By: Celerah Hewes, Project Manager for State Campaigns, Moms Clean Air Force
Date: April 20, 2022
About: Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard, Docket ID No. EPA-HQ-OAR-2021-0668
To: Environmental Protection Agency
Thank you so much for the opportunity to testify on this important issue. My name is Celerah Hewes, and I am a Project Manager for Moms Clean Air Force, an organization of over a million moms and dads concerned about the impacts of climate change and air pollution on our children’s health. I am here today to support the Good Neighbor Plan and strongly recommend extending its ozone protections to cover more sources in more areas and requiring them to comply more quickly.
I live with my daughter in Albuquerque, New Mexico, where our county has consistently received an F rating for ozone pollution, or smog, from the American Lung Associations’ “State of the Air” report. Nitrogen oxides are a direct threat to health and are highly reactive, meaning they can form into ground-level ozone pollution. Here in the Southwest, we are also aware that when NOx combines with heat and sunlight in the atmosphere, they form smog, which is a lung irritant and asthma trigger.
Ozone can cause not only breathing problems, but also heart problems and premature death. Long-term exposure can lead to permanently reduced lung function in children and may cause central nervous system, reproductive, and developmental harm. It is becoming an increasing reality that we have to check our local ozone and air quality before going outside to play, walking the dog, or enjoying a day outdoors. Last summer, ozone pollution was further exacerbated by wildfires in Arizona, meaning our air quality was so bad my daughter's summer camp could not go outside at all.
For regulatory purposes, ozone season is considered May 1–September 30. But in some Western states, we are seeing this season extend to all 12 months of the year. Localized ozone pollution in these areas impacts the health of local communities. We should do everything we can to ensure that our children’s health is protected, but we should also consider the daily implications to the life of future generations if we do not take swift action. EPA needs to act quickly to finalize this proposal into law, because it is very long overdue.
I appreciate that EPA is not only requiring emissions reductions from power plants in upwind states, but also from other industrial sources. I urge EPA to expand the covered sources further to better protect public health. This proposed rule sets source-specific NOx reduction requirements in 26 states. Today I ask that EPA extend these requirements to all power plants and all major industry sources in both upwind and downwind areas. We all share the air and deserve to breathe easier, knowing the EPA is doing its job and protecting all of us from pollution. Not only does NOx from these sources contribute to ozone problems downwind, it also creates localized pollution that impacts health in fenceline communities. Cleaning them up is essential to meeting EPA’s commitments on environmental justice.
In conclusion, NOx is a powerful air pollutant on its own, as well as being a precursor to ozone and numerous other pollutants that have detrimental impacts on human health, especially on our children whose little lungs are just developing. I urge EPA to strengthen and finalize this proposal to control emissions from the vast array of sources that put public health at risk from NOx and ozone pollution.
Thank you for your time today.