EXECUTIVE SUMMARY
Region 6 FY 2003 Environmental Justice Action Plan
The Region 6 Office of Environmental Justice (OEJ) is committed to finding solutions to
environmental and health problems that may affect all Americans especially minority and/or low
income populations who may be disproportionately impacted. Region 6 is committed to finding
solutions through partnerships and strategic alliances with communities, governments, business,
industry, and academia. By educating, serving and facilitation EJ attempts to empower all
stakeholders to meaningfully participate in developing and implementing programs and projects
that affect their lives. The Guiding Principle is that everyone, regardless of race or income, is
entitled to live in a clean environment.
Region 6 OEJ is organizationally structured to maximize opportunities to fully integrate
and administer the environmental justice program in the Region. The core office consists of five
(5) full time employees under the direct authority of the Deputy Regional Administrator (DRA)
supported by a seven-member Environmental Justice Workgroup representing each program
Division. The training function of the Office is supported by the EJ Training Team consisting of
six trainers who perform both internal and external training
The EJ Team, EJ Workgroup, and EJ Training Team operate under the functional
leadership of the Environmental Justice Coordinator who also serves as the EJ Team Leader. The
Coordinator is the Regional expert and advocate for Environmental Justice and Intergovernmental
Relations and serves as the senior advisor to the Regional Administrator, Deputy Regional
Administrator, and Senior Managers for Environmental Justice. Some Region 6 OEJ
Environmental Justice initiatives are funded through various sources; however, at this time, there
is no consistent funding source for OEJ special programs and projects.
Region 6 OEJ and program offices advocate that States be encouraged to address the issues
of environmental justice. Grants are provided for States, tribes, and other entities to implement
the water, hazardous waste, air, pesticide, solid waste, lead-based paint, underground storage tank
and children's health programs. Region 6 will continue to encourage that Performance
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Partnership Agreements (PPAs), Performance Partnership Grants (PPGs), and Categorical
Grants to States include grant conditions specific to environmental justice. Region 6 OEJ and
Program Divisions are willing to work closely with Headquarters OEJ, the AA-ships, and
Environmental Council of States (ECOS) in development of PPA/PPG language appropriate to
promote increased environmental justice involvement on the part of the States.
Region 6 OEJ participates in regular coordination and reporting activities with the
headquarters OEJ, including monthly in EJ Coordinator Conference calls, the development of
semiannual NEJAC updates, and the generation of biennial status reports.
Region 6 OEJ maintains regular relationships with external stakeholders including
environmental groups/coalitions, industrial facilities and associations, local and State agencies
and elected officials, as well as other federal agencies including Agency for Toxic Substances and
Disease Registry (ATSDR), Heath Resources Service Administration (HRSA), U.S. Army Corps
of Engineers (USACE), National Oceanic and Atmospheric Administration (NOAA), the
United States Geological Survey (USGS), and myriad other agencies. Region 6 OEJ has
developed and regularly distributes printed materials, including the EJ brochure in both English
and Spanish, the EJ Grant-Writing Training Guidebook, and other outreach documents. Region
6 OEJ maintains a mailing list of potential stakeholders who receive periodic mailings and
notifications and participates in Community Industry Panels and specialized community-based
workgroups. In November 2002, EPA sponsored its first Regional Listening Session in Houston,
Texas. Stakeholders from all five Region 6 States participated in this forum.
Region 6 OEJ works closely with the U.S.-Mexico Border Program to serve all
communities along the border to meet the EJ needs of the border communities and stakeholders.
Regional personnel facilitate the creation of a two-way communication process with the border
community, serve as a liaison to increase EPA access to affected communities to create a
meaningful community participation process and serve as a source of information and support for
these communities. Region 6 has extensive materials that are accessible to non-English-speaking
language groups in Texas and New Mexico. The border area has large Spanish-speaking
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constituencies particularly along the U.S. Mexico Border, while many Vietnamese-speaking
communities are thriving on the Texas Gulf Coast.
Region 6 OEJ is currently providing training to various internal and external stakeholder
groups as part of the Regions implementation of the EJ Training Collaborative. Region 6 has
played an active role in developing foundational environmental justice training tailored to a wide
variety of audiences including internal audiences, state, community and industry audiences. In
addition, OEJ provides grant writing training in various areas to assist prospective grant applicants
in preparation of grant proposals.
In 1993 Region 6 developed the EPA Environmental Justice Index Methodology for EJ site
analysis. The methodology uses Geographic Information System (GIS) maps, census
demographic data and the Hazard Index (HI) method to mathematically rank individual sites.
Region 6 is committed to use all tools at its disposal to effectively address environmental justice
issues in the Region, including the Environmental Justice Mapper, Environmental Justice Toolkit.
While the EJ Index identifies economically stressed and minority populations, the analysis can be
expanded to identify education, employment, and cultural factors.
The EJ Implementation Strategy requires regular reporting/accountability information be
furnished to the Deputy Regional Administrator by each program Division. These reports serve as
a tool to evaluate the effectiveness of the regional Environmental Justice program. The reports
address applicable program goals for EJ contained in the Divisions' strategic plans. Each Division
will report their EJ progress to the DRA, according to their specific program goals and activities
twice a year. One of these reports will coincide with the annual National Environmental Justice
Advisory Council (NEJAC) meeting. Additional reporting elements may be added to address
specific NEJAC issues. Each division will report on these general elements.
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REGION 6 FY 2003 ENVIRONMENTAL
JUSTICE ACTION PLAN
rev. 9/30/02
1. Region 6 Environmental Justice Philosophy, Mission and Vision Statements:
The Region 6 Office of Environmental Justice (hereinafter referred to as "OEJ") is
committed to finding solutions to environmental and health problems that may affect all
Americans, especially minority and/or low income populations who may be disproportionately
impacted. Region 6 is committed to finding solutions through partnerships and strategic alliances
with communities, governments, business, industry, and academia. By educating, serving and
facilitation, OEJ helps to empower all stakeholders to have meaningful participation in
developing and implementing programs, projects and policies that affect their lives. Effective
administration of OEJ is important to the Region because studies show that: (1) minority and low-
income communities may be disproportionately affected by environmental hazards1 and thus are in
need of information and assistance; (2) a sizeable portion of the Region's population lives in areas
where Environmental Justice issues potentially pose a concern; (3) the Environmental Justice
Executive Order 12898 states that EPA is the lead federal agency for Environmental Justice.
Our Guiding Princible is that everyone, regardless of race or income, is entitled to live in
a clean environment.
Region 6 OEJ's overarching Vision is as follows:
•	Environmental justice communities must be empowered to affect their own
destinies.
•	Strive to be an exemplary model of environmental justice programs and
implementation for all environmental justice partners—governments, communities,
business, industry and academia.
1.
U.S. GENERAL ACCOUNTING OFFICE, SITING OF HAZARDOUS WASTE LANDFILLS AND THEIR CORRELATION WITH RACIAL AND ECONOMIC STATUS OF
SURROUNDING COMMUNITIES 2 (1983). The GAO study reported a strong correlation between race and poverty and the location of hazardous waste facilities.
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•	Strive to advance the concept of environmental justice beyond mitigation to
prevention.
Region 6 OEJ's Vision for EJ internal operations is as follows:
•	Strive to work as a united force within Region 6.
•	All Region 6 employees should develop a working knowledge of environmental
justice tools and principles.
