Testimony for Georgia’s Department of Natural
Resources Regarding Proposed Amendments to Rules for Air Quality Control,
Chapter 391-3-1, Clean Air Mercury Rule Jennette Gayer,
Environment Georgia
Good Afternoon
and thank you for the opportunity to speak on the important issue of reducing
mercury emissions from coal-fired power plants and Georgia’s state-specific mercury
reduction rule. My name is Jennette Gayer, I’m an Advocate with Environment
Georgia. As you may know, Environment Georgia is a statewide non-profit,
non-partisan environmental advocacy organization.
Summary: Given the public health
and environmental threats posed by mercury pollution from Georgia’s coal-fired
power plants, the weakening of the Clean Air Act’s federal mercury pollution
reduction requirements, and the availability of mercury pollution control
technologies, Environment Georgia appreciates EPD’s state-level efforts to
draft a rule that will cut mercury pollution from Georgia’s coal-fired power
plants. Unfortunately, serious loop holes and flaws continue to exist in the
proposed rule and we urge the state to address these concerns as they move
forward in implementing this much-needed proposal.
Trading is Inappropriate for Mercury:
Mercury is a
potent neurotoxin that poses significant human health hazards. Mercury can
affect multiple organ systems, including the nervous, cardiovascular, and
immune systems, throughout an individual’s lifetime. In 2000, the National
Academy of Sciences found the evidence of neurodevelopmental effects of mercury
to be “extensive.”
Mercury hot
spots are those areas with mercury deposition higher than in surrounding areas,
and there is both significant evidence that hot spots exist and that coal-fired
power plants create hot spots in nearby communities. It follows that the
communities near or in a mercury hot spot will face an increased public health
threat due to increased mercury levels.
For example,
initial results from an ongoing EPA study show that 67 percent of the mercury
in rain collected at a monitoring site in Steubenville,
Ohio originated from coal-burning
power plants within 400 miles of the site.
Conversely,
studies have also shown that when mercury emissions are reduced from a source,
the surrounding environment shows lowered mercury levels. Specifically, a 2003
study by the state of Florida, the EPA and the
U.S. Geological Survey found that the levels of mercury found in largemouth
bass and other wildlife in the Everglades have
declined about 80 percent since state and federal agencies required municipal
and medical waste incinerators to cut their mercury emissions.
The effect of
allowing facilities to transfer or trade mercury allowances inside or outside
of Georgia
will be communities that are threatened by these high concentrations of mercury
pollution or ‘hot spots’. The hazards associated with mercury contamination
make this outcome unacceptable and while technology requirements will
eventually force the reduction of mercury pollution from most plants in Georgia, this would seem to be the worst type of
NIMBYism, since mercury allowances that we allow to leave our state may well
come back to Georgia
via waterways or seafood imports. Also, we should be concerned about the health
of all children, not just those growing up in Georgia.
An Emissions Cap is Necessary:
Additionally,
we urge EPD to adopt an emission cap in addition to the current required
technology standards. A clearly defined emission cap will make citizen
enforcement possible while the existing reporting which is based on technology
operation standards will set hurdles that even savvy citizen activists, media
and other interested parties will find daunting.
The EPA
acknowledged in 2001 that complying with the Clean Air Act and requiring
maximum achievable mercury emissions reduction from power plants would result
in a 90 percent cut within three years. We see no reason to not adopt a similar
cap—for all plants large and small.
Further Mercury Testing is Needed
Finally, current
information on mercury deposits in fish and humans in Georgia are
faulty at best. We urge the EPD to increase their fish testing requirements in
the proposed rule, stepped-up sampling should be supported by a polluter pays
type fee on the regulated community.
Thank you
again for the opportunity to speak today and thank you to the EPD for the steps
that have been taken on this important issue. We look forward to working out
these critical details.
