Did you ever wonder about the expression mad as a hatter? Until the 1940s, hatters used nitrates of mercury to soften the furs used to make beaver and other felt hats. By breathing these vapors of mercury, many of the hat makers developed the symptoms of mercury poisoning.

We now know that mercury is a cumulative poison that causes kidney and brain damage. Physical symptoms include trembling (known at the time as hatter's shakes), loosening of teeth, loss of co-ordination, and slurred speech; mental symptoms include irritability, loss of memory, depression, anxiety, and other personality changes. This was called mad hatter syndrome.1

Today, the biggest source of mercury in the environment is no longer hat manufacturing, but the burning of coal that contains mercury. The mercury falls from the sky and gradually accumulates in the tissues of animals. Forty-five U.S. states and territories now issue mercury advisories warning children and pregnant women to avoid eating fish that concentrate mercury pollution.2

The U.S. Environmental Protection Agency (EPA) estimates that as many as 630,000 fetuses each year may be exposed to unsafe levels of mercury in pregnant women's blood. Children exposed to even low levels of mercury in the womb can suffer developmental delay and permanent damage to their motor functions, language skills, visual/spatial abilities, and memory.3

The EPA and the Food and Drug Administration have issued for the first time a draft joint advisory on methyl mercury in fish and shellfish. This advisory warns pregnant women to limit their consumption of fish, including canned tuna. It also warns that parents should limit the consumption of fish by children. But not only pregnant women and children should be careful. An astonishing 50 percent of Americans who eat fish regularly exceed the mercury health limit, and 10 percent exceed the limit by a factor of four. Adults are also susceptible to developing heart, kidney, and immune system disorders because of mercury consumption. Anglers and certain ethnic groups who eat large amounts of fish face two to five times these health risks. Clearly, dramatically curbing mercury pollution will improve all of our lives.4

Unfortunately, while two parts of the federal government are warning about the dangers of mercury, the Bush Administration is moving ahead to weaken the Clean Air Act regulations related to control of mercury.

Power plants are the largest source of mercury in the environment. Mercury pollution is not a by-product of combustion, but rather is a metal present in coal that is released when the coal burns. Different types of coal are contaminated with different amounts of mercury. Current law (section 112 of the Clean Air Act amendments of 1990) requires that toxic air pollutants such as mercury be controlled to emission levels that can be achieved by the "maximum achievable control technologies" (MACT) within three years after regulations are finalized. Each new power plant is required to limit mercury emissions to the lowest level by 2008. Existing power plants are to reduce their emissions to the average of the best performing 12 percent of power plants.5

In December 2001, the EPA informed the electric power industry that they believed that the MACT standard would result in a 90 percent reduction in mercury from power plants, that is, a reduction from 50 tons a year to five tons per year. This reduction was to occur at each plant and no trading of emissions between plants was to be permitted.

But on January 30, 2004, the Administration announced its prefer- ence for a much weaker proposed standard. Instead of implementing the standard by 2008, it proposed to extend the timeline by a decade, to 2018. Instead of reducing annual releases to five tons a year by 2008, it would reduce emissions to 15 tons a year by 2018.

Delaying the standard for 10 years could allow nearly 500 tons more mercury to be dumped into the environment than if the standard were adopted in 2008, and an additional 10 tons more per year would still be dumped into the air after the standard kicks in. Another option proposed not only more mercury pollution but would allow utilities to trade emissions so that some areas' plants would not be cleaned up at all.6

Initially, the Environmental Protection Agency had planned to stop receiving comments on these regulations by March 30, 2004, but public outcry has forced the agency to extend the comment period to June 29, 2004. So far, nearly a half million citizens, and some 50 civic, environmental, and faith groups have petitioned the Environmental Protection Agency for stronger standards. This is the largest response ever to an EPA rule making.7

Fortunately, the smaller sources of mercury in the environment-mercury in thermometers, in fluorescent bulbs, in light switches, and in batteries-are being quickly controlled. The control of municipal waste and hospital incinerators quickly reduced the amount of waste from those air pollution sources.

It is the largest air pollution source-power plants-that has eluded control. Power plants continue to spew unlimited amounts of mercury into the air. Because this mercury "bio-accumulates" in animals like fish, it will be a bigger and bigger health problem until we actually reduce the amount of mercury being dumped into the environment by the utility industry.

