By: Lucia Valentine, West Virginia State Coordinator, Moms Clean Air Force
Date: September 28, 2022
About: Environmental Protection Agency Docket ID No. EPA-HQ-OLEM-2022-0174
To: Environmental Protection Agency
Thank you for the opportunity to testify today. My name is Lucia Valentine, and I am the West Virginia Organizer for Moms Clean Air Force. I am from Shepherdstown, West Virginia, and have lived in the Mountain State my whole life.
I support the proposed EPA Safer Communities by Chemical Accident Prevention (SCCAP) rule, which will strengthen the Risk Management Program to help better protect the health and safety of communities living near chemical and petrochemical facilities. Many Risk Management Program facilities throughout the United States are in areas that are seeing increasing impacts from climate change, such as coastal flooding, inland flooding, wildfires, and storm surge. West Virginia is now one of the most at-risk states for climate-related flood disasters in the nation. A recent study and report found that roughly a third of Risk Management Program facilities are at increased risk from climate impacts. EPA needs to require Risk Management Program facilities to incorporate climate and natural disaster risks into their plans and have plans to address any associated loss of power.
When and if a flood disaster occurs in West Virginia—often referred to as the “birthplace of the chemical industry”—many communities located near chemical facilities are at a heightened health risk because Risk Management Program facilities contain chemicals that are known to be dangerous to human health. Beyond West Virginia, nearly 200 million Americans live near Risk Management Program facilities in the US, making this not just an environmental concern, but a public health concern as well.
It is EPA’s responsibility to regulate chemical and petrochemical facilities appropriately since many of the accidents that impact surrounding communities are preventable. The EPA Risk Management Program directly affects the emergency preparedness of a community. In the event of a chemical emergency, facilities should minimally be equipped with backup power, leak detection, and real-time air monitoring to minimize the adverse outcomes of disasters. It is critical that the Risk Management Program requires analysis of consequences to local communities before siting new facilities and taking into account the cumulative impacts of other industrial polluters in the community.
Thank you for your time today.