Advocating strategies for reducing greenhouse gas emission to a level supportive of a livable climate.

Author: Kevin Cross Page 1 of 2

Open Letter to our Congressional Delegation: We Need a Green New Deal!

Letter sent on January 22nd, 2021

Dear Members of the Colorado Congressional Delegation:

When the Green New Deal Resolution (H. Res. 109 and S. Res. 59) was first introduced in Congress in early 2019, the Colorado Coalition for a Livable Climate voted wholeheartedly to endorse it.  We communicated that position to you in a letter dated June 24th, 2019.

The impacts of the climate crisis have continued to accumulate over the past year and half, from the burned forests and air pollution caused by the Cameron Peak and East Troublesome wildfires here in Colorado, to the devastation resulting from the North Atlantic’s most active hurricane season ever in the Gulf States, Mexico, and Central America.  This crisis may be moving more slowly than the COVID-19 pandemic, but the threat it poses to our well-being, our economy, the environment, and indeed human civilization itself is far larger over the coming decade.

We are heartened by the incoming administration’s climate team hires and several cabinet nominations, and by changes in the House and Senate that will make it possible to begin taking serious steps toward addressing the climate crisis at the scale required.  We urge you to support legislation in the 117th Congress that will slash our nation’s greenhouse gas emissions, begin to heal the natural world, and put people back to work at livable wages.  A Green New Deal is what’s needed.  Please join together with your colleagues and get to work on it.

Sincerely,

COLORADO COALITION FOR A LIVABLE CLIMATE

Micah Parkin (350 Colorado)

Leslie Glustrom (Clean Energy Action)

Jan Rose (Climate Reality Project Denver-Boulder Chapter)

Kevin Cross (Fort Collins Sustainability Group)

Theron Makley (Wind and Solar Denver)

Ph. 970-484-3141     https://colivableclimate.org

The Colorado Coalition for a Livable Climate (CCLC) is comprised of 31 organizations that collectively develop and advocate strategies for reducing Colorado’s greenhouse gas emissions to levels supportive of a livable climate.

Groups Decry Xcel Energy’s Move to Slow Down Climate Action in Colorado

News release dated December 4th, 2020

Denver–Groups representing thousands of Coloradans have called into question why Xcel Energy, the state’s largest utility who has long positioned itself as a climate leader, has moved to join litigation to slow climate action in Colorado.  The diverse coalition of environmental, justice, health, and climate advocacy groups offered statements below.

Earlier this month, Public Service Company of Colorado, Xcel Energy’s subsidiary, moved to intervene in lawsuits filed by WildEarth Guardians and the Environmental Defense Fund  against Governor Polis and the state for failure to meet a July 1, 2020 deadline to propose regulations that meet greenhouse gas reduction targets set by House Bill 19-1261—Colorado’s Climate Action Plan. 

WildEarth Guardians and the Environmental Defense Fund jointly moved to oppose Xcel’s motion on November 30.

Xcel Energy has long lifted themselves as a climate leader by investing in renewable energy and electrifying the transportation grid—but taking legal action that advocates to slow Colorado’s progress towards its climate goals is not climate leadership. Xcel is now the state’s only utility that has not committed to retiring all coal-fired power by 2030. 

Advocates today offered the following statements in response:

“This isn’t leadership on climate, this is an affront to Colorado’s efforts to confront the climate crisis and curtail greenhouse gas pollution. With its latest legal motion, Xcel seems to be showing us all that it’s goal is to stymie and slow climate progress, not to advance bold action for the climate in the state.”

“Xcel has disappointed us greatly. They have held us hostage as they pump greenhouse gases into colorado. As they support  things can only hurt us. No longer. Xcel says they care about us, about Colorado but we know they only care about themselves. We have seen the health effects of GHG emissions and the effects it has on our earth, on our bodys we are running out of time. They have no excuses left. I am a youth in CO my life is on the line. as they refuse to stop we feel attacked and hurt. Xcel is being a child and they must be held to their responsibilities”.