The costs of inaction are great. At a recent public forum in Massachusetts, scientists from that state summarized the dangers of doing nothing and noted that state action alone, though important, is not enough. A Tufts University study found that the direct costs of environmentally-attributable neurobehavioral disorders, such as those caused by mercury pollution (in Massachusetts alone) total between $40 million and $150 million each year, with indirect costs totaling an additional $100 million to $400 million. Massachusetts and Connecticut are moving now to require an 85 to 95 percent reduction in mercury emissions in the next five to nine years. Such state-level progress is encouraging, but air pollution crosses borders and so real progress can only come from reductions made throughout the country.

Dr. Steve Petron, Board Member of the National Wildlife Federation and Senior Ecosystems Scientist for CH2M Hill, has demonstrated how toxic mercury pollution from power plants harms our nation's aquatic wildlife. Species that depend on fish for food are the most at risk. Loons, bald eagles, otters, amphibians, and other animals are already facing or could soon face decline.

And lastly, Dr. Praveen Amar, Director of Science and Policy for the Northeast States for Coordinated Air Use Management (NESCAUM), represented state air quality regulators by stressing that mercury control technologies are available and affordable, and by expressing the need for smart federal environmental laws to drive technology innovation and application. As a recent NESCAUM report found, "Where strong regulatory drivers exist, substantial technological improvements and steady reductions in control costs follow."8

Suggested Action:

In response to overwhelming public request for more time to comment, the EPA has extended the time for comments (as noted above) to June 29, 2004. Send your comments to Docket ID No. OAR-2002-0056.

Admin. Mike Leavitt
Environmental Protection Agency
1200 Pennsylvania Ave
Washington, D.C. 20460
Attention Docket ID No. OAR-2002-0056

Dear Administrator Leavitt,

I am writing to urge you to cut mercury emissions from power plants by 90 percent by 2008, without subjecting children in vulnerable communities to the risk of toxic hotspots. As a Presbyterian, I believe that God expects us to care especially for the most vulnerable of God's children. Pregnant women carrying unborn children and new born children are the most affected by mercury pollution.

Your agency has identified coal-fired power plants as the largest industrial source of mercury in our environment. Mercury pollutes our nation's lakes, rivers, and coastlines and contaminates fish in at least 45 states.

Scientists within your agency now estimate that 15% of American women of childbearing age may be carrying mercury levels that are unsafe for their future children. Mercury threatens healthy brain development, and can cause lifelong and irreversible neurological damage in fetuses and young children.

Counseling families to avoid mercury contamination in fish is not enough to solve this problem - we must aggressively target mercury pollution at its source. Progress is already being made with some sources. For example, the health care industry has committed to phasing out mercury use in hospitals and clinics, and EPA has required 90% emissions reductions from medical and municipal waste incinerators.

Your proposed rules for power plant mercury stand in stark contrast. EPA's own Children's Health Protection Advisory Committee recently expressed concern that these proposals are insufficient to protect child health. They would take far too long to achieve dramatic mercury reductions, and could create or worsen mercury hotspots that threaten children in some unlucky communities.

Every child in America deserves a chance to grow up healthy and meet his or her full potential. I urge you to abandon your proposed cap and trade rule and instead adopt a rule that will ensure maximum mercury protections - as quickly as possible.

From the 214th General Assembly (2002):

1. Educate Presbyterians through PC(USA) offices and publications about the environmental and health consequences of pollution from outdated coal-fired power plants and the benefits of ensuring that these plants adhere to tighter air pollution limits, and the economic consequences of such actions.

2. Ask all Presbyterians to exercise stewardship by urging government officials to support federal policies and multipollutant legislation that will, in the most cost-efficient way,

a. enforce current clean air laws by federal and state governments;

b. resist efforts to abolish or undercut established clean air programs;

c. enact new clean air laws for power plants that will substantially reduce pollutants that cause smog, acid rain, respiratory disease, mercury contamination, and global warming;

d. end the "grandfather" loophole that exempts older coal-fired plants; and

e. encourage federal funding of technologies that will facilitate and/or reduce the cost of implementing these recommendations.

3. Direct the Stated Clerk to communicate this new policy to power companies that have outdated coal-fired plants that were "grandfathered" under the Clean Air Act.

4. Direct the Washington Office and Environmental Justice Office to incorporate these concerns into their advocacy work in environmental issues. (2002 Statement — PC(USA), pp. 72, 598-599 "On Cleaning Up Power Plant Pollution")