By: Kindra Weid, Electric School Bus Outreach Coordinator, Moms Clean Air Force
Date: January 8, 2025
About: NOx New Source Performance Standards, Docket #EPA-HQ-OAR-2024-0419
To: EPA
My name is Kindra Weid, and I am a nurse and an air quality advocate from Southeast Michigan. I am volunteering with Moms Clean Air Force and Michigan Clinicians for Climate Action today in providing this testimony. Thank you for listening to these public comments on EPA’s NOx standards for new gas-fired power plants. I appreciate EPA’s efforts with this proposed rulemaking but encourage the agency to further strengthen NOx protections in the final version of the rule.
I felt the importance of speaking with you today because over the course of my 25 years as an RN, I have witnessed many people struggling to breathe. I currently work in a medical ICU, and the majority of our patients have chronic heart or lung conditions, such as asthma, COPD, or cardiovascular disease, which makes them particularly vulnerable to the inhalation of nitrogen oxide pollution.
Everyone here likely knows someone with one of these health conditions, and it's important to understand these standards EPA is considering have real-life consequences for human health—things that I see at the bedside. Watching someone struggle to breathe, or struggling to breathe yourself, is unsettling, scary, and difficult to witness. Gasping to catch one’s breath causes panic and anxiety—I wouldn’t wish it on anyone. That is why I’m urging EPA to set stronger NOx standards.
Nitrogen oxides are harmful to human health—this fact is well supported by a robust body of scientific research and peer-reviewed literature. According to EPA, NOx emissions serve as an irritant to the airway and can exacerbate chronic respiratory conditions leading to hospitalizations and visits to the emergency department. Longer-term exposure may contribute to the development of asthma as well as increase the susceptibility of acquiring respiratory infections. Children, older adults, those with chronic heart and lung conditions, pregnant women, outdoor workers, and people who live near direct sources are particularly vulnerable to its impacts. NOx emissions from newly constructed power plants should be limited as much as current technology is capable of to protect human health—especially our most vulnerable populations.
According to 2022 data from the Environmental Defense Fund, Texas, Florida, and Michigan have the highest levels of NOx pollution, respectively. This is not a list we want to find ourselves on. The highest emissions of nitrogen oxides in a congressional district were seen in Michigan’s 8th district, which includes the city of Flint. When thinking about this rulemaking process, please consider how it will impact the most vulnerable among us, and please put into place the most stringent of protections possible.
EPA has not revised NOx standards for new gas-fired power plants since 2006, making updates to these protections long overdue. Currently, there is widely used technology available to minimize NOx pollution, and we strongly support implementation of these technologies along with even stricter considerations to protect human health.
Despite their known environmental and health harms, gas-fired power plants are slated to be built across our state and country in the coming years. That is why it is so important for EPA to set stricter new source performance standards for these new, modified, or reconstructed power plants. EPA has the opportunity to set strong, health-guarding standards for NOx emissions that will impact the health of future generations. Please do all that is within your power to make them as protective as possible.
Thank you for your time and attention today.