We believe that all human life is sacred, each person conceived is of equal and innate value and is worthy of protection. Our commitment to Jesus Christ compels us to care for life from the moment of conception until natural death. Jesus’ call for abundant life isn’t just a spiritual connection but a call for us to have a quality of physical life as well. “Jesus said, ‘Let the little children come to me, and do not hinder them, for the kingdom of heaven belongs to such as these’” (Matthew 19:14). The psalmist wrote, “For you created my inmost being; you knit me together in my mother’s womb” (Psalm 139:13). Our commitment to Jesus Christ compels us to do all we can to protect unborn children from mercury poisoning.
Mercury is a highly damaging neurotoxin that, when ingested by pregnant women, crosses the placenta and results in irreversible brain damage. The same impacts occur even after birth as mothers can transfer mercury through breastmilk. Coal-fired electric utilities are America’s largest source of mercury — and with this rollback, their emissions will go back up. When emitted the mercury deposits in our water bodies, is consumed by fish and enters our food stream.
Before the Mercury Rule became law 1-in-6 children in the United States were born with levels of mercury in their blood high enough to cause brain damage. Since its promulgation, 99.9% of utilities have complied with the Mercury Rule, and there has been an 80% reduction in mercury emissions. In addition, recent evidence demonstrates that mercury levels in the most popularly consumed fish have declined. In short, the Mercury Rule is working.
Perhaps the most damaging part of this rollback attempt is the exclusion of so-called co-benefits or ancillary benefits from the rule’s cost-benefit analysis — in this case the benefits the Mercury Rule achieves from also reducing soot and smog and other pollutants. Excluding such co-benefits contradicts guidelines from the Office of Information and Regulatory Affairs (OIRA) to federal agencies issued by the George W. Bush administration in 2003, which state: “Your analysis should look beyond the direct benefits and direct costs of your rule-making and consider any important ancillary benefits and countervailing risks.” When looking at the costs and benefits to society of a regulation, it makes little sense to ignore certain benefits because of how they are labeled. From society’s perspective, from the perspective of human health, from the perspective of faith, they’re just benefits. All God’s children deserve the right to “have life, and to have it to the full” (John 10:10).
Acting Administrator Wheeler: As a pro-life Christian I ask you to leave the Mercury and Air Toxics Standard (MATS), or the Mercury Rule, alone. Your effort to severely weaken this Rule will be harmful to children’s bodies, especially the unborn, thereby violating EPA’s mission to protect human health. This rollback effort would not only set the stage for utilities to stop using their mercury control technology, it would also create a highly damaging precedent for all future regulations by eliminating so-called co-benefits from consideration when deciding whether or not to issue a new rule. For the sake of our children, please leave the Mercury Rule alone.