Letter cites EPA proposals to remove mercury from toxics list
The Harbor Consortium of the New York Academy of Sciences has released the text of a letter it has sent today to President George W. Bush, the United States Environmental Protection Agency, and the United Nation's Environment Programme about pending policy changes that "remove mercury from the chemical toxics lists, extend the time frame in which a 90 percent reduction of mercury emissions will be achieved, and the latest wording in the draft joint EPA/FDA fish consumption advisory."
The Consortium, a broad-based stakeholder group organized by the Academy, has been studying the sources of pollution by mercury (and other toxins) into the New York/New Jersey harbor watershed and recommending strategies for reducing or preventing further contamination of the watershed. The Consortium's report on mercury and methyl mercury pollution in the Harbor has been published by the Academy and is available online, http://www.nyas.org/scitech/harbor
Signed by Harbor Consortium chair, Dr. Charles W. Powers, the letter cites Academy studies that indicate that "a serious effort by the U.S. and the world community to minimize mercury emissions from coal combustion" is needed, and notes that "reductions in atmospheric releases will eventually result in lower mercury levels in fish," which warrants the creation of fish advisories that are "both protective of health for all populations and yet promote fish consumption for its important health benefits."
TEXT OF LETTER FOLLOWS:
December 18, 2003
The President of the United States
The Executive Office of the President
1600 Pennsylvania Avenue, NW
Washington, DC 20500
Dear President Bush:
I am writing to communicate the findings developed by the New York Academy of Sciences' Harbor Consortium pertinent to EPA's current proposals to remove mercury from the chemical toxics list, extend the time frame in which a 90% reduction of mercury emissions will be achieved and the latest wording in the draft joint EPA/FDA fish consumption advisory. The Harbor Consortium has devoted the last several years to understanding the sources and flows of mercury and the environmental and economic impacts of mercury releases to the New York/New Jersey Harbor.
The Harbor Consortium is a broad-based stakeholder group including local, community and environmental groups and representatives of industry and business, local, state and federal government and regulatory agencies, academia, labor and conservation organizations.
The group's work has been to quantify the sources, sinks and flows of mercury and methylmercury in the New York/New Jersey Harbor Watershed in order to identify where pollution prevention could contribute to long-term reductions in loadings of contaminants and to develop practical strategies to reduce contaminant emissions. Although our work has been regional, many of our recommended actions require a national and international commitment. A copy of our report, published by the New York Academy of Science, and a list of Consortium members is attached. The report is also available to the public at (www.nyas.org/scitech/harbor).
Our studies indicate that control of mercury air emissions starts a clear sequence of events that can better protect public health: early control of mercury air emissions will lead to reduced atmospheric deposition of mercury to surface waters where mercury moves up the food chain to fish. The sooner levels of methylmercury in fish go down, the sooner the warnings about consumption of fish with mercury can become less onerous. And as that happens, we are all freed to return to healthful consumption of fish protein from our Harbor and all other surface waters.
What led us to that conclusion? Our studies indicate that a serious effort by the U.S. and by the world community to minimize mercury emissions from coal combustion, the largest mercury source at a global level, is needed and that there are readily available emissions controls for mercury from coal burning facilities.
Our work has been usefully informed by another technical initiative exploring related aspects of the effects of mercury in this region.
The State of New Jersey, concerned about mercury in its air and waters, formed the New Jersey Mercury Task Force that identified the major activities and pathways of mercury releases (http://www.state.nj.us/dep/dsr/mercury_task_force.htm). A key Task Force recommendation is to "Participate in and support regional, national, and global efforts to reduce mercury uses, releases, and exposures." The Task Force also recommended removing mercury from products and significantly reducing mercury emissions from coal combustion, iron and steel melting industries, and other sources, including solid waste incineration. The New Jersey Department of Environmental Protection proposed on December 10 of this year new requirements to achieve up to a 90 percent reduction of mercury emissions from the state's coal-fired power plants by 2007. The proposed regulations also mandate a reduction of mercury emissions from the state's iron and steel melters by 75 percent by 2009, and a further reduction of mercury emissions from New Jersey's municipal solid waste incinerators. The Department estimates that if New Jersey's rules were enacted nationally, annual mercury emissions from coal-fired power plants alone would decline from approximately 48 tons to about five tons.
