To: Taryn Finnessey, Senior Climate Change Specialist, Colorado Water Conservation Board/Department of Natural Resources
CC: Governor John Hickenlooper, All Colorado State Senators and Representatives, All Fort Collins City Councilmembers
From: Kevin Cross, Colorado Coalition for a Livable Climate Spokesperson
Date: November 2nd, 2017
Re: Comments on draft 2017 Colorado Climate Plan
The Colorado Coalition for a Livable Climate, which is comprised of 21 organizations advocating strategies for reducing Colorado’s greenhouse gas emissions to levels supportive of a livable climate, has reviewed the draft 2017 Colorado Climate Plan, and offers the comments provided below.
We appreciate the fact that the Department of Natural Resources has prepared the draft 2017 Colorado Climate Plan, and believe that it presents an important opportunity to move forward in an area of vital concern to our State’s future well-being. Overall, we see the document as largely a review of initiatives that are already in place or well underway, rather than as a detailed presentation of new initiatives that will allow the State to achieve the climate goals set forth in Executive Order D 2017-015 released this past July. Further, we are concerned that those climate goals are based less on climate science than on political considerations.
We look forward to the release of a Colorado Climate Action Plan in the near future, having goals based on climate science, and describing clearly how those goals can be achieved. In this connection, we recommend for your consideration the process undertaken by the City of Fort Collins in 2013 – 2015. That process resulted in a Climate Action Plan Framework that features some of the most ambitious greenhouse gas emissions reduction goals in the world (80% below 2005 levels by 2030, and carbon neutrality by 2050), and a roadmap for how to achieve those goals. The State of Colorado would do well to follow a similar process as soon as possible.
Our detailed comments on the 2017 Colorado Climate Plan follow.
Review of the Draft 2017 Colorado Climate Plan
By the Colorado Coalition for a Livable Climate (CCLC)
November 2nd, 2017
The draft 2017 Colorado Climate Plan (referred to in this document as “the Plan”) is available here.
Page i: C.R.S. 24-20-111 calls for the development of “climate action plans”, not “climate plans.” We wonder why the word “action” was dropped from the title of the Plan. That word communicates that the State actually intends to take serious measures toward addressing the climate crisis, and we strongly believe that it should be included in the title of the Plan.
Page ii: The CCLC appreciates the fact that the Governor established a measureable goal for reducing Colorado’s total greenhouse gas (GHG) emissions via executive order in July of this year. However, it is important to acknowledge that a 26% reduction by 2025 compared to 2005 levels is not supportive of limiting the global average temperature rise to 1.5 – 2.0 degrees Centigrade with respect to the pre-industrial average, as called for in the 2015 Paris Climate Agreement. Colorado should instead be targeting a reduction of 2 – 3 times that figure by 2025. Additionally, Colorado should establish a longer term GHG emissions reduction goal of 80% – 100% compared to 2005 levels by 2030.
Page 4: State agencies providing input to the Plan are listed, and reference is made to “key stakeholders” who provided additional input, although these stakeholders are not named. We wonder whether climate scientists, ecological scientists, soil scientists, engineers, economists, and other experts at the University of Colorado, Colorado State University, or other Colorado-based institutions were consulted concerning the goals and the means of achieving those goals proposed in the Plan. If not, why not?
Pages 5 and 6: The “Clean Air Clean Jobs” act is referenced as reducing “emissions” due to substituting natural gas (i.e. methane) for coal in the power sector. While gas-fired power plants emit less Sulphur Oxides, Nitrogen Oxides, and Carbon Dioxide than coal-fired plants do per unit of electricity produced, they likely increase total greenhouse gas emissions. This is because methane is a powerful greenhouse gas, and is released during the extraction and transportation processes. Recent research indicates that the methane leakage rate in the Denver-Julesburg Basin is 4%, which means that the use of natural gas is more harmful to the global climate than is burning coal. Fracked gas also has well-known harmful effects to public health, safety and quality of life, as is clearly indicated by the more than one thousand complaints that the Colorado Oil and Gas Conservation Commission (COGCC) has received from people living near oil and gas wells this year alone.
The CCLC expects that methane emissions during the extraction and transportation processes will be fully accounted for in the “greenhouse gas emissions tracking rule” to be developed by the Department of Public Health and Environment that is mentioned on page 6.