•	Through training, employees should apply these tools and principles in their daily
work as an integral part of their day-to-day work in all Region 6 activities.
•	Region 6 employees should strive to be innovative and proactive in identifying and
addressing environmental justice issues.
•	Positive internal efforts should be routinely rewarded and recognized.
Region 6 OEJ's Vision for strategic alliances:
•	All stakeholders should understand and respect the need for environmental justice
and be willing to work cooperatively to solve problems.
•	When appropriate, serve as a catalyst for all stakeholders to assist and encourage
them in implementing environmental justice principles and formulating effective
solutions through strategic alliances.
•	Environmental justice stakeholders should create their own strategic alliances to
address environmental justice issues in their communities.
2. Organizational Infrastructure and Management Support:
The Region 6 EJ Program is an organization structured to maximize opportunities to fully
integrate and administer the environmental justice program in the Region. The core office
consists of five full-time employees under the direct authority of the Deputy Regional
Administrator (DRA). This placement strategically positions the Office at the highest level in
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the organization so that cross/multi media EJ activities are managed most efficiently.
Additionally, by virtue of its placement in the DRA office, the full weight of the DRA is
conferred to OEJ. The work of the Office is also supported by an Environmental Justice
Workgroup which consists of seven team members, each representing his/her Program Division.
Each workgroup member, appointed by the Division or Office Director, is also supported by an
alternate representative who serves in his/her absence. The workgroup serves to augment and
support EJ implementation activities at the Division level and advises Divisional management
and staff on EJ related issues. This empowers Region 6 to fully integrate EJ within the program
areas. The training function of the office is supported by the EJ Training Team consisting of six
trainers who perform both internal and external training.
II Operational Resources/Program Support:
OEJ is staffed by the following personnel:
El Team
Lawrence Starfield, DRA and EJ Office Manager
Olivia-R Balandran, Team Leader
Shirley Augurson, EJ Senior Specialist
Warren Arthur, EJ Project Manager
Nelda Perez, EJ Specialist
Shirley Quinones - EJ Specialist/Grants Coordinator
El Workgroup
Teresa Cooks, Compliance and Enforcement Division
Charles Faultry, Multimedia Planning and Permitting Division
Dina Granado, Water Quality Division
Margie Floyd, Management Division
Kathleen Robinson, Superfund Division
Patty Senna, Office of External Affairs
Sherry Brown-Wilson, Regional Counsel
EJ Training Team:
Lead Trainers: Shirley Augurson, Mary Wilson
Sam Balandran
Charles Faultry
Amy May
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Connie Suttice
II Functions of The EJ Coordinator (Team Leader) and EJ Team:
The Environmental Justice (EJ) Coordinator (Team Leader) and members of the EJ
Team are the Regional experts and advocates for environmental justice and intergovernmental
relations. The EJ Team Leader serves as the advisor to the Regional Administrator, Deputy
Regional Administrator, and Senior Managers for environmental justice. The EJ Team Leader
with the support of the EJ Team is responsible for the following:
Represents the Regional office in relations with organizations and individuals concerned
with environmental justice issues, and as appropriate with local governments, State
Legislatures, Governors Offices and Congress.
Recommends and develops Regional policy to foster mutual understanding and
cooperation.
Establishes constructive relationships with local officials/staff and environmental justice
organizations, to encourage support and understanding of the Region's programs.
Is the Regional point of contact for environmental justice, with knowledge and
understanding of environmental justice operations, key players and stakeholders
(legislative, economic, business and commerce, media, environmental) as well as major
issues and trends that may influence EPA operations.
Implements environmental justice programs assigned to the Region and coordinates actions
with Headquarters and Regional offices as well as other Federal Agency counterparts,
anticipates controversial issues and advises the RA/DRA accordingly, recommending
specific courses of action.
Identifies key stakeholders, and develops and maintains relationships with them.
Provides advice and assistance to senior management and staff on environmental justice
issues and coordinates liaison between EPA and persons/organizations involved in
environmental justice issues, assists and reviews testimonies, statements of policy, staff
briefings and environmental justice proposals. Provides information to stakeholders.
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Ensures adequate and timely responses to environmental justice inquiries and serve as
subject matter specialist on key environmental justice legislation as well as
local/State/Federal Government budgets impacting the Region's environmental justice
operations.
Analyzes the political climate of areas with environmental justice issues; coordinates
activities to obtain understanding of and support for the Agency's goals, policies and
programs; arranges for courtesy visits between the RA/DRA and environmental justice
officials and leaders; represents EPA by coordinating and participating in briefings,
courtesy visits, conference calls and meetings between the Agency and constituents.
Works with the media and cross-media Divisions to develop an integrated (geographic)
approach that proactively solves/resolves environmental justice issues.
Facilitates meetings and works on teams to address multi-media cross-program
coordination. Works to integrate issues across program lines, bringing together key
Regional staff and environmental justice stakeholders.
Identifies multi-media, strategic opportunities, partnerships, and collaborations among
agencies and environmental justice stakeholders and builds relationships to impact EPA
issues before they become problems.
Manages the Environmental Justice Grants Program.
Tracks environmental justice legislation.
Analyzes and examines a range of environmental protection issues.
Identifies options for interacting with federal/State/Local environmental justice officials on high
priority initiatives.
Makes recommendations to RA/DRA, and senior management to propose approaches, to resolve
problems, or to take some other course of action to accomplish program objectives.
Evaluates Regional policy options to promote and facilitate understanding and endorsement by
locally elected officials.
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Identifies opportunities to develop or amend Regional strategic priorities in the areas of
community based environmental protection and alternative performance-based strategies.
Recommends plans and policies designed to meet program objectives or assists policy makers in
formulating policy in sensitive and difficult areas.
5.	Performance Partnership Agreements (PPAs) and Performance Partnership Grants
(PPGs):
The OEJ and program offices encourage the States to address the issues of environmental
justice. Grants are provided for States, Tribes, and other entities to implement the water,
hazardous waste, air, pesticide, solid waste, lead-based paint, underground storage tank and
children's health programs. At this time all of the Regional States have entered into Performance
Partnership Agreements (PPAs) with EPA and three Region 6 States (i.e., Oklahoma, Louisiana,
and Texas) have Performance Partnership Grants (PPGs).
For the future, Region 6 recommends that PPG and PPAs include grant conditions specific
to environmental justice. Enhanced public participation is one of the critical EJ concerns that
States address as conditions of PPAs and PPGs. Agreements should also include funding for
translation and interpretation services to improve public access to decision-making and
information gathering processes.
6.	Internal Organizational Engagement:
Region 6 OEJ participates in regular coordination and reporting activities with the
headquarters OEJ including regularly participating in EJ Coordinator conference calls, EJ Small
Grant conference calls, development of semiannual NEJAC updates and biannual status reports.
Region 6 is also a major contributor to OEJ initiatives including the EJ Guidance development.
Program Divisions consistently collaborate with other Divisions and agencies to address
serious environmental and health issues in EJ communities. Meaningful and continuous outreach
and education to citizens and environmental groups in EJ areas is a major focus. Historically,
citizen input has been utilized for targeting and enforcement actions. Management and staff work
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together to discuss and develop new approaches to address the needs of EJ communities. An
example of this collaboration is the Calcasieu Parish initiative in Louisiana. This effort sought
input from citizens, State and local governments, other Divisions, and HQ OEJ to develop and
implement a plan to address the immediate needs of the Calcasieu community.
