By: Shaina Oliver, Colorado Field Organizer
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
Thank you for taking the time to hear my comments. I’m Shaina Oliver, Indigenous Peoples Rights Advocate, Field Organizer with Moms Clean Air Force Colorado, and EcoMadres outreach coordinator. We are a national organization of parents united against harmful air pollution and climate change to protect our children’s health and future.
Colorado Moms and EcoMadres urge you to consider the health of our children and strongly urge your leadership to oppose this proposal to redefine “begin actual construction,” which would undermine our children’s health and communities' choice to make their voices heard on construction that may bring dangerous air pollution. Construction projects should reflect the voices of communities and most importantly must protect children’s health.
Importantly, I’m a mother of four children. We are federally recognized tribal members of the Navajo Nation, living, learning, and working in northeast Denver, Colorado. As a Tribal member and mother, I’ve seen the environmental deterioration of my ancestral lands and its impacts on public health on and off the Navajo Reservation due to the environmental racism in U.S. laws, regulations, and policies. Our communities have been on a path of cleaning up toxic contaminants and addressing our ground-level ozone pollution that has left our community in Denver in nonattainment, with levels that are unhealthy to breathe. As Moms we know these toxic environments are detrimental to our children’s health and their future. Communities have been facing these environmental assaults and are on track in building resilience and looking toward a future that doesn’t overlook community voices.
For far too long, our communities have been battling premature deaths, adverse birth outcomes, mental illness, cancer, respiratory illness, and autoimmune disease. And it’s common for our children to have one or many of these adversities in our communities. Our communities need leadership to consider economies that include community voices and that protect our children’s health.
As a mom and as a parent with family members with asthma, we are most vulnerable to environmental impacts from polluting facilities and developments, like the new pollution sources that would be covered by this proposed rule. Communities have long waited for environmental protections that best protect our children from harmful contaminants that have the potential to alter genes, disrupt development of internal organs, and harm baby’s health before they even take their first breath. According to the American Lung Associations’ 2026 "State of the Air" report, the Denver-Greele-Aurora area is among the top 10 cities for terrible ozone pollution.
Moms know maternal health is vital to a baby’s health, and factors outside a mother’s control—like pollution in the air she breathes—can be detrimental. Colorado parents and Moms Clean Air Force urge your leadership to oppose redefining “begin actual construction.” Parents’ and communities’ voices are just as important as the voices of industry.
Importantly, the rights of Tribal sovereignty must be respected in the right to exist as a Sovereign Nations, and we reserve the right to exist as inherent to future generations.