This matters because there is a direct link between mercury emitted to the atmosphere and mercury levels in fish--both those fish caught in our lakes and streams and the commercial fish caught in our world's oceans. Reductions in atmospheric releases will eventually result in lower mercury levels in fish. That this is an important public health issue that currently poses tough choices for public health officials is seen in the fact the FDA and the EPA are currently struggling to articulate a fish consumption advisory that is protective of health for all populations and yet encourages fish consumption for its important health benefits.
The negative health impacts of mercury and methylmercury exposure, especially in children and pregnant women, demand that effective control technologies be implemented. Our studies indicate that implementation of effective mercury controls should be mandated nationally and urged internationally as expeditiously as possible. I, members of the Consortium or Academy staff would be happy to meet with you or your representatives at your convenience to discuss our findings and how they impact on policy related to these issues.
Sincerely, Charles W. Powers PhD
Chair - New York Academy of Sciences' Harbor Consortium
New York Academy of Sciences
2 E. 63rd Street
NY/NJ Harbor Consortium
New York Academy of Sciences
Charles Powers, Principal Investigator, Consortium on Risk Evaluation with Stakeholder Participation (CRESP II) and President, Institute for Responsible Management
Brad Allenby, Vice President, Environment, AT&T Corporation
Winifred Armstrong, Economist, retired, Regional Plan Association
Nada Assaf-Anid, Department Chair, Chemical Engineering Dpt., Manhattan College
Michael Aucott, Research Scientist, NJ Department of Environmental Protection
Janina Benoit, Professor, Wheaton College
Lauri Boni, Center for Children's Health and the Environment, Mount Sinai School of Medicine
Robert Borg, Chairman, Kreisler Borg Florman
Sandra Brewer, Biologist, US Fish and Wildlife Service
Joanna Burger, Professor, Environmental & Occupational Health Sciences Institute, Rutgers University
Mary Buzby, Principal Scientist, Merck & Co.
Phyllis Cahn, Associate Director, Aquatic Research and Environmental Assessment
Carter Craft, Director of Programs, Metropolitan Waterfront Alliance
Herzl Eisenstadt, Counsel, International Longshoremen's Association
Paul Elston, Founder, NY League of Conservation Voters/Former Chair, NYC Water Board
Leonard Formato, President, Boulder Resources
Frederick Grassle, Director, Institute of Marine and Coastal Studies
Michael Gochfeld, MD, Professor, Robert Wood Johnson Medical School
Manna Jo Greene, Environmental Director, Hudson River Sloop Clearwater
Ronald G. Hellman, Director, Americas Center on Science & Society, City University of New York
Brian Jantzen, President, Full Circle Inc.
Andrew Kasius, Program Administrator, COAST
Zoe Kellman, Scientist, New Jersey Department of Environmental Protection
Keith Lashway, Director, Small Business Environmental Ombudsman, Empire State Development Co.
Reid Lifset, Associate Director, Industrial Environmental Management Program, Yale University
Simon Litten, Research Scientist, Division of Water, NYS Department of Environmental Conservation
Brian Marsh, Biologist, U.S. Fish and Wildlife Service
Thomas Morris, Program Director, IBM Corporation
Wendy Neu, Vice President, Environmental & Public Affairs, Hugo Neu Corporation
Joel O'Connor, Adjunct Associate Professor, SUNY at Stony Brook, retired, EPA
Stephen Ramsey, Vice President, Corporate Environment Programs, General Electric Co.
