By: Vanessa Lynch, Pennsylvania Field Organizer, 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 Vanessa Lynch and I am a Pennsylvania Field Organizer for Moms Clean Air Force. Moms Clean Air Force is an organization of over 1.5 million parents united against air pollution - and the urgent crisis of our changing climate - to equitably protect children’s health. I live in the Pittsburgh area in southwest Pennsylvania with my husband and two children.
For over a decade, Moms Clean Air Force has been advocating for strong protections from fossil fuel power plant pollution. EPA’s efforts to address NOx are greatly appreciated, and in this proposed rule, I appreciate the use of continuous emissions monitoring. But gas power plants are capable of achieving greater reductions in pollution with the same technologies proposed in the rule. Pennsylvania families like mine deserve the strongest protection possible from health-harming pollution. EPA must strengthen NOx protections in the final version of the rule and must expand the use of continuous emissions monitoring.
Pennsylvania was ranked 48th in the nation for the rate of growth of renewable energy sources over the past decade by the PennEnvironment Research and Policy Center. PJM Interconnection is a little-known company that operates the electric grid for the Pennsylvania region and beyond, coordinating the flow of electricity and running wholesale markets that determine the mix of energy sources that power our homes and businesses.
PJM has created a bottleneck where renewable energy projects are not being allowed to move forward, ultimately leading Governor Shapiro to intervene and demand changes that would lead to diversity and reliability in our energy sources in the Commonwealth. Fossil fuel un-reliability and PJM’s failure to speedily connect new clean resources to the grid are creating severe problems.
Why does this matter? Appalachia, where I live, is at a disproportionately high risk of increases in the number of new fossil fuel-fired power plants generating NOx pollution, and is especially vulnerable to any weaknesses in the NOx standards. According to the U.S. Energy Information Administration, most new natural gas plants are being built in the Gulf Coast, Appalachia, and Florida.
A systematic review study assessing over 32 million births found exposure to soot and smog, for which NOx is a precursor pollutant, is associated with an increased risk of preterm birth and low birth weight. As a mother who has experienced my son being born early and spending time in the NICU, I can tell you watching your brand-new infant struggle to breathe is frightening.
For the first decade of his life, my son was prone to breathing difficulties when sick leading to the need for nebulizer treatments. When he was six months old, I sat in the waiting room of the local children’s hospital in the middle of the night for over 6 hours watching his chest retract as he struggled to breathe while we waited to be seen by a doctor.
Decreasing NOx pollution for fenceline communities can protect other families from experiencing what I did. This is why continuous emissions monitoring is vital for the protection and enforcement of the NOx standards. In addition to strengthening NOx protections in the final version of the rule, please expand the use of continuous emissions monitoring to all covered units.
EPA’s NOx standards for new gas power plants haven’t been updated since 2006, making updated protections for Appalachian families like mine long overdue. Thank you for working on this vital standard, and I encourage you to create the strongest possible rule for the sake of Pennsylvania’s children.