By: Melody Reis, Director of Federal Policy, Moms Clean Air Force
Date: January 8, 2025
About: NOx New Source Performance Standards, Docket #EPA-HQ-OAR-2024-0419
To: EPA
Thank you for the opportunity to testify. My name is Melody Reis. I’m the Director of Federal Policy at Moms Clean Air Force, an organization of parents and caregivers who are committed to protecting children from the harmful effects of air pollution. On behalf of families across the country, I’m here to urge EPA to strengthen its proposed nitrogen oxides (NOx) rule and to adopt the most protective standards possible to reduce emissions from gas-fired power plants.
EPA has not revised its NOx standards for new gas-fired power plants since 2006—the last revision was nearly 20 years ago—making updates to these protections both urgent and long overdue. Moreover, there’s widely used technology that’s capable of meeting a more protective standard.
Pollution from gas-fired power plants has been linked to a wide range of health harms, and it’s critical that emissions standards for new power plants are as protective as possible of public health. Gas-fired power plants emit NOx, a component of both ozone and particle pollution, that’s also dangerous on its own. NOx has been linked to a number of respiratory issues, including airway inflammation and asthma attacks as well as increased hospital and emergency room visits.
I live in the DC area, which has been identified by the American Academy of Pediatrics as a pediatric asthma hotspot. Parts of the city have rates of pediatric asthma that are twice the national average. And in the American Lung Association’s latest State of the Air Report, the DC Metro region received a D for air quality based on the number of high ozone days in recent years. (Ozone, again, is formed by NOx when it reacts with other pollutants in the presence of sunlight.) High ozone days mean parents, teachers, and other caregivers often need to change plans to limit outdoor activities for children, especially children with conditions like asthma. They mean it’s likely more people will struggle to breathe and more people will visit the hospital.
We know NOx contributes to this problem and we know there are widely available technologies to reduce NOx pollution. We applaud EPA’s recognition of the important role technologies like combustion controls and selective catalytic-reduction can play in reducing emissions, but we know these technologies are capable of even greater reductions than what is proposed in the rule. We believe our families and communities deserve the strongest protections possible from health-harming pollution and urge EPA to strengthen the final version of the rule. Thank you for your time.