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Comments on the Interstate Air Quality Rule Proposed by the U.S. EPA, Docket ID No. OAR-2003-0053

Comments by Citizens Campaign for the Environment
Submitted to the United States Environmental Protection Agency

March 30, 2004

Citizens Campaign for the Environment (CCE) is an 80,000 member, not-for-profit, non-partisan advocacy organization working to protect public health and the natural environment throughout New York State and Connecticut. CCE operates from five regional offices across New York State and interacts with New York and Connecticut residents to advance sound environmental policies and practices throughout the year.

Pollution caused from Acid Rain has been one of CCE’s highest priorities for over 10 years. New York, Connecticut and the rest of the Northeast have long been a victim to pollution coming from Midwest power plants. Nitrogen Oxides (NOx) and Sulfur Dioxides (SO2) released from these power plants are major sources of the acid rain problem that the entire Northeast has and is suffering from. The USEPA has proposed the Interstate Air Quality Rule (Docket ID No. OAR 2003-0053) to address the problem. CCE offers the following comments on the proposed rule:

Comments

Citizens Campaign for the Environment is very pleased that the USEPA has proposed the Interstate Air Quality Rule. For over 10 years, CCE has advocated that Congress pass legislation to make significant reductions on NOx and SO2 emissions, which are two pre-cursors to acid deposition. Although CCE is disappointed that Congress has been unable to pass legislation to fix the problems associated with acid rain, we strongly support the adoption of the Interstate Air Quality Rule proposed by the USEPA. A 65% reduction in NOx and 70% reduction in SO2 implemented over the next 10 years will substantially alleviate the problems associated with Acid Rain.

Market-based cap and trade programs, such as the one proposed in the Interstate Air Quality Rule, have proven to be very effective. In fact, the existing cap and trade program currently in effect for SO2 has been very cost effective and industry has an almost perfect record of compliance. In a report to Congress in January of 2004, the Research Council of the National Academy of Science recommended that when regulating multiple pollutants from similar sources, the EPA should use a market-based cap and trade approach to address regional transport of pollution.

The proposed rule will substantially reduce NOx and SO2 emissions, which will have profound benefits to both human and ecological health. These benefits include, but are not limited to:

Ecological benefits
The benefits to the ecological health of New York, Connecticut, and the entire Northeast will be very significant.

• The proposed rule will reduce the airborne deposition of nitrogen to watersheds, where nitrogen contributes to crop damage and eutrophication of water bodies like the Long Island Sound and Chesapeake Bay. Atmospheric deposition is a rapidly growing anthropogenic source of biologically available nitrogen in marine and coastal systems causing massive die-off of plants and animals as well as degradation of essential coastal ecosystems habitat (e.g. seagrass beds). Decreased inputs of nitrogen to estuarine and coastal water can have significant ecological benefits including an increase in biological diversity.
• The New York State Department of Environmental Conservation has identified the single largest non-point source cause of poor water quality in NY as acid rain. The reductions in NOx and SO2 will significantly improve the health of our lakes and streams. As estimated by the USEPA, the amount of chronically acidic lakes in the Adirondacks will be reduced to zero by the year 2030. Throughout the northeast, the amount of chronically acidic lakes will be reduced from 6% to 1%.
• The proposed rule will allow for healthier forests in the northeast. A substantial reduction in NOx and SO2 will directly impact the health of plant tissue and soil conditions in the forestlands of the northeast.

Human Health Benefits
The USEPA estimates that every year, 10,000 Americans lose their lives prematurely due to power plant emissions. These reductions of NOx and SO2 would cut ambient air concentrations of PM 2.5, which would lead to a lower incidence of cardio-respiratory illness and death associated with PM 2.5 pollution. Hence, significant reductions in emissions will benefit human health. In addition, measures taken to reduce emissions of NOx and SO2 will have the co-benefit of reducing mercury emissions from power plants. EPA studies have shown that human consumption of fish contaminated with mercury lead to health problems such as neurological disorders and birth defects.

Benefits to Buildings
Approximately 900,000 properties of aesthetic and historical value are at risk for damage from air pollution including sulfates. The new rule will aid historic preservation by reducing acid and particulate deposition that damages cultural monuments and other materials.

Benefits to National and State Parks
Pollutants emitted from power plants greatly contribute to decreased visibility throughout different parts of the eastern United States. The new rule would add to visibility improvements in our scenic national parks, notably the Shenandoah and Great Smoky Mountain national parks. In addition, the Adirondacks will substantially benefit.

Economic Benefits
The economic benefits derived from recreational and commercial fishing and shellfishing, farming and tourism are enormous.

RECOMMENDATIONS
CCE offers the following recommendations for the proposed rule:

1. Accelerate and Increase Emission Reductions

Although the proposed reductions in emissions are significant, CCE recommends that the EPA consider even deeper cuts in NOx and SO2 emissions. CCE also recommends that these cuts be implemented on a shorter timetable.

With the severe ecological degradation that the entire Northeast has endured due to acid rain, the need for an accelerated rate of recovery is vital. Faster and deeper cuts in emissions will hasten the ecological recovery of places such as the Adirondack Park.

2. Lower Emissions of NOx in Summer Season

CCE recommends that the USEPA pay special attention to Nitrogen Oxide emissions during summer months. The adverse effects of ozone on human health are especially apparent in summer, and therefore, NOx emissions should be regulated appropriately.

3. Monitor the Program

The success of this program will be very reliant upon adequate monitoring. The EPA must make it clear to Congress and the Administration that continued monitoring of acid deposition is essential to assess both the success of the program and where it may be improved. In order for this to occur, Congress and the Administration must continue to make sufficient funds available throughout the course of the program. Evaluating the long-term environmental response to the emission reductions will require the continuation and expansion of networks and data collection efforts. These must include long-term monitoring of air quality, wet and dry deposition, ecological changes of streams and lakes, soil chemistry, and the health of critical plants and animals.

Thank you for your careful consideration of CCE’s comments. We look forward to the successful implementation of the Interstate Air Quality Rule and ultimately ending the detrimental effects of acid rain.

Respectfully Submitted,

Brian Smith
Program Coordinator