U.S. Environmental Protection Agency, Region 9 

ENVIRONMENTAL JUSTICE ANALYSIS 

MCELMO CREEK UNIT OIL PRODUCTION FACILITY

PROPOSED PSD PERMIT NO. NU 05-01 

October 2014 

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 tribal, minority or low-income populations potentially 

affected by its proposed action on the McElmo Creek Unit Oil Production Facility (MCU 

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

exposure to relevant criteria pollutants.” Shell II, Slip Op. at 73. 

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. 

With respect to the proposed amended PSD permit for the MCU Facility, EPA regulates 

emissions affecting the following NAAQS: nitrogen dioxide (NO2) (1-hour and annual average), 

ozone (1-hour average), sulfur dioxide (SO2) (1-hour and 3-hour average), and carbon monoxide 

(CO) (1-hour and 8-hour average). The pollutants that do not require PSD review are particulate 

matter less than 2.5 micrometers in diameter (PM2.5), particulate matter less than 10 micrometers 

in diameter (PM10), and lead (Pb). EPA has determined that the MCU 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. 

FACILITY DESCRIPTION 

The MCU Facility is an existing oil and gas production operation located in Section 31, 

Township 40 South, Range 25 East within the Four Corners Area on the Navajo Nation Indian 

Reservation near the city of Aneth, San Juan County, Utah. The map in Figure 1 shows the 

location of the Facility. 
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Figure 1: Location of McElmo Creek Unit Oil Production Facility 

The McElmo Creek Unit oilfield is one of four oilfield units in the greater Aneth oilfield on the 

Navajo Indian Reservation in southeastern Utah as shown in Figure 2. 
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Figure 2: Oil field Units in the Aneth Oil Field 

(Source: Resolute Natural Resources Company) 

The Facility is on the McElmo Creek Unit oilfield, which includes field operations and a gas 

compression plant. The Main Flare is located at the gas compression plant. The MCU Facility 

started operation in the 1950s and was owned by Superior Oil at the time. Mobil Exploration 

and Producing U. S. Inc. (Mobil)1

 purchased the Facility in 1984. Resolute Natural Resources 

 

1

 References to Mobil include Mobil Exploration & Producing U.S., Inc. and ExxonMobil Production Company. 

The ExxonMobil Production Corporation was formed in 1999 by the merger of Exxon and Mobil, and ExxonMobil 

became the owner and operator of the MCU facility that year. 
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Company (Resolute), in partnership with Navajo Nation Oil and Gas Company, acquired Mobil’s 

ownership interest in April 2006 and assumed operation of the Facility on June 1, 2006. 

PROJECT DESCRIPTION 

This permit action consists of incorporating pollution limits, terms, and conditions for the 

already existing Main Flare into the PSD Permit for the MCU Facility pursuant to a federal 

Consent Decree, which was filed and became effective on June 8, 2005. Paragraph 14.a of the 

Consent Decree requires the owner and operator of the MCU Facility to submit, to EPA, a PSD 

permit application in accordance with the CAA and the PSD regulations at 40 CFR § 52.21 for 

the MCU Facility’s Main Flare not later than the 180 days after the effective date of the Consent 

Decree. The Consent Decree requires that the PSD application include, among other things, 

BACT and air quality analyses for SO2, CO, NOx, and VOC for the Main Flare. It also requires 

that the PSD application include terms and conditions that are at least as stringent as the 

following Consent Decree requirements.2 

 Paragraph 9.a (Emission Limits) 

 Paragraph 10 (Monitoring) 

 Paragraph 11 (Operation and Maintenance of Main Flare and Compressors) 

 Paragraph 25(i)-(ix) (Reporting and Recordkeeping Requirements) 

Mobil submitted a PSD application dated December 5, 2005 for the Main Flare, and also 

provided supplemental information in 2006 and 2007. Resolute submitted a revised PSD 

application dated April 2008 for the Main Flare, as well as various supplemental information 

thereafter. 

This PSD permit action also consists of updating the equipment covered in the PSD Permit, 

which includes removing emission units that have been shut down and removed from the MCU 

Facility site and the associated requirements that apply to these units. 

REGULATORY FRAMEWORK

Under the CAA, a new major stationary source and a major modification to an existing major 

stationary source in an area that has been designated attainment or unclassifiable are regulated 

under the PSD program. In addition, certain other pollutants for which no NAAQS have been set 

are subject to regulation with a defined applicability threshold under the PSD regulations. 

