Statement on Rulemaking Concerning State Greenhouse Gas Emissions

This statement was delivered at the Colorado Air Quality Control Commission hearing on February 20th, 2020.  An earlier version was delivered at the Air Pollution Control Division hearing on January 16th.

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 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.  Critically, SB19-096 requires that the rules needed to achieve our GHG emission reduction goals be proposed by July 1st of this year.

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.  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 require top-down measurements of GHG emissions via flyovers to assess actual emissions being leaked from the oil and gas industry in Colorado, considering that studies have indicated that Colorado’s actual methane emissions are 2-5 times higher than currently estimated.  The data from ground and air-based monitoring will help improve the estimate of methane emissions in the next Colorado GHG Inventory Report.

Finally, we believe it is important for Colorado to recognize the contribution of its fossil fuel exports to the climate crisis.  The AQCC can do this by requiring that future GHG Inventory Updates include the anticipated CO2 emissions from fossil fuels exported from Colorado for use elsewhere as a sidebar to the historic and projected GHG inventories.

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

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