By: Elizabeth Bechard, Senior Policy Analyst, 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 for the opportunity to testify. My name is Elizabeth Bechard, and I am a Senior Policy Analyst at Moms Clean Air Force and a graduate student in public health. I am from Durham, North Carolina, and I am the mother of two young children. I support this ozone transport proposal and strongly recommend extending it to cover more sources in more areas and requiring them to comply more quickly.
EPA’s proposal will establish limits for NOx pollution, which is a direct threat to human health. Exposure to air pollution containing NOx and ozone during pregnancy is associated with adverse birth outcomes, like low birth weight, preterm birth, and stillbirth. A 2017 study estimates that in the US, 8,000 stillbirths per year may be attributable to chronic ozone exposure. As the mother of twins who were born prematurely and were low birth weight, and as someone who has experienced pregnancy loss twice, I can say from personal experience that adverse birth outcomes can be devastating for families. It is heartbreaking to know that air pollution contributes to this. No parent deserves to wonder if breathing polluted air will harm their babies before they’re even born.
And as many of you know, air pollution containing NOx and ozone harms children after they are born too. Because their small lungs are still developing, children are at greater risk for the respiratory harms of air pollution. NOx can cause airway inflammation, cough and wheezing, and a greater likelihood of asthma attacks, emergency department visits and hospital admission for people with lung disease. NOx is also highly reactive, and it can form into ground-level ozone pollution. Ozone can cause breathing problems, 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.
Both NOx and ozone pollution are major threats to public health, and EPA’s ozone transport proposal will help protect the health of babies, children, and other vulnerable populations.
I appreciate that EPA is not only requiring emissions reductions from power plants in upwind states, but also from other industrial sources. Expanding the covered sources further will offer even better protection for public health. Currently, the proposed rule sets source-specific NOx reduction requirements in 26 states, and EPA should extend these requirements to all power plants and all major industry sources in both upwind and downwind areas. NOx pollution from these sources contributes to ozone problems downwind, but it also creates localized pollution that impacts health in fence-line communities. Cleaning them up is essential to meeting EPA’s commitments on environmental justice.
There is no time to waste in addressing NOx and ozone pollution. EPA needs to act quickly to finalize this proposal into law, because it is very long overdue. It’s designed to reduce emissions of nitrogen oxides from specific fossil fuel-fired power plants in 25 states and specific large industrial polluters in 23 states to enable downwind communities to meet the 2015 ozone standards. That means people breathing unhealthy levels of ozone downwind have been waiting seven years for cleanup, and they shouldn’t have to wait any longer.
Once again, both NOx and ozone air pollution are major threats to public health. I strongly support EPA’s ozone transport proposal and urge you to strengthen and finalize the proposal to control emissions from the wide variety of sources that put public health, and especially the health of our babies and children, at risk. Thank you for the opportunity to testify.