Colorado Coalition for a Livable Climate

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

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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.

COGCC Mission Change Rulemaking needs your input!

Colorado needs your help. So does the planet.

Right now, the Colorado Oil & Gas Conservation Commission (COGCC) is revising its operating rules to reflect a major change in its mission mandated by law: from ‘fostering’ O&G development to ‘regulating’ O&G in a manner that prioritizes the protection of public health, safety, welfare, the environment and wildlife, and minimizing adverse impacts on air, water, soil, and biological resources from O&G development.

This COGCC Mission Change rulemaking will have major consequences for future impacts from O&G development, including climate impacts. The rulemaking offers an important avenue for reducing climate damage by O&G development. Your voice is needed to make it happen.

COGCC has drafted proposed rules and is now receiving comments on the draft rules. COGCC will hold a hearing on August 24.

The draft rules will not adequately reduce climate impact and damage by O&G development. Shortcomings in the draft rules include:

While the new rules require estimation of GHG emissions for new O&G developments, there are no standards, limits, mandated reductions, or consequences for GHG emissions. There are no consequences for getting the estimated emissions wrong—intentionally or not. There is nothing in the draft rules that say if you emit 2 tons per year or 500 tons per year of GHGs, then the permit should be denied.

There are no consequences for cumulative climate impacts from new O&G developments, or cumulative negative impacts to air quality and to public health, and no recognition of the severity of these issues in the Front Range and over the Four Corners. The draft rules do not recognize that cumulative effects of O&G development in or near populated areas is correlated to negative health impacts (nosebleeds, asthma attacks, headaches, sore throats, or other health impacts) and to ozone alert days. The draft rules do not provide that such cumulative impacts should trigger limits or stop new permits for O&G development.

The draft rules ignore that methane traps 86x more heat than CO2, with significant near-term climate impact, and that methane lingers in the atmosphere for about 20 years. The draft rules ignore that methane emissions continue to significantly accelerate climate change, pushing the climate crisis toward a tipping point, after which it becomes nearly impossible to stop the runaway warming.

The draft rules are negligent in failing to protect our climate, public health and air quality, and in failing to uphold the climate goals established by legislation and by the Polis administration.

The draft rules need to be revised to provide much more protection for climate, public health and air quality.

Your voices are needed to persuade COGCC to adopt rules that provide far more climate protection than the current draft rules.

There are two ways for for submitting comments in the rulemaking, regarding how you want to see COGCC handle future O&G permits and operations.

1) Submit a written statement (called a 510 Statement). It can be as little as a page, or as long as you need to make your point(s).

510 Statements are due by Friday August 14 at 5pm.

Send to <>

Subject: Mission Change Rulemaking 510 Statement

The Commission prefers a PDF of your statement, but you can send in a Word doc or just write your statement in the body of the email.
Put the date of the submission just above your signature.
End with: Sincerely, /S/ your name (/S/ is the symbol for an electronic signature)
Provide your complete address, email and phone number under your signature.
Do not indicate you’re a member of any specific group.
Most of the climate/envionmental advocacy groups in Colorado are formal Parties to this rulemaking, and therefore are not allowed to submit 510 Statements because we already submitted a prehearing statement.

2) Provide comment by testifying at the rulemaking hearing (via Zoom) on Monday, August 24th, beginning at 4pm. Testimony will be limited to 2 minutes and those who sign up in advance will be given priority. Prior to August 24, the Commission will allow persons to sign up to make oral statements, but that form hasn’t been posted yet. Those who sign up in advance will be given priority.

Talking points are provided HERE (from 350 Colorado and Climate Reality Project).

If you want to take a look, the proposed rules can be viewed HERE. The rules are daunting to get a handle on – and 510 statements and oral testimony can make general points, not necessarily referencing specific rules.

Thank you for advocating to COGCC to reduce climate damage from oil & gas development – which will make a difference in the fight to save our planet.

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

Update on ballot initiative 174: 2,500′ fracking safety zones

 On July 1, 2020, the Colorado Supreme court invalidated Governor Polis’ emergency rules for collecting petition signatures online and by mail.  The initiative sponsor, Safe and Healthy Colorado, therefore decided to suspend its effort to get this initiative on the ballot this year.