Program personnel coordinates, consults and works with the EJ Office regarding
information and community concerns at removal and remedial sites in EJ communities. Staff
recognizes the need to heighten awareness of community interactions in EJ communities and
ensure the EJ community members are informed and involved.
7. External Stakeholder Engagement:
Region 6 maintains regular relationships with external stakeholders including
environmental groups/coalitions, industrial facilities and associations, local and State agencies
and elected officials as well as other federal agencies including Agency for Toxic Substances and
Disease Registry (ATSDR), Heath Resources Service Administration (HRSA), U.S. Army Corps
of Engineers (USACE), National Oceanic and Atmospheric Administration (NOAA), the
United States Geological Survey (USGS), and myriad other agencies. OEJ participates in
Community Industry Panels (including the Norco/New Sarpy CIP and the Beaumont-Charlton
Poullard CIP) and works with specialized community-based workgroups (Cesar Chavez/ Southeast
Houston Health and Environmental Workgroups).
In November 2002, EPA Region 6 sponsored its first Regional Listening Session in
Houston, Texas. The session was held from November 14 - 16, 2002. This was the first Regional
Listening Session held by an EPA Region nationally. In the December 2001 National
Environmental Justice Advisory Council (NEJAC) meeting, regional offices were charged to hold
the listening sessions. The purpose of the session is to have interactive, solution-oriented
dialogues with the community, and in partnerships with federal, state, Tribal, local and municipal
government representatives. A steering/planning committee made up of community leaders,
industry representatives, academia, state and other federal agencies was formed. The process
included brainstorming to identify the major issues of concern. Several subcommittees were
formed to handle each identified issue. Under each issue, a list of concerns was identified. The
list was prioritized and a few of those issues under each umbrella were identified to have a
solution-oriented dialogue at the session. Stakeholders from all five Region 6 States participated.
The Deputy Regional Administrator and Division Directors along with the subject matter experts
also participated. Several State Commissioners/Chairmen were invited. All sessions were
facilitated by certified facilitators. Extensive follow-up activities which came out of the session
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are currently underway. The subcommittees are continuing to communicate and follow up on
action items.
Region 6 maintains a Regional web site which has a mechanism for online user input and
inquiries. In addition, Region 6 has developed and regularly distributes printed materials
including the EJ brochure, EJ Grant development guidebook, and other outreach documents.
Region 6 OEJ maintains an ongoing relationship with key environmental coalitions
including the Southwest Network for Economic and Environmental Justice and the Louisiana
Environmental Action Network. These coalitions and their member organizations provide
plentiful opportunities to identify potential EJ issues and stakeholder groups who could benefit
from coordination with Region 6 OEJ. Additionally, OEJ regularly receives telephone calls and e-
mail inquiries from groups and individuals who require assistance. OEJ maintains a mailing list of
potential stakeholders who receive periodic mailings and notifications.
Region 6 OEJ collaborates with other federal agencies to alert other agencies to areas of
concern when EPA does not have regulatory authority.
Region 6 OEJ, in collaboration with the Program offices, has launched an innovative
process called the Region 6 Planning and Scoping Process which has as its main feature a
collaborative methodology for interactively identifying, categorizing, and prioritizing health,
safety, and environmental concerns. Local stakeholder participation in this hands-on direct
collaborative process is an essential element. Many of the issues identified in this process have EJ
applicability.
Region 6 currently encourages Supplemental Environmental Projects (SEPs) in high risk
disproportionately exposed areas. In 2003 at least 50% of SEPs will benefit EJ communities. In
order to give residents an opportunity to have meaningful input into the SEP negotiation process,
Region 6 has launched an internet-based (SEP) Idea Library which was created as a tool for
Region 6 to enhance community involvement. These ideas may be considered by violators of
Federal environmental laws during the case negotiation process. The project must relate to the
environmental violation.
Region 6 has a goal of accomplishing over 50% of inspections/investigations and
compliance assistance activities in high risk disproportionately exposed EJ communities.
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The public notice process (Administrative Penalty Order notice) considers EJ as it keeps
the public informed of fines proposed in the EPA administrative process including the amount of
the proposed fine and the location of the facility where the fine is assessed. The information
which is available in the local and regional newspapers will also be found in all community
libraries. Computers in each library have access to the EPA Region 6 web site. The public will be
notified of the location of these notices through mail-outs to minority and community groups
prepared from a list provided by the Regional EJ coordinator.
Program personnel conduct extensive efforts to assure EJ community involvement at all
sites in EJ neighborhoods. EJ community involvement and interactions at National Priority Sites
(NPL, removal sites and Brownfields communities) include educational efforts, community/EPA
interactions, meetings, one-on-one contacts, web pages, etc. to ensure that the EJ community
interaction is customized to each community's needs. All related removal and remedial site
information is typically placed into site repositories located in the communities where the
Program actions take place. Region 6's Superfund policy for community involvement is "early
and often" community involvement and interactions.
At each Superfund site, particularly those in EJ communities, EPA staff encourage the use
of Community Advisory Groups (CAGs) by offering CAG organization training and related tools.
EPA staff participate in CAG meetings whenever possible.
Program personnel are aware of the lack of effective community infrastructure services in
a large number of EJ communities. Extensive emergency exercises are conducted in EJ
communities in efforts to provide the communities with real tools that can be utilized in an
emergency. Planning and implementation for/of the emergency exercises always includes EJ
community leaders' participation so that program personnel have a real awareness and
understanding of the communities' needs. The community is provided technical advice,
emergency evacuation and Shelter-in-Place, as well as a general awareness of emergency
responses.
In Superfund, the Region 6 State agencies are required to consider the impacts of a site
assessment on the impacted EJ community.
Superfund personnel provide copies of all of the Site Status Summaries, site fact sheets and
Five Year Reviews on the Superfund web page. Many of the documents are also provided in the
Spanish language. Hard copies of these documents are made available to those without computer
access.
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On-Scene-Coordinators, Remedial Project Managers and Community Involvement
Coordinators work closely with their contractors to encourage the contractors to hire workers in
impacted EJ communities.
Superfund staff also provides the opportunity to EJ communities not eligible for Technical
Assistance Grants to avail themselves of the opportunity to access the services of the Technical
Outreach Services for Communities (TOSC). TOSC can assist communities in 1) obtaining
training to help them work more efficiently with government agencies; 2) providing training in
better managing community group environmental efforts; 3) take environmental samples at
contaminated sites; 4) facilitate meetings and numerous other services.
Region 6 has an extensive tribal outreach program. Over the next year training will be
provided to tribal nations to enhance their knowledge of tribal wetlands issues and surface water
quality monitoring and/or standards issues. Additionally Regional personnel will educate tribes
on new grant opportunities and will award at least one new cooperative agreement to a tribe or
consortia. Training will also be conducted on drinking water and system operation.
8. Special Initiatives for Persons with Limited English Proficiency.
OEJ works closely with the regional U.S.-Mexico Border Program to serve all communities
along the border. Region 6's commitment is to meet the EJ needs of the border communities and
stakeholders. Regional personnel facilitate the creation of a two-way communication with the
border community, serve as a liaison to increase EPA access to affected communities, and try to
fill the gaps of the Border Program regarding EJ. Some of the activities that the Border Program
conducts, with the assistance of the OEJ, are extensive outreach activities to inform and educate
the border communities about EJ and to identify their specific EJ needs. The Border Program also
is committed to strengthening the capacity of the border communities to become organized and
articulate their issues and concerns. This will create a meaningful community participation process
so that they will be encouraged to take an active role in protecting their environment.