  • Phoebe Dominguez, 350 Youth Action Committee Head, Phoebe4climate@gmail.com   

“Scientists have made it clear that if we want any chance of staying below 1.5C warming we must be almost completely decarbonized by 2030. (See Reality Check: Climate 2020) 

Xcel should be focusing on more rapidly decarbonizing their electric system by 2030 or sooner, instead of using their vast legal resources to slow our climate efforts down.”

“Decarbonizing Colorado’s electricity supply quickly is the most cost-effective route toward meeting our greenhouse gas pollution reduction goals and doing our part to protect the climate.  Xcel needs to step up to the plate and help, rather than hinder this effort.” 

“Independent studies such as the recent one by GridLab, Sierra Club, and NRDC show utilities need to close coal by 2025 and get to around 75% renewable electricity by 2025.  This should be the baseline for their planning. Thus far, Xcel has been doing their utmost to delay the shift, as here, and maximize what remaining profits they can squeeze out of their old model, to the harm of we who actually live in Colorado.  Despite their advertising, their fossil fuel plants are no longer the most affordable, safe, or reliable path forward. Their largest coal plant was down for repairs almost all year.”

“Moms in Colorado are really disappointed in Xcel. We had hoped their Transportation Electrification Plan was a sign that they were going to work with us to lower our carbon 

emissions and protect our children’s future but joining this lawsuit will only serve to slow down our climate action. It’s like when you think your kid has done something really nice and made you a snack but then you find worms in it.” 

“Continuing to operate coal facilities and gas plants like Cherokee in overburdened frontline communities is part of Xcel’s current plan. We need Xcel to focus on decarbonization and just transition for the health of the planet and local communities as fast as possible instead of coming to the defense of climate inaction.” 

“The Denver Metro North Front Range continues to be plagued by poor quality air during a pandemic that affects the health of everyone living here.  It is disappointing that Xcel continues to remain a roadblock to progress to address poor air quality.  Instead of intervening to delay the transition to renewable clean energy, they should focus their efforts and resources on being part of the solution.”  

“The people spoke in 2019, they want real reductions in GHGs.  It’s an imperative if we are to play our part in saving the planet.  The first step said the people and their representatives is a 26% in such pollution by 2025.   It is up to Governor Polis to translate that command into action.  So far he has been missing in action.  Even a first grader knows you can’t make 4 into 3 unless you subtract 1.  Polis must have missed the lesson on subtraction.  Mostly, he’s been running the state by press release.  That doesn’t work.  He needs to get his hands dirty and tell the polluters their days are numbered, that subtraction is part of their future.  It’s the law.”  

  “On the heels of the worst wildfire season on record Coloradans deserve climate leadership from the states largest utility, Xcel Energy.” 

  • Kelly Nordini, Executive Director, Conservation Colorado

“Generating clean and healthy power for Colorado families and communities is a key step in meeting our statewide emissions goals. As the largest provider of electricity in Colorado, Xcel Energy has a responsibility to help us lead a just and equitable transition to renewable energy sources,” said Ren Smith, organizer at the Sierra Club in Colorado. “Instead, Xcel is clinging to costly and dirty power plants, often located in vulnerable, low-income communities of color. Our utility needs to stop using ratepayer dollars to exacerbate the climate crisis with its polluting plants.”

“Xcel has shown consistent disregard for the health of the planet and people. Xcel is Dirty there is no way around that. We need the government to get this monopoly in line, closing coal by 2025 and getting from 70% dirty this past year to 75% clean by 2025, not having the Governor indebted to them for helping with his lawsuit.” 

“In facilitating meditations, I often urge people to understand our connection with the world around us, and to not avoid or run away from what is happening. I urge Xcel to do the same, listening to the clear scientific consensus that reliance on fossil fuels has led us to dramatically alter the world that supports us. But working in partnership with Colorado and local communities, Xcel can help transition to an economy that is financially, environmentally, and socially sustainable.” 

