ASPPH and its partners in the Healthy Air Coalition on Wednesday submitted detailed comments on the EPA’s proposed “National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units – Reconsideration of Supplemental Finding and Residual Risk and Technology Review” (EPA-HQ-OAR-2018-0794). The comment letter said, “The Mercury and Air Toxics Standards (MATS) is one of the most important public health protections put in place by the US Environmental Protection Agency to reduce these emissions of hazardous air pollutants (HAPs) in the communities we serve. Our organizations fully support the current standards and strongly disagree with EPA’s determination that it ‘is not ‘appropriate and necessary’ to regulate HAP emissions from power plants under Section 112 of the Clean Air Act.” The American Lung Association took the lead in drafting the response.
The letter also asserts that, “Fundamentally, our organizations believe that EPA has no authority to reverse the ‘appropriate and necessary’ finding, and no authority to either to remove the coal- and oil-fired power plants from the Act’s list of sources that must be regulated without satisfying the criteria in section 112(c)(9), or to rescind MATS…. [W]e are …keenly aware of the harmful health effects of air pollution. Research has shown that these toxics are especially dangerous because of the harm they can cause to the respiratory, cardiovascular, nervous, endocrine, and other essential life systems within humans. Toxic emissions can even cause developmental disorders and premature death.”
ASPPH and its allies said, “This proposal to revoke the ‘appropriate and necessary’ finding seeks to undermine the MATS and other lifesaving standards being challenged in court or weakened or overturned by EPA. Anything less than the full continued enforcement of these standards could result in increased emissions of deadly pollutants, and health impacts and premature deaths that should have been prevented under these widely supported, fully implemented safeguards. Our organizations continue to oppose any weakening of the standards, including the creation of a subcategory for bituminous coal use as a fuel in electric utilities. EPA’s proposal to consider a subcategory for such fuels would allow the covered plants to emit greater quantities of acid gases instead of complying with the standards that already apply to these plants.”