The Border Program and OEJ have worked collaboratively on projects and activities of
benefit to the Spanish-speaking community in the border. In 2001, a Border Environmental Justice
Roundtable for border stakeholders and representatives of grassroots EJ organizations on both
sides of the border was held in El Paso, Texas. Hosted by the Regional Administrator, the Deputy
Regional Administrator, and the Executive Director of Southwest Network of Economic and
Environmental Justice, the meeting enabled these community representatives to discuss their
concerns with EPA, Texas Natural Resource Conservation Commission officials, and
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representatives of the Border Environment Cooperation Commission and the International
Boundary and Water Commission, which are binational agencies. These officials were able to
provide solutions to many of the concerns, and a mechanism was established to try to address the
other issues. OEJ and Border Team staff provided facilitation and translation for the meeting, and
the stakeholders were pleased with the progress made and the relationships that were established.
A follow-up meeting will be held in the near future to continue the process toward progress in this
important EJ community.
Region 6 has established a Border Compliance Assistance Center which is a "One-Stop-
Shop" for small to medium size businesses to help them understand their regulatory obligation
related to import/export and transportation of hazardous waste between the US and Mexico.
Information is presented in both in English and Spanish.
OEJ staff develop needed materials in Spanish for outreach to the Hispanic community,
such as fact sheets on the OEJ Small Grants Program, question-and-answer fact sheets on EJ and
EJ topics, etc. Certain existing materials are also translated as needed, such as the OEJ brochure to
ensure that stakeholders of limited English ability may also have access to important information.
Materials in Spanish targeted for persons with limited English-speaking ability and of limited
education, such as many colonia residents, are especially tailored for this audience to ensure that
they are easy to read and to comprehend.
The Program personnel examines the ethnic makeup of each community that has a site
requiring a Superfund removal or remedial action. If the EJ community has specific language
concerns, the Program ensures that all site-related materials provided to the community are
translated into the appropriate neighborhood language. At all meetings in EJ communities with
foreign language needs, EPA provides interpreters at the public meetings. Attention is also given
to communication concerns in EJ communities as to the best communication vehicles to transmit
information most effectively to the community for maximum community outreach and community
feedback opportunities.
In all communities, specifically EJ communities, program personnel works closely with
the 540 Local Emergency Planning Committees (LEPCs). The LEPCs are volunteer groups
comprised of local community members (police, industry, city officials, medical personnel,
press/news media, emergency management departments of cities, and neighborhood community
members) living in the impacted neighborhoods. EPA works closely with LEPCs to provide
expert information and training opportunities. Region 6 is one of the few Regions that provides an
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annual LEPC Conference for the volunteers. The LEPC concept is the most successful non-funded
volunteer community in the United States.
In addition, a Memorandum of Understanding is in place which serve the border
environmental justice communities. The University of Texas at Brownsville is a member of the
Hispanic Association of Colleges and Universities (HACU) Association and is located at
Brownsville, Texas. EPA has a workgroup currently working on the development of a plan of
action specifically tailored for environment education, environmental projects, and environmental
justice issues in the lower Rio Grande Valley. The goal of this program is to provide guidance and
assistance in the development of the university's plan for addressing environmental projects,
education, and as needed environmental justice in the Lower Rio Grande Valley.
The Border XXI Environmental Information Resources Workgroup has developed "The
Wire". The Wire is a project which, in conjunction with the U.S. Mexico Chamber of Commerce
will equip four border communities with computers to access environmental information via the
Internet. Region 6 has also launched its Border XXI Web Site to provide new information on the
updated Border 2012 Program. This is a one stop web site for communities and others searching
for environmental information to the U.S. Mexico Border, and other environmental information as
requested.
Region 6 has extensive materials that are accessible to non-English speaking language
groups in Texas and New Mexico. These areas have large Spanish-speaking constituencies
particularly along the U.S. Mexico Border and Vietnamese speaking communities on the Texas
Gulf Coast.
9. Specific Grant Programs for Which EJ Will Be Listed as a Funding Priority
In addition to the EJ Small Grants Program and PPGs discussed earlier, EPA awards
capitalization grants, authorized by the Clean Water Act and Safe Drinking Water Act, to States
for the purposes of providing low-interest loans for both water and wastewater infrastructure
projects in low-income communities. Through the Clean Water and Drinking Water State
Revolving Loan Fund programs, States can provide subsidies to disadvantaged communities to
reduce the economic impact of the communities' infrastructure projects. Since 1991, Congress has
appropriated approximately $335.8 million in financial assistance through the Texas and New
Mexico Colonia Programs directed toward disadvantaged and minority communities along the
U.S./Mexico Border area. These funds are to address the human health and environmental
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protection needs of the border communities. Many of these communities are unincorporated (i.e.,
colonias) with low median incomes.
The Brownfields Program has 49 grant awardees working on site assessment, cleanup and
redevelopment of Brownfields properties. These awardees, which include cities, counties,
planning organizations, Tribes and States, are predominately concentrating on brownfields that
are located in minority and disadvantaged neighborhoods. Over the last seven years of existence
of the EPA's Brownfields program, Region 6's grantees have leveraged over $1.5 billion in
redevelopment projects. Nearly all of this influx of new money has gone to benefit
environmental justice communities through the creation of new jobs, green space addition, and
increased revenues and city services brought about by the enlargement of their respective tax base.
The overall health of many of these communities has improved also due to the removal or
elimination of exposure to hazardous constituents and a reduction in crime and health-related
illnesses that are so often a result of having a lower standard of living. The Superfund Program
requires that grantees provide EJ communities the opportunities to be included in grant-related
community activities.
In 2003 Region 6 will target several border communities tor new brownfields grants. In
order to facilitate this goal the Region will conduct at least one workshop and award at least one
new cooperativ merit for site assessment Revolving Loan Fund (RLF) and cleanup to a
border com nun
If a group wishes to apply for a Superfund Reuse/Redevelopment grant, the input and
involvement of the impacted EJ community is a ranking factor for awarding of the grants. The
Reuse grants provide EJ communities the opportunities to have a voice in the redevelopment or
reuse of NPL sites in their communities. The community input into the remedial decisions can
change the level of the cleanup, depending on the site reuse plans.
In addition to the Reuse and Brownfields grant opportunities, Superfund offers the EJ
communities the opportunity to apply for the Technical Assistance Grant (TAG) in EJ sites
located in neighborhoods with an NPL site in the community. The TAGs provide the EJ
communities with funds to hire independent technical or health experts who can review and
interpret technical or health-related materials developed as part of the NPL remedial process.
10. Professional and Organizational Development:
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Region 6 is currently providing training to various internal and external stakeholder
groups as part of the Region's implementation of the EJ Training Collaborative. Region 6 has
played an active role in developing foundational environmental justice training tailored to a wide
variety of audiences. The Region will endeavor to present this training to internal audiences, State,
community and industry audiences to increase the understanding and implementation of the
principles of environmental justice. The training encompasses an examination of the issues and
elements of environmental justice, legal authorities, case studies and EJ tools. The collaborative is
comprised of representatives from community, federal and State government, and industry. As
scheduling permits, EJ Fundamental Training will be completed by all Region 6 employees in
accordance with the Regional EJ Training Plan. These sessions will include modules on best
practices and lessons learned.
