When will Trump administration live up to pro-life values at EPA?

When will the Trump administration live up to its stated pro-life values for all our children, both pre-born and born? President Trump, his Acting EPA Administrator Andrew Wheeler and Assistant EPA Administrator for Air and Radiation Bill Wehrum enforced the most egregious act yet by this EPA to undermine the health and lives of our unborn children by gutting the Mercury and Air Toxics Standard (MATS).

Mercury is a highly toxic neurotoxin that, when ingested by pregnant women, crosses the placenta and results in irreversible brain damage in unborn children. The same impacts occur even after birth as mothers can even transfer mercury through breastmilk — a perfectly calibrated, God-designed newborn nutrition source. There are no known safe levels of mercury and even with the current success brought about by the MATS rule, our streams, rivers, lakes and oceans still contain harmful levels of the life-destroying heavy metal. 

{mosads}Coal-fired electric utilities are America’s largest source of mercury. When emitted the mercury deposits in our water bodies, is consumed by fish and enters our food stream. Every state in the nation still has active fresh-consumption advisories against consuming fish contaminated by mercury. The threat to our children is very much alive. 

As Catholic and evangelical Christians, we believe that all human life is sacred, each person conceived is of equal and innate value and all human life 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. It is a pro-life concern, plain and simple.

“We’re not changing the mercury standard,” Wheeler told reporters several weeks ago.  

But in this era of “fake news,” Wheeler has to know that removing the “appropriate and necessary” perquisite finding from the rule opens the door for energy devlopers to pursue lawsuits to overturn the standards, while Wheeler plays Pontius Pilate blaming the court for eliminating the standard.

Keep in mind, Wheeler’s former client Bob Murray of Murray Energy outlined the goal of reversing the MATS Standard in his infamous “Action Plan” letter sent to Vice President Mike Pence and other Trump senior officials in March 2017.

While Wheeler can claim utilities will not turn off their existing control equipment, he has made no commitment that EPA would continue to enforce compliance with the standard and thus there is no guarantee that public utility commissions will not choose lower rates over continued mercury control. Instead, there is every likelihood that this action would open a wide door for increased emissions of this life-threatening toxin. 

This potential for regulatory confusion among utilities already in compliance with the rule is why the Edison Electric Institute and other utility groups have written letters to EPA and offered comments against the MATS revision for the Office of Management and Budget’s (OMB) review. With 99.9 percent of American utilities already having operational mercury removal systems, and the few that do not awaiting installation, the utilities see a high dollar amount of stranded assets that will not be recoverable if the rule is amended as proposed.

Perhaps the most damaging element of the whole effort, though, is that the proposed changes would exclude co-benefits or ancillary benefits from the rule’s cost-benefit analysis. This 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.”

{mossecondads}What parent wouldn’t count the benefit of playtime at the playground when deciding to repair their son or daughter’s leaking heart valve? What parent wouldn’t consider the benefit of walking again as a result of setting their child’s fractured leg? Neither are “direct benefits” of the interventions, strictly speaking, but are obvious and appropriate considerations. 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.

If Wheeler chooses to put past clients ahead of EPA’s mission to “Protect Human Health and the Environment,” we ask Senators on both sides of the aisle to reject his expected nomination to EPA Administrator. Wheeler’s MATS revision does not square with our faith or the faith of millions of pro-life Americans. All God’s children deserve the right to “have life, and to have it to the full” (John 10:10).

Rev. Mitchell C. Hescox is the president and CEO of The Evangelical Environmental Network.

Sister Mary Elizabeth Clark is the director of the Sisters of Saint Joseph Earth Center.

Sister Marie Lucey is the associate director of Franciscan Action Network.