By: Shaina Oliver, Colorado Organizer, Moms Clean Air Force and EcoMadres
Date: April 16, 2025
About: Adding Ultrafine Particles & Black Carbon to Colorado Toxic Air Contaminants Reporting
To: Air Quality Control Commission
Thank you for your leadership in this difficult time. I am Shaina Oliver, a Field Organizer for Moms Clean Air Force, an organization of 1.5 million Moms, Dads, and Caretakers fighting for our children’s health and environmental well-being. Over 43,000 members in Colorado are looking up to leadership to protect their children’s health and environmental safety. Reg. 3 and 7 are important to our communities to improve air quality and protect our most vulnerable communities from the harmful impacts of air pollution.
Moms Clean Air Force-EcoMadres Colorado chapter support Reg. 3 in requiring increased emission fees to fund various air programs that support the Division’s Programs, including air toxics reporting and permitting by increasing fees to Air Pollutant Emission Notice (APEN) and regulated pollutants and hazardous air pollutants (HAPs). We support Reg. 7 revisions to expand Toxic Air Contaminants and additional air pollutant (“CAP”) reporting to all sources subject to annual Oil and Natural Gas Annual Emission Inventory Reporting (“ONGAEIR”).
Additionally, we support proposals to include Ultrafine Particles and Black Carbon to be included in the toxic air contaminant reporting program. Colorado’s statute states that an air toxic is an air pollutant that may cause an adverse ecological or environmental effect. Ultrafine Particles meet this definition and are harmful due to their size and impacts on health, including decline in microvascular function and pulse amplitude, inflammatory responses, oxidative stress-induced genotoxicity, decreased lung function, and decreased vasomotor function. Black Carbon meets this definition for its ability to absorb heat and light, and can contribute to climate change, but health risks include cardiovascular and cardiopulmonary mortality, adverse birth outcomes, decreased cognition, and lung cancer. Research by the World Health Organization have guidelines to develop ambient air quality measurement protocols for Black Carbon. The WHO identifies both UFPs and Black Carbon as health risks, and both meet the statutory definition of a Toxic Air Contaminant, which “Air Toxics are pollutants that cause or may cause cancer or other serious health effects, such as adverse reproductive effects or birth defects or adverse environmental and ecological effects.”
According to the American Lung Association’s “State of the Air”, the Denver Metro region ranks sixth worst in cities to breathe due to ozone-smog pollution. Ozone-smog pollution is detrimental to developing and vulnerable bodies, putting our children and elderly at risk. Additionally, the CDC reports that 500,090 Coloradoan’s are asthmatic, and that includes me and my youngest child.
Being Indigenous, POC, and/or low-income, we are marginalized and segregated into communities that lack access to clean air, water, adequate housing, health care, and education. We are disproportionately impacted by the respiratory health harms like asthma, COPD, stroke, and death on the Navajo Reservation and off the Reservation because we are forced to live in these conditions. And equally important, the nation is deeply disturbed by the lack of willingness of our legislators in protecting people of color in policy, and that needs to change.
As parents, Moms Clean Air Force-EcoMadres Colorado chapter urge your leadership to support Reg 3 & 7 and to consider including Ultrafine Particles and Black Carbon to the Toxic Air Contaminants reporting program to better represent communities most vulnerable to toxic air pollutants.