Environmental Justice
Regulatory
Executive Order (E.O.) 12898 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations - was issued in 1994 to ensure minority and low-income populations are given equal consideration during the analysis of the environmental impacts with the goal of achieving environmental protection for all communities.
According to the EPA’s Final Guidance for Incorporating EJ Concerns in EPA's NEPA Compliance Analysis (1998) (Guidance), an Environmental Justice analysis must be completed if:
- the percent of low-income population within the affected area is greater than or equal to that of the county;
- if the minority population in the affected area exceeds 50 percent or is 10 percentage points higher than the county or state level.
Baseline Conditions
Norwood’s low-income population (13.9%) is 1.5 times greater than that of San Miguel County (8.5%). Norwood’s foreign-born population (9.5%) is about 10 percent higher than San Miguel County (8.5%) and about the same as the rate in Colorado (9.5%). These statistics indicate that an Environmental Justice analysis is appropriate for this EA. (U.S. Census Bureau, 2022).
Consequences
Any project-related impacts would affect this minority and low-income population.
Socioeconomics
Baseline Conditions
Norwood, Colorado is a rural ranching community with a population of 551; 240 housing units; 192 incorporated acres. The unemployment rates in Norwood and San Miguel County are 3.4% and 3.1%, respectively, (USCB, 2022).
Consequences
Employment - The workforce at the Project site during the 2-3-year construction period would require as many as 300 workers. In-migration of the work force from other counties or adjacent states would be necessary to meet the 300 workers needed during construction. The effects on regional employment as a result of constructing the Project would be beneficial, but minor since the majority of workers would need to come from outside of Norwood.
Housing - According to the San Miguel Regional Housing Authority, Housing Needs Assessment for San Miguel County (2018), there is a “well-recognized deficit of affordable housing for the local workforce”. Rental housing and availability of temporary accommodations such as hotels and motels in Norwood and San Miguel County could not accommodate the potential influx of workers. San Miguel county prohibits man-camps. Most of the workforce would have to commute from outside of San Miguel County. The Project would have further exacerbate housing needs in Norwood and the County.
Public Services - Norwood has one gas station (with four pumps), three hotels, one grocery store, one coffee shop, one restaurant, and a saloon. Though the generation of direct sales and income taxes would be a benefit, the influx of up to 300 out-of-town workers during the construction period would also be a significant burden public services in Norwood. Information on medical and emergency services is provided in Section 3.15.
Town Culture and Identity - The Project would result in a 1009.4-acre facility outside of a 192-acre town. The proposed Project would be an industrial structure encompassing an area 5.25 times the size of the town. The town of Norwood would be dwarfed in the shadow of the proposed solar facility. Long-time residents express concern over the potential loss of identity, as if their community, built on generations of ranching and the commerce that is specific to the town of Norwood, will experience a significant shift away from the culture with which they identify. More recent residents have stated that they move to Norwood for the small-town aesthetic and that the aesthetics will be significantly changed if an industrial plant is constructed in town, not just near their property. The SLB tract is currently leased by a rancher who keeps his bulls on the property. If the proposed Project was implemented, he would have to find another place to keep his bulls which would incur costs of either leasing another tract, purchasing property or changing his herd management.
According to the Solar Energy Development PEIS, large solar development projects can have significant impacts on small rural communities. Social disruption is likely to occur once an arbitrary population growth rate associated with solar energy development projects has been reached, with an annual rate of between 5 and 10% growth in population resulting in a breakdown in social structures, an increase in alcoholism, depression, suicide, social conflict, divorce, and delinquency, and deterioration in levels of community satisfaction. The number of new residents from outside the region of impact is likely to lead to some demographic and social change in small rural communities. Communities hosting these development projects are likely to be required to adapt to a different quality of life, with a transition away from a more traditional lifestyle of ranching in small, isolated, close-knit, homogenous communities with a strong orientation toward personal and family relationships, toward a more urban lifestyle with increasing cultural and ethnic diversity and increasing dependence on formal social relationships within the community. (Impacts of Solar Energy Development, Chapter 5.17 Socioeconomics DOE and BLM, 2010, 2012).
The proposed project would have significant adverse effects on local services including grocery and fuel availability, currently set to support Norwood’s population of 551. The proposed project would have significant and irrevocable adverse effects on the culture and identity of Norwood.
No Action Alternative
The Project would not be constructed under the No Action Alternative. No socioeconomic or environmental justice effects would occur.