  • Kim Fessenden, Founding Partner, Sowing Seeds of Sustainability: Colorado Coalition of Interfaith Young Adults, kimdfess@gmail.com

“We need clean air, and Unite North Metro Denver neighborhoods haven’t been getting it.  Instead, we have a utility that is close to 70% dirty and wants to stay that way as long as it can, pulling as much money as it can, out of Colorado.  Now it is even trying to intervene to help the state avoid its obligations!  Instead our leaders, from Gov. Polis to his appointees, should simply follow the law.  That’s the right thing to do.”

PRPA’s energy plan will burn money as well as carbon

October 3, 2020

By Luc Nadeau and Seth Miller

Mayor Brian Bagley recently authored an op-ed explaining why he, as a board member of our municipally owned utility Platte River Power Authority (PRPA), will vote to adopt an energy portfolio plan that fails to comply with Longmont’s 2-year-old mandate to achieve 100% carbon-neutral electricity by 2030. That proposed plan only claims 90% renewable energy by 2030, and adds a new reciprocating internal combustion engine (RICE) natural gas plant to provide the rest.

To be built in 2030 at a cost of over $160 million, this RICE plant would represent a staggering misfire of an investment: bad for the planet, and bad for our pocketbooks. Bagley is supporting the power plant equivalent of a film camera in a world about to turn digital, and if we are not careful we will be making payments on its unused concrete and steel for decades to come.

Mayor Bagley begins his op-ed by stating the minimum requirements we all share for PRPA: reliable electricity at reasonable rates. The proposed RICE plant is a “peaker,” which only fires up when demand for energy exceeds the current supply. These plants operate less than 10% of the time but are 100% critical: Without peakers, our power would be as volatile as the Colorado weather.

One “green” alternative to a natural gas peaker is battery storage, rechargeable systems that store surplus energy for use when needed. Today, the price of power gas peakers is roughly equal to batteries when built to bridge short dark spells like nightfall. But when power must cover a sunless, snowy winter morning, batteries must be made bigger to cover the longer time before recharge, at a much higher cost. Mayor Bagley claims these costs are too great — that we should curtail our renewables ambitions and tie our future to gas instead.

And he might be right. If the world stayed exactly as it is.

But take a step outside, and the planet doesn’t seem so stable. As we write, the mountains are burning, ash fills the air, and public demand for climate action is growing. In fact, last year our own Colorado Legislature passed bills to require zero-emission electricity statewide by 2040.

Read that sentence again: The RICE plant Mayor Bagley wants to commission in 2030 will have to be scrapped after just 10 years of use. And there is a high likelihood that future laws will clamp down even tighter on carbon emissions. Mayor Bagley is encouraging Longmont to make a decades-long bet on fossil fuels, and we stand to lose tens of millions of dollars if he is wrong.

Meanwhile, batteries are getting cheaper. PRPA’s internal forecasts — the ones that informed Mayor Bagley’s choice of gas — predict that batteries will drop in price by 27% over the next 10 years. The reality is that battery prices have dropped over 20% … since last summer. A recently published study by the Sierra Club confirms that we can economically achieve 98-99% renewable energy by 2030 thanks to new developments in batteries and other energy technologies including grid integration, distributed energy resources, and demand management. The last 1-2% of our energy may indeed come from gas (with fracking later replaced by renewable gas from sources such as landfills), but such smaller plants will not require the kind of $160 million bet on the future of fracking that Mayor Bagley envisions.

The mayor has tried to defend the RICE plant as a “parachute” to be used in case of emergency, but the truth belies that: PRPA literally has no other plan on the table today. If this plant is indeed a parachute, let’s add a clause to the board’s measure that states this explicitly: “PRPA is only recommending a RICE plant as a placeholder for future zero-carbon technologies. It will not be deployed without an exhaustive search for carbon-neutral alternatives.”

