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MEMORANDUM

To: Docket ID No. EPA-HQ-OAR-2012-0133

From: Nick Parsons, US EPA

Date: December 11, 2013

Subject: Environmental Justice Review: Amino/Phenolic Resins, Acrylic and Modacrylic 

Fibers Production, and Polycarbonate Production

1.0 INTRODUCTION

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

policy on environmental justice. 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. A key 

element of environmental justice is ensuring that all people have an opportunity for meaningful 

involvement in decision-making. Certain groups may not have participated in decision making 

historically because of economic (e.g., income), social (e.g., language barriers, education levels, 

distrust of government), and structural reasons. A critical concern is whether, and the extent to 

which, communities have the ability to influence the types and number of regulated activities 

taking place in their community, as well as the requirements, conditions, and parameters by 

which they must operate (e.g., permit conditions).

The EPA aims to notify and engage the public in a variety of ways. Each rule is reviewed 

to identify the appropriate methodology and meaningful involvement may consist of one or more 

of the following: notices on the EJAir website, community call discussions, fact sheets, 

community meetings, and/or webinars. A fact sheet for the proposed risk and technology review 

of the National Emission Standards for Hazardous Air Pollutants: Amino/Phenolic Resins, 
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Acrylic and Modacrylic Fibers Production, and Polycarbonate Production will be posted on the 

EPA’s Technology Transfer Network at http://www.epa.gov/ttn/oarpg/t3fs.html.

2.0 DEMOGRAPHICS

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

adverse human health or environmental effects on minority, low income, indigenous 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, low income, or indigenous populations.

These proposed standards may improve public health and welfare, now and in the future, 

by reducing HAP emissions that may contribute to adverse environmental and human health 

impacts. The reductions in HAP emissions associated with the rule are expected to benefit all 

populations living near the sources affected by this rule. 

To gain a better understanding of the source category and near source populations, the 

U.S. EPA conducted a demographic analysis on each of the source categories for this 

rulemaking. This analysis only gives some indication of the prevalence of sub-populations that 

may be exposed to air pollution from the sources and therefore would be those populations that 

may be expected to benefit most from these regulations; it does not identify the demographic 

characteristics of the most highly affected individuals or communities, nor does it quantify the 

level of risk faced by those individuals or communities. 

The information in each of the following tables provides near source (within 3 miles) data 

for several demographic categories, and highlights those that exceed 20 percent of their 

corresponding national averages.

Table 2.1 Summary of Demographic Data Analysis (Amino/Phenolic Resins)

DEMOGRAPHIC 

SUMMARY1

NEAR SOURCE 

TOTAL

% OF NEAR 

SOURCE TOTAL

NATIONAL 

TOTAL

% OF NATIONAL 

TOTAL

POPULATION 577,008 312,861,256

WHITE 388,377 67% 226,405,205 72%

AFRICAN AMERICAN 123,835 21% 39,475,216 13%

NATIVE AMERICAN 5,212 1% 3,646,995 1%

OTHER OR 

MULTIRACIAL 59,584 10% 43,333,840 14%

MINORITY2188,631 33% 86,456,051 28%

HISPANIC OR LATINO359,095 10% 54,181,245 17%

AGE 0 - 4 39,996 7% 20,465,068 7%
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AGE 0 - 17 138,011 24% 75,217,176 24%

AGE 65+ 66,529 12% 40,830,262 13%

NO HIGH SCHOOL 

DIPLOMA 63,535 11% 32,060,510 10%

BELOW POVERTY LINE 115,121 20% 43,616,850 14%

>= 1.2 of National Average

Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA.

1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facility level total may 

not match this summary total.

2. The “Minority” 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. All of the races noted in the table may include Hispanics.