As mentioned previously in this document, the MCU Facility is located in the Four Corners 

Interstate Air Quality Control Region which is currently designated as attainment or unclassified 

for all criteria pollutants: NO2, SO2, CO, PM10, PM2.5, lead, and ozone. The U.S. Environmental 

Protection Agency (EPA) is the PSD permitting authority for stationary source located on the 

Navajo Nation Indian Reservation since the tribe does not have a delegated or federallyapproved PSD program. 

 

2

 See Paragraph 4.o of the Consent Decree. 
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The following is a summary of the PSD permit history associated with the MCU Facility.3

 February 2, 1987 – Initial PSD permit issued for the Stage 2 CO2 Project. 

 October 27, 1987 – Amended PSD permit issued replacement of the three reciprocating 

internal combustion engines with two 3216 HP natural gas-fueled. 

 March 21, 1989 – Amended PSD permit issued to change stack heights. 

 April 19, 1991 – Amended PSD permit authorized (1) replacement of existing heating 

with a waste heat recovery unit; (2) temporary replacement of an gas turbine with an 

identical unit during maintenance overhaul of the turbine, (3) increase of the rating of an 

existing gas turbine from 3216 HP to 4390 HP; and (4) removal of a gas turbine from the 

permit that was never installed. 

EPA’s current PSD permit action for the MCU Facility consists of incorporating the applicable 

terms and conditions of the Consent Decree into the PSD Permit for the MCU facility, and 

updating the PSD Permit to remove equipment that has been shut down and removed from the 

Facility. Other than the replacement of a fixed speed fan with a variable speed fan to provide 

better pollution control at the Main Flare, this permit action does not authorize any new 

construction or modification of existing equipment at the MCU Facility. 

ENVIRONMENTAL JUSTICE SCREENING

Description of Local Area 

The existing Facility is located near the city of Aneth, San Juan County, Utah on the Navajo 

Nation Indian Reservation. The area near Aneth is used primarily for oil and gas extraction and 

production. As shown in Figure 2 above, the MCU site is one of four oil field units located in 

the Aneth Oil Field. 

Figure 3 below shows the locations of cities and towns within 50 km (31 miles) of the MCU 

Facility, as well as other cities within the vicinity of the site. Table 3 below shows that almost 

all of the cities and towns within 50 km of the site each have populations that are less than 1000 

persons. The Ute Mountain Reservation in southeastern Utah and in southwestern Colorado is 

the only other Indian reservation located within 50 km of the MCU Facility. 

 

3 The previous PSD permits for the MCU Facility were issued by the United States Environmental Protection 

Agency, Region 8 Office (EPA Region 8). EPA Region 8 was the PSD permitting authority for the portion of the 

Navajo Nation Indian Reservation in Utah until October 9, 1991. According to a Memorandum of Agreement dated 

October 9, 1991 between EPA Regions 6, 8, 9 and the Navajo Nation Indian Reservation regarding the 

implementation of EPA-related activities on the reservation, this authority was transferred to EPA Region 9. The 

Navajo Nation Indian Reservation covers portions of northeastern Arizona, southeastern Utah, and northwestern 

New Mexico. 
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Figure 3: Cities/Towns within 50 km of MCU Facility 

Table 1: Cities/Towns within Vicinity of MCU Facility 

City Distance from MCU Facility Population 

Aneth, UT 5 km ( 3.1 mi) 501 

Montezuma Creek, UT 19 km (11.8 mi) 335 

Bluff, UT 30 km ( 18.6 mi) 258 

White Mesa, UT 32 km (19.9 mi) 242 

Red Mesa, AZ 36 km ( 22.4 mi) 480 

Tselaki Dezza, UT 36 km (22.4 mi) 109 

Teec Nos Pos, AZ 39 km (24.2 mi) 730 

Towaoc, CO 42 km (26.1 mi) 1,087 

Beclabito, NM 48 km (29.8 mi) 317 

Cortez, CO 60 km (37.3 mi) 8,482 

Shiprock, NM 71 km (44.1 mi) 8,295 

Farmington, NM 109 km (67.7 mi) 45,877 

Kayenta, AZ 110 km (68.4 mi) 5,189 

(Source: U.S. Census Bureau, 2010 Demographic Profile) 
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Demographics 

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

by a 50 km radius from the MCU Facility. This radius includes the primary populations that are 

expected be impacted by the emissions from the Facility. In Tables 2 and 3, EPA captured 

demographic information within four radii surrounding the MCU Facility at 5, 15, 25 and 50 

km.4

 Appendix A contains maps of this data. 

