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MEMORANDUM

To: PVC NESHAP Docket

From: Tina Ndoh, US EPA

Date: September 9, 2010

Subject: Review of Environmental Justice Impacts: Polyvinyl Chloride

1.0 INTRODUCTION

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes Federal 

executive policy on environmental justice (EJ). Its main provision directs Federal agencies, to 

the greatest extent practicable and permitted by law, to make environmental justice part of their 

mission by identifying and addressing, as appropriate, disproportionately high and adverse 

human health or environmental effects of their programs, policies, and activities on minority 

populations and low-income populations in the United States.

EPA defines “Environmental Justice” to include meaningful involvement of all people 

regardless of race, color, national origin, or income with respect to the development, 

implementation, and enforcement of environmental laws, regulations, and polices. To promote 

meaningful involvement, EPA has developed a communication and outreach strategy to ensure 

that interested communities have access to this proposed rule, are aware of its content, and have 

an opportunity to comment during the comment period. During the comment period, EPA will 

publicize the rulemaking via EJ newsletters, Tribal newsletters, EJ listservs, and the internet, 

including the Office of Policy, Economics, and Innovation’s (OPEI) Rulemaking Gateway 

website (http://yosemite.epa.gov/opei/RuleGate.nsf/). EPA will also provide general rulemaking 

fact sheets (e.g., why is this important for my community) for EJ community groups and conduct 

conference calls with interested communities. In addition, state and federal permitting 

requirements will provide state and local governments and members of affected communities the 

opportunity to provide comments on the permit conditions associated with permitting the sources 

affected by this rulemaking.
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2.0 DEMOGRAPHICS

EPA has determined that this proposed rule will not have disproportionately high and 

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

increases the level of environmental protection for all affected populations without having any 

disproportionately high and adverse human health or environmental effects on any population, 

including any minority or low-income populations. Additionally, the Agency has reviewed this 

proposed rule to determine if there are existing disproportionately high and adverse human 

health or environmental effects on minority or low-income populations that could be mitigated 

by this rulemaking. An analysis of demographic data shows that the average percentage of 

minorities, percentage of the population below the poverty level, and the percentage of the 

population 17 years old and younger, in close proximity to the sources, differ from the national 

averages by 3%, 1.8%, and 1.7%, respectively, at the 3-mile radius of concern. These 

differences in the absolute number of percentage points from the national average indicate a 

9.4%, 14.4%, and 6.6% over-representation of minority populations, populations below the 

poverty level, and the percentages of the population 17 years old and younger, respectively.

Table 2.1 Summary of Demographic Data Analysis

In determining the aggregate demographic makeup of the communities near affected 

sources, EPA used census data at the block group level to identify demographics of the 

populations considered to be living near affected sources, such that they have notable exposures 

to current emissions from these sources. In this approach, EPA reviewed the distributions of 

different socio-demographic groups in the locations of the expected emission reductions from 

this rule. The review identified those census block groups within a circular distance of a half, 3, 

Categories

Miles 

Radius

Total 

Number 

of Block 

Groups

Minority 

Population

Average 

of 

Percent

Minority

Population 

Living Below 

Poverty 

Level

Average of 

Percent

Population 

Below 

Poverty 

Level

Population 

<18 Years 

Old

Average of 

Percent 

Children

<18 Years 

Old

National -

All 

categories

210, 537 71,000,000 33 36,000,000 13 73,000,000 26

PVC 0.5 1 40 5 39 4 233 26

PVC 3 106 55,000 35 20,000 14 42,000 27

PVC 5 343 213,000 38 69,000 14 155,000 28
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and 5 miles of affected sources and determined the demographic and socio-economic 

composition (race, income, age) of these census block groups. The radius of 3 miles (or 

approximately 5 kilometers) has been used in other demographic analyses focused on areas 

around potential sources.1,2,3,4 Minority populations include American Indians, AfricanAmericans, Hispanics, Other and Multi-racial as indicated in census data. 

 

1 U.S. GAO (Government Accountability Office). Demographics of People Living Near Waste Facilities. Washington 

DC: Government Printing Office; 1995.

2 Mohai P, Saha R. “Reassessing Racial and Socio-economic Disparities in Environmental Justice Research”. 

Demography. 2006;43(2): 383–399.

3 Mennis J. “Using Geographic Information Systems to Create and Analyze Statistical Surfaces of Populations and 

Risk for Environmental Justice Analysis”. Social Science Quarterly, 2002;83(1):281-297.

4 Bullard RD, Mohai P, Wright B, Saha R, et al. Toxic Waste and Race at Twenty 1987-2007. United Church of Christ. 

March, 2007.