will also include an oxidation catalyst to 

reduce CO emissions; however, the oxidation catalyst is not required to meet BACT 

requirements under the PSD permit for the PPEC because CO is not regulated under this PSD

permit as explained above.

 

2 To date, the SDCAPCD has not been classified under the 1997 8-Hour Ozone NAAQS Standard, but during 2012, 

EPA intends to make a formal determination the area has attained the 1997 NAAQS. However, EPA recently 

designated San Diego as nonattainment for the newer and more stringent 2008 0.075 ppm NAAQS for ozone. 

Requirements related to the 2008 NAAQS are pending.

3 New source review in non-attainment areas is different from PSD review. Because a non-attainment area already 

has air quality that does not meet national health standards, and yet to preserve the ability for economic development 

to occur in those areas without exacerbating air quality and public health concerns, the CAA requires that sources 

seeking to build or expand in a non-attainment area must meet LAER and offset their anticipated new emissions by 

eliminating emissions of an equal, or depending on the severity of the non-attainment, greater amount. LAER 

requires a level of emissions reduction, through the use of control technology or other approaches, that is as or more 

stringent than BACT, which is required in attainment/unclassifiable areas. 
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The facility is expected to have emissions of pollutants regulated under the PSD program 

as shown in the following table.

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Table 1: Estimated Emissions and PSD Applicability

Pollutant Estimated Annual 

Emissions 

(tons/year)

Major Source 

Threshold 

(tons/year)

Significant 

Emission Rate 

(tons/year)

Does PSD 

apply?

CO 96.4 250 100 No

NO2 70.4 250 40 Yes

PM 37.2 250 25 Yes

PM10 37.2 250 15 Yes

PM2.5 37.2 250 10 Yes

SO2 4.1 250 40 No

Pb 0 250 0.6 No

H2SO4 3.4 250 7 No

GHG (in 

mass tons)

623,299 250 0 Yes

As mentioned above, BACT is required under the PSD permitting program. EPA’s proposed 

permit for the Project includes, among other requirements, the use of BACT to limit emissions of 

NOX, PM, PM10, PM2.5, and greenhouse gases, to the greatest extent feasible.

Demographics, Public Participation/Outreach Activities, and Air Quality in the Otay Mesa 

Area

Description of Local Area

The proposed Project would be located in San Diego County in an unincorporated area 

known as Otay Mesa. The proposed site is comprised of a 9.99 acre parcel of previously 

disturbed land located at 7363 Calzada de la Fuente, Otay Mesa, CA 92154 in the existing Otay 

Mesa Business Park. The site is already served by paved roads and other public utilities and is 

zoned for heavy and mixed industrial use, technology business park, and conservation uses, with 

heavy industrial being the major use. Existing site and land uses in the vicinity of the proposed 

Project include the Otay Mesa Generating Project (a natural gas-fired power plant) and two 

correctional facilities (the Richard J. Donovan Correctional Facility and the George F. Bailey 

 

4 While there is a NAAQS for lead, this facility is not expected to emit lead.
5

County Correctional Facility). The area is located approximately 21 miles (~33.8 km)5southeast 

of downtown San Diego and approximately 1.5 miles (~2.4 km) north of the U.S./Mexico 

border. 

The Project site is located within an industrial business complex, with the residential area 

nearest to the Project located approximately seven miles (11.3 km) west in Ocean Crest, a 

residential neighborhood in the southern section of San Diego. Based on available information, 

there are a few residences within a five mile (8.0 km) radius of the proposed facility, with the 

closest being approximately 1.6 miles (2.6 km) away. Other population centers located within 

San Diego County in the vicinity of the Project site include the City of Imperial Beach (13

miles/21.0 km west) with a population of 23,324, the City of Chula Vista (15 miles/24.1 km 

northwest) with a population of 243,916, National City (17 miles/27.4 km northwest) with a 

population of 58,582, and the City of San Diego (25 miles/40.2 km northwest) with a population 

of 1,307,402, as of the 2010 census. 