Table 2: Average Population and Median Household for Facility Location and Surrounding Areas 

Distance / Area Population Median Household Income 

5 km (3.1 mi) 167 $29,159 

15 km (9.3 mi) 1,152 $32,378 

25 km (15.5 mi) 1,856 $35,239 

50 km (31.1 mi) 11,199 $34,932 

Ute Mountain 1,742 Not available 

Navajo Nation 173,667 Not available 

San Juan County, UT 14,299 $37,615 

State of Utah 2,657, 236 $60,564 

The population data in Table 2 shows that there are less than 200 people within 5 km (3 miles) of 

the MCU Facility site, and a little more than 11,000 people within 50 km (31 miles) of the site. 

This is about 6% of the total population on the Navajo Nation Indian Reservation. This data, as 

well as the population data in Table 1 above, indicates that the area near the MCU Facility is 

sparely populated compared to the population on the Navajo Nation Indian Reservation, and that 

are likely very few residences near the site. 

The median household incomes for populations within 5 to 50 km of the Facility range between 

$29,159 and $35,239. These figures are just below the average median income of $37,615 for 

San Juan County, but much lower than the average median income of $60,564 for Utah. 

Comparable income data was not available for the Navajo Nation Indian Reservation. 

 

4

 U.S. Census Bureau, 2000 and 2010 Data; ESRI, 2012; TANA, 2006; Google, 2012. Population derived assuming 

uniform population distribution and, therefore, represents an average.
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Table 3: Other Average Demographic Information for Facility Location and Surrounding Areas 

Distance / Area 

Percent 

Minority 

Population 

Percent 

Population 

under 18 

Years of 

Age 

Percent 

Population 

over 64 Years 

of Age 

Percent 

Linguistically 

Isolated 

Households 

Percent Over 

Age 25 w/o 

High School 

Diploma 

5 km (3.1 mi) 95.7% 37.3% 8.0% 7.9% 20.3% 

15 km (9.3 mi) 93.4% 36.1% 8.0% 7.5% 21.2% 

25 km (15.5 mi) 65.6% 32.8% 10.6% 4.8% 21.5% 

50 km (31.1 mi) 54.5% 32.2% 11.6% 7.9% 19.9% 

Ute Mountain 97.7% 29.4% 4.8% Not available Not available 

Navajo Nation 98.1% 37.4% 9.5% Not available Not available 

San Juan County, UT 55.8% 34.2% 10.8% 1.4% 10.4% 

State of Utah 18.8% 31.4% 8.9% 1.0% 5.3% 

Table 3 shows several demographic percentages near the MCU Facility. The percentage of 

minority population near the Facility is over 90%. These percentages are close to the minority 

population percentage of 98% for the Navajo Nation Indian Reservation. The minority 

population within 50 km of the Facility and on the Navajo Nation Indian Reservation is almost 

all Native American. These values are above the percentages of 55.8% and 18.8% for San Juan 

County and Utah, respectively. 

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

process.5

 The percentage of linguistically isolated households between 5 and 50 km from the 

Facility ranges from 4.8% and 7.9%. These values are much higher than the percentages of 1.4% 

and 1.0% for San Juan County and Utah, respectively. Comparable data for linguistically isolated 

households was not available for the Navajo Nation Indian Reservation. 

 

Children and elderly populations are sensitive groups that are particularly susceptible to 

exposures of high concentrations of air contaminants. These groups are reflected in the 

populations under the age of 18 for children, and over the age of 64 for the elderly. Table 3 

shows the percentage of the population under the age of 18 ranges from 32.2% and 37.3%, and 

over the age of 64 from 8.0% to 11.6% between 5 km and 50 km of the site. These percentages 

are similar to the percentages for the Navajo Nation Indian Reservation of 37.4% for populations 

under 18, and 9.5% for populations over 64. Additionally, these percentages for population close 

to the Facility are similar to the percentages for San Juan County and Utah of 34.2% and 31.4%, 

respectively, for populations under age 18, and 10.8% and 8.9% for populations over age 64. 

