In December, the EPA proposed to stop regulating hazardous air pollutant (HAP) emissions from power plants altogether under the Mercury Rule (Mercury and Air Toxics Standards), stating that it was no longer “appropriate and necessary” to do so after a limited cost-benefit analysis. Since implementation in 2011, this standard has been credited for saving approximately 17,000 lives per year and has been extraordinarily effective, with 99.9 percent of coal and oil-fired power plants in compliance and in reducing airborne exposure to mercury by 81 percent. Because of its imminent threat to the health of our nation, particularly people of color, women, and children, Sojourners felt called to take action on this issue. The morning of the hearing, we gathered with other people of faith to pray in front of the EPA, then testified before the EPA, urging for the Mercury Rule to be upheld and for the agency to live up to its mission to ‘protect human health.’ Below is the text from my testimony as Sojourners’ Climate Justice Coordinator:
Good morning. My name is Melody Zhang. I am a Christian and a member of Young Evangelicals for Climate Action, and the Climate Justice Coordinator for Sojourners, a Christian advocacy organization. We are motivated by our Christian faith to act as responsible stewards of creation and to protect the abundance and diversity of the fullness of life by advocating for alternatives to fossil fuel energy which are more equitable and just, for the sake of the most vulnerable among us. This includes women, children, and the poor. In the U.S., coal-fired mercury pollution threatens the health and well-being of these people groups most severely, and in disproportionate ways. That is why I am compelled to testify before you today.
In its briefing regarding the changes proposed to be made to the Mercury and Air Toxins rule, the EPA states that the financial cost of regulating hazardous air pollutants for coal and oil-fired power plants to be greater than the financial benefits, and because of this it is no longer “appropriate and necessary” to regulate HAP emissions. It is my understanding that this is the primary reason for removing these standards. As a Christian, I urge you today to consider all of the real costs implied in removing these standards, including public health costs to our nation’s vulnerable populations. Real costs are insidious, and cannot be seen immediately, but they multiply over time.
The MATS rule has been extremely effective in its 8 years of implementation. 99.9 percent of plants are already in full compliance with the rule and because of this, exposure to mercury nationwide has already been reduced by 81 percent. In fact, prior to MATS Hazardous Air Pollutants installment, 1 in 6 babies born were exposed to alarming amounts of mercury, and it is reported that the implementation of this guideline saves approximately 11,000 lives every year. As such, there has been unusually intense opposition to this proposed rule change from all ends of the political spectrum, and for good reason.
I am here to remind you that mercury is a highly potent neurotoxin that, when ingested by pregnant women, crosses the placenta and results in irreversible brain damage in unborn children. There are no known safe levels of mercury. This means that any amount of exposure to mercury is a real threat to the development of any child in utero and early in life. Even for adults, any amount of exposure to mercury can have toxic effects on the nervous, digestive, and immune systems, and can trigger tremors, memory loss, cognitive and motor dysfunction. It can be fatal. No wonder it is listed by the World Health Organization as one of the top 10 chemicals of major public health concern.
I call Detroit my home. As some of you may know, there is a zipcode in Detroit well-known for being the most polluted area in the entire state of Michigan, and that is 48217. They are my neighbors. Over the last 8 years, they have benefited from the HAP MATS rule and were able to breathe in cleaner air because of it. Now 44 percent of them live in poverty, 82 percent are black, and 100 percent of them will have their livelihoods jeopardized if this life-saving standard is removed. I cannot sit idly by and watch my neighbors bear the brunt of this rule change. I must speak up for them because this is a classic issue of environmental justice.
EPA, your very mission is to protect human health and the environment. When I hear the words protecting human health, I think of the example of Jesus, who both proclaimed and demonstrated the gospel by performing acts of spiritual and physical healing. Jesus always acted out of compassion for and intentionally went towards the overlooked and underheard. Each person conceived is of inherent and equal value and dignity, and all human life is worthy of protection. We must make more of an effort to care for all of life.
Today I challenge you to live up to your mission by keeping the hazardous air pollutants rule for the sake of the flourishing of our neighbors, our children, and ourselves. Doing the opposite of this could only be called irresponsible and reckless. Today I urge you to respond compassionately. I believe this act will be paid back tenfold.
We were glad to be speak out at the EPA hearing and were joined with more than 30 other faith leaders on March 15 in prayer and petitioning against the rollback of the Mercury Rule. The agency will take public comment until April 17. Please join us in acting faithfully by submitting a comment on the EPA proposal here, using the sample comment provided below. We will continue to watch and pray for the EPA’s final decision in the coming weeks.
Uphold HAP regulations under MATS to protect human health
As a Christian, I am deeply concerned by the EPA’s proposal to stop regulating hazardous air pollutant emissions under the MATS Rule.
Since implementation in 2011, this standard has been credited for saving 17,000 lives every year and has proven extremely effective in reducing airborne exposure to mercury by 81 percent. Any amount of exposure to mercury can have toxic effects like cognitive and motor dysfunction, memory loss, and damage to the nervous, digestive and immune systems. Because of its imminent threat to the health of our nation, particularly to people of color, women, and children, I implore you to uphold the regulations on hazardous air pollutants under MATS and ‘protect human health’, as it states in your very mission.
I am reminded of the story Jesus tells in the gospels about the one lost sheep: “Doesn’t he leave the ninety-nine and go after the lost sheep until he finds it? When he finds it, he joyfully puts it on his shoulders and goes home.” Jesus always went intentionally towards the overlooked and treated each and every person as if their life were worthy of protection. EPA, I challenge you to live up to your mission to ‘protect human health,’ considering all of the real costs involved in removing these standards. I urge you to respond compassionately to the thousands of voices who have already cried out against this plan by keeping the hazardous air pollutants rule.