Date: July 20, 2022
To: Mike Foote, Chair, RAQC Board RAQC Board Members
1445 Market Street
Denver, CO 80202
Dear Mr. Foote and Regional Air Quality Council Board Members,
The Denver Metro/North Front Range (DMNFR) region cannot afford to continue to miss our attainment goals for ozone. It is critical that the RAQC approve a State Implementation Plan (SIP) that is strong and includes control measures that meaningfully and significantly reduce ozone precursor emissions.
Recently, the SIP modeling has missed the mark and resulted in too few meaningful pollution reductions. This SIP must be proactive and result in real pollution reductions, which is why we write to you today in support of the local government comments you received on July 7.
The cost of missing our attainment goals is high.
Because ozone pollution comes from a chemical reaction between sunlight, oxygen, and a mixture of pollutants including NOx (nitrogen oxides) and VOCs (volatile organic compounds), it’s critical that we reduce the sources of NOx and VOCs from everything from motor vehicle exhaust to industrial processes.
The health and economic impacts of failing to address ozone nonattainment are high. People’s health and our quality of life are on the line.
According to the American Lung Association’s (ALA) 2022 State of the Air report, the Denver-Aurora metropolitan area’s failing grade for high ozone days means 3.6 million people are at risk of harm to their health including 1.2 million people of color. Ozone impacts hit especially hard in Disproportionately Impacted Communities (DICs). These communities suffer from the cumulative impacts of additional air pollution as well as soil and water pollution. High ozone levels on top of high localized pollution can lead to even worse health outcomes in the very communities that often have limited access to health care.
Ground-level ozone can have a particular impact on people with underlying health conditions. According to the ALA, in the Denver-Aurora metropolitan area this includes:
- 59,113 kids with pediatric asthma
- 274,959 adults with asthma
- 125,939 people with Chronic Obstructive Pulmonary Disease (COPD)
- 162,350 people with cardiovascular disease
- 39,619 pregnant people who are exposed to adverse health impacts to themselves and their developing fetus
As scientists have studied air pollution over the decades, we have learned that ozone impacts not just our lungs but cardiovascular disease, stroke, Alzheimer’s Disease, and diabetes.
During high ozone days, public health officials warn that people should limit their risk by reducing their time outdoors and limiting exercise. These public health warnings cut against Coloradans outdoor lifestyle and quality of life. It also threatens the tourism industry, which in 2019 contributed $24.2 billion to our economy and supported 180,000 jobs.
In 2021, we had 75 ozone action alerts. It’s time our SIP met the moment and meaningfully reduced ozone precursor emissions in a way that ensures that our entire nonattainment area comes into attainment. No one solution will get us there. We need the RAQC to recommend a combination of measures that ratchet down pollution. Recently, leaders from Boulder County, the City and County of Denver, the City of Aurora, the City and County of Broomfield and Colorado Communities for Climate Action (CC4CA) sent a letter to the RAQC on July 7, with nine potential strategies for consideration.
Every year we fail to meet ozone health levels is another year millions of people are unnecessarily exposed to dangerous levels of ozone pollution. Now is the year we need the RAQC to step up and approve a strong SIP with meaningful control measures.
To that end, our organizations endorse the comments filed by the local governments mentioned above. The RAQC should consider the policies put forth to develop and adopt a package of rules based on those recommendations to protect the health and future of Coloradans.
Danny Katz, Executive Director, CoPIRG (Colorado Public Interest Research Group)
Andrew Forkes-Gudmundson, Senior Manager for State Legislative and Regulatory Affairs, Earthworks
Rebecca Curry, Colorado Policy Counsel, Earthjustice
Alex DeGolia, Director, US Climate, Environmental Defense Fund
Lorena Gonzalez, Climate Advocate, Conservation Colorado
Tracy Coppola, Colorado Senior Program Manager, National Parks Conservation Association
Micah Parkin, Executive Director, 350 Colorado
Shaina Oliver, Field Consultant, Moms Clean Air Force Colorado Chapter
Jeremy Nichols, Climate and Energy Program Director, WildEarth Guardians
Sarah Clark, Lead Organizer, Colorado Sierra Club
Joro Walker, General Counsel, Western Resource Advocates
Katara Burrola, Environmental Justice Organizer, Mi Familia Vota
Ean Thomas Tafoya, Colorado State Director, GreenLatinos