November 3, 2025
Earthworks appreciates the opportunity to provide comments on the proposed revisions to the ozone state implementation plan (SIP).
Our comments on Colorado’s ozone SIP will be narrowly focused on:
1) Support for the proposed revisions to Regulation 7 that would require operators of facilities in the Denver Metro/North Front Range (DMNFR) ozone nonattainment area to control emissions from separator maintenance during the summer ozone season while also urging the Commission to adopt the proposals offered by the Local Government Coalition (LGC) and Environmental Defense Fund (EDF) to further strengthen the draft rule.
2) Request that the Air Quality Control Commission (AQCC) take more aggressive action to curb ozone precursor emissions and consider control strategies outlined in the Regional Air Quality Council’s (RAQC) Control Strategy Blueprint.
Separator maintenance
Earthworks strongly supports the proposed revision to Regulation 7 that would require operators of facilities in the DMNFR ozone nonattainment area to control emissions from separator maintenance during the summer ozone season and urges the Commission to disregard arguments by industry stakeholders that aim to strip this provision from the draft rules…