By: Celerah Hewes, Senior Manager, State Field Campaigns
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
My name is Celerah Hewes, and I am a Senior Manager of State Field Campaigns for Moms Clean Air Force working with communities fighting fossil fuel and petrochemical expansion across the county. I live in Albuquerque, New Mexico, with my family, and for nearly a decade, I have worked alongside moms, dads, and caretakers concerned about the health impacts of air pollution on their families. An essential tool in fighting pollution is the permitting process, which provides a way for community concerns to be heard, makes room for a discussion of ways to offset excess emissions, and allows economic development to take place in a thoughtful and considered way that does not impair human health and quality of life.
Today, I am here as a parent and a representative of the 1.6 million members of Moms Clean Air Force to strongly oppose EPA's proposal to redefine "begin actual construction." This proposal would let polluters begin construction on major new pollution sources before communities have a voice—putting children's health at risk and making it nearly impossible to stop harmful facilities once construction has begun.
This proposal would redefine what it means to “begin actual construction.” Allowing companies to excavate land, build foundations, and put in site infrastructure before they've even applied for air pollution permits. Not only does this remove the opportunity for community input; it also guts preconstruction review intended to protect nearby communities.
The result is a threat to children’s health: Nearly half of all children in the U.S. already live with unhealthy levels of air pollution, according to the American Lung Association's 2026 State of the Air Report. Families have a right to ask what increased pollution will mean for their children’s developing lungs before construction begins, not after.
My parents both had careers that intersected with large construction projects, from civil engineering to building and design. They took pride in the work they did knowing that it would better the lives of families. It was thoughtful and intentional with an eye towards building community and creating family sustaining jobs. That dream of making communities better is destroyed when we take away their voices and sabotage the vital health protections that give families the small amount of agency they have over the air they breathe and the pollution they are exposed to.
Many facilities likely to benefit from this proposal would be disproportionately sited in communities of color and low-income communities already overburdened by pollution. This would include AI data centers, petrochemical plants, and other fossil fuel infrastructure, which are seeing unprecedented rollbacks in environmental and health protections already. These are communities where children already face elevated risks of asthma, adverse birth outcomes, and other serious health harms.
The New Source Review program is one of the most powerful tools communities have to protect public health, and this proposal would sabotage that protection. Public health cannot be an afterthought. I strongly oppose EPA's proposal to redefine "begin actual construction" on behalf of myself and Moms Clean Air Force and I urge you to protect the careful analysis of new pollution sources so development takes place in a way that does not impair human health and quality of life. Our children deserve nothing less.