Xcel Energy’s Pueblo Comanche 3 Just Transition

Xcel Energy, Colorado's largest utility, is scheduled to decommission and replace the Comanche 3 coal plant in Pueblo – the state's single largest climate pollution source – by 2031. Healthy Air and Water Colorado (HAWC) recently submitted testimony to the Colorado Public Utilities Commission (PUC) urging decision-makers to consider the public health impacts of possible new gas-fired power plants as part of the state’s energy resource planning to continue our progress toward a clean energy future.

Dr. Jim Crooks, HAWC Advocate and environmental health expert, made the case that while switching from coal to gas for electricity is better, gas plants still seriously harm public health. Burning gas releases pollutants like fine particulate matter (PM2.5) and chemicals that create ground-level ozone—both linked to heart disease, lung problems, and premature death.

>> Read Answer Testimony from Dr. Jim Crooks

HAWC Executive Director Alex Boian argued that the PUC should require that Xcel factor in public health impacts when approving new energy projects. Current plans to build gas plants don’t include adequate analysis of how those power plants will impact people’s health, putting our communities at further risk.

>> Read Answer Testimony from Alex Boian

Our message was clear: Burning gas makes people sick – especially in communities already struggling with poor air quality. Here's what you need to know:

Gas Plants Harm Public Health—And We’re Not Talking About It

While coal is on the way out, new gas plants still emit harmful pollutants like fine particulate matter (PM2.5), nitrogen oxide (NOx), and ozone precursors that can trigger asthma, heart attacks, strokes, and premature death. Yet these health impacts are missing from the conversation when utilities propose new power plants.

The Tools Exist to Measure Health Impacts – Let’s Use Them

Right now, utility plans focus on long-term climate costs using the “Social Cost of Carbon,” but that leaves out the real and immediate harm caused by PM2.5, NOx, and ozone. We’re urging regulators to require full health impact analyses using EPA-endorsed tools like COBRA and InMAP – so decision-makers can see the full cost of pollution.

Protect the Communities Already Bearing the Burden

New gas plants shouldn’t be built in places already dealing with high pollution levels. Communities designated as disproportionately impacted and areas like the Denver Metro/North Front Range ozone non-attainment zone deserve better. Health data should guide where we do – and don’t – build new energy infrastructure.

What HAWC Is Fighting For

We’re calling on the Colorado Public Utilities Commission to:

• Require utilities to track and report PM2.5 emissions.
• Conduct a full health impact analysis before approving new gas plants.
• Use that analysis to keep polluting facilities out of the most vulnerable communities.

Why It Matters

When we make energy decisions without considering public health, we all pay the price – especially kids, seniors, and those with chronic health conditions. By putting health at the center of Colorado’s energy future, we can build a system that’s not just clean, but safe and just for everyone.

Join us in advocating for a healthier, more equitable energy future. Learn more and get involved at www.CleanUpXcel.org.

If you are a health provider who lives or serves patients who live in Pueblo or the surrounding area and you would like to get directly involved with our effort, please email aboian@hawcolorado.org.