By: Isabel González Whitaker, Associate Vice President for Public Engagement
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 Isabel González Whitaker. I live with my family in Memphis, Tennessee, and I am the Associate Vice President at Moms Clean Air Force, the community of 1.6 million moms and caregivers advocating for clean air in our neighborhoods in order to protect our families and children from pollution. I strongly oppose EPA’s proposal to redefine "begin actual construction," which would allow companies to build out facilities and power infrastructure before they've applied for air pollution permits. I know firsthand that trying to get a company or facility to alter its pre-existing infrastructure is nearly impossible.
How do I know? I live in Memphis, less than ten miles from the ever-expanding xAI data centers that were constructed without community input and are being sued for illegally operating dozens of large scale poison-spewing gas turbines. The air quality in Memphis gets an F grade from the American Lung Association every year due to freight traffic, industrial pollution, tons of rail yards, and pre-existing fossil fuel plants. Now add to this the unpermitted gas turbines operating at xAI that are operating despite community protest. It's a nightmare scenario for families like mine whose children have respiratory issues and for sure shouldn't be breathing NOx, formaldehyde, and other toxic chemicals that are coming from these power sources.
This proposal is offensive to every mother and individual who cares about clean air for themselves and for children. And frankly who doesn’t want clean air? Think of the schools, churches, and homes that are proximate to the thousands of potential facilities this proposal would allow to build out with no proper accountability for air quality. We are not opposed to economic growth. We all need jobs. But it is EPA's job to make sure development happens with human health in mind, with transparency of cumulative pollution impacts, and with community partnership.