Ira Rubenstein, Executive Director, NY Environmental Business Association
Anthony Rumore, President, Joint Council 16, International Brotherhood of Teamsters
Manuel Russ, Member, Citizens Advisory Committee to NYC DEP on Pollution Prevention
Vincent Sapienza, Director, Environmental Affairs, Bureau of Wastewater Treatment, NYC DEP
Martin Schreibman, Director, AREAC and Distinguished Professor, Brooklyn College, CUNY
Dennis Suszkowski, Science Director, Hudson River Foundation
John T. Tanacredi, Professor, Earth and Marine Sciences, Dowling College
Nickolas Themelis, Professor, Earth Engineering Center, Columbia University
Andrew Voros, Director, Clean Ocean and Shore Trust
Iddo Wernick, Senior Associate II, Information, World Resources Institute
Rae Zimmerman, Director, Institute For Civil Infrastructure Systems, New York University
Ex Officio Members
Atef Ahmed, Manager of Environmental Programs, Port Commerce Dept., The Port Authority of NY & NJ
Annette Barry-Smith, Project Manager, Waterways Development, The Port Authority of NY & NJ
Kathleen Callahan, Director, US EPA Region 2
Steve Dorrler, Scientist, Port Commerce Department, The Port Authority of NY & NJ
Deborah Freeman, Pollution Prevention Coordinator, US EPA Region 2
Tristan Gillespie, Environmental Protection Specialist, US EPA, Region 2
Rolland Hemmett, Regional Science Advisor, US EPA, Region 2
Richard Larrabee, Director, Port Commerce Department, The Port Authority of NY & NJ
Joseph Malki, Project Engineer, RCRA Programs, US EPA Region 2
Irene Purdy, Project Officer, EPA Region 2
Walter Schoepf, Environmental Scientist, Strategic Planning Team, US EPA Region 2
Thomas Wakeman, General Manager, The Port Authority of NY & NJ
Other Participants and Observers
Steven N. Chillrud, Associate Research Scientist, Lamont-Doherty Earth Observatory, Columbia U.
Alicia Culver, Senior Research Assistant, INFORM Inc.
Tom Belton, Research Scientist, Bureau of Environmental Assessment, NJ DEP
Michael Connor, Executive Director, San Francisco Estuary Institute, previously at New England Aquarium
Charles Driscoll, Distinguished Professor of Civil and Environmental Engineering, Syracuse U.
Eric Erdheim, Senior Manager Government Affairs, National Electrical Manufacturers Association
William Fitzgerald, Professor, Department of Marine Sciences, University of Connecticut
Eugenia Flatow, Board Chair, New York City Soil and Water Conservation District
Ed Garvey, Geochemist, TAMS Consultants, Inc - An Earth Tech Company
John Haggard, Vice President, Corporate Environment Programs, General Electric Co.
Carlton Hunt, Research Leader,, Battelle Ocean Sciences, Inc.
Edward Konsevic, Lab Manager, Meadowlands Environmental Research Institute (MERI)
Tim Kubiak, Biologist, US Fish and Wildlife Service
Joel LeFevre, Joint Council 16, International Brotherhood of Teamsters
Janet MacGillivray, Attorney, Mount Sinai School of Medicine
Robert Mason, Professor, University of Maryland
Hugh Morrow, President, North America International Cadmium Association
Ronald Sloan, Scientist, Division of Fish, Wildlife and Marine Resources, NYS DEC
Lawrence Swanson, Director, Waste Reduction and Management Institute, SUNY at Stony Brook
Valerie Thomas, Research Scientist, Princeton Environmental Institute, Princeton University
Judith Weis, Professor, Marine Biology and Aquatic Toxicology, Rutgers University
New York Academy of Sciences
Susan Boehme, Director, NY/NJ Harbor Project
Marta Panero, Project Manager, NY/NJ Harbor Project
Ellis Rubinstein, President and CEO
Rashid Shaikh, Director of Programs
New York, NY 10021