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OAQPS ENVIRONMENTAL JUSTICE ANALYTICAL TEAM REPORT

RULE / ACTION

Pulp and Paper

OBJECTIVE

This report aids rule writers in drafting required environmental justice preamble language for 

E.O. 12898, as well as addressing the Agency’s three Final Agency Review (FAR) EJ questions:

(1) How did your public participation process provide transparency and meaningful participation 

for minority, low-income, and indigenous populations, and tribes?

(2) How did you identify and address existing and new disproportionate environmental and 

public health impacts on minority, low-income, and indigenous populations, and tribes?

(3) How did actions taken under #1 and #2 impact the outcome or final decision? 

SCOPE

 Total # of unique facility locations = 174

 Data Source: ICR (contact Jim Hirtz)

EJ ASSESSMENT

Meaningful Involvement (FAR question #1)

To promote meaningful involvement, EPA has held public webinars 

(www.epa.gov/air/ej/announce.html) and held discussions during its 2011 Environmental 

Justice Conference. Stakeholder meetings were also held with Sierra Club, Earth Justice, and 

with organizations that participated in EPA Environmental Justice outreach efforts. Further 

stakeholder and public input is expected through public comment and follow-up meetings with 

interested stakeholders.
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Demographic Results (FAR question #2)

Method(s)

 Proximity-to-Source: Comparative analysis of 3 mile or 5 km radius demographics to 

national averages. 

Source(s)

 CenRANK (proximity)

Proximity-to-Source 

The sector-wide analysis of near source populations reveals that while most demographic 

categories are below or within 10 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 3 percentage points (15 percent versus 12 percent), or +25 

percent, and those age 65+ exceed the national average by 2 percentage points (14 percent 

versus 12 percent) or +17 percent. 

Table 1

A facility-level review of near source populations shows that the densely populated area 

surrounding the Wisconsin Paperboard Corp., WI facility is a main contributor to the African 

American total with 69,292, or 19%, of the total Pulp and Paper sector African American 

population (69,292 / 365,077). Other locations making significant contributions to the sector’s 

total African American population are Rock-Tenn Company Mill Division Inc., OH (37,416), 

Newman & Company, PA (30,480) and PaperWorks Industries Inc., PA (20,630). The four areas 

combined make up 43% of the sector’s total African American population (157,818 / 365,077). 

Additionally, the Wisconsin Paperboard Corp., WI area has a high percentage of people living

below the poverty line at 30%, which is 17 percentage points above the national average of 

13%, or +131%. In the sector summary (table 2) we highlight the top three regions and states by 

number of facilities, and the top three facilities with the highest near source population totals. 

The excel file that accompanies this report contains the near source demographic data for all 

facilities.

POPULATION1 WHITE

AFRICAN 

AMERICAN

NATIVE

AMERICAN

OTHER OR 

MULTIRACIAL MINORITY1

HISPANIC OR 

LATINO2 AGE 0 - 17 AGE 65+

NO HIGH 

SCHOOL 

DIPLOMA

BELOW 

POVERTY 

LINE

2,437,688 1,929,157 365,077 20,449 123,005 508,531 78,804 604,248 343,439 314,843 353,183

79% 15% 1% 5% 21% 3% 25% 14% 13% 14%

285,339,128 214,539,706 35,043,873 2,489,515 33,265,937 70,799,422 39,083,760 77,245,364 35,491,274 36,660,464 37,181,029

75% 12% 1% 12% 25% 14% 27% 12% 13% 13%

Sources: The demographics are from the U.S. Census Bureau, 2000. Information on the facilities is from U.S. EPA.

1. Racial and ethnic categories overlap and cannot be summed..

2. The “Minorities” population is the overall population (in the first column) minus white population (in the second column).

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.

DEMOGRAPHIC 

SUMMARY

NEAR SOURCE TOTAL

NATIONAL TOTAL

% OF NEAR SOURCE TOTAL

% OF NATIONAL TOTAL
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Table 2

Sector Summary

Totals

# of Facilities Near Source (3 mi) 

Population

Sector 174 2,437,688

Top Three

Regions

4 60 388,546

5 43 1,011,870

6 19 103,226

States

WI 22 490,785

GA 16 110,963

AL 12 22,335

Facilities

PA NEWMAN & COMPANY 230,474

WI WISCONSIN PAPERBOARD CORP 148,451

OH ROCK-TENN COMPANY MILL DIVISION 

INC 118,269

To evaluate potential areas of environmental justice concern, the EPA highlights the near 

source areas that are equal to or exceed a threshold factor of 1.25 times national averages for 

race, ethnicity and/or poverty demographic categories.1(The EPA acknowledges that 

environmental justice areas may exist in areas below this threshold.) Analysis of this data shows

71 facilities with a near source population of 855,587 that are equal to, or exceed, this 

increased threshold. This is 41% of all facilities, and 35% of the near source population in the 

sector. The facility with the largest near source population in this subgroup is the Wisconsin 

Paperboard Corp. facility with a total of 148,451. The area surrounding this facility is comprised 

of 54% minority (+116% the national average of 25%), and 30% of people living below the 

national poverty line (+131% the national average of 13%). Table 3 provides a snapshot of the 

top three regions, states and facilities.

Table 3

Potential 

Areas of 

Concern 

Summary

Exceeding Threshold Factor

# of Facilities Near Source (3 mi) Population

Sector 71 855,587

Top Three

Regions

4 39 275,336

6 14 86,064

10 6 110,593

States

GA 11 92,388

AL 11 15,384

LA 6 50,832

Facilities

 

1 The demographic categories evaluated on whether they meet or exceed the threshold are: Minority Only; Hispanic 

Only; Poverty Only; Minority & Hispanic; Minority & Poverty; Hispanic & Poverty; Minority, Hispanic & Poverty. 
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WI WISCONSIN PAPERBOARD CORP 148,451

OH ROCK-TENN COMPANY MILL DIVISION INC 118,269

WA SIMPSON TACOMA KRAFT CO LLC 68,557

Additionally, the EPA provides a summary of “facility clusters.” For the purposes of this report, 

a facility cluster is defined as an area where multiple facilities are in close proximity to each 

other such that the study areas overlap, and a census block can be attributed to one or more 

facilities. The following population totals are the combined near source populations for all 

facilities notated.

Facility Clusters 

Four facility clusters

o Georgia Pacific Consumer Products LP - Green Bay Broadway Mill, WI + 

Thilmany Papers Nicolet Mill, WI +

Green Bay Packaging Inc- Green Bay Mill, WI +

Georgia Pacific Consumer Products LP - Green Bay Day Street Mill, WI = 127,855 total

population

o [Three] NewPage Wisconsin Systems Inc, WI + 

NewPage Corp - Biron Mill, WI = 21,999

Three facility cluster

o Longview Fibre paper & Packaging Inc., WA +

Weyerhaeuser Co., WA +

North Pacific Paper Corporation (NORPAC) (Longview Mill), WA = 43,3292

Two facility clusters (Seven areas - see excel file)

Charge to Project Lead (FAR question #3)

How did actions taken under [FAR questions] #1 and #2 impact the outcome or final decision? 

 

2 This cluster has one or more facilities exceeding the 1.25 * national average threshold.