By: Giovanna Rossi, New Mexico Field Organizer, Moms Clean Air Force
Date: January 8, 2025
About: NOx New Source Performance Standards, Docket # EPA-HQ-OAR-2024-0419
To: EPA
Good morning, and thank you for the opportunity to provide comments on the Environmental Protection Agency’s (EPA) proposed updates to nitrogen oxide (NOx) emission standards for new gas-fired power plants. My name is Giovanna Rossi, and I am a field organizer for Moms Clean Air Force in New Mexico, an organization of one and a half million moms and dads concerned about the impacts of climate change and air pollution on our children’s health.
This proposal represents a crucial step forward in protecting public health and addressing overdue updates to standards that directly impact millions of families. We appreciate EPA’s efforts, but 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. We ask EPA to strengthen NOx protections in the final version of the rule.
I live with my husband and two children in Albuquerque, New Mexico, where our county has consistently received an F rating for ozone pollution, or smog, from the American Lung Associations’ “State of the Air” report. My daughter’s best friend has asthma and often had to miss playground time or even classroom time because of having to go get her inhaler.
Nitrogen oxides are a direct threat to health and are highly reactive. Here in the Southwest, we are aware that when NOx and volatile organic compounds combine with heat and sunlight in the atmosphere, they can form ground-level ozone pollution, also known as smog. Smog is a lung irritant and asthma trigger. Smog exacerbates and is linked to a variety of serious lung and heart diseases as well as premature deaths. It is especially dangerous for children as their lungs are still developing, but also poses an increased risk to people with asthma, the elderly, and people who are active outdoors.
The health consequences of NOx emissions are severe and far-reaching. Breathing in NOx can trigger asthma attacks, worsen lung function, and increase hospital visits. For children, who take more breaths per minute than adults and whose lungs are still developing, exposure to NOx can cause lifelong health challenges including asthma. Pregnant individuals face heightened risks, with studies linking NOx exposure to complications like high blood pressure and low birth weight.
The Clean Air Act mandates that EPA regularly review and update performance standards to reflect the best available technology. However, NOx standards for gas-fired power plants have not been revised since 2006—nearly a generation ago. Technology now allows for emissions reductions up to 87% lower than those achieved under the outdated standards.
EPA’s proposal to require selective catalytic reduction technology and continuous emissions monitoring is a positive step. However, the proposal can and should go further to ensure the strongest possible protections. Gas-fired power plants are capable of greater reductions using existing technologies, and our families deserve nothing less.
I commend the EPA for addressing this critical issue and urge the agency to finalize the strongest possible standards. We cannot afford to delay. Our children, families, and communities have a fundamental right to breathe clean air. As a parent, I do all I can to care for my children’s health, but we need the EPA to do their part to strengthen NOx protections in the final version of the rule. Every child deserves to breathe clean air.
Thank you for your efforts and for prioritizing public health.