In April, Mothers & Others For Clean Air’s Dr Anne Mellinger-Birdsong spoke at an EPA hearing about a proposed rule to require stronger air pollution controls on power plants and industrial facilities that make air pollution that affects the health of people in neighboring states. The rule is about ozone, but it regulates nitrogen oxide because it is the main chemical that turns into ozone. The rule requires more facilities to install pollution controls, and it requires facilities that have installed controls to actually use them. (Yes, you read that right.)
Good neighbors don’t make pollution that harms or kills their neighbors!
#HealthyAirIsHealthCare #CleanAir
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My name is Anne Mellinger-Birdsong. I’m a pediatrician and I specialize in environmental public health. I’m speaking on behalf of Mothers And Others For Clean Air. We support this proposed rule, but we urge EPA to make it stronger and require compliance sooner. This rule is based on 2015 ozone standards and is long overdue, and as a result people’s health has been damaged for far too long.
Ozone is a hazardous gas that forms from other chemicals every day in heat and sunlight. Some of those chemicals are nitrogen oxides. Any time we burn any kind of fuel, nitrogen oxides are produced, because air is 78% nitrogen and nitrogen oxides are always a by-product of burning anything.
In addition to being a substrate for ozone formation, nitrogen oxides directly damage health. In a study last year, Meng and colleagues found that in the United States, nitrogen oxides cause 1.6% of all deaths.(1) Nitrogen oxides cause hospitalizations and emergency visits, increase the number of asthma attacks, affect heart disease, and as Gauderman and colleagues found, they damage children’s and teens’ lung growth.(2) Another study in the Journal of the American Heart Association found that nitrogen oxides increase blood pressure in children.(3)
Ozone is also very damaging to health: it causes asthma attacks, affects heart disease, and makes emphysema worse. Where I live Atlanta, we have first-hand experience seeing what happens when we have cleaner air and less ozone: during the 1996 Olympics our ozone went down because there was less traffic, and our children had fewer asthma attacks, needed less asthma medicine, and had fewer hospitalizations for asthma.(4) Another recent study found that long-term higher levels of ozone caused as much emphysema progression as 29 pack-years of cigarettes.(5)
This rule will not only help people in downwind states, it will also help people in communities that had power plants and industrial facilities built right next to them. Because of our country’s environmental racism, the fence-line communities are often communities of color, and the pollution from the power plants and industrial facilities exacerbates health inequities.
Ozone and nitrogen oxides cause so much health harm, that this rule will help prevent many deaths, hospitalizations, asthma attacks, lung damage, heart disease. Reducing air pollution is so good at preventing disease and death, that it can be seen as a form of health care. That’s why at Mothers And Others For Clean Air we say Healthy Air Is Health Care.
We urge EPA to expand the covered facilities to include all power plants and all industrial sources in both upwind and downwind states. That will protect the health of more people including the most vulnerable children and communities.
It doesn’t make sense to allow facilities to buy emission allowances when they already have pollution controls installed. They could be running their already installed pollution controls, instead of continuing to damage neighbors’ health and lives. This proposed rule gives facilities that already installed pollution controls too long to comply. The pollution controls are installed, and the facilities should be required to use them by May 2023.
Because this rule is overdue, facilities are only now being required to meet 2015 standards, even as the next review of ozone begins. Every year we learn more and more about how damaging ozone and nitrogen oxides are to human health. Therefore, this rule should be as strong as possible, and implemented as quickly as possible. There is no need to continue to allow vulnerable children and communities to suffer from damaged health when pollution controls could be installed sooner.
In summary, Mothers And Others For Clean Air supports this proposed rule and we urge EPA to make it stronger and implement it sooner.
References:
1. Meng, et al. Short term associations of ambient nitrogen dioxide with daily total, cardiovascular, and respiratory mortality: multilocation analysis in 398 cities. BMJ 2021;372:n534. https://doi.org/10.1136/bmj.n534
2. Gauderman, et al. Association of Improved Air Quality with Lung Development in Children. N Engl J Med 2015;372:905-13. DOI: 10.1056/NEJMoa1414123
3. Huang et al. Effects of Ambient Air Pollution on Blood Pressure Among Children and Adolescents: A Systematic Review and Meta-Analysis. J Am Heart Assoc. 2021;10:e017734. DOI: 10.1161/JAHA.120.017734
4. Friedman, et al. Impact of Changes in Transportation and Commuting Behaviors During the 1996 Summer Olympic Games in Atlanta on Air Quality and Childhood Asthma. JAMA 2001;285:897-905. https://jamanetwork.com/journals/jama/fullarticle/193572.
5. Wang et al. Association Between Long-term Exposure to Ambient Air Pollution and Change in Quantitatively Assessed Emphysema and Lung Function. JAMA. 2019;322(6):546-556. doi:10.1001/jama.2019.10255
04/21/2022