African American = +8 percentage points or +70%

Below Poverty Line = +6 percentage points or +43%

Table 2.2 Summary of Demographic Data Analysis (Acrylic and Modacrylic Fibers 

Production)

DEMOGRAPHIC 

SUMMARY1

NEAR SOURCE 

TOTAL

% OF NEAR 

SOURCE TOTAL

NATIONAL 

TOTAL

% OF NATIONAL 

TOTAL

POPULATION 18,420 312,861,256

WHITE 8,185 44% 226,405,205 72%

AFRICAN AMERICAN 8,292 45% 39,475,216 13%

NATIVE AMERICAN 107 1% 3,646,995 1%

OTHER OR 

MULTIRACIAL 1,836 10% 43,333,840 14%

MINORITY210,235 56% 86,456,051 28%

HISPANIC OR LATINO32,159 12% 54,181,245 17%

AGE 0 - 4 1,467 8% 20,465,068 7%

AGE 0 - 17 4,881 26% 75,217,176 24%

AGE 65+ 1,835 10% 40,830,262 13%

NO HIGH SCHOOL 

DIPLOMA 1,890 10% 32,060,510 10%

BELOW POVERTY LINE 2,599 14% 43,616,850 14%

>= 1.2 of National Average

Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA.

1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facility level total 

may not match this summary total.

2. The “Minority” 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. All of the races noted in the table may include Hispanics.

African American = +32 percentage points or +257%

Minority = +28 percentage points or +101%

Age 0 - 4 = +1 percentage point or +22%
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Table 2.3 Summary of Demographic Data Analysis (Polycarbonate Production)

DEMOGRAPHIC 

SUMMARY1

NEAR SOURCE 

TOTAL

% OF NEAR 

SOURCE TOTAL

NATIONAL 

TOTAL

% OF NATIONAL 

TOTAL

POPULATION 51,367 312,861,256

WHITE 36,506 71% 226,405,205 72%

AFRICAN AMERICAN 5,500 11% 39,475,216 13%

NATIVE AMERICAN 422 1% 3,646,995 1%

OTHER OR 

MULTIRACIAL 8,939 17% 43,333,840 14%

MINORITY214,861 29% 86,456,051 28%

HISPANIC OR LATINO320,653 40% 54,181,245 17%

AGE 0 - 4 4,448 9% 20,465,068 7%

AGE 0 - 17 15,473 30% 75,217,176 24%

AGE 65+ 5,063 10% 40,830,262 13%

NO HIGH SCHOOL 

DIPLOMA 7,222 14% 32,060,510 10%

BELOW POVERTY LINE 7,878 15% 43,616,850 14%

>= 1.2 of National Average

Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA.

1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facility level total may 

not match this summary total.

2. The “Minority” 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. All of the races noted in the table may include Hispanics.

Other or Multiracial = +3 percentage points or +26%

Hispanic = +23 percentage points or +132%

Age 0 – 4 = +2 percentage points or +32%

Age 0 – 17 = +6 percentage points or +25%

No High School Diploma = +4 percentage points or +37%

The analysis of demographic data used proximity-to-a-source as a surrogate for exposure 

to identify those populations considered to be living near affected sources, such that they have 

notable exposures to emissions from these sources. The demographic data for this analysis were 

extracted from the 2010 census data, which were provided to the EPA by the United States 

Census Bureau. Distributions by race are based on demographic information at the census block 

level, and all other demographic groups are based on the extrapolation of census block group 

level data to the census block level. The socio-demographic parameters used in the analysis 

included the following categories: Racial (White, African American, Native American, Other or 

Multiracial, and All Other Races); Ethnicity (Hispanic); and Other (Number of people below the 
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poverty line, Number of people with ages between 0 and 18, Number of people greater than or 

equal to 65, Number of people over age 25 without a high school diploma). 

In determining the aggregate demographic makeup of the communities near affected 

sources, the EPA focused on those census blocks within 3 miles of affected sources and 

determined the demographic composition (e.g., race, income, etc.) of these census blocks and 

compared them to the corresponding compositions nationally. The radius of 3 miles (or 

approximately 5 km) is consistent with other demographic analyses focused on areas around 

potential sources1234however, not necessarily associated with the distance health risks are seen. 

To the extent that any minority, low income, or indigenous subpopulation is disproportionately 

impacted by the emissions as a result of the proximity of their homes to these sources, that 

subpopulation also stands to see increased environmental and health benefit from the emission 

reductions called for by this rule.

 

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.