There are multiple Indian tribes located within the vicinity of the proposed Project. The 

Jamul Indian Village of California is located within a 15 km radius to the northeast of the Project

site. The Sycuan Band of the Kumeyaay Nation is located within a 25 km radius to the northeast 

of the Project. Tribal lands located within a 50 km radius include the Campo Band of the 

Kumeyaay Nation, the Viejas Band of the Kumeyaay Indians, the Capitan Grande Reservation, 

and the Barona Band of Mission Indians. Neighboring tribal lands located outside the 50 km 

radius include lands of the La Posta Band of Mission Indians, the Cuyapaipe Reservation, the 

Inaja and Cosmit Reservation, the Mesa Grande Band of Diegueno Mission Indians, and the 

Santa Ysabel Reservation.

Demographic Information

EPA's screening for potential environmental justice concerns focused on an area 

encompassed by a 25 km radius from the proposed facility. We chose this area to consider 

because our modeling analysis indicates that a 25 km radius includes the primary populations 

that may be impacted by emissions from the Project. However, because this large an area is 

much greater than typically considered for community level impacts, EPA also includes 

demographic information for areas closer to the proposed facility. Our analysis indicated that 

there are no residents living within a 2 km radius of the proposed Project. We included

demographic information for areas of 5 and 15 km radii for comparison. These areas are all 

encompassed within the County of San Diego. Thus, to compare health information, EPA will 

present metrics for both San Diego County and the State of California as a whole.

Demographic information is captured within four radii surrounding the proposed Pio Pico

Energy Center at 50, 25, 15, and 5 km6.

 

5 All distances are approximate.

6 U.S. Census Bureau, 2000 and 2010 Data; ESRI, 2012; TANA, 2006; Google, 2012.
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Table 2: Demographic Information for Proposed Project Location and 

Surrounding Areas

City/Area

Population

(2010 

Census)

Percent 

Minority

(2010 

Census)

Percent 

Under 

Age 18

(2010 

Census)

Percent 

Over 

Age 64

(2010 

Census)

Percent 

Linguistically 

Isolated

(2000 Census)7

Percent 

w/o High 

School 

Diploma

(2000 

Census)

Average 

Median 

Household 

Income, $

(2000 

Census)

5 km 9,568* 78.34 21.62 3.37 11.69 17.98 $69,779

15 km 276,728* 81.60 27.80 9.70 11.20 25.30 $52,762

25 km 660,853* 70.60 26.20 10.60 9.30 25.70 $41,305

50 km 1,183,062* 40.80 19.80 19.80 5.80 12.60 $52,268

Imperial 

Beach 23,324 64.00 25.40 9.00 5.68 23.08 $35,927

Chula 

Vista 243,916 79.60 27.90 10.00 9.27 21.49 $47,829

National 

City 58,582 88.30 25.50 10.60 21.13 42.98 $30,389

City of 

San Diego 1,307,402 54.90 21.40 10.7 8.13 17.22 $50,649

San Diego

County 3, 095,313 51.54 23.40 11.40 6.75 17.42 $51,621

State of 

CA 37,253,956 59.85 24.95 11.40 9.62 23.21 $52,719

* Population derived assuming uniform population distribution.

The three radii closest to the proposed facility (5, 15, and 25 km) capture populations 

above the state average for percent minority, while the population’s minority percentage 

decreases as distance from the Project increases (50 km from the proposed facility). The 5, 15 

and 50 km radii surrounding the proposed facility capture populations similar to or above the 

state average for median household income, while the median household income captured in the 

25 km radius is more than $10,000 below the state average.

Linguistic isolation limits a household’s capacity for civic engagement in the regulatory 

process. 8The two radii closest to the proposed facility capture households that are similar or 

slightly higher than the state average for linguistic isolation. Linguistic isolation decreases 

slightly with distance from the project (25 and 50 km). The percent of linguistically isolated 

households in the State of California is 9.62%, as compared with the percent of households 

located within 25 km of the Project, which is 9.30%. 

Education level is another factor that may influence susceptibility and vulnerability to air 

pollution. Limited formal education is a barrier to employment, health care and social resources, 

 

7

2010 U.S. Census data was not available for these metrics at the time of this analysis.

8

A linguistically isolated household is defined by the U.S. Census Bureau as a household in which no member 14 

years old and over (1) speaks only English or (2) speaks a non-English language and speaks English "very well." In 

other words, all members 14 years old and over have at least some difficulty with English. 
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and can increase the risk of poverty, stress, and impacts from environmental stressors. The

percent of the population over 25 years of age without a high school diploma within a 25 km 

radius of the Project (25.70%) is slightly higher than the state average of 23.21%. The percent of 

the population without a high school diploma decreases with respect to the population closest to 

the facility (17.98%).