In addition, OEJ provides grant-writing training in various areas to assist prospective grant
applicants in preparation of grant proposals.
11. Environmental Justice Assessment:
Region 6 developed the EPA Environmental Justice Index Methodology for site analysis.
It is a modification of the Region's Human Health Risk Index (H.I.) formula. The environmental
justice methodology defines demographic criteria, applies basic principles of science, and requires
environmental managers to use program specific data to identify communities of most concern. In
1993, Region 6 adopted the EJ Index protocol (see Attachment A) The methodology uses
Geographic Information Systems (GIS) maps, census demographic data and the Hazard Index
(HI) method to mathematically rank individual sites. The method is automated in GIS and
currently analyzes 50 square miles and one square mile geographic area (communities). The
method has an automated mapping facility. The Environmental Justice Formula is derived from
the Human Health Risk Index (H.I.)2 and is consistent with the approach used in all Region 6
risk-based algorithms: Exposure multiplied by Hazard equals Risk.
Human Health Risk Index (HRI) = Exposure X Hazard
These EJ methodology criteria (population, percent minority, and percent economically
stressed households in the study area) become the "analytical definition" for environmental
justice. Each of these parameters is ranked to facilitate the mathematical prioritization process. In
identifying an environmental justice site, it is also appropriate to consider the health risks
associated with the site. An integrated resource system, combining information from federal and
State databases such as RCRA and CERCLIS, aids in the analysis of pollution potential and
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hazard potential in a given area. As technologies advance the capability to evaluate cumulative
impact of risks, the Region will adopt these technologies to enhance its analysis.
Region 6 is committed to use all tools at its disposal to effectively address environmental
justice issues in the region including the Environmental Justice Mapper, Environmental Justice
Toolkit. While the EJ Index identifies economically stressed and minority populations, the
analysis can be expanded to identify education, employment, and cultural factors.
The Enforcement Division provides training, maintenance, and future development of the
Geographical Information System demographic system to assist other Divisions in implementation
and utilization of basic EJ demographic analyses. The National Environmental Policy Act,
Federal Facilities, and Comparative Risk programs will use the Region's Geographical
Information System EJ index methodology to accomplish the Agency's goal of EJ awareness and
incorporation of EJ into program activities.
Compliance Assurance and Enforcement Division (6EN) uses the EJ Index methodology
and Geographical Information System technology, whenever possible, as a factor in the
development of enforcement actions, targeting facilities for investigations and/or
single/multimedia inspections, which will ensure the consideration of EJ issues that may occur. EJ
criteria are also used to set priorities. For example, the use of EJ indicators can trigger the focus of
an Agency sector initiative, or a Regional priority area.
The EJ indexes are considered during the case development stages of the enforcement
actions by identifying violators located in an EJ community. Where possible, cases in EJ areas
will be issued and settled in less than one year. Settlement negotiations include SEPs that benefit
the community, such as negotiating with the facility to pay for the mandatory three-year
reinspection and management plan development for a school in its community, pay for cost to
abate asbestos or lead at a school, educate the community about the hazards of lead, testing low-
income and minority children' blood level. Community organizations, citizen groups and other
interested parties will be notified of the outcome of EJ cases, through the mail and other
communication medium.
Unless the EJ methodology proves otherwise, staff approaches all communities that
experience removal or remedial actions as EJ communities. All efforts are made to ensure that
community communications take into consideration the specific EJ concerns that might be
evidenced by the analysis. Staff uses the methodology on a consistent basis when they review site
decisions and communications delivery.
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12. Program Evaluation:
The EJ Implementation Strategy requires regular reporting/accountability information be
furnished to the Deputy Regional Administrator (DRA) by each Program Division. These reports
serve as a tool to evaluate the effectiveness of the regional Environmental Justice program. The
reports address applicable program goals for EJ contained in the Divisions' strategic plans. Each
Division reports its EJ progress to the DRA, according to their specific program goals and
activities twice a year. One of these reports, the year-end report, will coincide with the updates for
the annual National Environmental Justice Advisory Council (NEJAC) meeting. Additional
reporting elements may be added to address specific NEJAC issues. Each Division reports on these
general elements, as applicable:
a.	Funding for EJ communities (including the following elements: grants, grant
conditions, cooperative agreements, and commitments; contracts, Interagency
Agreements, Discretionary Funds)
b.	Permits and permitting issues resolved in EJ communities
c.	EJ Analyses performed
d.	Number of EJ communities identified thru analysis
e.	Resulting Actions in EJ communities
f.	Public Meetings/Hearings held in EJ communities
g.	Increased Outreach Efforts in EJ communities
h.	Enforcement in EJ communities
I.	Environmental clean-ups in EJ communities
g.	Corrective actions in EJ communities
h.	Encouragement to the States to work in EJ communities
In addition, each Division specifically reports on these elements of public participation:
a.	Community inquiries from EJ communities
b.	Educational sessions in EJ communities
c.	Response to requests from EJ communities
d.	Addressing language barriers in EJ communities
e.	Public meetings/hearings in EJ communities
f.	Encouragement to the States to work in EJ communities
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Attachment A
Environmental Justice Index
Methodology

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Computer Assisted
Environmental Justice Index
Methodology
Office of Planning and Analysis
U. S. EPA Region 6
July 1994

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TABLE OF CONTENTS
CHAPTER IV -Environmental Justice
A.	Introduction	
B.	Methodology and Computer System Overview...
1. Calculation of the Degree of Vulnerability
a.	The Minority Status Variable -DVMAV
(DV-Minority Average)
b.	The Economic Status Variable -DVECO
(DV-Economic Status)
2.	Calculation of Population Factor
3.	Calculation of the Potential Environmental Justice
Index
C.	System Features	
1.	The User's Guide
2.	Input
D.	Examples of Region 6 Environmental Justice Analyses
1.	Enforcement Targeting
2.	Permitting for Industrial Sites
a.	Environmental Impact Statement -Wallace, Louisiana
b.	Underground Injection Well -Winona, Texas
c.	Wastewater Treatment Plant -Marrero, Louisiana
d.	Uranium Processing Facility -Gore, Oklahoma
3.	Superfund
a.	West Dallas, TX Superfund Site
1)	Waste Disposal Site and West Dallas EJ Analysis
2)	Results
b.	Emergency Response -Houston Scrap, Houston, Texas
E. Discussion	
References	 11

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Environmental Justice Maps

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CHAPTER IV
Environmental Justice
A. Introduction
Environmental Justice refers to the pledge or assurance that no population
will endure a disproportionate share of the country's pollution. Evidence has
been presented that minority and low income communities are exposed to more
environmental pollutants than the general population.1 A modification of the
Region 6 Human Health Risk Index (HRI) formula2 is used to define and
prioritize specific sites as to their potential for environmental justice
concerns. The HRI-Justice methodology defines justice criteria, applies basic
principles of science, and enables environmental managers to use program
specific data to identify communities of most concern.
The Human Health Risk Index (HRI) enables users to select specific HRI
subfactors and perform special regulatory, health, and social-economic
analyses. These special applications include environmental justice studies,
enforcement targeting analyses, environmental impact studies, and pollution
prevention project assessments.
