By: Shaina Oliver, Colorado Organizer, Moms Clean Air Force and EcoMadres
Date: April 24, 2025
About: Title V Operating Permit for Holly Energy’s Denver Product Terminal
To: Air Pollution Control Division (APCD)
Thank you for taking my comments. I’m Shaina Oliver, field organizer and Indigenous Peoples’ Rights Advocate with Moms Clean Air Force-EcoMadres Colorado chapter. We are a national organization of 1.5 million moms, dads, and caregivers united in protecting our children from harmful air pollution and the impacts of human-caused climate change, with over 43,000 members in Colorado. Moms Clean Air Force Colorado Chapter supports the requirements of Title V air-pollution permit reporting of Holly Energy and for analysis of cumulative impacts of environmental justice communities as required by HB24-1338.
While the intent of requiring reformulated gasoline (RFG) is to reduce ozone precursors during the hot summer months, this permit could increase NOx emissions—an ozone precursor—potentially leading to a localized rise in ozone levels. Additionally, this expansion is located just outside the border of an environmental justice (EJ) community where the enviro screen excludes these communities that are within proximity of Holly Energy. Serious consideration should be given to applying the higher standards required for EJ communities to this facility, as cumulatively impacted residents live within 2,000 feet of the Holly Energy Terminal. Given the concerns regarding the effectiveness of RFG, cumulative impacted communities need a thorough technical review to assess whether the benefits of RFG outweigh the increase in localized pollution, with a particular focus on the health of the most affected residents along with community outreach.
Currently, Denver-Aurora-Greeley Communities ranks sixth for worst air quality for ozone-smog pollution according to the American Lung Association's “State of the Air” report, which is detrimental to elders, maternal, children, and baby’s health. These pollutants also exacerbate respiratory illnesses like asthma. Over 500,000 Coloradoans with asthma, like me and my youngest child, are vulnerable to these harmful pollutants, according to CDC reports.
Parents of Colorado are counting on your leadership to protect our children’s health and environmental safety. Moms Clean Air Force Colorado urge your leadership to ensure Title V permitting processes remain and to conduct a thorough analysis and outreach of cumulative impacted communities as required by HB24-1338 Cumulative Impacts & Environmental Justice | Colorado General Assembly; before approving or disapproving changes to Holly Energy operations. Thank you.