This is the testimony Moms Clean Air Force’s regional manager, Elizabeth Brandt gave on November 6, 2019 asking EPA to be more protective of our children, our families, and our communities by updating the current standards for ethane cracker plants:
Hello, and thank you so much for listening to my testimony today. My name is Elizabeth Brandt, I am a social worker and regional field manager for Moms Clean Air Force. Moms Clean Air Force is an organization of more than one million parents across America who are taking action against air pollution and climate change. We are motivated by love for our children, and we are asking the EPA to stand strong in protecting their health. I want the EPA to always keep in mind that the health of American kids is at stake in these decisions.
I’m not a technical expert, I am a mom and a social worker. I grew up next to a copper smelting site in Tacoma, Washington that has impacted my family’s health. What I’ve learned from our family’s experience is that American families must have a voice in decision making about industrial areas, and that this voice is most powerful if it is used before a new industrial facility sets up shop or expands in your neighborhood. There is nothing I can do to prevent the peers I grew up with from having cancer in their 40s which may be related to the high levels of carcinogens we were exposed to as babies living next to a copper smelter. I’d have to turn back time to change our exposure to harmful chemicals.
I couldn’t prevent my sister’s cancer, but I still have a mission to protect the health of my kids and their peers. It is the responsibility of all adults and EPA leaders to protect the children, who don’t yet have a voice to speak about pollution in the air they breathe.
This requires me to learn about issues that don’t come up in everyday conversations- like ethane cracker plants. Unfortunately, these factories aren’t churning out graham crackers. They are turning fracked fossil fuels into the building blocks of plastic. As they make this plastic, they are using tremendous amounts of electricity and generating hazardous pollutants.
The proposed amendments to the 2002 Ethylene Production National Emission Standards for Hazardous Air Pollutants (NESHAP) include some provisions that reduce emissions of hazardous air pollutants from these ethane crackers. However, the emission reduction estimated from this proposed rule is dwarfed by the increase in emissions of hazardous air pollutants from new facilities and planned facilities. A November 2018 US Department of Energy report estimates that between 2018 and 2040, the production capacity of ethylene will increase by over 85 percent. The proposed rule frames the industry growth in terms of facility number instead of capacity. By looking at just number of facilities, the EPA fails to capture the immense industry growth projected by the DOE due to the massive scale of the new facilities, as well as the planned expansions of existing facilities. The proposed updates to the NESHAP are not strong enough given EPA’s legal requirement that these facilities employ the maximum achievable pollution controls. If these weak standards are finalized, we will be stuck with them for many years, so let’s get this right!
The Environmental Protection Agency needs to update current standards for ethane crackers to be more protective of our children, our families, and our communities.
Children are more vulnerable to air pollution than adults. Their hearts beat faster than ours and they breathe more rapidly. Their bodies are growing, and their organ systems are rapidly developing. They need the most protective pollution controls to keep them healthy. Hazardous Air Pollutants can cause cancer, neurological problems, cardiovascular problems, respiratory problems, birth defects, and asthma attacks. It appears that the EPA did not examine prenatal risks associated with ethane crackers in its analysis, which is a major public health shortcoming. Air pollution is a factor in preterm birth and birth defects.
I live here in the DC Area where this hearing is being held so I can deliver my testimony in person. However, many who live in impacted communities may not be able to attend this public hearing since it would be a hardship. The majority of US ethane cracker plants are located along the Gulf Coast of Texas and Louisiana, near communities that are low-income and communities of color. The EPA estimates that 2.8 million people live near ethane cracker plants that are putting their health at risk. Ethane cracker plants make air pollution worse in places where communities are already breathing significant chemical and manufacturing industry pollution. More than 150 chemical and manufacturing facilities are located along the Mississippi River in Cancer Alley. This hearing should be held in an impacted community.
EPA’s own analysis shows that emissions from the ethylene production source category disproportionately harm minorities, low-income populations, and those without a high school diploma. EPA addresses this fact by noting that these groups then have the most to gain from the emissions reduction expected from this rule. However, when these meager emission reductions are placed in the context of the expected emission increase from new sources, it’s clear that there are very serious environmental justice implications.
The Appalachian region in Pennsylvania, Ohio, and West Virginia, along the Ohio River, is being targeted for the next big expansion of ethane cracker plants. Construction of the region’s first ethane cracker plant is under way in Southwestern Pennsylvania in an area that is economically depressed and already struggles with poor air quality. The Ohio River Valley ethane cracker plants are being built there to be closer to the plastic feedstock, ethane, which is being fracked out of the nearby Marcellus and Utica Shales. In this region, oil and gas companies are fracking for plastic.
In addition, millions of tons per year of carbon dioxide are released from these facilities; that pollution drives global warming, which threatens our health, our communities, and our children’s future. Plastic production is among the largest contributors to global greenhouse gas emissions from the industrial sector. We need federal limits on greenhouse gas pollution from ethane cracker plants so our children can have a healthy climate.
We only have one shot at getting these standards right for the health of our kids. The NESHAP standards are unlikely to be revised before my kids are fully grown. Our American children are our greatest resource and investment in the future. As a parent I have one simple request for the EPA: please consider their health first. No amount of profit can be traded for a healthy kid!