Every day the path to renewables becomes more economically compelling, not less. We encourage Mayor Bagley to listen to the voters and ratepayers and to renewable energy experts, and lead us to a future that is both cheaper and greener. Not despite our shunning of fossil fuels, but because of it.

Dr. Seth Miller is an emerging technology consultant with a focus on energy storage, as well as low-emission substitutes across a range of industries. He has a PhD in chemistry from Caltech, and has been a Longmont resident for 8 years. Luc Nadeau sits on the Board for Sustainable Resilient Longmont and serves as chair of the SRL Renewable Energy Committee. He has an MS in fire ecology from Colorado State University and has been involved in a number of green business startups. Luc has been a Longmont resident for over 20 years.

PRPA’s billion-dollar battery strawman

October 6, 2020

By Marcia Martin

Last Thursday, Platte River Power Authority (PRPA) betrayed the people of Longmont.

Longmont, Fort Collins, Loveland and Estes Park founded and own PRPA. It generates and delivers electric power to the four cities. In 2018, each city, starting with Longmont, mandated 100% carbon-free electricity by 2030. It’s PRPA’s job to make that happen.

PRPA betrayed us by deceiving the public about our mandate. They must periodically create Integrated Resource Plans (IRPs) describing how they will meet our power needs. IRPs are 20-year plans, but revised roughly every five years. PRPA is about to adopt a new IRP which falls short of the 2030 mandate.

The plan squanders our money by investing in new fossil-fueled generators (called RICE plants) so late in the IRP cycle that they will violate state law if operated to the end of their useful life. Though PRPA should not even be considering such a foolish plan, they are aggressively promoting it. Board member Mayor Brian Bagley fired an early volley in this disinformation campaign in his Times-Call op-ed of Friday, Sept. 25.

I believe Mayor Bagley’s defense of PRPA’s proposal is sincere. PRPA’s leadership is at fault. They are not dealing honestly with the Board of Directors or the public. We deserve better.

PRPA set up a choice between two options. The first claims to achieve a 90% reduction in carbon emissions by 2030. (Quantitative analysts in the community disagree.) It grows renewables, but also adds 100 megawatts of capacity from gas-fired RICE plants in 2030, and more in 2038(!). This is nothing like a zero-carbon plan.

PRPA wants RICE because you can engage a RICE turbine very fast at need. That’s called “dispatchable” capacity. It fills gaps in renewable production, keeping power supply aligned with demand. But because RICE burns gas from fracking, its environmental penalty is nearly as bad as coal. Colorado now requires utilities to end coal burning by 2030 and all fossil fuels by 2040.

Here’s the deception: PRPA positioned a second portfolio that does meet the 2030 mandate as the sole alternative to the RICE plants. But that portfolio was designed to fail.

The zero-carbon portfolio changes little until 2030, then spends a billion dollars on utility scale batteries to replace PRPA’s fossil fuel plants. PRPA inflated the cost of that by assuming battery prices would only drop 27% by 2030. (Battery prices dropped 20% last year alone.) Consumer rates, they threatened, would need to begin going up next year to cover the cost of the future batteries.

No power engineer would construct a zero-carbon energy portfolio this way. It was designed from the start to “prove” the 2030 goal impossible and make those RICE plants look good. It’s a billion-dollar battery strawman.

Local activists called out this deception in February. But last Thursday, when PRPA and the board met to finalize the IRP, PRPA returned to their false dichotomy, wasting the session ridiculing the zero-carbon model and evangelizing for the RICE plants. They didn’t discuss carbon-neutral dispatchable alternatives to RICE — even though they exist. PRPA told the board to “sell” the public on the 90% portfolio. They handed out draft letters to the editor for board members to sign and submit to local papers.

This is wrong. PRPA should take direction from its board, not vice versa.

