By: Cynthia Palmer, Senior Analyst, Petrochemicals
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
I’m Cynthia Palmer, Senior Analyst for Petrochemicals at Moms Clean Air Force.
When we were little, we spent countless hours filling out page after page of our “Connect the Dots” workbooks. We created smiling elephants and other masterpieces.
It so happens, connecting dots is not just for teaching fine-motor skills to two-year-olds.
Let’s connect the dots on New Source Review.
Under current law, before breaking ground or modifying a major pollution source, companies must obtain a preconstruction air permit. The permit process offers an opportunity
- To analyze local air quality impacts
- And to consider alternatives to the proposal.
New Source Review gives communities a chance to weigh in before the polluter locks us in to decades of added health risks.
But the EPA proposal pushes the MUTE button on public input.
EPA’s Orwellian proposal does this by changing the definition of “begin actual construction.” It would allow major polluters to excavate land and put in foundations, structures, utilities—everything except the artificially delineated so-called “pollutant emitting” components. They could do all this without even notifying people about their plans.
Once the polluting corporation has invested money in the new facility, it becomes virtually impossible to stop it.
EPA’s proposal would let incinerators, data centers, plastics facilities, and other major polluters infiltrate communities without a shred of transparency or democratic process.
Connect the dots to see what’s at stake. The situation has been going from bad to worse for children and families living near toxic enterprises, because Mr. Zeldin’s EPA has been hellbent on dismantling or substantially weakening our nation’s health and safety rules—giving major polluters carte blanche to release potent carcinogens into our air and water and threaten neighborhoods with chemical fires, leaks, and explosions.
Letting facilities pollute with impunity means more life-altering illnesses for children and families, including for the millions of Americans who have just lost health insurance.
EPA says that the polluting corporations face “regulatory burdens.” But you know who faces the real burdens?
- Talk to families here in Virginia, where data centers are blanketing the air with fine particulates and formaldehyde, linked to cardiovascular and respiratory illness and dementia.
- Talk to the parents in the Houston Ship Channel, where children face leukemia due to 1,3-butadiene exposures from the petrochemical facilities surrounding their homes.
- Talk to anyone living in Los Angeles who spent this Memorial Day weekend in evacuation shelters amidst four simultaneous chemical disasters.
Your New Source Review proposal is an insidious attack on America’s children and families, and it must be scrapped. We urge EPA to return to its historic mission of protecting children, families, and all people. Thank you.