By: Elizabeth Brandt, National Field Manager, 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
Hello, and thank you for listening to my testimony today. My name is Elizabeth Brandt, I am a social worker and a National Field Manager for Moms Clean Air Force. Moms Clean Air Force is an organization of more than one million parents across America who are taking action against air pollution and climate change.
Many coal-fired power plants in the US are still polluting at levels above what is achievable through available modern solutions. EPA’s proposed update will strengthen the Cross-State Air Pollution Rule, which will mean more people in downwind states will be safer from pollution that can cause serious heart and lung diseases and even early deaths. The proposed update will also encourage more power plants to invest in clean, affordable zero-emitting power, which will help more upwind states be “good neighbors” as the Clean Air Act requires. I urge EPA to swiftly finalize the update and put a more protective Cross-State Air Pollution Rule in place.
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. I live in Maryland, which is on the list of states with industrial polluters that would have to clean up under this proposal. That’s a good thing—not only will we stop contributing to poor air quality in other states, but we’ll also clean up these sources of pollution for people in my state who live nearby. Maryland also receives a great deal of ozone pollution from other states west of here. Many Maryland counties received an “F” for ozone pollution. All of my fellow Marylanders deserve to breathe clean air, and this can only be achieved through EPA action to reduce pollution across the nation.
In my community, we have high ozone alert days during the summer. As a parent, it’s difficult to balance my kids’ need to play outside with the need to protect them from harmful 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. As a parent, I have a duty to protect my kids, which often means skipping an afternoon at the pool or a midday hike. However, this compounds the many health and mental harms our kids have experienced due to the pandemic. More than ever, my kids need to be outside socializing with their friends. And more than ever, keeping them inside could drive me round the bend.
America owes all of its children an equal shot at clean air and a healthy childhood, and we cannot do this without strong EPA regulation of cross-state air pollution.
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. EPA should extend these requirements to all power plants and all major industry sources in both upwind and downwind areas.
In addition to strengthening and finalizing this proposal, EPA must also speed up the rest of its work to implement and enforce the 2015 ozone standards. Setting these health-based standards won’t result in cleanup unless states implement and EPA enforces. EPA should seize this opportunity to make up ground by requiring controls to be as stringent as technologically feasible, both to ensure compliance with the 2015 ozone standards and to avoid falling further behind when the next standards come out.
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.