Page 2: The Plan makes numerous references to the Colorado Water Plan beginning on page 2, and does not offer anything significant that goes beyond what is contained in that document. The Colorado Water Plan advocates for more dams, diversions, and depletions from Colorado’s rivers on both sides of the divide. Most of Colorado’s rivers — including the namesake Colorado River — are already severely depleted and cannot withstand any more dams or diversions. The Colorado Water Plan is insistent on Colorado “getting its allotment” by diverting every legally allowed drop of water before our rivers reach the state line – north, south, east, or west. This is not consistent with climate planning. Instead, it’s a prescription for river destruction that could have disastrous consequences, given the predictions related to warming and drying that climate scientists are now predicting. We need to protect and restore our rivers to achieve climate resilience, not just for the human inhabitants of Colorado, but also for the animals and plants that are essential components of the environment of our beautiful state.
4 Greenhouse Gas Emissions
Page 1: Data is provided showing that Colorado’s economy grew while carbon intensity per unit of state GDP declined, and that the national economy grew while carbon emissions declined slightly. The Plan should acknowledge that these emissions reductions will have to be accelerated dramatically if Colorado and the United States are to be able to contribute in a meaningful way to the mitigation of climate change.
Page 2: Executive Order D 2017-015 is referenced for the third time (see also page ii of the Executive Summary and page 6 of the introduction, and our previous comment on the Governor’s overall greenhouse gas emissions reduction goal). The Governor’s goals for electricity sector CO2 emissions reductions are 25% by 2025 and 35% by 2030 compared to 2012 levels. These goals are far too cautious, both compared to what is needed in order to mitigate climate change and what many Colorado communities have achieved, have committed to, or are contemplating. For example, Aspen already operates on 100% renewable electricity, Pueblo has committed to achieving 100% renewable electricity by 2035, Colorado State University has committed to 100% renewable electricity by 2030, and the Platte River Power Authority is currently studying how to achieve net zero carbon emissions for its four member cities (Fort Collins, Longmont, Loveland, and Estes Park) by 2030.
Page 4: Governor Ritter’s Executive Order D 004 08 called for statewide greenhouse gas inventories to be released every five years, starting in 2012. The first greenhouse gas inventory was not released until 2014, and contained several important deficiencies as outlined previously by the CCLC here. Given the threat posed by climate change to Colorado, the CCLC calls on the State to update its greenhouse gas inventory annually instead of once every five years. We note that the City of Fort Collins releases an annual community greenhouse gas inventory, and are confident that the State of Colorado has the capability to do so as well.
Page 11: The Plan mentions a number of local government targets and initiatives, many of which are significantly more ambitious than those set forth in the Plan for the State of Colorado. The State should be taking inspiration from local efforts and making an effort to meet or exceed those efforts – not setting goals that will be relatively easy to attain and which are far lower than what will be needed to successfully mitigate climate change.
Pages 2 – 5: While the Plan celebrates Colorado’s accomplishments in the realm of renewable energy, it fails to set forth any new goals for renewable energy production. The Plan should set a target date for obtaining 100% of Colorado’s electricity from renewable sources between 2030 and 2035.
Pages 11 – 12: The Plan discusses Colorado’s fossil fuel extraction industries (coal, oil, and gas) without recognizing that in order to meaningfully address climate change, the majority of remaining fossil fuel resources will have to be left in the ground. We will not be able to continue extracting coal, oil, and gas at anything close to the present rates if we are to preserve a livable climate. Suggesting that we just need to use water more efficiently, capture methane, and employ waste heat recovery in the fossil fuel extraction process to address climate change is simply a form of climate change denialism.
Page 8: The plan mentions private electric vehicles and the need to expand charging station infrastructure. It does not – but should – advocate for the rapid electrification of the entire ground-based transportation system, including private vehicles, buses, commercial trucking, and rail. Electricity used for transportation will need to be generated with renewable resources. Continuing to rely on fossil fuels for transport for decades into the future will not allow us to achieve the greenhouse gas emissions reductions required to preserve a livable climate.
Page 3: The Plan discusses the 2015 Colorado Resiliency Framework, and notes that the State engaged with 450 “stakeholders” in developing that document about their views on the roles and responsibilities of state governments, local governments, and community institutions in making communities more resilient. Little in the Plan suggests that the Executive Branch engaged with the numerous institutions in Colorado, including but not limited to relevant departments and colleges at the University of Colorado and Colorado State University, the National Renewable Energy Laboratory, the Rocky Mountain Climate Organization, and the Rocky Mountain Institute, to help establish the goals and the means proposed to achieve those goals that are set forth in the 2017 Climate Plan. The CCLC believes strongly that such a collaborative effort would greatly increase the likelihood that the next State Climate Action Plan will successfully lay out a road map that would enable Colorado to contribute in a significant way to addressing the problem of climate change. We call on the Governor and the Department of Natural Resources to begin work on such a Climate Action Plan immediately.