The Colorado Air Pollution Control Division (APCD) has not yet made a ruling on the PRPA application for an air quality permit for the proposed 5 new gas turbines at the Rawhide Energy Station. We are reaching out to highlight a critical permitting issue that most commenters haven’t yet heard about— this major-scale project is being treated as a minor one—blocking our right to a public hearing with the Air Quality Control Commission (AQCC). The AQCC needs to hear from us!
PRPA’s proposal involves five new 40 MW fracked gas turbines totaling 200 MW at an already major industrial facility. Under state and federal air quality law, projects of this scale are evaluated to determine whether they constitute a major source of air pollution, based on their aggregate potential emissions.
In this case, the APCD erroneously processed the Rawhide project as a minor source permit, which limits the scope of review and avoids a formal public hearing before the Air Quality Control Commission.
How you can help:
The AQCC is holding a public meeting on Wednesday, February 18 at 4:30 pm, which includes a general public comment session at the beginning of the meeting on any air pollution issue.
- Submit a written comment to the AQCC before Feb. 18 explaining why a major-source determination and public hearing are warranted. Submit your comment via email to: cdphe.aqcc@state.co.us and michael.ogletree@state.co.us. See sample letters below.
- Sign up to speak at the Feb. 18 meeting. Register here: https://us02web.zoom.us/meeting/register/DYWQff0TR1SExSbU0MT6GQ#/registration
You do not need to write or say anything super technical. A clear and simple statement that you believe this project warrants major-source treatment and a public hearing is sufficient. Here are some sample paragraphs which you can personalize:
Sample Paragraph 1 – Clear and Direct
I urge the Air Quality Control Commission to treat PRPA’s Rawhide gas turbine proposal as a major source under the Clean Air Act and require a public hearing. The proposed permit appears to rely on unverified assumptions and arbitrary accounting—not enforceable limits—to create the false appearance of staying under the thresholds that trigger major review. A project of this size, with five new gas turbines and potentially high levels of NOₓ and other pollutants, deserves full scrutiny. The public has a right to weigh in before construction begins, not after the fact.
Sample Paragraph 2 – Emphasizing Health and Fairness
I am deeply concerned that PRPA’s proposal for five new fracked gas turbines is being processed as a “minor” source, when the scale and cumulative pollution suggest it should be classified as major. Northern Colorado communities already face serious air quality challenges, especially with ozone. If this project goes forward without enforceable limits and without a proper public hearing, it would undermine both health protections and public trust. The Commission should intervene and ensure a full, fair review process.
Sample Paragraph 3 – Legal Focus with Layperson Clarity
The Clean Air Act requires a different permitting process for “major” sources of pollution, including stronger limits, deeper review, and a public hearing. The 200 MW Rawhide turbine project crosses those lines—or comes close enough that it must be reviewed under major source rules. Right now, it looks like the permit relies on modeling assumptions instead of enforceable safeguards. That’s not legally sufficient. I respectfully request that the Commission evaluate the permit’s classification and ensure public hearing rights are upheld.
While the Commission will not take immediate action during this meeting, it can:
- receive concerns about the misclassification of PRPA’s project as minor,
- be formally put on notice of the public’s objections to permitting the gas plant,
- and begin to consider whether a public hearing should be required.
This is the right moment to loudly and clearly state:
This PRPA project should be treated as a major source of potential air pollution, and the public is entitled by both state and federal law to a public hearing.
- For more information read the Substack article by Ethan Augreen (MA Environmental Leadership; Longmont, CO) “A Major Loophole: How Misclassifying PRPA’s 200 MW Permit Application for New Fracked Gas Turbines as “Minor” Can Undermine the Clean Air Act and Silence Public Oversight” to learn more about this issue (at https://ethanaugreen.substack.com/)
Thank you again for your engagement and for helping ensure that air quality decisions in Northern Colorado receive the level of public scrutiny the law intends.
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