Today, PRPA understands coal plants. Its antiquated modeling methods and hidebound thinking can’t handle the carbon-neutral technologies that will replace “natural” gas. They are distributed energy resources, chemical storage, and real-time load balancing through automation. The zero-carbon solution won’t be a crude, monolithic one like a billion dollars worth of batteries. It will be a combination of complementary means. PRPA must hire more creative experts and invest in better tools. When they’re an organization that’s prepared for the future, they won’t have to be afraid of the truth.

We are PRPA’s boss. Let’s insist that they improve their capability, engage honestly with us, and do their job.

Marcia Martin is a Member of the Longmont City Council. This op-ed represents her opinion, not an official policy of the City of Longmont. Martin is a software engineer and spent the last 7 years of her private sector career creating enabling technology for the all-renewable electrical grid.

PRPA Should not Build a Gas-fired Power Plant

Published in the Fort Collins Coloradoan on September 19, 2020

The recent collapse of our economy and routine activities is the result of a microscopic coronavirus that causes COVID-19. Without warning the entire human population became vulnerable, some more than others, but there was no populated place on earth that was spared.

This pandemic will pass (like the previous pandemics) and we will slowly get back to “normal.” Unfortunately, there is another threat to humans that is clandestine and potentially more lethal. This threat is the continued heating of our planet due to increasing greenhouse gas production from human activities.

Like COVID-19, there are believers and skeptics regarding climate change. Some non-believers in COVID-19, like Herman Cain, lost their lives because of risky behaviors. Many individuals who have been infected with COVID-19 will not experience serious consequences and recover completely. They are the lucky ones.

With climate change there will be some less affected but, eventually, all will suffer from the heating of the planet. If we fail to stop risky activities contributing to climate change, there will be serious consequences for our younger and future generations – unlike COVID-19, where older populations are more affected. It is sad when elderly die but tragic when young people suffer and die.

According to the Environmental Protection Agency, the burning of coal, fracked gas, and oil for electricity and heat is the largest single source of global greenhouse gas emissions. Additionally, gas-fired power plants – like the one Platte River Power Authority, PRPA, is proposing to build – not only contribute large amounts of greenhouse gases worldwide, they also emit pollutants that harm human health.

Burning gas in power plants emits pollutants like sulfur dioxide, particulate matter, and nitrogen oxides into the air. Emissions from coal- or gas-fired power plants cause increased asthma attacks, worsen emphysema and other lung diseases, increases heart attacks, and increase heart and neurologic impairments in developing fetuses and children.

To those of us in the medical field, the decision to close PRPA’s coal-fired Rawhide power plant by 2030 is a good one – better if closed earlier. But we cannot replace one dirty coal power plant with another dirty gas power plant. When combined with the greenhouse gas emissions accelerating climate warming the prudent action is to stop burning all fossil fuels like coal and gas – now.

As mentioned before, burning of any fossil fuel will worsen climate change and the health of people. Just like “clean coal” is an oxymoron, so is “natural gas.” “Natural gas” is methane, a non-renewable fossil fuel and a very potent greenhouse gas. Methane is released via venting at fracking sites and leakage during transportation. When burned, carbon dioxide, another greenhouse gas, is released and damages our planet and future.

If we can shut down the world economy for a microscopic virus, we can quickly change our energy culture to stop burning fossil fuels. Therefore, we cannot allow Northern Colorado’s utility provider, PRPA, to build a new gas plant.

Dr. Cory D. Carroll chair of Physicians for Social Responsibility of Colorado. He lives in Fort Collins.

Jared Polis Moves to Dismiss Himself from Climate Accountability

WildEarth Guardians news release for September 10th, 2020

Denver–Today, Colorado Governor Jared Polis moved a court to rule that he has no duty to protect the climate, arguing he is not legally required to achieve legislated greenhouse gas reduction goals in the state.

