By: Jayne Black, Wisconsin 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 afternoon. My name is Jayne Black, and I live in De Pere, Wisconsin. I am the Wisconsin Field Organizer for the national organization Moms Clean Air Force. On behalf of Moms Clean Air Force, I’m here to ask EPA to go further in strengthening NOx protections for new gas-fired power plants in the final version of the proposed NOx rule.
As a mother of a daughter with multiple sclerosis, I live with the knowledge and ramifications that air pollution is a very real contributing factor to my daughter’s disease and relapse episodes. One of the most dangerous types of air pollution to people with MS is NOx pollution. Every day, my daughter struggles to do the things we take for granted like getting out of bed, cleaning her home, taking a walk, and when she ventures outside her home, it is not a choice to wear a mask. She has to, and she has to carry a CO2 monitor to measure the quality of the air she’ll breathe. A CO2 monitor determines outdoor air quality by measuring the concentration of carbon dioxide (CO2) in the air, which acts as an indicator of overall ventilation and potential pollutant levels. Air pollution is something she must think about every day. She never forgets how aggressive her multiple sclerosis is, and as a young woman who no longer can work due to her disease, she focuses on wanting to live as long as possible, focusing on her husband and the limited things she can do.
According to research, exposure to NOX pollution, can potentially exacerbate the symptoms of multiple sclerosis (MS) by triggering inflammatory responses in the body, potentially increasing the risk of MS relapses due to its impact on the central nervous system through mechanisms like neuroinflammation and oxidative stress; essentially, high NOX levels may worsen existing MS symptoms in susceptible individuals. Research also suggests that NOx pollution may contribute to the development of MS.
There are 1 million people with multiple sclerosis, in the United States. I am here for them and all the people who live in communities near power plants who have multiple sclerosis, as well as those whose possibility of getting MS will also increase due to everyday exposure to NOx pollution. I am here to fight for justice in every breath.
I am deeply concerned about my state of Wisconsin in that there are multiple new gas-fired power plants that will be built here. WE Energies has proposed $2 billion in new gas plants and pipelines for Milwaukee, Kenosha, and Racine County, two of which received an F for air quality in the State of the Air Report, with Kenosha receiving an F for ozone. Wisconsin currently has 20,000 people who have multiple sclerosis. Additionally, NOx pollution also contributes to many other public health issues, like asthma, which my son has. Asthma is the most chronic disease in Wisconsin children. We can do better for Wisconsinites.
I want to acknowledge that I 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.
Thank you for your time today and the opportunity to share my family's story with you and to fight for environmental justice for all.




