June 28, 2013
Bob Perciasepe, Acting Administrator
Environmental Protection Agency
EPA Docket Center EPA/DC
Mail Code 28221T
1200 Pennsylvania Avenue N.W.
Washington, DC 20460.
RE: Docket ID No. EPA–HQ–ORD–2013–0292
Dear Acting Administrator Perciasepe,
As the U.S. Environmental Protection Agency (EPA) considers an important decision on whether it should consider reducing pollution in highly exposed communities, I urge you to please carefully evaluate the southwest Detroit neighborhoods.
Southwest Detroit zip codes (48209, 48210, 48216, 48217), River Rouge (48219) and Ecorse (48229) have the worst air quality in the State of Michigan. The following is the list of polluting industries in our communities:
· The only oil petroleum refinery (Marathon Oil) in the state.
· The largest waste water treatment plant. It is extremely outdated and causes an unbearable odor and noise pollution. Emissions data compiled by Southwest Detroit Environmental Vision (SDEV) in 2005 from National and State sources (MDEQ, NEI, and MAERS) indicated that the Plant was contributing four times the average of lead emissions in 48209 and that approximately 50% of the nitrogen dioxide in the area was coming from the facility. Yellow plumes are frequently observed spewing from the incinerators most likely caused by inefficient combustion of Nitrogen compounds in the sewage sludge.
· The largest rail yard in the state.
· Zug Island, located in River Rouge (at the boundaries of southwest Detroit). It is one of the most polluted areas in the country.
· We house the busiest North American international crossing, where over 10,000 trucks travel through every day. Asthma is three times higher among the adults that live in the zip code (48216) that houses the Ambassador Bridge.
According to a University of Michigan study, the neighborhoods around the area comprise six of the ten most polluted zip codes in Michigan. We have hundreds of air permits issued in a small geographic area that is home to large, predominately low income, African American community. Families have even
started a white cross campaign where they place small white wooden crosses on their lawn to commemorate the death of someone in their household due to cancer or respiratory disease.
The human impact is tremendous. The past two summers, my office received complaints about hydrogen sulfide odor that led to sore throats, headaches, and nose bleeds. Families have had to bring in their children from playing when the odor became overpowering to the point of causing nausea. Air quality samples contained lead and high levels methyl ethyl ketone, and we have large numbers of cancer and asthma cases. One of four children in Southwest Detroit has asthma.
Further, a groundbreaking national study was recently published which links air pollution exposures to higher incidence of autism. The study found that women who were exposed to mercury from diesel particulates while pregnant were twice as likely to have a child with autism than those who were exposed to cleaner air. My own son was recently diagnosed with autism. Southwest Detroit’s population is 40% children, and our community is one of the only growing populations. Younger populations are more vulnerable to exposure to pollution.
The EPA needs to know that the public cares about this issue so it does not just keep the status quo embracing an outdated risk assessment approach and means that the most vulnerable communities will remain polluted. I urge the EPA to finally adopt the best available scientific methods recommended by the National Academy of Sciences which will lead to meaningful action to reduce pollution. Every legislative session, I introduce a bill and urge support for a cumulative impact analysis for air permits in areas where there are high concentration of air permits. EPA must protect communities from cumulative impacts and risks, not just look at a single source, a pollutant, or an exposure pathway in isolation.
Communities need stronger, scientific protection now from air, water, pesticides, hazardous waste, and other kinds of pollution. EPA needs to implement the science now, including by updating its Clean Air Act standards for toxic air pollution.
Our families deserve to be protected.