By: Laurie Anderson, Colorado Field Organizer, Moms Clean Air Force
Date: December 10, 2024
About: Limited revisions to Suncor Plant 2 Title V operating permit
To: Air Pollution Control Division
My name is Laurie Anderson and I am a Colorado Field Organizer with Moms Clean Air Force - a community of over 1.5 million moms and dads united against air pollution—including the urgent crisis of our changing climate—to protect our children’s health.
I appreciate this opportunity to comment today regarding the Suncor Plant 2 Title V operating permit as it impacts the health of communities - especially our children, the elderly, and individuals with existing health conditions.
Many residents who are adversely impacted by industrial operations do not have the time or ability to engage in the permitting process - let alone become experts on air quality. However, they are aware that the 2023 EPA report found the Suncor refinery had more air pollution incidents compared to other refineries - which is concerning - and that Suncor has a pattern of non-compliance with over 1000 self-reported events and many more that went unreported.
Regardless of how much money Suncor has spent on repairs and upgrades, the fact remains that the permits must be written to protect the community. If additional filtration is needed - then add it, but if the root cause is aging equipment that is beyond its expected lifetime and no longer performing per the manufacturer specifications, then the solution may very well be that new equipment is needed - and not just more bandaids.
It is important to recognize that air quality monitoring funded by the Suncor settlement funds provided a year of independent, reference grade monitoring for multiple chemicals of concern. The Boulder AIR monitoring data not only showed high levels of certain chemicals that were anticipated, but also captured concerning levels of “Gas and Particle Phase Radioactivity”. The financial cost to keep the Boulder AIR monitors running was too high for the impacted community to achieve, but points to the need for funding from the entity responsible for the pollution to continue this independent, third party monitoring oversight - not the impacted community.
As additional monitoring continues, the protocols for measuring these chemicals are critical. If the monitors are mounted too low, much pollution will waft above without being detected. Additionally, detection levels, sensitivity, calibration, monitoring audits, and other factors will determine the effectiveness of the monitoring.
The division must put the health and safety of the residents first and ensure the Plant 2 permits protect residents living in the shadows of Suncor and those impacted even further away. This includes strong, protective rules followed by strict enforcement.
Thank you for your time.