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Friends -- Please make sure your organization is represented on the letter
below, telling the EPA that their proposed mercury plan
falls far short of what's achievable and necessary to protect public
health. I've included a brief backgrounder on the issue,
and below that the letter to EPA Administrator Leavitt.
Please email me your name, title, organization name, and
city by noon today, April 28, 2004. Thanks in advance
for your help!
Vicki
Levengood
Background: Mercury is a dangerous toxic metal that can cause severe neurological and developmental problems in unborn fetuses and young children whose brains are still developing. People are exposed to mercury mainly by eating contaminated fish. The EPA and forty-three states, including Michigan, have now issued advisories warning people, especially women and children, to avoid or limit eating certain fish because of mercury. But even with these warnings, the EPA estimates that 1 out of 6 U.S. women of childbearing age have potentially unsafe levels of mercury in their blood due to fish consumption. The best way to protect women and children from mercury is to eliminate it from its largest source: power plants. Coal-fired plants are the nation's largest uncontrolled source of toxic mercury, emitting approximately 48 tons each year in the nation. Michigan’s coal fired power plants emit nearly 2500 lbs of mercury pollution annually. According to the Environmental Defense, Michigan ranks second in the nation for mercury "hot spots" - areas where mercury deposition is exceptionally high. Smokestacks spew mercury pollution into the air, where it rains and snows down into our waterways, accumulating in fish and making them unsafe to eat. Amazingly, power plants have yet to be regulated for mercury pollution under federal clean air standards. After years of work by us and other public health advocates, the EPA is now under a deadline to reduce the dangers of mercury from power plants.Two years ago, the EPA's own scientists said current technologies could achieve a 90 percent reduction of mercury from power plants. But the electric and coal industries are pressing hard to avoid limiting their mercury emissions. The EPA's initial proposal was not only too weak to protect public health, but it reclassifies mercury so that it's not considered a "toxic pollutant," despite long-standing, clear evidence of mercury's effects as a developmental toxin. This will allow the EPA to avoid requiring power plants to use the best available technology to reduce emissions, as stipulated by the Clean Air Act. The public comment period on the EPA proposal ends Friday, April 30. April 28,
2004 The Honorable Michael O.
Leavitt Administrator
U.S. Environmental Protection
Agency EPA Docket Center (EPA/DC) Attention Docket ID No.
OAR-2002-0056 Dear Administrator
Leavitt: For more than three decades, the
Clean Air Act has improved public health and protected the environment. We, the undersigned environmental and
public health advocacy organizations (list will reflect actual signers),
strongly support the Clean Air Act and are writing to urge you to take prompt
and effective action, consistent with the Act’s requirements to clean up mercury
and other toxic air pollution from power plants. The Environmental Protection
Agency’s (EPA) current proposals to regulate mercury from utilities fall far
short of what the law requires, and they fail to protect the health of our
children and our environment. We
ask you to carry out the requirements of the Clean Air Act and fulfill your
agency’s duty to issue strong nationally applicable power plant air toxic
regulations. In
January, EPA proposed three alternatives to address hazardous air pollutant
emissions from coal- and oil-fired plants.
Unfortunately, these proposals do not meet the Clean Air Act’s
requirements for cleaning up air toxics.
For example, all of EPA’s proposals permit far more mercury pollution,
and for years longer, than the Clean Air Act allows, while failing to address
over sixty other hazardous air pollutants from power plants - like dioxin and
arsenic - that present an indisputable danger. The
toxicity of mercury has been proven time and again by scientists around the
world. EPA’s own scientists just
released an analysis estimating that 630,000 infants born in the United States
each year may be at risk of irreversible harm from mercury exposure in the womb
– including lowered intelligence, learning disabilities, and vision and hearing
problems. This number is a doubling of previous estimates. In adults, mercury
can cause irreversible damage to the brain and cardiovascular system, as well as
reduce fertility. Mercury
contamination in our lakes and streams is sufficient to have caused 43 states
and one U.S. territory to issue advisories cautioning people, particularly
pregnant women and children against eating certain types of fish, and warning
America’s 41 million recreational anglers that the fish they catch may not be
safe to eat. Like pregnant women and children, subsistence fishermen remain at
high risk from the effects of mercury-tainted fish. We
can address this serious public health problem that threatens our quality of
life. According to many states,
industry experts, and past EPA analyses, precombustion practices and technology
that would dramatically reduce mercury emissions and satisfy legal requirements
are available and cost-effective.
Annual mercury pollution from power plants could be reduced from 48 tons
today, to just 5 tons beginning in late 2007. Additionally, greater demand for the
processes, technology and equipment that remove mercury from smokestacks will
not only lower the cost of emissions reductions, but would benefit U.S. jobs and
our economy. We
are also concerned that your preferred proposal would allow the trading of
mercury credits. While a “cap and
trade” program may be effective and appropriate for non-toxic air pollutants, it
is not permitted by section 112(d) of the Clean Air Act for hazardous air
pollutants. A trading scheme would allow dirty power plants to continue to emit
high levels of mercury by simply purchasing credits from cleaner plants, while
further endangering the health of surrounding communities. As
the Administrator of the EPA, you have a duty to fulfill the requirements of the
Act related to toxic power plant emissions. The newest scientific studies show that
controlling mercury emissions works; surrounding communities and aquatic
ecosystems almost immediately benefit from toxic emissions reductions. We urge
you to finalize a rule as quickly as possible that meets the requirements of the
law, and that does not delay the relief our children and communities need from
exposure to toxic power plant pollution.
The risks to the health of future generations of Americans, and the
associated costs that will be borne by our families and communities far outweigh
the cost to utilities of requiring emissions reductions based on the maximum
achievable control technologies. We
look forward to supporting your efforts to develop standards that protect the
health of women, children, and our communities as quickly as
possible. Sincerely,
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