By: Elizabeth Bechard, Public Health 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 today. My name is Elizabeth Bechard, and I am a Public Health Manager with Moms Clean Air Force. I live in Essex, Vermont, with my eight-year-old twins, and I'm here today on behalf of Moms Clean Air Force to ask that EPA go further in strengthening NOx protections in the final version of the proposed NOx rule.
Pollution from gas-fired power plants has been linked to a wide range of public health harms, and it’s critical that emissions standards for new power plants are as protective as possible of our families’ and communities’ health. Gas-fired power plants emit nitrogen oxides (NOx), a dangerous form of pollution that has been linked to asthma and other forms of respiratory illness. NOx is also a precursor pollutant that contributes to the formation of ozone and particle pollution. All three of these pollutants—NOx, ozone, and particle pollution—have been linked not only to respiratory illness, but also to cardiovascular harm and increased risk of adverse birth outcomes, like low birth weight and preterm birth.
While I don’t live in close proximity to a gas-fired power plant myself, I know from personal experience that adverse birth outcomes can have a profound and lasting impact on a family’s quality of life—and I wouldn't wish these experiences on anyone else. When my twins were born prematurely at 34 weeks in 2016, the days they spent in the NICU were nothing like I’d imagined my first days of motherhood might be. They were both born too small, and my daughter struggled to breathe for several days: I didn’t get to hold her until she was four days old because she was hooked up to so many machines in an incubator.
At eight years old, my twins are doing well in many ways—but I often wonder if we are still living with the impacts of their premature birth. Premature birth has been linked to higher risk of both ADHD and sensory processing disorder in children, both of which are conditions my son lives with and which impact our entire family. It breaks my heart to know that pollutants like NOx, ozone, and particle pollution contribute to outcomes like those my own family has experienced, because every child deserves the healthiest start possible. And it is heartbreaking to know that the health burden of pollutants like NOx falls disproportionately on communities already overburdened by environmental harms, including communities of color and communities living in close proximity to oil and gas facilities, including power plants.
Our NOx standards for new gas power plants haven’t been updated since 2006, making updated protections for families and communities long overdue. I thank EPA for the effort to update these protections and for basing the proposed standards on the use of selective catalytic reduction, a widely used and cost-effective technology. However, 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. On behalf of Moms Clean Air Force, I ask EPA to strengthen NOx protections in the final version of the rule, and to expand the use of continuous emissions monitoring to hold facilities accountable for their pollution—and for the impact it has on families and communities. Thank you for your time.