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, 

and can increase the risk of poverty, stress, and impacts from environmental stressors. The 

percentage of the population with less than a high school education within 50 km of the MCU 

 

5

 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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Facility ranges from 19.9% to 21.5%. These percentages are much higher compared to the 

percentages of 10.9% and 5.3% for San Juan County and Utah, respectively. 

Status of Air Quality in the Area 

The MCU Facility is located within the Four Corners Interstate Air Quality Control Region 

which is currently designated as attainment or unclassified for all criteria pollutants for which 

EPA has established a national ambient air quality standard (NAAQS). These pollutants include 

ozone, PM10, PM2.5, NO2, CO, SO2, and lead. 

Impact of MCU Facility’s Emissions 

This environmental justice analysis focuses on the potential impacts on minority or low income 

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

for the Facility. For this project, those are emissions potentially affecting the NAAQS for NO2 

(1-hr and annual), ozone (1-hour average), SO2 (1-hour and 3-hour average), and CO (1-hour and 

8-hour average).6

 EPA has determined from the modeled results for the project that impacts from 

the project are below the applicable NAAQS for all of the PSD pollutants regulated under the PSD 

permit, as discussed in more detail below.

The maximum modeled concentrations for the MCU Facility’s Main Flare are below the 

significant impact levels (SILs) for annual and 1-hour NO2, and for annual, 24-hour and 3-hour 

SO2, and EPA determined that a cumulative air quality impacts analysis was not required to 

demonstrate compliance for these pollutants/averaging times. See Table 4 below. For these 

pollutants/averaging times, EPA has determined from the modeled results for the Main Flare that 

the impacts are below the applicable NAAQS. 

Table 4: McElmo Creek Unit Significant Impacts 

NAAQS pollutant & 

averaging time 

Project-only Modeled 

Impact μg/m3

Significant Impact 

Level (SIL), μg/m3

Project impact 

significant? 

NO2, 1-hour 5.0 7.5 (4 ppb) No 

NO2, annual 0.15 1 No 

SO2, 1-hour 11.6 7.9 (3 ppb) Yes 

SO2, 3-hour 11.6 25 No 

SO2, 24-hour 4.65 5 No 

SO2, annual 0.93 1 No 

CO, 1-hour 30 2000 No 

CO, 8-hour 30 500 No 

For 1-hour SO2, Resolute performed a PSD cumulative air quality impacts analysis. The results 

of this analysis, shown below in Table 5, demonstrate that emissions from the Main Flare will 

not cause or contribute to exceedances of the 1-hour SO2 NAAQS. 

 

6

 The potential emissions of PM2.5, PM10, and Pb for this project are not subject to PSD review. 
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Table 6: McElmo Creek Unit Compliance with SO2 (1-hour) NAAQS 

NAAQS 

pollutant & 

averaging time 

All Sources 

Modeled Impact 

(ug/m3) 

Background 

Concentration 

(ug/m3) 

Cumulative impact 

w/ background 

(ug/m3) 

NAAQS 

(ug/m3) 

SO2, 1-hour 26.76 79 105.76 196 

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, such as persons with 

asthma, children, and the elderly. Given EPA’s determination that the emissions increase for 

pollutants subject to PSD review for the MCU Facility will not cause or contribute to 

exceedances of the NAAQS, we do not expect the emissions increase of NO2, CO, and SO2

associated with the Facility’s Main Flare to result in adverse human health impacts to any 

population; therefore, we do not expect that our action would have disproportionately high and 

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

PUBLIC PARTICIPATION/OUTREACH ACTIVITIES 

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

community for the proposed PSD permit decision for the MCU Facility. 

