By: Dominique Browning, Co-Founder and Director, Moms Clean Air Force
Date: May 9, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2018-0794
To: Environmental Protection Agency
Thank you very much for this opportunity to testify about the new Mercury and Air Toxics Standards. I am here in support of the most protective standards possible. I am also asking that EPA close a lethal lignite loophole that has relaxed emissions standards for coal plants that burn high-polluting lignite coal.
I’m representing the million and a half members of Moms Clean Air Force. We have been working to strengthen protections from mercury and other toxic metals for over a decade.
It is beyond my comprehension that, in this day of sophisticated understanding of neurology, any coal plant operator would think it permissible to poison our air and water with mercury. No amount of mercury exposure is safe for the fetal brain, and the brains of babies and toddlers. Mercury disrupts the intricate and fragile architecture of the developing brain.
Previous mercury standards have worked—methylmercury levels in fish from certain parts of the country have dropped. The costs of stopping this pollution are significantly lower than predicted—billions of dollars lower. And finally, in the last decade there have been major improvements in pollution control technology.
Meanwhile the cost of suffering from methylmercury poisoning, or caring for a child so afflicted, is incalculable. How do you put a price on heartbreak?
Our work to stop mercury pollution is far from done. Too many communities remain exposed to dangerous levels, as well as to toxic metals such as arsenic, lead, nickel, and chromium.
The highest mercury-polluting coal plants are concentrated in Texas and in North Dakota. Other large polluters are in Appalachia and in the Midwest.
Mercury has significant local and regional impacts. People living near coal-fired power plants bear a disproportionate burden of the pollution from those stacks. But mercury moves around. It travels. Nearly all fish from US waters have detectable levels of methylmercury. There are consumption advisories in all fifty states.
Lignite, or “low-rank,” coal is especially highly-polluting. The five highest-polluting coal plants in this country burn lignite coal, even though lignite coal accounted for only 8% of total U.S. coal production in 2019.
There is no acceptable basis to justify the Lignite Loophole, which permits lignite plants to emit far more toxic pollution than other coal-fired plants. This should be corrected by EPA—to protect the health of all Americans.
Mercury exposure is associated with neurological and cardiovascular damage as well as endocrine disruption, diabetes risk, and compromised immune function. For pregnant mothers, mercury exposure can lead to neurocognitive problems in their children—there is no safe level of mercury exposure below which these effects are known not to occur. To say that another way: No amount of exposure to mercury is safe.
Mercury. Arsenic. Chromium. Lead. Not what any schoolchild in the United States should find in her lunchbox sandwich.