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MEMORANDUM

To: Pulp and Paper Docket (EPA-HQ-OAR-2007-0544)

From: John Bradfield, US EPA

Date: December 6, 2011

Subject: Review of Environmental Justice Impacts: Pulp and Paper

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. To promote 

meaningful involvement for the risk and technology review (RTR) of the NESHAP for pulp and 

paper making (subpart S), EPA held public webinars (www.epa.gov/air/ej/announce.html) and 

hosted 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.

2.0 DEMOGRAPHICS

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.
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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. 

Additionally, the Agency has reviewed this rule to determine if there is an 

overrepresentation of minority, low income, or indigenous populations near the sources such that 

they may currently face disproportionate risks from pollutants that could be mitigated by this 

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

may be exposed to HAP pollution from the sources affected by this rulemaking; 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 demographic data in Table 2.1 shows that while most demographic categories are 

below or within 2 percentage points 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. 

Table 2.1 Summary of Demographic Data Analysis

Demographic Summary Near Source 

Total

% of Near 

Source Total

National 

Total

% of National 

Total

Population 2,437,688 285,339,128

White 1,929,157 79% 214,539,706 75%

African American 365,077 15% 35,043,873 12%

Native American 20,449 1% 2,489,515 1%

Other or Multiracial 123,005 5% 33,265,937 12%

Minority1508,531 21% 70,799,422 25%

Hispanic or Latino278,804 3% 39,083,760 14%

Age 0-17 604,248 25% 77,245,364 27%

Age 65+ 343,439 14% 35,491,274 12%

No High School Diploma 314,843 13% 36,660,464 13%

Below Poverty Line 353,183 14% 37,181,029 13%

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

1The “Minorities” population is the overall population (in the first row) minus white population (in the second row).

2The Census Bureau defines “Hispanic or Latino” as an ethnicity rather than a racial category, Hispanics or Latinos 

may belong to any race.

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

extracted from the 2000 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 

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 sources1 2 3 4however, not necessarily associated with the distance which health risks 

are seen. In addition, air quality modeling experience has shown that the area in the vicinity of an 

individual source of emissions can generally be considered the area with the highest ambient air 

levels of the primary pollutants being emitted for most sources, both in absolute terms and 

relative to the contribution of other sources (assuming there are other sources in the area, as is 

typical in urban areas).5 While facility processes and fugitive emissions may have more localized 

impacts, the EPA acknowledges that because of various stack heights, terrain and meteorological 

conditions there is the potential for dispersion beyond 3 miles. 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.

5 Fox, Tyler. “Additional Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour 

NO2 National Ambient Air Quality Standard”. U.S. EPA. March, 2011.