Introducing the Three O Eco and Inviting You to Take Action

This week I’m going to introduce a new Gaian Reflections occasional feature, the Three O Eco (3OECO), or 30-minute Earth Changing Opportunity.* I’m not yet sure how often these will be included. They won’t be frequent, nor generic, but saved for clear and needful opportunities where a quick spurt of activism could make a real difference.

This week, the 3OECO is submitting a written public comment to the Environmental Protection Agency Administrator, Michael S. Regan (Americans only).** Earlier this week, the U.S. EPA proposed new strengthened standards “to significantly reduce hazardous air pollutants from chemical plants,” which would “dramatically reduce the number of people with elevated air toxics-related cancer risks in communities surrounding plants” that use ethylene oxide (EtO) and chloroprene (chemicals used to make antifreeze and synthetic rubber (neoprene), respectively).

It’s rare that a government press release uses the word “dramatically” but scrolling to the end, the release mentions a community risk assessment the EPA conducted that found that “the numbers of people with elevated cancer risk could drop by 96 percent in communities surrounding chemical plants, if the proposal is finalized.” Not 5 percent. Not even fifty percent, but 96 percent! So with these changes, instead of 100 people having elevated cancer risks, four would.

In summary, the new standards would hold chemical facilities accountable for the emissions of certain chemicals (including EtO and chloroprene as well as benzene, vinyl chloride, 1,3-butadiene and others. Facilities using, making, storing, or emitting those chemicals would have to monitor pollutants in the air directly at the fenceline of their plants (and thus reflecting levels in immediately-surrounding “fenceline communities”) and if the chemicals were above a certain threshold “owners and operators would have to find the source and make repairs.”

A chemical plant making ethylene on a cold night. (Image of Canadian Chemical Facility from WherezJeff via flickr)

It’s a cut and dry reform, certainly not radical (and probably not bold enough), but an important advancement of chemical rules last strengthened almost 20 years ago. According to the New York Times, the new regulations would help clean up more than 200 plants across several states, including one in Louisiana releasing chloroprene that the government determined was contributing to the highest cancer risk in the U.S.

Of course, facilities won’t be happy about this and the American Chemistry Council is surely already mobilizing its corporate constituents to write comments explaining why this will derail the U.S. economy. In its first statement, the ACC already warned that EtO is used in the development of electric vehicle batteries and thus these “overly conservative regulations…could threaten access,” tapping into the green sheen of this new manufacturing boom. It then goes on to say that the EPA’s assessment of EtO’s carcinogenic threat is overstated. (Feel free to read EPA’s assessment on how carcinogenic EtO is here.) The ACC then promises that “We will be engaging closely throughout the comment and review process,” a promise that sounds more ominous than helpful.

Which is exactly why Gaian Americans, and everyone who values clean air and environmental justice for all, and not just for those living away from polluting facilities (which I’m guessing may be nearly every reader of this newsletter), should make their voices heard and publicly support these new rules.

Of course, writing your own comment will be most meaningful, but I’m happy to create a basic template that makes the process easier to start:

Public Comment Template

Dear EPA Administrator Regan,

I applaud your public commitment to “prioritize the health and safety” of those living “in the shadow of chemical plants.” The EPA has an opportunity to reduce highly toxic chemical releases and improve the health and wellbeing of millions of Americans as well as countless non-human-beings also affected by these toxins. Thank you for taking action.

Inevitably you will receive pressure from industry to weaken these proposed regulations, arguing that they will hurt the American economy in many different ways. Certainly that’s not true and the chemical facilities can make the necessary changes to their infrastructure to prevent the poisoning of innocent Americans. But if they cannot, it is the health and safety of the American people and the environment in which all creatures live and are part of that should and must take precedence. So please do not yield to the artificial threats industry makes. Time and again, as regulations have been made tighter, industry has adapted and has even benefited as they’ve reduced costs and threats of litigation, and as their workers and their families have become healthier.

Again I thank you for taking your action and implore you not to weaken these new regulations under the inevitable pressure you’ll face from industry groups.


[Your Name Here]

Of course, tailor your comment if you can, depending on where you live, or if you know some who have suffered from environmental diseases, or if you’ve worked with chemicals, or however you want to adjust to make this more personalized. Thank you for taking action and if you do, please share your comment as a comment below. One further note, as this proposed regulation is new, it has yet to enter the Federal Registry (so comments can’t be posted quite yet). I will include the link next week (or once published) so you can easily add your comment. Finally, if you want to delve deeper into this issue, there’s a webinar training for communities on April 13th at 7pm ET. There you can learn more about the regulation and about providing comments.

Please share this invitation with other friends, co-workers, and community members so they too can add their voice. (Image of chemical facility in Germany by India Chesea via flickr)

Mining Our Way to Ecotopia

Speaking of the Renewable Energy Transition and the increasingly mythological deference people are instilling it with, next Wednesday (April 19 at 2pm ET), Ecological Footprint co-creator Bill Rees, Professor of Environmental and Ecological Engineering John Mulrow, and PhD Student in Environmental and Ecological Engineering Miriam Stevens will be joining me for a Gaian Faith Climate Action Week online talk on “Earth Destruction by a Different Name: Dispelling the Myths of a Renewable Transition.” It’s easy to imagine that we can grow our way out of the climate crisis, but the truth is that climate change and the many other environmental problems we now face are symptoms of transcending the Earth’s carrying capacity (or in simpler terms too many humans consuming too much in unsustainable ways (I = Population x Affluence x Technology)). So come and join that honest conversation about the challenges we face and the more real solutions we must embrace (rather than mining our way to ecotopia). You can learn more at our Upcoming Events page, or register here.


*Yes, yes, I know this is more about changing how humans live, but who could pass on that straightforward acronym. Besides, my first attempt was the ThirtyMAO (thirty-minute action opportunity). Tell me 3OECO isn’t a heckuva lot better…

**Sorry everyone else, but I’m sure there are other 3OECOs you could suggest? Add those to a comment below.

Share this Reflection:

2 Responses

  1. Bart Everson

    “National Emission Standards for Hazardous Air Pollutants” are now open for comment on the Federal Register. Here’s the link:

    And I’m pasting my comment below. Thank you for bringing this to our attention!

    Dear EPA Administrator Regan,

    As a confirmed cynic, I was surprised and indeed heartened to learn of your recent, public commitment to “prioritize the health and safety” of those living “in the shadow of chemical plants.” This is an amazing positive step from an agency which too often has seemed like a puppet of the industries it is supposed to regulate.

    As a resident of New Orleans, I cling desperately to the notion that the air I’m breathing might be somewhat less toxic than the air just up the river a piece. I suppose the folks in Baton Rouge look downriver and think similar thoughts. But you know what? The people in-between gotta breathe too, even those living in the area known as Death Alley.

    As a human being embedded within the interconnected planetary ecosystem, I know that poisoned air anywhere is a threat to life everywhere. I’m quite certain that reducing toxic chemical releases will improve the health and well-being for billions of people around the world. Our more-than-human kin will also benefit.

    I wonder if the petrochemical industry can make the changes necessary to avoid poisoning the Earth? If they can’t, our health and safety must take precedence. That should be non-negotiable.

    Please, don’t weaken these new regulations. I know the EPA will face enormous pressure from industry groups. Stay strong! We are counting on you.

    Thank you for taking this action.

    Bart Everson

    • Erik Assadourian

      Wonderful letter. Thanks for posting, Bart!

      And your comment also prompted me to post my own (having been delayed until the rule got published to the Register)!

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