Connecticut Coalition for Environmental Justice

Electrical Power Plants

Good Morning Ladies and Gentlemen. My name is Dr. Mark Mitchell. I am a public health physician specializing in environmental health. I am also President of the Connecticut Coalition for Environmental Justice. Environmental Justice mans that no community, regardless of income, race, or ethnicity should bear a disproportionate share of environmental burdens due to corporate or environmental policies. CCEJ is a coalition of more than 30 organizations concerned about the strong correlation between the number of environmental hazards located in a Connecticut town and the percentage of low income people and people of color in that town, as documented by the Connecticut Department of Environmental Protection. In addition, we see a higher rate environmentally related disease, such as asthma, diabetes, and cancer in these communities. We believe that this is environmental racism. Connecticut Coalition for Environmental Justice was started to attempt to reduce the disparity in environmental hazards and associated environmental disease between communities of color, low income communities and the rest of Connecticut. This is why we are very concerned about the Filthy Five power plants and the Governor's Executive Order 19.

We are pleased with the DEP proposal to address 61 power generators that are exempted from current air pollution standards rather than only five. These power plants are disproportionately in communities of color. Bridgeport and New Haven have the largest power plants in Connecticut and consequently, have the highest amounts of air pollution. Although asthma is not a reportable condition, and we therefore do not have information for all towns, we do know that we have very high rates of asthma in several Connecticut cities. Twenty five percent of all children in New Haven have asthma according to a report by the Connecticut Voices for Children. This is almost three times the national average. Several neighborhoods in Bridgeport report similar rates. Hartford has the highest documented asthma rates in the country according to a preliminary analysis be the Connecticut Children's Medical Center (all children have not yet been screened). Because of the disproportionate amount of air pollution and air toxins in these towns, we should do everything possible to decrease air pollution from plants located there. Although power plants have not been proven to cause asthma, the air pollution that they produce has been proven to cause asthma attacks in people who already have asthma. Nitrogen Oxides (Nox) and Sulfur dioxides (Sox) are known asthma triggers. In addition, particulate matter is known to trigger asthma, and fine particles (PM 2.5) have been directly correlated with daily death rates in elderly people and children due to respiratory and cardiac factors.

Although we think that the proposed regulations are a marked improvement on the current situation in terms of environmental justice and health effects from air pollution, we have some serious questions about specific portions of the proposal. We are particularly concerned about the provisions that allow for pollution credit trading. If this provision is fully utilized, we will not see the local reduction in asthma triggers from the reduction in Nox and Sox that the regulation promises. In addition, we are concerned that Facility averaging will average over a period of longer than one month. Physically, your body responds to peaks of air pollution as well as average exposures. If facility averaging is for longer than one month, it will be of minimal use in protecting public health. Ideally, we would like to see daily averaging.

In addition, we would like to make sure that Bridgeport Energy, which is co-located with the Bridgeport Harbor Station is not averaged in with this separately owned power plant.