Public Participation/Outreach Activities for EPA’s Proposed PSD Permit Decision

EPA is undertaking a number of actions to provide public participation opportunities to 

the community for its proposed PSD permit decision for the PPEC. 

In light of the Spanish-speaking population in the nearby community, EPA is issuing its 

public notice for the proposed PSD permit for the Project in both English and Spanish. The 

notice is being provided to the public through a wide variety of methods, including the 

following: posting on the EPA Region 9 website, publication in English in the San Diego Union 

Tribune, followed by an additional publication in Spanish in La Prensa San Diego; distribution to 

a mailing list of those who have requested to be notified by U.S. Mail of any actions related to 

the Project; and distribution by email to those who have requested to be notified by email. 

EPA’s proposed PSD permit for the Project, the accompanying fact sheet/ambient air 

quality impact report (Fact Sheet), and the Public Notice, will be available for review at the 

following locations: San Diego County Air Pollution Control District in San Diego, CA; San 

Ysidro Library in San Diego, CA; Otay Mesa-Nestor Library in San Diego, CA; Chula Vista 

Public Library, Civic Center Branch in Chula Vista, CA; National City Public Library in 

National City, CA; and San Diego Central Library in San Diego, CA. Key documents in EPA’s 

administrative record for the proposed PSD permit, including, among others, the permit 

application, the proposed PSD permit, and EPA’s Fact Sheet, are also available for public review 

on the EPA Region 9 website as well as at the EPA Region 9 Office in San Francisco, CA.

EPA has scheduled a public hearing for July 24, 2012 at the San Ysidro High School in 

San Ysidro, CA. The purpose of the public hearing is to provide the public with an additional 

opportunity to provide oral and/or written comments on EPA’s proposed PSD permit for the 

Project. EPA will be providing English-Spanish translation services at the public hearing. EPA 

has also prepared a public information sheet for distribution at the hearing that provides a brief 

overview of EPA’s proposed PSD permitting action for the Project. This handout has also been 

translated into Spanish and is available on the EPA Region 9 permit website: 

http://www.epa.gov/region9/air/permit/r9-permits-issued.html#part71.

Status of Air Quality in the Area

The District is designated as attainment or unclassifiable for PM10, PM2.5, NO2, CO, SO2, 

and lead. The District is also designated an unclassified ozone non-attainment area. As 

discussed above, the Project is not a major source of ozone or its precursors and does not trigger 

non-attainment New Source Review. The District’s FDOC, however, does addresses nonattainment pollutants, i.e., ozone precursors associated with the Project.
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Impact of Project’s Emissions on the NAAQS Applicable to the PSD Permit

EPA’s environmental justice analysis focuses on the potential effects on minority or low 

income populations from emissions that may affect the NAAQS that are applicable in the PSD 

review for the Project. Those are emissions potentially affecting the NAAQS for NO2 (1-hr and 

annual), PM2.5 (24-hr and annual), and PM10 (24-hr). As noted earlier, the potential emissions 

from the Project are below the significant emission rates for CO (1-hr and 8-hr average), SO2, 

and lead; thus, the Project is not subject to PSD review for those NAAQS.

EPA has determined from the modeled results for the Project that impacts are below the 

applicable NAAQS for the PSD pollutants regulated under the PSD permit, as follows: The 

modeled annual NO2 impact is 0.3 μg/m3, which is below the Significant Impact Level (SIL)9of 

1 μg/m3and therefore did not trigger a cumulative NAAQS analysis. The cumulative 1-hour 

NO2 impact is 179 μg/m3, as compared with the NAAQS of 188 μg/m3. The modeled 24-hour 

PM10 impact is 2.6 μg/m3, which is below the SIL of 5 μg/m3, and therefore did not trigger a 

cumulative NAAQS analysis. The cumulative 24-hour PM2.5 impact is 27.7 μg/m3, as compared 

with the NAAQS of 35 μg/m3. The modeled annual PM2.5 impact is 0.26 μg/m3, which is below 

the SIL of 0.3 μg/m3, and therefore did not trigger a cumulative NAAQS analysis. However, an 

annual PM2.5 analysis was done; the predicted annual impact is 14.4 μg/m3 compared with the 

NAAQS of 15 μg/m3.

