By: Molly Rauch, Public Health Policy Director, Moms Clean Air Force
Date: April 20, 2022
About: Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard, Docket ID No. EPA-HQ-OAR-2021-0668
To: Environmental Protection Agency
Thank you for the opportunity to testify on this important issue. My name is Molly Rauch, and I am Public Health Policy Director for Moms Clean Air Force, an organization of over a million moms and dads fighting for clean air and a safe climate for the sake of our children’s health. Moms Clean Air Force supports this ozone transport proposal, and we strongly recommend that EPA require sources to comply more quickly.
Today, the American Lung Association released its annual State of the Air Report. DC once again received a failing grade for ground-level ozone, or smog, a lung irritant that increases asthma attacks and interferes with normal lung development. For all of the 18 years I have lived in DC, my city has had dangerous ozone levels. My children are athletes who play outside. We take regular hikes in Rock Creek Park with our dog. We go on family bike rides. But I’ve learned over the years to check current air quality levels before doing any of these activities. Indeed, I check ozone levels daily during ozone season. If levels are high, we don’t go outside. I don’t want to harm my kids’ lungs. I also have had breathing problems over the years, and I can’t risk it for myself either.
In DC, almost all of our ozone pollution comes from other states. It is vital to my family’s health that upwind states act as good neighbors. We need power plants in Ohio, West Virginia, Kentucky, and beyond to limit NOx pollution, to better protect children here in DC.
This isn’t just a DC problem, of course. Our moms across the country experience the health effects of ozone. Three out of 8 Americans live in counties with unsafe ozone levels, according to ALA.
Much of the ozone pollution in our nation’s most populated cities is preventable. One of the things that is most concerning to our members is the fact that many highly polluting coal plants have pollution control mechanisms purchased and installed, yet they do not operate those devices. That’s like buying sunscreen and never using it. It’s not going to help prevent sunburn if you don’t use it. These unused, idle pollution controls could be actively preventing asthma attacks, lost school and work days, ER visits, and the billions of dollars in related healthcare and other costs that go alongside managing asthma. Asthma is the leading chronic disease of childhood, and the most frequent cause of missed school days. We’ve got to be doing more to prevent air pollution that can make asthma worse. We support requiring major NOx emitters to use the control devices that they already have installed to reduce this pollution.
We also support requiring coal plants to install vital pollution control devices. More than 75 coal plants across the country do not have pollution control technology installed for NOx. This is a major public health threat that must be remedied and we support this proposal that finally requires these plants to install pollution controls to reduce harmful NOx pollution.
Moms appreciate the significant public health benefits that would result from this ozone transport proposal. These measures would lead to 1,000 fewer deaths; 2,400 fewer hospital visits; 470,000 fewer missed school days, and 1.3 million fewer cases of asthma symptoms annually, for a total public health benefit of $15 billion per year.
However, we think that EPA must require that sources comply more quickly. The proposal gives sources more time than necessary to start to run their existing pollution controls or install new ones. Public health can’t wait any longer for the benefits of this cleanup.
- If polluting sources have existing controls, they should be required to run them by the start of the next ozone season: May 1, 2023.
- If polluting sources don’t have existing controls, they should be required to install and optimally run them by May 1, 2024.
In conclusion, NOx is a powerful air pollutant that increases the formation of ground level ozone. The more than 122 million Americans who breathe unhealthy levels of ozone will benefit from this rule that reduces harmful NOx pollution from power plants and other sources. Moms Clean Air Force supports this much needed proposal that will finally bring the ozone transport rule in line with current ozone standards. We urge EPA to strengthen this proposal by speeding up the compliance timeline to more quickly protect little lungs.