By: Celerah Hewes, National Field Manager, Moms Clean Air Force
Date: January 8, 2025
About: NOx New Source Performance Standards, Docket # EPA-HQ-OAR-2024-0419
To: EPA
Thank you for the opportunity to testify. My name is Celerah Hewes, and I am a National Field Manager for Moms Clean Air Force working with frontline communities around the country concerned about the air pollution their children breathe, but I am most importantly a mother. I live in Albuquerque, New Mexico, with my family. On behalf of Moms Clean Air Force, I am here to ask that EPA go further in strengthening NOx protections in the final version of the proposed NOx rule.
Like many other states, New Mexico has a long legacy of health harms from power plants and other industrial sources. From the San Juan Basin to Los Alamos and Albuquerque, our communities know how important it is to have protections in place to address NOx, and while we appreciate EPA’s efforts, we know that gas power plants are capable of achieving greater reductions in pollution with the same technologies proposed in the rule, and we believe our families and communities deserve the strongest protection possible from health-harming pollution.
For over a decade, Moms Clean Air Force has been advocating for strong power plant protections. We do this because we know that NOx pollution from gas-fired power plants is harmful for the health of our children and communities and has been linked to a wide range of health impacts, including asthma and other forms of respiratory harm, adverse pregnancy and birth outcomes, and cardiovascular harm.
EPA has not revised NOx standards for new gas-fired power plants since 2006, making updates to these protections critical and long overdue. We have widely used technology available to minimize NOx pollution and protect children, pregnant people, older adults, people with chronic conditions like asthma, and environmental justice communities are especially at risk of harm from NOx pollution.
As a mother, I often think about the world my daughter will grow up in. Will she grow into a healthy adult? Will she choose to raise children, and if she is pregnant, will she stay healthy through her pregnancy? Will my grandchildren be born healthy and thrive as children? When we think about the expansion of gas-fired power plants that will go online in her lifetime, these questions matter.
This rule addresses some important aspects of reducing NOx pollution from gas-fired power plants, such as establishing the “best systems for emissions reduction” and “continuous emissions monitoring,” but we know that gas power plants can achieve greater reductions in pollution with the same technologies proposed in the rule. We hope the final version will strengthen these NOx emissions standards across the board and require continuous emissions monitoring for all covered units. If we have the technology to give our children and future generations the best chance to avoid the health risks of NOx pollution why wouldn’t we require it be used to its fullest potential? Every child and community deserves to breath clean air. For the sake of my child and future generations, I ask that EPA do everything they can to provide them with that opportunity.