However, Safe and Healthy Colorado intends to bring this initiative back, and is asking people to “Pledge to Sign” a future petition for 2,500 foot fracking safety zones. 

ACTION: Please visit  and “Pledge to Sign.”

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.



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.

NCP4CE White Paper on PRPA Integrated Resource Plan

Northern Colorado Partners for Clean Energy Calls on PRPA to Implement 100% Renewable Energy in the Integrated Resource Plan

June 9, 2020


Platte River Power Authority (PRPA) is a municipal utility providing power to four cities along the Front Range: Fort Collins, Longmont, Loveland, and Estes Park. Beginning in 2018 with a City Council Resolution in Longmont, all four cities passed commitments to transitioning their communities to 100% renewable energy by 2030. Following these commitments, PRPA developed a Resource Diversification Policy that stated the following: “The board of directors (the board) directs the general manager/CEO to proactively work toward the goal of reaching a 100 percent non-carbon resource mix by 2030, while maintaining Platte River’s three pillars of providing reliable, environmentally responsible and financially sustainable electricity and services.”[i] For the last few months, PRPA has been working on an Integrated Resource Plan that represents a 20-year plan for the utility. At the February 27, 2020 PRPA board meeting, the initial draft of the IRP was presented.[ii]

This document provides an overview of the current draft IRP and calls on elected officials within the PRPA service area to demand that PRPA transition to 100% renewable energy as soon as possible, to avert a climate crisis.


Northern Colorado Partners for Clean Energy (NCP4CE) urges PRPA to take a closer look at Portfolio Option 3 (“Zero Carbon”), presented to the Board in February, by performing two sensitivity analyses, and then adopt that portfolio. We also urge PRPA to begin work on establishing an interim goal that achieves a high level of non-carbon electricity as soon as possible. Portfolio Option 3 is the only one that attains the 100% non-carbon goal adopted by the Board in December 2018 via its Resource Diversification Policy. Portfolio Option #1 represents business as usual. Portfolio Option #2 achieves only 90% non-carbon electricity by 2030 and includes construction of a new gas-fired plant in 2030. The fourth option doesn’t achieve even the low bar of 90% non-carbon electricity until 2036, with construction of a new gas-fired plant slated for that year.


Digging a little deeper into Portfolio Option 3 – the Zero Carbon option – we note that PRPA staff made a number of overly conservative assumptions that result in higher presumed rate increases compared to the other portfolios. For example, the future prices of wind and solar used in Portfolio Option #3 are 40% to 70% higher than the values predicted by an analysis by the National Renewable Energy Laboratory (NREL) in a study published in November 2018.[iii] Additionally, PRPA staff assumed that its four owner communities would do nothing over the next ten years to manage their electric loads – they excluded any mention of Demand Side Management (DSM) options. However, Fort Collins has already made progress in reducing its peak electric loads through its recently implemented “Time of Day” rates.[iv] The variety of DSM programs and their ability to reduce the peak load of the four owner communities of PRPA will likely increase significantly in the next few years as electric vehicles replace gasoline-powered vehicles, homes and businesses convert to heat pumps for heating and cooling, and grid-interactive power control devices become more readily available for residential and small business consumers.

Carbon and Methane Pollution

Portfolios 1, 2, and 4 ignore climate change and the need to rapidly move away from all carbon-based fuels. Total carbon dioxide pollution from the Rawhide power plant results in 2 million tons of CO2 being released into the atmosphere per year. An additional 1 million tons, approximately, comes from the Craig power plant per year.[v] The costs shown in the draft IRP fail to account for the social cost of carbon, which the PUC and the state legislature have recommended for utility long-range planning.[vi] It does not take into account that the EPA has deemed the Northern Front Range an ozone non-compliance area[vii], that nitrous oxides are one of the main precursors for the formation of ground-source ozone, and that PRPA’s Rawhide coal-fired power plant is the largest single point emitter of nitrous oxides in Larimer County.[viii] Our region has an F rating from the American Lung Association, and Fort Collins is listed as being one of the more polluted cities for air quality in the U.S.[ix]

