1

MEMORANDUM 

To: Sewage Sludge Incinerator Docket 

From: Amy Hambrick, US EPA 

Date: June 2010 

Subject: Review of Environmental Justice Impacts for New Stationary Sources and 

Emission Guidelines for Existing Sources: Sewage Sludge Incineration Units 

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. 

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 
2

proposed rule to determine if there was 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, as shown in Table 2.1, shows that the average of 

populations in close proximity to the sources, and thus most likely to be effected by the sources, 

were similar in demographic composition to national averages. 

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, 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

EPA’s demographic analysis has shown that these areas in aggregate have similar proportions of 

American Indians, African-Americans, Hispanics, Whites, and “Other and Multi-racial” 

populations, and similar proportions of families with incomes below the poverty level as the 

national average. 

REFERENCES 

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. 

Categories 

Miles 

Radius 

Total 

Population 

Minority 

Population 

% 

Minority 

Population 

Living Below 

Poverty Level 

% 

Population 

Below 

Poverty 

Level 

Population 

<18 Years Old 

% Children 

< 17 Years 

Old 

National - All 

categories 285,193,760 90,671,626 32 35,716,283 13 73,221,413 26 

SSI 0.5 668,923 179,447 27 75,567 11 157,592 24 

SSI 3 8,680,480 2,749,288 32 1,186,354 14 2,134,398 25 

SSI 5 18,285,051 5,882,098 32 2,382,580 13 4,503,383 25