Availability of Proposed PSD Permit Decision 

The proposed PSD permit, Ambient Air Quality Impact Report/Fact Sheet (AAQIR/Fact 

Sheet), and Public Notice will be available for review at the following locations which 

include Navajo Nation chapter houses and libraries in the region: 

 Navajo Nation Environmental Protection Agency, Fort Defiance, AZ, (928) 871-7692 

 Monticello Library, Monticello, UT, (435) 587-2281 

 Blanding Library, Blanding, UT, (435) 678-2335 

 Montezuma Creek Library, Montezuma Creek, UT, (435) 651-3309 

 Bluff Library, Bluff, UT, (435) 672-9996 

 La Sal Library, La Sal, UT, (435) 686-9936 

 Aneth Chapter House, Aneth, UT, (435) 651-3525 

 Red Mesa Chapter House near Montezuma Creek, UT, (928) 656-3679 

 Teec Nos Pos Chapter House, Teec Nos Pos, AZ, (928) 656-3662 

 Mexican Water Chapter House, Bluff, AZ, (928) 429-0986 

 Sweetwater Chapter House, Sweetwater, AZ, (928) 429-0977 

 Dennehotso Chapter, Dennehotso, AZ, (928) 658-3300 

Other key documents in EPA’s administrative record for the proposed PSD permit, including 

the permit application, the proposed permit, and AAQIR/Fact Sheet, are also available for 

public review on the EPA Region 9 website at http://www.epa.gov/region9/air/permit/r9-

permits-issued.html, as well as at the EPA Region 9 office in San Francisco, CA. 
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Public Meeting and Hearing 

EPA has scheduled one public information meeting followed by a public hearing for its proposed 

PSD permit decision: November 20, 2014 at the Aneth Chapter House in Aneth Creek, Utah. The 

purpose of the public information meeting is to provide interested parties with additional 

information and an opportunity for informal discussion of proposed PSD permit decision. 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 proposed PSD permit 

decision. 

While the percentage of linguistically isolated households is relatively low in the nearby 

communities and towns, the native Navajo language is Diné Bizaad, and some members of the 

Diné-speaking population in the nearby communities may prefer to express their comments in 

their native language at the public hearings. In order to encourage participation and aid attendees 

who would like to submit their comments in Diné, EPA is providing a Diné interpreter at both 

public information meetings and public hearings for its proposed PSD permit decision. 

EPA has also prepared a public information sheet for distribution at the hearings that provides a 

brief overview of EPA’s proposed PSD permitting action for the Project. This handout is 

available on the EPA Region 9 website at http://www.epa.gov/region9/air/permit/r9-permitsissued.html. 

Publication of Public Notice 

The notice of the proposed permit is being provided to the public through a wide variety of 

methods, including the following: 

 Posting on the EPA Region 9 website;

 Publication in the Navajo Times; San Juan Record in San Juan County, Utah; Cortez 

Journal in Cortez, CO; and Farmington Daily Times in Farmington, NM;

 Distribution to a mailing list of those who have requested to be notified by U.S. Mail of 

any actions related to the Facility; and 

 Distribution by email to those who have requested to be notified by email. 

Public Service Announcement Radio Broadcast 

Additionally, because of the high percentage of the population that is Navajo Indian in the area, 

EPA is issuing a public service announcement (PSA) in the Navajo Indian language of Diné to 

notify affected communities of our proposed PSD permit decision. The PSA will be made 

through the KTNN AM-660® commercial radio station that provides information and local 

news to the Four Corners Region (Arizona, New Mexico, Utah, and Colorado). 
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CONCLUSION 

Our analysis indicates that the emissions of the pollutant associated with the MCU Facility 

project and regulated under EPA’s proposed PSD permit will not result in adverse human health 

impacts to any population, 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. We also note that 

our outreach strategy will make information related to our proposed action more accessible to 

nearby communities, including potentially linguistically isolated populations that are primarily 

Diné speaking. 
APPENDIX A 

DEMOGRAPHIC INFORMATION & ASSOCIATED MAPS 

Contents 

Appendix # Demographic Info / Map 

A-1 Population Density 

A-2 Percent of Minority Population 

A-3 Percent of Population Under Age 18 

A-4 Percent of Population Over Age 64 

A-5 Percent Linguistically Isolated Households 

A-6 Percent Over Age 25 without a High School Diploma 

A-7 Median Household Income 
APPENDIX A-1: POPULATION DENSITY
APPENDIX A-2: PERCENT MINORITY POPULATION
APPENDIX A-3: PERCENT POPULATION UNDER AGE 18 
APPENDIX A-4: PERCENT POPULATION OVER AGE 64 
APPENDIX A-5: PERCENT LINGUISTICALLY ISOLATED HOUSEHOLDS
APPENDIX A-6: PERCENT POPULATION OVER AGE 25 WITHOUT HIGH SCHOOL DIPLOMA
APPENDIX A-7: MEDIAN HOUSEHOLD INCOME