In addition, natural gas alternatives such as the gas-fired Reciprocal Internal Combustion Engine (RICE) plant proposed in Portfolio 2 contribute to methane pollution. Methane is a harmful greenhouse gas. The global warming impact of burning natural gas at a power plant is less than that of burning coal, but the overall impact is greater once the emissions derived from extraction through unconventional means – such as fracking – are factored in. Given that PRPA has a significant amount of gas-fired generating capacity already in its portfolio, we do not support more investments in new gas plants or new natural gas infrastructure. PRPA’s existing gas generators may have a useful role to play in the near term, but our communities shouldn’t be building new natural gas infrastructure now that has a useful life span of 30-40 years.

Additional Concerns

With a move to 100% renewable energy, reliability can be improved by joining power pools. Earlier this year PRPA announced their decision to join the Western Energy Imbalance Market (WEIM).[x] Yet the current draft IRP does not account for the advantages gained from joining an energy imbalance market. While we are concerned that the price of energy from renewables is inaccurately overpriced in the IRP, we are also concerned that the price of energy from coal and natural gas is, likewise, underestimated. PRPA acknowledged in the IRP that they intend to account for the social cost of carbon, but an estimated cost of environmental damage for each portfolio has not been presented to the PRPA Board. Potential severance taxes and compliance costs for fossil fuel extraction should also be addressed. As pressure is mounting for investors to divest from fossil fuels, increased financing costs should be factored into future cost estimates. 


Based on this analysis, NCP4CE believes there are several critical components missing from what has been provided through the IRP engagement process that the public and our PRPA Board representatives need in order to make a sound decision regarding future investment decisions.

NCP4CE therefore respectfully requests that PRPA provide the following:

  • Siemens Report: The Siemens report that provided the modeling inputs for the future pricing of renewables should be made public immediately. These assumptions are critically important for understanding the economic impact of each of the four portfolios. PRPA’s modeling assumptions should be as transparent as possible. We request, therefore, that the Siemens report be made public.
  • Sensitivity Analyses: The economic impact of each of the four proposed scenarios is largely based upon future energy price assumptions for fossil fuels and renewables. We request that PRPA make those future energy price assumptions explicit for each of the four portfolios, and that PRPA frame the projected economic impact of each portfolio using a price sensitivity analysis. For Portfolio #3, we ask that a sensitivity analysis be conducted based on the percentage of renewables – in other words, what is the economic impact of reaching 95% renewable electricity at the earliest possible date? What is the economic impact of reaching 92.5% renewable electricity?..  90%?… etc..
  • Social Cost of Carbon: We request that PRPA release a report that estimates the cost of the environmental damage of each portfolio’s cumulative greenhouse gas emissions using the U.S. federal social cost of carbon.
  • DER Integration Plan: PRPA staff have stated in their reports to the Board that DERs will be a critically important facet in helping PRPA reach its 2030 Resource Diversification goal. NCP4CE understands a committee has been formed to develop a strategy for the incorporation of DERs. While this work is ongoing, NCP4CE requests that PRPA staff include a general description of how it plans to use DERs in each of the four portfolios they propose. 
  • 2023 Interim Goal: NCP4CE reiterates its request that PRPA devise an interim goal to reach 70% renewable electricity, system-wide (not “delivered electricity”) by 2023. Our modeling shows that this is feasible and will result in reduced costs for PRPA ratepayers. Our specific request is not for the Board to adopt this goal directly, but to ask the PRPA modeling team to conduct an analysis using NCP4CE’s modeling assumptions and produce a report for the Board that details the modeling assumptions, investment requirements, cost implications, and rate impacts of achieving such a goal.




