Report on Colorado’s Adoption of Health-Based Air Quality Standards

Introduction: Advancing Sustainable Development Through Air Quality Control

The Colorado Air Quality Control Commission (AQCC) has adopted new health-based standards for five toxic air contaminants (TACs). This regulatory action represents a significant step towards achieving key United Nations Sustainable Development Goals (SDGs), particularly those concerning public health, sustainable communities, and responsible industrial practices. The new benchmarks, established following a 2022 state law, will serve as foundational elements for future permitting regulations, shifting focus from solely greenhouse-gas emissions to pollutants with direct, adverse health impacts.

Alignment with Sustainable Development Goals (SDGs)

SDG 3: Good Health and Well-being

The primary objective of the new standards is to advance SDG 3, specifically Target 3.9, which aims to substantially reduce deaths and illnesses from hazardous chemicals and air pollution. The regulations establish health-protective thresholds for five priority pollutants emanating from industrial, energy, and waste management sources.

• Formaldehyde: Linked to respiratory issues and cancer.
• Benzene: A known carcinogen that can also impact reproductive systems.
• Hexavalent Chromium: A carcinogen associated with respiratory ailments.
• Ethylene Oxide: Affects nervous and respiratory systems.
• Hydrogen Sulfide: Can cause headaches, nausea, and psychological disorders.

SDG 11: Sustainable Cities and Communities

The rulemaking process explicitly considered the cumulative impact of pollutants on vulnerable populations, directly addressing SDG 11, Target 11.6, which calls for reducing the adverse per capita environmental impact of cities by improving air quality. Environmental advocates argued for more stringent standards to protect communities disproportionately affected by pollution due to systemic factors. The commission acknowledged the need to consider extrinsic risks like socioeconomic status and healthcare access in protecting these communities.

SDG 12: Responsible Consumption and Production

By targeting emissions from sources such as oil and gas wells, industrial plants, and manufacturing facilities, the new standards promote SDG 12, Target 12.4, on the environmentally sound management of chemicals and wastes. The regulations are designed to hold producers accountable for pollutant releases, encouraging cleaner production methods to minimize adverse impacts on human health and the environment.

Regulatory Process and Stakeholder Deliberations

Establishing Health-Protective Benchmarks

The AQCC’s deliberations centered on defining appropriate risk levels, reflecting the inclusive and participatory decision-making process outlined in SDG 16 (Peace, Justice and Strong Institutions). Key points of debate included:

1. Cancer Risk Level: The commission adopted a benchmark corresponding to a cancer risk of one in one million people, rejecting industry proposals for a less stringent 10-in-one-million risk level.
2. Non-Cancer Risk Level: A significant debate occurred over the Hazard Quotient (HQ) for non-cancer health effects. The Air Pollution Control Division (APCD) proposed an HQ of 0.3 to account for cumulative exposures, while industry sectors advocated for an HQ of 1.0, consistent with most other states.

Balancing Environmental Health and Economic Viability

In line with the principles of SDG 8 (Decent Work and Economic Growth), business leaders raised concerns about the potential economic impact of the new standards, particularly since their application in permitting was not yet defined. As a concession, regulators added a provision ensuring that the benchmarks cannot trigger new regulatory or economic impacts without a subsequent rulemaking hearing, providing a more predictable framework for industry.

Decision and Future Implementation

A Compromise on Regulatory Standards

The AQCC reached a compromise that balanced scientific data, public health imperatives, and economic concerns. The final decision involved:

• Setting the non-cancer Hazard Quotient at 1.0 for formaldehyde, hexavalent chromium, ethylene oxide, and hydrogen sulfide. Commissioners reasoned this was a more realistic standard for individual pollutants.
• Establishing a separate, more stringent non-cancer concentration standard for benzene, a known carcinogen, aligning with standards set by the California Environmental Protection Agency.

Next Steps: Integrating Standards into Permitting

While the health-based standards have been approved, their full impact remains contingent on future rulemakings that will integrate them into permitting requirements. The commission formally acknowledged that the current benchmarks do not account for multi-pollutant impacts, stating that this critical consideration will be addressed in future regulatory actions. This forward-looking approach ensures a continued commitment to protecting public health and advancing Colorado’s alignment with global sustainability targets.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 3: Good Health and Well-being

   The article’s central theme is the establishment of “health-based standards for five air pollutants” to prevent “major health problems” such as cancer, respiratory issues, and reproductive system problems. The entire regulatory process described is aimed at protecting human health from the adverse impacts of air pollution.

