We are writing to alert you to a major environmental decision by
the Clinton EPA. The EPA is very close to a decision on new air
and water regulations (known as the "cluster rule") for the pulp
and paper industry. Although EPA Administrator Carol Browner,
recently assured a coalition of grass roots and national
environmental groups that she will not make a final decision
until spring, inside sources tell us that top EPA officials are
leaning in favor of the paper industry.
Right now, the EPA is engaged in an intensive internal debate.
They are deciding whether to allow the paper industry to continue
using dioxin producing chlorine and chlorine dioxide or switch to
totally chlorine-free (TCF) bleaching. Short of TCF, the EPA
could also choose a middle ground of oxygen delignification
(removing the sap from the wood with oxygen instead of chlorine
or chlorine dioxide, a first step to TCF).
Environmentalists are urging the EPA and the White House to gear
their new regulations to TCF along with new paper purchasing
policies by the federal government that would allow Uncle Sam to
buy TCF paper.
Beyond living up to campaign promises to protect the environment,
this issue also calls into question the Clinton Administration's
commitment to environmental justice.
When the EPA announced their proposed pulp and paper regulation
in the July 15th federal register, they made no reference to
compliance with the Clinton Administration's executive order on
environmental justice (EO #012898). That order specifically
states that agencies must determine whether new policies have
disproportionate impacts on "minority and low-income
populations."
On this issue, the impact is infamous. In 1990 EPA scientists
estimated that Asian and Native Americans living near pulp mills
consume an average of 100 to 150 grams of fish a day over a year.
Other studies put fish consumption levels by Native Americans as
high as 400 grams a day. However, the EPA assumes the average
American eats only 6.5 grams of fish per day. (For comparison, a
15 ounce can of salmon weighs about 400 grams or a month's
average consumption.)
EPA scientists also estimated that about 610,000 people living
near pulp mills have family incomes at or below the poverty line.
And those with higher fish consumption levels may face a one in
1,000 cancer risk. And according to census figures, most pulp
mills in the south eastern U.S. are located in towns with higher
than average African American populations.
Dioxin isn't the only hazard posed by pulp mills, the use of
chlorine compounds to bleach pulp and paper can also result in
hundreds of other toxic pollutants such as the banned pesticide
toxaphene.
The solution to all of these problems is TCF bleaching processes.
The paper can be just as white and strong. And it is already the
dominant paper process in northern Europe. It is also the key to
the "closed loop" non-polluting mill of the near future.
To turn the EPA around it is crucial that organizations send or
fax letters to the White House and EPA as soon as possible.
Katie McGinty, White House Counsel on Environmental Quality
The White House
Washington, D.C. 20500
(202) 456-2710 (fx)
Carol Browner, EPA Administrator
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
(202) 260-0279 (fx)
SAMPLE LETTER
Dear President Clinton/Carol Browner;
The first environmental test of your second term will probably be
the pending pulp and paper regulations known as the "Cluster
Rule." The right decision by you could spell relief for more
than half a million African American, Native American, Asian
American and low-income communities whose diets depend upon the
fish and drinking water down stream from polluting pulp and paper
mills.
In this regard we were very alarmed that EPA's federal register
notice on the Cluster Rule failed to even mention how this rule
would comply with the Executive Order on Environmental Justice
(EO #012898). We were equally alarmed to hear that top EPA
officials are "leaning" toward very weak regulations that would
continue to allow contamination of rivers and streams with
dioxins and other poisons created by chlorine and chlorine
dioxide bleaching processes.
As you know, EO #012898 directs federal agencies to "determine
whether their programs, policies, and activities have
disproportionately high adverse human health or environmental
effects on minority populations and low-income populations" (Sec.
3-301 & Sec.3-302).
According to EPA's "Analysis of the Potential Populations at Risk
from the Consumption of Freshwater Fish Caught Near paper Mills,"
15,000 Native Americans and 30,000 Asian Americans living near
dioxin contaminated effluent from pulp mills "consume an average
of 100 to 150 grams of fish flesh each day over the course of the
year." Other studies estimate fish consumption as high as 300
grams a day.
The EPA also estimated that another "610,000 people living in the
vicinity of pulp and paper mills have family incomes at or below
the poverty level. These individuals are also expected to derive
a significant portion of animal protein from subsistence and
sports fishing in rivers near paper mills."
In addition, the EPA calculated that these communities face a 1
in 1,000 to 1 in 1,500 risk of cancer from dioxin contaminated
fish.
These findings contrast sharply with EPA's estimate of 6.5 grams
of fish consumed each day by "average Americans." (To put this
in perspective, a 15 ounce can of salmon weighs about 400 grams.)
Fortunately, there is a practical solution to this problem. By
switching to totally chlorine-free (TCF) bleaching as much of
Europe has already done, we can not only "control" dioxins, we
can eliminate them.
Unfortunately, there is only one pulp mill in the U.S. that has
made this change. However, Canada has a set a 2002 target date
for acheiving zero AOX effluent (a water quality standard that
only TCF mills can meet.)
Now is the time for you to make the Cluster Rule a model for both
environmental justice and pollution prevention. Requiring the
paper industry to embrace TCF paper processes is the only way to
accomplish these twin goals.
We look forward to hearing from you on this crucial issue at your
earliest convenience.
Sincerely,