The Environmental Justice chapter describes how a modification of the HRI can
evaluate and rank environmental justice concerns around commercial hazardous
waste sites. This HRI-justice example uses Geographic Information System (GIS)
maps, census demographic data and the HRI method to mathematically rank
individual sites. The example's extensive use of GIS maps is for demonstration
purposes only. Justice information can be demonstrated using HRI criteria and
rankings alone. The method described is automated in GIS and currently
analyzes 50 square mile and one square mile geographic areas (communities).
The method also has an automated mapping facility. Examples of other special
applications in this document are: enforcement targeting and facility
permitting.
The Environmental Justice Formula is derived from the Human Health Risk Index
(HRI) 2 and is consistent with the approach used in all risk based algorithms:
Exposure multiplied by Hazard equals Risk.
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Human Health Risk Index (HRI) = Exposure X Hazard
The Potential Environmental Justice Index (EJ) defines "exposure" as the
population exposed and assumes the total population of a study area is
impacted by environmental justice factors. In the HRI, hazard has two
components: Degree of Impact (DI) and Degree of Vulnerability (DV). DI is a
chemical specific parameter. Inclusion of this factor requires chemical
exposure and toxicity information. For the justice formula, Degree of Impact
(DI) is not calculated. Potential risk from chemical exposure can be
calculated separately (Chapter II, Enforcement Targeting). Degree of
Vulnerability is calculated for EJ and includes two criteria: a community's
percent minority representation and percent economically stressed households.
These EJ methodology criteria (population, percent minority, and percent
economically stressed households in the study area) become the "analytical
definition" for environmental justice. Each of these parameters are ranked to
facilitate the mathematical prioritization process. Sites are evaluated
using an environmental justice formula and ranked on a scale of 0 to 100.
Although higher scores can indicate greater potential justice concern, the
population density, percent minority population, and percent of economically
depressed household data are the more important analytical factors. When
evaluated independently, they often provide greater insight to the potential
environmental justice concerns and can be used alone to rank sites (i. e.,
sites ranked on percent minority or economic status, or the combination of
these two factors). The methodology user should realize that even an index
ranking of zero can have significant EJ concerns. For example, an unpopulated
area will rank a zero, but if owned by minority and/ or low income groups, the
site may have significant EJ importance.
Environmental Justice Formula:
Environmental Justice Index (EJ) = Exposure X Hazard
(PE/ PC X POP) X (DI X DV)
where:
PE = Population Exposed
PC = Population in Community
PE/ PC = 1 (assumes total population is effected)
POP = Population Density Ranking (0 -4)
DI = Degree of Impact ( = 1)
DV = Degree of Vulnerability (Minority Ranking X Economic Ranking)
Minority Representation Ranking (1 -5)
Economic Status Ranking (1 -5)
therefore:

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EJ index = [Population Ranking] X [Minority Ranking X Economic Ranking]
[ POP (0 -4) ] X [ (1 -5) X (1 -5 ) ]
Because all HRI subfactors are mathematically related, data from smaller
analysis (i. e., environmental justice, enforcement targeting) are directly
applicable to formal HRI risk evaluations. Therefore, all special application
studies contribute to an ever larger risk analysis. Use of the HRI formula
assures the investigator that risk data is evaluated by documented,
consistent, peer reviewed ranking criteria. B. Methodology and Computer
System Overview The Environmental Justice Analysis System (EJ) is resident on
the Region 6 EPA Geographic Information System (GIS) and uses other systems
(i. e., RCRIS, CERCLIS, TRI, PCS) supported by the Region's Novel LAN to
provide locational information to GIS. All Region 6 Programs can perform site
specific environmental justice demographic analyses. The Programs are
responsible for the locational accuracy of the data submitted to the computer
system and accurate communication or environmental justice findings.
A one and fifty square mile study area is analyzed around each EJ point
location. The computer system clips a circular coverage with a 4 mile radius
(50 square miles) from the Census TIGER coverages 3 . Data is extracted from
various Census files to address methodology criteria. The EJ index is
calculated by finding the percentages for each subfactor for the 50 square
mile area, ranking the percentages based on scaling criteria, and multiplying
the rankings. The same process is performed for the one square mile analysis
(approximate 0.56 mile radius).
The Environmental Justice Index calculated from these subfactors, or the
independent subfactors comprising the Environmental Justice Index, should be
used as a Demographic Correlation Variable for studies conducted by Programs.
These studies serve to evaluate Agency policies or procedures regarding
sociological equity. EPA activities for evaluation can include enforcement
targets, permit decisions, grant awards, or risk calculations. 1.
Calculation of the Degree of Vulnerability Degree of Vulnerability (DV) for
the HRI 2 is the mean of ranking values of demographic data for the minority,
economic status, age, pregnancy, life-style factors, and pre-existing disease
subfactors (see Chapter I).
Of the subfactors above, minority representation and economic status
(household income) are used in the EJ formula. Each DV-EJ subfactor has a
scaling range from 1 to 5. The HRI-Justice vulnerability scaling scores are
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multiplied. Therefore, the maximum value for Degree of Vulnerability in the EJ
formula is 25. The scaling criteria for the Degree of Vulnerability
subfactors (percent minority and percent economically stressed) are derived
from the HRI Degree of Vulnerability Ranking Methodology. Like the HRI,
subfactors for the fifty and one mile study areas (EJ communities) are
compared to the state in which it resides. Region 6 state EJ criteria (1990
Census) are:
State	% Minority	% Economically stressed
Texas	39.4 %	27.6 %
Louisiana	34.2 %	36.3 %
Arkansas	17.7 %	36.0 %
Oklahoma	19.0 %	32.0 %
New Mexico	49.0 %	31.0 %
The evaluation criteria for the Degree of Vulnerability subfactors is:
HRI Degree of Vulnerability Ranking Methodology
Criteria Score
Percentage of residents in the risk group
is less than or equal to the state %	1
Percentage of residents in the risk
group greater than the state percentage
but less than or equal to 1.33 times	2
the state percentage
Percentage of residents in the risk
group greater than 1.33 times
the state percentage but less than or	3
equal to 1.66 times the state percentage
Percentage of residents in the risk
group greater than 1.66 times
the state percentage but less than or	4
equal to 1.99 times the state percentage
Percentage of residents in the risk
group greater than or equal to 2 times	5
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the state percentage
a. The Minority Status Variable -DVMAV (DV-Minority Average The Ethnicity
(DVMAV subfactor is derived from a comparison of the area's percent of
minority population to the calculated state percent minority population. For
example, the average minority percentage in Texas is 39.4 %. The EJ
methodology scaling criteria for Texas is:
MINORITY STATUS VARIABLE
Percent (% Minority Representation	Score
<39.4 % ( < Texas state average	1
>	39.4 % and < 52.4 %	2
>	52.4 % and < 65.4 %	3
>	65.4 % and < 78.8 %	4
>78.8%	5
Region 6 chose to include the Hispanic population in the definition of
minority, even though this populous may have reported themselves as white in
the 1990 Census. The minority population of a Region 6 community is defined as
the Census 1990 total of the non-white population plus the white Hispanic-
Origin population.