 As stated above, the NAAQS are health-based standards and are designed 

to protect public health with an adequate margin of safety, including sensitive populations. 

Taking into account these modeled results in light of the health-based nature of the applicable 

NAAQS, EPA has determined that the proposed emissions for these pollutants from the PPEC 

will not result in disproportionately high and adverse human health or environmental effects on 

minority populations and low-income populations.

Table 3: PPEC Impacts as Compared with Significant Impact Levels

NAAQS pollutant & 

averaging time

Project-only 

Modeled Impact 

ug/m3

Significant Impact 

Level (SIL), μg/m3

Project impact 

significant?

NO2, 1-hr 111 (27) 7.5 (4 ppb) Yes

NO2, annual 0.3 1 No

PM10, 24-hr 3 5 No

PM2.5, 24-hr 2.6 1.2 Yes

PM2.5, annual 0.26 0.3 No

Sources: PSD Application Table 4-24, p.PSD 4-43pdf.152

 

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Projects with project-alone predicted impacts are required to do a cumulative impact analysis for comparison to 

NAAQS for that pollutant.
9

Table 4: PPEC Compliance with the NAAQS

NAAQS 

pollutant & 

averaging 

time

All 

Sources 

Modeled 

Impact

Background 

Concentration

Cumulative 

impact w/ 

background

NAAQS 

(ug/m3)

NO2, 1-hr 111 (hourly) 179 188 (100 

ppb)

PM2.5, 24-hr 0.7 27.0 27.7 35

PM2.5, annual 1.9 12.5 14.4 15

Sources:

NO2, PM2.5 (NAAQS): PSD Application Table 4-25, p. PSD-4.45 pdf154

PM2.5 (PSD increment): Letter from Sierra Research (S. Hill) to EPA (G. Rios) on modeling, December 2011

Pollutants for Which Area Exceeds Air Quality Standards

Although ozone is not regulated under EPA’s PSD permit for the Project, nor is the 

Project a major source of ozone precursors, we note as background that the District is designated 

an ozone non-attainment area. Scientific studies have linked ground-level ozone exposure to a 

variety of problems, including, for example, airway irritation, coughing, and pain when taking a 

deep breath; wheezing and breathing difficulties during exercise or outdoor activities; 

inflammation, which is much like a sunburn on the skin; aggravation of asthma and increased 

susceptibility to respiratory illnesses like pneumonia and bronchitis; and permanent lung damage 

with repeated exposures. 

With respect to ozone levels in San Diego County, EPA, the State of California, and the 

local air districts are working diligently through the air quality planning process under the CAA 

to ensure that there is a comprehensive plan with adequate controls for attaining and maintaining 

the 1997 0.080 ppm NAAQS for ozone. Based on the 2009 – 2011 monitoring data, the San 

Diego ozone nonattainment area is attaining the 1997 NAAQS for ozone. During 2012, EPA 

intends to make a formal determination the area has attained the 1997 NAAQS. However, EPA 

recently designated San Diego as nonattainment for the newer and more stringent 2008 0.075 

ppm NAAQS for ozone. Requirements related to the 2008 NAAQS are pending. Further, as 

noted above, the District’s FDOC includes provisions to address ozone precursors.

Conclusion 

Our analysis indicates that this Project will not cause or contribute to air quality levels in 

excess of health standards for the pollutants regulated under EPA’s proposed PSD permit for the 

Project, and that there will not be disproportionately high and adverse human health or 

environmental effects with respect to these air pollutants on minority or low-income populations 

residing near the proposed Project or the community as a whole. Nonattainment pollutants are 

addressed by the State and District Project approval and comprehensive air quality planning 

processes. We also note that our outreach strategy will make information related to our proposed 

action more accessible to nearby communities, including linguistically isolated populations that

are primarily Spanish speaking.