By: Samantha Schmitz, Project Manager, DC Events and 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 Samantha Schmitz, and I'm the Project Manager, DC Events and Policy, at Moms Clean Air Force. I live in Washington, DC, and I'm here to urge EPA to further strengthen NOx protections for new gas-fired power plants in the final rule to protect vulnerable kids and communities across the country.
Research has found that breathing in NOx can cause inflammation of airways, worsened coughing, wheezing, and asthma attacks among other respiratory ailments. I have struggled with severe asthma throughout my entire life and know that I’m not alone as 25 million other Americans have asthma as well. Asthma attacks have left me hospitalized several times, which has not only had a profound impact on me but my entire family. If you ask my parents, they’ll tell you about the trauma of watching a young child gasp for air and struggle to breathe in an emergency room and even just at regular doctor’s visits after.
To make matters worse, NOx pollution is especially dangerous because it’s a “precursor pollutant” that contributes to the formation of ground-level ozone and particle pollution—both of which are dangerous, health-harming pollutants themselves. Ozone and particle pollution both irritate the lungs, triggering asthma attacks, coughing, and shortness of breath. When I hear this, it brings me back to the late nights in emergency rooms as a kid hooked up to a nebulizer, and as an adult, I can’t help but think about if NOx contributes to the many times I’m outside and struggle to breathe.
The American Lung Association’s State of the Air Report gives Washington, DC, a letter grade D for ozone and C for particle pollution already. I fear that if a new gas-fired power plant were to be built nearby without the proper safeguards, these grades would drop exponentially and so would the health of our communities.
Additionally, a 2022 review of multiple studies found that elevated levels of nitrogen dioxide (NO2), a type of NOx, are associated with adverse pregnancy and birth outcomes. Exposure to soot and smog from NOx as a precursor pollutant furthers the risk of preterm birth and low birth weight. And from there, exposure to NOx pollution over time can cause asthma in children. These alarming statistics are ones that I can’t help but fixate on as I consider having children in the near future myself.
The timeliness of strong protections from NOx could not be more imperative as these standards have not been updated in almost 20 years. When they were last updated in 2006, I was in elementary school. To me, this is an issue of generational justice for Gen Z and all of the generations to come as your decisions today will impact our health and safety far longer into the future. As you're considering the safeguards around power plants that have yet to be built, you must keep young adults, children, and future generations at the forefront of your considerations.
Notably, the science and existing technology demonstrate that gas power plants are capable of achieving greater reductions in pollution with the same technologies proposed in the rule. Although I appreciate EPA’s current proposal, I strongly urge you to enshrine stronger NOx protections to protect the health and safety of all communities and especially future generations. Thank you for your time.