The data used to calculate the minority percentage is found in the block level
file called P. L. 94-171 of the 1990 Census 3 . The field used is P004 0002
which is defined as White with no Hispanic-Origin. This value is subtracted
from the total population, giving the number of people who are Non-White or
White with Hispanic-Origin. The percentage of people in the study area that
are Non-White or White with Hispanic-Origin is compared to the State
percentage of people in this same census category. Detailed documentation of
the state census numbers used and methodology calculations is found in the EJ
Computer System User's Guide (Potential Environmental Justice Index)4
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b. The Economic Status Variable -DVECO (DV-Economic Status) The Economic
Status (DVECO) subfactor is derived from a comparison of the area's percent
economically stressed to the calculated state percent economically stressed
population. Census household income data is block group level data. The block
group scaling score is used for each census block in the HRI-Justice
calculation when finding the EJ index for a block. For the Economic Status
subfactor, the risk group is assumed to be households that make less than
$15,000 a year. For example, in Texas the percentage of such households is 27.6
%. The economic status scaling criteria for Texas is:
ECONOMIC STATUS VARIABLE
Percent (%) Households below $15 K Score
< 27.6 % ( < Texas state average)	1
>	2 7.6 % and < 3 6.7 %	2
>	3 6.7 % and < 4 5.8 %	3
>	45.8 % and < 55.2 %	4
>	55.2 %	5
The data used to calculate the economically stressed percentage is found in
STF3A of the 1990 Census 3 , specifically the files STF301 and STF314. The
economic data found in the P80 category of STF314 is reported by household,
therefore, to find the percentage of economically stressed it is necessary to
use the number of households from P5 field (P0050001 of STF301 as a
denominator. The fields used to total the low income group are the sum of
P0800001, P0800002, P0800003, and P0800004 of STF314. Detailed documentation
of the state census numbers used and methodology calculations is found in the
EJ Computer System User's Guide 4 .
2. Calculation of Population Factor
The Population Factor (POP used in the justice formula is the population
density score for the study area. The population density ranking (POP is
determined by evaluating the total population from POPIOO of PL94171, and
evaluating the average one square mile population for the area. The density is
ranked by the scaling criteria following. The criteria scores range from 0 to
4 .
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POPULATION FACTOR Density Ranking
Population per Sq. Mile Scaling Score
0
0
>	0 and < 2 00
>	2 00 and < 1,000
>	1,000 and < 5,000
>	5,000
2
4
3
1
The population is found for the study area and ranked on a one square mile
area.
3. Calculation of the Potential Environmental Justice Index The product of the
subfactors, Minority Status (DVMAV), Economic Status (DVECO), and Population
Factor (POP) is the Potential Environmental Justice Index (EJ). The maximum
possible value of the EJ index is 100.
C. System Features
1. The User's Guide
A Region 6 EJ Computer System User's Guide 4 is available (Potential
Environmental Justice Index). The guide presents the computer screens
experienced by users through the menu activity as well as general GIS lessons
on using the Data General interface with UNIX for support of Environmental
Justice data processing.
Quality Assured Locational Data
THE MOST IMPORTANT STEP OF GEOGRAPHIC INFORMATION SYSTEM APPLICATIONS IS THE
PROCESSES THAT ASSURE THE LOCATIONAL DATA USED IS ACCURATE.
THE ACCURACY OF THE DATA IS THE REQUESTING PROGRAM'S RESPONSIBILITY.

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Before anyone evokes the Environmental Justice System, consideration for
Quality Assured Locational Data must be made. The system tracks the Quality
Assurance of the location, the Requestor's name and Program-Code.
2. Input
There are two methods of input currently available for the EJ system,
individual site processing and batch processing. Both use Latitude and
Longitude location for conversion to GIS-albers coordinates (X-axis, Y-axis).
Programs and primary data gathering groups use Latitude and Longitude as the
standard method of identifying location, therefore, this system is designed to
address this data format.
The EJ system employs an interactive menu interface to evoke the proper method
of input. The Individual Site Processing Option prompts the user for
information that meet the output criteria where the system cannot answer the
query. The Batch Processing Option prompts the user for a file name where
dBase data has been stored.
The user is responsible for input for:
Name of the Requestor
Source of Quality Assured Locational Data
Latitude/ Longitude
EPA Identifying number and Site Name
Mail Code
Users collect data from the EPA Mainframe systems or through program file
research and are responsible for the accuracy of the information. If the need
exists to evaluate more than 1 location, a dBase file can be built by the user
to transfer the batch of locations to GIS. The EJ System will automatically
convert the dBase file into a format compatible with the Region 6 GIS system.
The user is given the steps to complete the task through the User's Guide on
How to Transfer dBase Files to GIS.
D. Examples of Region 6 Environmental Justice Analyses

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1. Enforcement Targeting
One of the many applications for environmental justice evaluations is
enforcement targeting. This is a procedure which ranks industrial facilities
as to the potential impact each site may pose to human health and the
environment. Region 6 typically identifies facilities that have been non-
compliant in more than one media program (Air, NPDES, RCRA).
These facilities are subjected to a computerized risk screening methodology
using census information and Toxic Release Inventory (TRI) data. These
facilities are also evaluated by the Environmental Justice computer
methodology. Each site can be ranked by potential risk, environmental justice
ranking, population around each site, economic status of surrounding
communities, or by minority representation for the one and fifty square mile
study areas. Facilities which score high in historical noncompliance, risk, and
environmental justice are potential priority enforcement targets. A four mile
radius was demographically evaluated for each industrial facility and ranked
from 0 to 100.
2. Permitting for Industrial Sites
A major responsibility of EPA and State environmental agencies is the
permitting of industry related activities which impact the environment. The
Region's EJ formula is used to accurately access demographic information for
one and fifty square mile areas around sites being considered for permit
privileges. The following examples are for individual sites, but the EJ system
is also used to evaluate permitting practices for whole regulatory programs
(i. e., RCRA, NPDES, MSW) involving hundreds of sites. Table IV. 1 shows the
EJ analysis findings for four permitted sites described below and Houston
Scrap in Houston, Texas.
a. Environmental Impact Statement -Wallace, Louisiana
A plastics manufacturing facility asked regulators for a permit to build a
plant near Wallace, Louisiana, on the west bank of the Mississippi river (the
lower half of Maps 1 -3). EPA Environmental Impact Statements do not
traditionally assess environmental justice issues. The EJ formula was used to
characterize the demographics of the community around the proposed site. The
site of interest is approximately in the center of each map. Map 1 shows the

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minority ranking of each block, Map 2 the economic status for census block
group, and Map 3 demonstrates EJ index values for each census block.
The data indicates that one square mile around the site is sparsely populated
(133 residents), one-hundred percent minority, and economically stressed. The
plastics facility did not build in this area. The EJ analysis was used as an
Regional awareness tool.
b. Underground Injection Well Permit Application -Winona, Texas Gibraltar Well
# 186)
A company in the deep piney woods of East Texas applied for a permit to
continue injecting hazardous waste underground. A segment of the small
community town of Winona, Texas opposed the facility operation and the
issuance of a permit. Maps 4-6 show the demographics surrounding the facility.
There are few residents near the injection well (0.56 mile radius from site).
This does not indicate a lack of potential EJ concern. Program managers are
responsible for accessing demographic information and determinating possible
EJ concern.
c. Wastewater Treatment Plant -Marrero, Louisiana
Conditions of an NPDES permit were evaluated for a wastewater treatment plant
in Southern Louisiana near New Orleans. EJ demographic information was used by
EPA staff for a public meeting. The information is shown in Maps 7 -9.
d. Uranium Processing Facility -Gore, Oklahoma
Sequoyah Fuels is a uranium processing facility on the banks of the Arkansas
and Illinois Rivers in Eastern Oklahoma. The company has several permits from
EPA and DOE. A Native American environmental group has opposed the facility's
operation and requested an EJ analysis. Notice the zero population reported
for the 1 square mile study area. The EJ analysis does not evaluate worker
populations. The facility borders land owned by Native Americans. Maps 10 -12.