“With this court filing, Governor Jared Polis has sadly made clear that he has no intention of doing anything meaningful to confront the climate crisis,” said Jeremy Nichols, Climate and Energy Program Director for WildEarth Guardians.  “This is a huge letdown for the kids, families, communities, and constituents who hoped that Jared Polis would put their health and welfare first and actually take genuine action to confront the climate crisis.”

In a motion to dismiss himself from a WildEarth Guardians’ lawsuit over the failure of his administration to meet legally required emission reduction deadlines, the Governor argued he has no responsibility to reduce greenhouse gases or meet any climate goals in Colorado.

At issue is the failure of the Polis administration to meet a legal deadline to propose new regulations to achieve a 26% reduction in statewide emissions by 2025, a 50% reduction by 2030, and a 90% reduction by 2050. The failure to ensure greenhouse gas reductions isn’t just jeopardizing the state’s climate progress, it’s putting disproportionately impacted communities at risk.

Under Colorado Senate Bill 19-096, the administration was required to propose regulations to reduce emissions by July 1, 2020. After July 1, 2020 passed with no proposed regulations, WildEarth Guardians filed suit to compel action.

In response to WildEarth Guardians’ lawsuit, Jared Polis argued that the Colorado Air Quality Control Commission, not the Governor, is responsible for reducing greenhouse gases. However, the Air Quality Control Commission is appointed by and serves at the pleasure of the Governor.

“Governor Polis is essentially blaming the housekeeper for the fact that his own house is dirty,” said Nichols.  “Unfortunately, rather than lead, he’s dodging and asserting that others are responsible for Colorado’s lack of climate progress and climate justice.”

“With the climate crisis fueling drought, wildfires, and extreme temperatures in Colorado, it’s disappointing that Governor Polis feels that confronting the climate crisis is not his job,” added Nichols.

We won’t back down on fracking

Published in Colorado Politics on July 30, 2020

Regarding Gov. Polis’ recent announcement that he has worked with both the oil and gas industry and environmental groups to withdraw ballot measures in 2020 and prevent future ballot measures through 2022: The 32 environmental groups that make up the Colorado Coalition for a Livable Climate (CCLC) wish to clarify that not one of our groups was included in those “conversations” (“Give pivotal new oil and gas law a chance,” July 24). The governor also failed to contact Safe & Healthy Colorado and Colorado Rising, the only two environmental groups directly involved in pursuing ballot measures this year.

Our member groups also strongly disagree with the governor’s opinions about the low value of ballot measures and the effectiveness of the implementation of SB-181. The Colorado Oil & Gas Conservation Commission’s disastrous handling of SB-181 during its weak rule making attempts has only been effective in allowing the oil and gas industry to continue their status-quo, harmful drilling activities nearly unabated. For example, the current proposed setback rulemaking by COGCC is lacking in scientific basis and is offensive to frontline communities that have been voicing their suffering for years. What has been proposed is not an improvement from the current inadequate and harmful setback distance.

It has been 15 months since SB-181 was signed into law, yet fracking still continues in force near the front steps of our homes, schools and throughout our communities. Permits for increased drilling in vulnerable areas continue to pass through the COGCC with ease. The harmful emissions from fracking continue to degrade the health of tens of thousands of Coloradans.

How long does the governor expect Coloradans to wait? He leaves us no choice but to continue to put ballot measures in place to address this violation. Without immediate, meaningful change in regulations that are in compliance with the law, expect to see our member organizations strongly supporting ballot measures in 2022 in order to enact protections for public health and safety that the governor and the COGCC have failed to provide.

Leslie Weise

Polis Must Get Colorado on Track to Meet Climate Goals

Published in the Denver Post on July 6th, 2020

While Colorado is leading the way on climate action, its accountability to climate justice remains elusive as the state is still way off track to meet legally required greenhouse gas reduction targets.

This lack of climate progress is putting Colorado’s most disproportionately impacted populations—Black and Latino communities, low-income neighborhoods, and indigenous peoples—at tremendous risk. This has to change.

