By: Ashley Hillard, North Carolina Field Organizer
Date: May 28, 2026
About: Revision to “Begin Actual Construction” in the New Source Review Preconstruction Permitting Program, Docket # EPA-HQ-OAR-2025-0618
To: U.S. Environmental Protection Agency
Good morning,
My name is Ashley Hillard, and I am the North Carolina Field Organizer for Moms Clean Air Force. We are a national organization of 1.6 million parents and caregivers united against harmful air pollution and climate change, advocating for the protection of children’s health.
Moms Clean Air Force strongly opposes the EPA's proposal to redefine "begin actual construction." This proposal would let polluters begin construction on major projects like data centers and petrochemical plants before communities are able to share input on the potential impacts of air pollution associated with the projects—putting children's health at risk and making it nearly impossible to stop harmful facilities once construction has begun. Corporate development must take place in a thoughtful way that does not impair human health and quality of life.
Under the current law, before breaking ground on a new facility that would be a significant source of air pollution (or a major modification of an existing source), companies must obtain a preconstruction air permit in order to:
- Analyze local air quality impacts and ensure the new facility(or modified existing facility) won't impair health-based air quality standards (the NAAQS)
- Consider alternatives to the proposal before money is spent and construction begins
- Give communities a chance to weigh in before a pollution source locks them into decades of added health risk
My family and I deal with a range of issues connected to air quality—from severe allergies to COPD. The New Source Review program is an important tool for communities to ensure that health impacts are examined before, not after, a major pollution source is built. Communities should have a say over how land is used and understand the risks associated with proposed development projects on their health and the health of their loved ones. Dangerous air pollutants like particle pollution and ozone have the potential to harm children’s health, impacting their lung and brain development. According to the American Lung Association's 2026 State of the Air Report, Mecklenburg County received an F for high ozone days—with pollution affecting approximately 270,000 children. There are already approximately 40 data centers in Charlotte, with proposed moratoriums being discussed by the City Council. Nearly half of all children in the U.S. already live with unhealthy levels of air pollution.
Families have a right to ask what increased pollution will mean for their children’s developing lungs before construction begins, not after. Thank you.