Statement on Rulemaking Concerning State Greenhouse Gas Emissions

This statement was delivered at the Colorado Air Pollution Control Division hearing on January 16th, 2020.

The Colorado Coalition for a Livable Climate (CCLC) has advocated for the adoption of strong greenhouse gas (GHG) emission reduction goals by the State since our inception in 2015.  The Intergovernmental Panel on Climate Change tells us that in order to have a better than even chance of avoiding climate catastrophe, i.e. to limit the global average temperature rise to no more than 1.5° C above pre-industrial levels, the entire world needs to achieve net zero GHG emissions by 2040.  We believe that Colorado should achieve that goal even sooner, given our historic emissions and our access to ample renewable energy resources.

Last year, the Colorado General Assembly passed SB19-096 and HB19-1261, which together establish GHG emissions reduction goals for 2025, 2030, and 2050.  While the latter two goals don’t go far enough, we are fully supportive of the 2025 goal, which is to reduce emissions by 26% compared to 2005 levels.  It is essential to begin making deep reductions as soon as possible, since GHGs such as carbon dioxide and fluorinated gases remain in the atmosphere for many hundreds – if not thousands – of years.

SB19-096 and HB19-1261 give primary regulatory power over GHGs to the Air Quality Control Commission (AQCC).  While we appreciate the AQCC moving toward regulating hydrofluorocarbons (HFCs), we note that those two acts do not limit the AQCC’s scope to regulating HFCs.  According to the 2019 draft Colorado GHG Inventory Report, HFCs and other fluorinated gases will constitute less than 1% of all GHG emissions this year.  In order to start making real progress toward the 2025 goal, the State needs to move aggressively to limit the emissions of all significant GHGs, specifically carbon dioxide, methane and nitrous oxide, in addition to fluorinated gases.

Addressing methane emissions is particularly important, given the potency of that greenhouse gas and the large amounts of it emitted during the process of extracting fracked oil and gas.  Additionally, there is a large body of research suggesting that estimates by the EPA of the amount of methane that leaks from those wells are too low.  We believe that when the State develops its next GHG Inventory Report, this research should be taken into account.  Continuous ground-based monitoring at oil and gas facilities is required by SB19-181, and the AQCC should include this in its rulemaking.  The AQCC should also consider requiring spot measurements of emissions from aircraft.  The data from ground and air-based monitoring will help improve the estimate of methane emissions.

In conclusion, the CCLC calls on the Air Pollution Control Division to ask the AQCC to initiate the Regulation 22 process as soon as possible, to move quickly in developing that regulation, and to address the emissions of all significant GHGs so that Colorado can do its part to address the global climate crisis.

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