By: Karin Stein, Iowa Field Organizer, Moms Clean Air Force
Date: January 8, 2025
About: NOx New Source Performance Standards, Docket #EPA-HQ-OAR-2024-0419
To: EPA
I am Karin Stein, Iowa Organizer for Moms Clean Air Force. I’m here today to ask EPA to go further in strengthening NOx protections from new gas-fired power plants.
Even though I don’t suffer from upper respiratory issues, controlling NOx emissions nonetheless feels personal to me, because I am a mother who identifies with what happens to children and their families, and because I am an immigrant from Latin America who identifies most closely with immigrants in Iowa, many of whom are people of color with no voice or access to medical care. Both of these groups of people are disproportionately affected by air quality in my state.
Iowa is a state that feels the impact of NOx pollution coming from other areas. Asthma rates in Iowa are higher than the national average, and people’s lives in my state are impacted every day. People don’t think of Iowa—a mostly rural state—as having air quality problems, but we do—most notably from agricultural activity, industrial sources, and power plants, both coal-operated and gas-operated.
We can’t get away from heavy, diesel-propelled agricultural equipment. It is common knowledge that heavy-duty vehicles are an important source of NOx.
And we know what it is like to live with the impact of dangerous NOx pollution from power plants: The asthma and heart disease rates in the areas where MidAmerican operates its aging coal plants in Iowa are staggering, particularly among Indigenous and Latino populations nearby and downwind. And our gas-operated power plants, which operate under seriously outdated emissions standards, do their part in adding to our NOx pollution problem in Iowa.
We can’t get away from these sources of NOx pollution, and our summers are getting hotter and hotter, thus aggravating our exposure to the ozone and particle pollution that results from NOx.
What do I say to my friend in Muscatine, Iowa, whose 12-year-old son has been in the intensive care unit in Iowa City so many times that the nurses keep books and toys for him in a special cubby for his next visit with a severe asthma attack?
What do I say to my colleague from the Winnebago Tribe near Sioux City, Iowa, who breaks down in angry tears when she describes how many of her family members suffer from serious lung problems, and how many of her community members have died prematurely from heart disease? Their Tribal lands are located downwind from existing coal plants, and they have been told that perhaps those plants will be replaced with gas plants soon and they will all benefit. Unless emissions standards for gas plants are tightened not only for new plants, but also for existing plants, human suffering will not improve enough.
As said, our asthma rates in Iowa are higher than the national average. We can’t get away from already existing NOx pollution, and our ever-hotter summers make these pollution precursors so much worse. In solidarity with communities around the country that will be impacted by NOx emissions from new gas-fired power plants, we plead with EPA to at least reduce the compounding contribution of NOx from new gas plants by strengthening NOx emissions protections across the board in the final version of this rule.
Thank you.