October
16,
2006
Mr. David Gardner, NYSDEC
Division of Air Resources
625 Broadway, 2nd Floor
Albany, NY 12233-3254
Dear Mr. Gardner,
The New York State Ornithological Association (NYSOA) is very
pleased that the DEC has a draft regulation that will regulate
emissions of mercury from New York State’s coal-fired power
plants. The mercury levels in several species of fish in
both the Adirondack and Catskill Parks are high enough for the
NYS Department of Health to issue warnings against eating these
species of fish. The Common Loon is a New York State “Species
of Special Concern”. The reason for this concern is a serious
decline in the number of Common Loons breeding in NYS waters during
recent decades, which may result in part from their eating fish
from our state’s mercury contaminated waters. This
species could in the future be elevated to the “Endangered” category
unless the mercury emissions are reduced.
NYSOA applauds the DEC for setting levels for 90% reduction of
mercury emissions by 2015 which is in contrast to the U.S. Environmental
Protection Agency’s Clean Air Mercury Rule which only requires
a 70% reduction of mercury emissions by 2018. Both agencies (DEC
and EPA) allow emission ‘trading’ of credits between
coal-fired electric generating units both inside and outside New
York State, a practice that can lead to uneven levels of contamination
of bodies of water depending on their geographic location. The
bodies of water near power plants would likely have much higher
levels of contamination than bodies of water farther from the plants.
The New York State Ornithological Association strongly supports
the efforts of the DEC to reduce mercury emissions. We urge
the DEC to further reduce the time line for compliance and to eliminate
the trading of emission credits. The sooner the waters are free
of mercury, the healthier the environment for all living plants
and animals including humans, who also often consume fish from
NYS waters.
Very
truly yours,
Gail
M. Kirch
Conservation
Co-chair
cc : John Ozard, NYSDEC
ADK Council |