In 2019, Gov. Jared Polis signed into law House Bill 1261, which committed to reducing statewide greenhouse gases 26% by 2025, 50% by 2030, and 90% by 2050. This landmark legislation also called for regulators to prioritize achieving these reductions in communities experiencing disproportionate environmental harms and risks from sources of climate pollution.

In other words, Polis’ commitment to climate action wasn’t just to curtail pollution, but to do so where the pollution disproportionately threatens the health and welfare of people of color, low-income neighborhoods, and tribal communities. Recognizing the vital importance of achieving climate justice, in 2019 Colorado’s Legislature also passed Senate Bill 96, which required the Polis administration to propose new regulations to achieve the state’s greenhouse gas reduction targets. The law set a deadline to propose these new rules by July 1, 2020.

That deadline has now passed and Colorado is nowhere near meeting its greenhouse gas reduction goals and nowhere near achieving climate justice. Reports by both nongovernmental organizations and the state’s own consultants show that under our current trajectory, we are not even close to being on track to meet our 2025 and 2030 emission reduction targets. With no near-term success in sight, the prospect of long-term climate progress is wishful thinking.

The consequences of this missed deadline and lack of progress are all too real for people living in the shadow of the Suncor oil refinery north of Denver. This refinery has been all over the news in the past year because of ongoing air pollution violations. Even though regulators this year fined Suncor nearly $9 million, the company continues to report unlawful releases of toxic gases like hydrogen sulfide, benzene, sulfur
dioxide, and more.

All this air pollution impacts the neighboring community where more than half the residents live below the poverty level and more than 75% are people of color. It’s a poster child for environmental injustice, where a dangerous source of air pollution disproportionately affects people who are underprivileged, disenfranchised and disempowered.

And it’s a poster child for climate injustice. Suncor’s refinery happens to be one of the largest sources of greenhouse gas emissions in Colorado, every year releasing as much climate pollution as 200,000 cars.

With Gov. Polis’ commitment to climate action, one would think addressing the Suncor oil refinery’s pollution would be near the top of the list of strategies to reduce greenhouse gases. It’s not.

In fact, the state’s most recent list of potential strategies to reduce greenhouse gas emissions doesn’t even mention disproportionately impacted communities, let alone facilities like Suncor. Making matters worse, Colorado regulators aren’t scheduled to consider adopting any new rules to limit climate pollution until 2021 at the earliest.

We know Gov. Polis has good intentions, but the state’s failure to reduce greenhouse gases has very real implications for the health and well-being of the most vulnerable Coloradans.

July 1, 2020, has passed with no meaningful progress toward meeting the state’s climate goals. Legal deadlines matter. This isn’t just about urgent action to reduce greenhouse gases to protect our global climate, it’s about achieving environmental justice in this state.

Good intentions aren’t enough to confront the climate crisis. For equity and justice, Gov. Polis has to get Colorado back on track to meet its greenhouse gas reduction targets and live up to its commitment to meaningful climate action.

By Jeremy Nichols and Ean Thomas Tafoya

Open letter to AQCC on Potential Path to Meeting 2025 Climate Goal

July 1, 2020

Dear Commissioners Milford, Butler, Gerber, Gonzalez, Grobe, Jones, Rueter, Schendler, and Williams:

The Colorado Coalition for a Livable Climate has supported the adoption of strong greenhouse gas (GHG) emission reduction goals by the State since our inception in 2015.  We have followed the Air Quality Control Commission’s rulemaking efforts this year with both interest and concern.  Our concerns center around the fact that the one regulation approved to date does not go very far toward meeting the ambitious climate goals set by the General Assembly in the spring of last year.  Further, we do not see much sense of urgency on the part of either the Colorado Department of Public Health and Environment (CDPHE) or the Colorado Energy Office (CEO) in supporting the development of rules that are up to the task of meeting those goals.

