Comment submitted by Mothers & Others For Clean Air

I’m a pediatrician who has specialized in environmental health for 30 years. I am submitting a comment on behalf of Mothers and Others For Clean Air. We strongly oppose EPA’s proposal to change the definition of “begin actual construction” for the New Source Review process. This change would damage children’s health, and it is harmful for the whole community. This proposal would let companies begin construction before they get an air pollution permit. Companies could do major construction before parents and communities have any input on what is happening to them. Right now, companies can’t break ground until they get their air pollution permit. As part of the permit process, documents and plans have to have full public review, including expected increases in air pollution and control methods the companies plan to use. Parents and community members are able to attend hearings or submit comments. But under this proposal, companies could cut down trees, build foundations, build roads, electricity, plumbing, drainage and other site infrastructure, before they apply for a permit. Because the cost and investment could be in the millions, it will be difficult for communities to stop construction. They will have no input on whether the facility is near schools, playgrounds, or homes. This would severely damage children’s health. The likely industries that would use this plan include data centers, power plants, petroleum and plastic refining, processing, and manufacturing plants, other fossil fuel infrastructure, and biomass. All of these industries make air pollution that consists of PM2.5, NOx, VOCs, and other hazardous air pollutions. PM2.5 damages children from before they’re born all the way through the teen years. It causes preterm birth, low birthweight, decreased cognitive development, damaged (stunted) lung growth, it causes asthma and asthma attacks, it affects children’s ability to learn in school, and it affects children’s mental health. PM2.5 causes lung disease, heart disease, strokes, dementia, and cancer in adults. VOCs cause many different effects depending on what chemical they are. Some cause headaches and other central nervous system problems, some cause cancer, some cause other problems in the body. This proposal fails to protect vulnerable groups, such as children, elders, and communities of color, by preventing the opportunity for public input before construction begins. It is especially harmful to communities that have historically been excluded from economic and cultural opportunities, and still lack the resources to be able to address a built environment that damages health. The whole point of New Source Review in the Clean Air Act is to allow communities the ability to review plans and weigh in before anything is built. The whole point of the Clean Air Act is to protect our children’s and our health. EPA’s primary mission is to protect the environment in order to protect our health. This proposal does not protect health, it damages it. It is the exact opposite of what EPA is supposed to do. Children do not choose where they live, where they go to school, or whether the air they breathe is healthy and clean. They do not decide whether industrial facilities are across the street from their schools, playgrounds, or homes. Adults make these decisions for them, and we have the ethical and fiduciary responsibility to make sure that all children in the U.S. have the opportunity to learn, grow and thrive. This proposal is the opposite of protecting health, it undermines the purpose and intent of the Clean Air Act and New Source Review. Therefore, I and Mothers and Others For Clean Air strongly oppose this proposal. Scientific studies will be sent by email to avoid copyright problems.