3. Superfund
a. In 1991 areas of West Dallas were
contaminated soil. One source of the
found to contain varying levels of lead
pollution had been the RSR Smelter.
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Region 6 EPA and the Texas Natural Resource Conservation Commission (TNRCC)
are removing contaminated soils from the Dallas community. A component of the
risk management plan was an evaluation of communities adjacent to permitted
hazardous waste facilities being considered to receive the West Dallas soil.
The soil was not hazardous. A proposed landfill in Avalon, Texas was evaluated
using the Environmental Justice methodology. 1). Waste Disposal Site and
West Dallas EJ Analyses Avalon, TX is a small rural community about fifty
miles south of Dallas. CSC Disposal is a hazardous waste site in the city. The
Minority Status, Economic Status, and Population Factor of the Region 6 EJ
methodology were calculated for the community around the landfill site. Maps
13 -15 demonstrate the 1 and 50 square mile EJ analyses for the Avalon, CSC
facility. An analysis of the West Dallas site is also presented in Maps 16 -
18 .
Other waste disposal facilities were considered for the disposal of West
Dallas soil. Two of these sites were landfills near Conroe, Texas and Monroe,
Louisiana.
2) Results
Demographic information produced by the EJ methodology characterized each
waste site considered for landfill disposal of West Dallas soil. The
environmental justice information was combined with transportation distance,
transport safety, facility design, and cost considerations to decide which
landfill was the best overall disposal site choice. The Avalon site was
selected. The non-contaminated soil was transported and deposited at this
regulated site in 1993-94.
b. Emergency Response -Houston Scrap, Harris County, Texas Houston Scrap is a
battery cracker, collecting lead from used auto batteries for recycling. Lead
concentrations on site in excess of thirty percent have been measured, offsite
contamination is known to exist, but the full extent has not been identified.
The company has been ordered to immediately remome contaminated waste piles.
Emergency response has fenced the area to keep the public out. Remedial
activities are anticipated once the surficial waste piles are removed. Maps 19
-21. E. Discussion 1. Environmental Justice Index scores are a general
ranking tool. Population density, percent minority population, and percent of
economically depressed household data are the more important analytical
factors. When evaluated independently, they often provide greater insight to
the potential environmental justice concerns and can be used alone to rank
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sites (i. e., sites ranked on percent minority or economic status, or the
combination of these two factors). The methodology user should realize that
even an index ranking of zero can have significant EJ concerns. For example,
an unpopulated study area will rank a zero, but the land can be owned by or
adjacent to land owned by minority and/ or low income groups. The uranium
processing plant bordering Native American land in Gore, Oklahoma is such a
site (Maps 10 -12).
2.	The Region does not believe an environmental health risk must exist before
there can be justice concerns. This is evident by the absence of risk criteria
from the EJ methodology. An analysis of an area's potential risk from chemical
releases is calculated at a default value of 1. Region 6 has an automated risk
methodology developed independent of EJ analysis. Both justice and risk
evaluations are used for enforcement targeting projects.
3.	Environmental justice has great potential to be misunderstood by government
and the public. Application of the basic principles of science can help
prevent this misunderstanding. An accurate assessment of demographic data will
compliment our community outreach and environmental justice awareness efforts.
4.	The EJ Index is derived from the product of three criteria factors with
values ranging from 0 -4, 1 -5, and 1 -5. The index can range from 0 -100,
but, mathematically, there are not 100 index values possible. This should be
remembered when using the methodology for enforcement targeting and other
multi-site applications. The range of possible values is smaller for
facilities ranking between 50 and 100 than for those ranking from 1 to 49.
Therefore, there can be a greater demographic difference between two
facilities ranking 60 than for two sites ranking 20.
5.	Methodology users should realize that if ranking factors for minority and
economic status are both ranked "5", and the site is in a relatively low
population area, the highest possible EJ Index is only 25 (on a scale from 0
to 100). Therefore, higher rankings require high population areas. The
computer code describing the spacial and mathematical aspects of the
methodology is documented in the Pilot Degree of Vulnerability and Potential
Environmental Justice Index System Documentation.
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6.	Although the subfactors are similarly weighted, it is possible that
population may have been an "indicator" factor. Meaning, wherever population
density is high, the other subfactors tend to rank high. Urbanization may be a
concern in this regard. Statistical analyses are planned to further study this
possibility.
7.	Environmental justice criteria rankings can be very different when the 50
square mile area is compared to the 1 square mile evaluation. Subfactor
differences are caused by a change in the number of census blocks analyzed and
the actual demographics for the individual blocks. When the study area boundry
(line for the 0.56 mile or the 4 mile radius) crosses through a census block,
the population is assumed to be equaly distributed through the block's area.
Therefore, if a block with 1000 residents is halved, a population of 500 is
counted for that block. This process can potentially cause significant error
depending on the number of blocks and the degree of population segregation
within each block.
8.	Although EJ studies can be statistically analyzed using standard methods,
obtaining statistical significance for study areas with few census blocks is
more difficult than for larger areas. Several of the one mile study areas had
less than 30 census blocks. Avalon, Texas has 14 and not all of those were
complete (totally within the study area).
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TABLE IV. 1 Environmental Justice - Permitting Industrial Sites
Location
Population
(Ranking)
Minority
Percentage
(Ranking)
Economic
Percentage
(Ranking)
EJ Ranking
Index
Value
Wallace, LA	6,436
(50 sq. mi.)	(1)
Wallace, LA	133
(1 sq. mi.)	(1)
67.5 h
(4)
100. 0
(5)
41.8
(2)
39.3
(2)
10
Winona, TX
(50 s q. mi)
Winona, TX
(1 s q. mi.)
2, 060
(1)
16
(1)
26.0
(1)
12 . 5
(1)
31.4
(2)
27 . 1
(1)
Gore, OK	1,973
(50 sq. mi.)	(1)
Gore, OK	0
(1 sq. mi.)	(0)
21.7
(2)
0 %
(1)
47 . 8
(3)
0 %
(1)
Dallas, TX
(50 s q. mi.)
Dallas, TX
(1 s q. mi.)
137,276
(3)
1, 616
(3)
73.4
(4)
99.4
(5)
38 . 5
(3)
69. 8
(5)
36
75
Houston, TX
(50 s q. mi.)
Houston, TX
(1 s q. mi.)
206,442
(3)
3, 953
(3)
(5)
92.2
(5)
48 . 1
(4)
54 . 5
(4)
60
60
References
-14-

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1. U. S. EPA. Environmental Equity: Reducing Risk for All
Communities, Policy, Planning, and Evaluation (PM-221),
EPA230-R-92-008, June 1992
2. U. S. EPA. Region 6 Human Health Risk Index Draft Document
Policy and Analysis Section, Dallas, TX, January 1991.
3.	U. S. Census Bureau, TIGER STF3A Census Coverage, P. L. 94
171, P004_ 0002.
4.	U. S. EPA.
Index: User's
5. U. S. EPA.
Environmental
TX, September
Region 6 Pilot Potential Environmental Justice
Guide, Dallas, TX, April 1994
Region 6 Degree of Vulnerability and Potential
Justice Index System Documentation, Dallas,
1993

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