2. SDG 9: Industry, Innovation, and Infrastructure

   The regulations directly impact various industries, including “oil and gas wells,” “industrial plants,” “cement-manufacturing plants,” “coal-fired power plants,” and “medical-device-manufacturing.” The new standards will necessitate changes in industrial processes and infrastructure to limit emissions, pushing these sectors towards more sustainable operations.

3. SDG 10: Reduced Inequalities

   The article explicitly mentions the need to protect “vulnerable populations grouped into polluted neighborhoods because of systemic racism” and “disproportionately impacted communities.” The debate over setting stricter benchmarks considers the “cumulative impact of multiple toxics” on these groups, directly addressing the goal of reducing health inequalities.

4. SDG 11: Sustainable Cities and Communities

   The focus on air quality directly relates to creating sustainable and safe urban and residential environments. The article discusses pollutants affecting communities like “north Denver and Commerce City” and the need to manage emissions from sources like “wastewater-treatment plants,” which are crucial components of city infrastructure.

5. SDG 12: Responsible Consumption and Production

   The article addresses the environmental cost of industrial production by focusing on the release of hazardous chemicals. The regulations on pollutants like formaldehyde, benzene, and ethylene oxide are a direct attempt to achieve the “environmentally sound management of chemicals” and reduce their release into the air from production processes.

6. SDG 16: Peace, Justice, and Strong Institutions

   The entire article describes the functioning of a state-level institution, the “Colorado Air Quality Control Commission.” It details a public, regulatory process involving hearings, debates between industry and environmental groups, and the establishment of legally binding rules. This demonstrates the development of effective, accountable, and transparent institutions responsible for environmental governance.

2. What specific targets under those SDGs can be identified based on the article’s content?

• Target 3.9:

  By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination. The article directly supports this by describing the creation of standards to limit exposure to five specific air toxics known to cause “cancer,” “respiratory ailments,” and other “adverse impact to their health.”

• Target 9.4:

  By 2030, upgrade infrastructure and retrofit industries to make them sustainable…and greater adoption of clean and environmentally sound technologies and industrial processes. The new “permitting regulations” will force industries like oil and gas, manufacturing, and wastewater treatment to adopt processes that reduce emissions of the five toxic air contaminants.

• Target 10.3:

  Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies and practices. The article highlights that the law “called upon regulators to consider the cumulative impact of multiple toxics” and protect “vulnerable populations,” which is a direct attempt to reduce the unequal health outcomes faced by residents in “disproportionately impacted communities.”

• Target 11.6:

  By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality. The regulations are a direct measure to improve air quality in Colorado’s communities, particularly those affected by industrial pollution, such as Commerce City.

• Target 12.4:

  By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle…and significantly reduce their release to air…to minimize their adverse impacts on human health and the environment. The rules specifically target the release of five hazardous chemicals (formaldehyde, benzene, etc.) into the air from industrial sources.

• Target 16.6:

  Develop effective, accountable and transparent institutions at all levels. The article details the deliberative and public process of the “governor-appointed regulatory board” (AQCC), which includes hearings, testimony from various stakeholders, and a final vote, showcasing an institution in action.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

• Concentration of specific pollutants in the air:

  The primary indicators are the measured levels of the five specific toxic air contaminants (TACs): Formaldehyde, Benzene, Hexavalent chromium, Ethylene oxide, and Hydrogen sulfide. The article mentions a proposed standard for formaldehyde of “.074 parts per billion.” Monitoring the ambient concentration of these pollutants is a direct way to measure progress.

• Health risk benchmarks:

  The article specifies two clear, quantifiable indicators adopted by the commission to set the standards:

  • A cancer risk level set at “one in one million people.”
  • A non-cancer risk level measured by a “hazard quotient (HQ) of 1.”

  These benchmarks serve as the basis for the regulations and are measurable indicators of the desired level of safety.

• Rates of pollution-related illness in specific communities:

  An implied indicator is the rate of specific health issues in affected areas. The article notes that residents in communities like Commerce City “say they’ve been exposed for too long to toxic pollutants that have led to higher rates of cancer and respiratory illnesses.” Tracking these health statistics over time, especially in “disproportionately impacted communities,” would be a key indicator of the regulations’ effectiveness.

• Number of industrial permits issued/modified under the new standards:

  Progress towards Target 9.4 and 16.6 can be measured by tracking how the new “health-based standards” are “worked into permitting requirements.” The number of permits that are reviewed, modified, or denied based on these new air quality rules would indicate the institutional enforcement of the policy.

4. Create a table with three columns titled ‘SDGs, Targets and Indicators” to present the findings from analyzing the article.

Source: tsscolorado.com