Although we understand the resource constraints faced by the CDPHE, the CEO, and the AQCC itself, we do not view working seriously to meet the goals set by the General Assembly for 2025 and 2030 as “optional.”  In fact, the world as a whole will need to achieve net zero greenhouse gas emissions by the mid-2030s in order to have a better than even chance of avoiding the catastrophe that would ensue should the average global temperature increase by more than 1.5° Celsius over pre-industrial levels.

According to the latest Colorado Greenhouse Gas Inventory Report, 60% of the State’s GHG emissions in 2020 will come from three economic sectors: electric power, natural gas and oil extraction, and transportation.  The CCLC therefore respectfully recommends that the AQCC focus its efforts on those three sectors as it develops rules to meet the first goal established by the General Assembly: 26% overall GHG emission reductions by 2025 compared to 2005 levels.

We have performed an analysis that suggests that 70% GHG emission reductions in the electric power sector, 25% GHG emission reductions in the natural gas and oil sector, and 13% GHG emission reductions in the transportation sector compared to 2005 levels would be sufficient to achieve the 2025 goal.  That analysis is attached to this letter.

We propose the following three rules – in broad outline – to achieve these emission reductions:

  1. Require every utility operating in Colorado to reduce its GHG emissions by 70% compared to 2005 levels by 2025.
    1. Utilities should be required to submit their plans for doing this to the AQCC by the end of 2022, and to put their plans in place no later than January 1, 2024.
    1. The AQCC should establish a schedule of fines that would apply to utilities in case of non-compliance.
  • Establish GHG emission reduction requirements for each oil and gas operator in the State based on current production and leakage levels sufficient to reduce the sector’s GHG emissions by 25% compared to 2005 levels by 2025.
    • This rule should go into effect no later than January 1, 2024.
    • The AQCC should establish a schedule of fines and/or shut down enough oil and gas wells owned by each operator by January 1, 2025 in case of non-compliance in order to bring those operators into compliance.
  • Establish a “feebate” program for new vehicle purchases that would increase registration fees significantly for fossil fuel-powered vehicles and increase rebates significantly for electric vehicles.
    • This program should be put in place no later than January 1, 2024.
    • The fees and rebates should be set based on an economic analysis that would have 13% GHG emission reductions compared to 2005 levels for this sector as the goal.
    • This is a “market-based approach”, and as such does not require any penalties in case of non-attainment of the goal in the first year.  Instead, the new registration fee and rebate schedule should be modified in subsequent years as necessary in order to meet the goal.

We believe that the AQCC should prioritize work on the first proposed rule, since it would have the largest impact.  Work on that rule should begin this year and be completed as early as possible next year.  Development of the second and third proposed rules should begin next year, and be completed either later that year or in early 2022.

We are not certain that the recommended new vehicle feebate program could be established by rule.  If it cannot be, the AQCC should consider increasing the emission reduction targets for the electric power and natural gas and oil extraction sectors, and recommend that the General Assembly pass a law putting the feebate program into place.

We believe that adoption of these proposed rules would allow the State to meet its 2025 climate goal with minimal economic impact.  Please do not hesitate to contact us should you have any questions concerning our analysis or recommendations.  We would welcome the opportunity to speak with each of you.

Sincerely,

COLORADO COALITION FOR A LIVABLE CLIMATE

PRPA Intention to Submit a Clean Power Plan

Here is an audio copy of the PRPA Board of Directors meeting that took place on May 28th, 2020. At minute 12:45, staff and the board begin discussing why they believe it is important to submit a “Clean Power Plan” to the State – even though doing so is not a legal requirement. The discussion provides insight into why PRPA announced its intention to close the Rawhide coal-fired power plant sixteen years ahead of schedule on June 16th of this year. The audio reveals the different values and perspectives of each of the board members and their staff.

https://drive.google.com/file/d/12sbps93YjQWa2RWYpJ540HMgdnzQaAEr/view

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