[iv] Fort Collins City Council Meeting Presentation February 11, 2020

[v] The EPA’s Emissions and Generation Resources Integrated Database (eGRID) lists the 2018 emission factor for the Rawhide power plant as 2,085 pounds of CO2e per MWh of generation. The 2018 emission factor in eGRID for the Craig power plant is 2,292 lb CO2e/MWh. The 2018 emission factor for electricity from RMPA in the WECC – our section of the grid –  is listed by the EPA’s eGRID as 1,282 lb/CO2e/MWh. Electricity is purchased by PRPA under a joint dispatch agreement to compensate for planned and unplanned outages at Rawhide and Craig. PRPA’s 2019 Annual Budget Report shows that Rawhide is budgeted to produce 2,303 GWh in 2019, Craig is budgeted to produce 742 GWh, and purchased electricity is budgeted to be 193 GWh. From this data, we deduce that PRPA’s CO2e emissions from its two coal plants and from purchased electricity will be 3.374 million tons in 2019. PRPA has emitted over 3 million tons of CO2e from those three sources each year, 2017-2019.

[vi] The EPA’s Emissions and Generation Resources Integrated Database (eGRID) lists the 2018 emission factor for the Rawhide power plant as 2,085 pounds of CO2e per MWh of generation. The 2018 emission factor in eGRID for the Craig power plant is 2,292 lb CO2e/MWh. The 2018 emission factor for electricity from RMPA in the WECC – our section of the grid –  is listed by the EPA’s eGRID as 1,282 lb/CO2e/MWh. Electricity is purchased by PRPA under a joint dispatch agreement to compensate for planned and unplanned outages at Rawhide and Craig. PRPA’s 2019 Annual Budget Report shows that Rawhide is budgeted to produce 2,303 GWh in 2019, Craig is budgeted to produce 742 GWh, and purchased electricity is budgeted to be 193 GWh. From this data, we deduce that PRPA’s CO2e emissions from its two coal plants and from purchased electricity will be 3.374 million tons in 2019. PRPA has emitted over 3 million tons of CO2e from those three sources each year, 2017-2019.


[viii] The EPA requires large emitters of greenhouse gases to report annual emissions to the Greenhouse Gas Reporting Program (GHGRP). Large emitters are defined as any entity emitting over 25,000 tons of CO2e per year. Based on GHGRP data, as was reported in 2016, PRPA’s Rawhide power station is by far the largest emitter of greenhouse gases in Larimer County. According to the EPA’s eGRID, Rawhide power station emitted 1,114 tons of NOx emissions in 2018. NOx emissions are a necessary precursor for the formation of ground-source ozone. The federal Bureau of Transportation Statistics states that the average NOx emissions for cars on the road in 2019 was 0.289 grams/mile. Assuming the average car is driven 12,500 miles a year, the NOx emissions at Rawhide is equivalent to 279,752 additional cars on the road.




Northern Colorado Partners for Clean Energy (NCP4CE) is a coalition of organizations in the four municipalities that own the Platte River Power Authority (PRPA). We have a shared goal of transitioning PRPA to 100% renewable electricity by 2030. NCP4CE is a committee of the Colorado Coalition for a Livable Climate, but retains autonomy with regard to its work with the PRPA and all local initiatives. The member organizations of the NCP4CE are: 350 Northern Colorado, Colorado Renewable Energy Society, Colorado Sierra Club, Community for Sustainable Energy,, Environment Colorado, Estes Valley Clean Energy Coalition, Fort Collins Sustainability Group, Renewables Now Loveland, Sustainable Resilient Longmont, Transition Fort Collins. For more information please visit

NCP4CE Calls on PRPA to Implement 100% Renewable Energy in the Integrated Resource Plan


June 9, 2020- Today, Northern Colorado Partners for Clean Energy released the attached white paper calling on the Platte River Power Authority (PRPA) to Implement 100% renewable energy in the Integrated Resource Plan (IRP). This document outlines compelling data points and central arguments for strengthening PRPA’s commitment to renewable energy in the IRP.

“2030 is a long ways away. That’s still a decade longer of fossil fuel pollution in our communities. PRPA should be doing everything it can to transition off of coal and gas in a way that either meets or exceeds city commitments to 100% clean energy by 2030.”  said Sarah Snead, Organizing Representative, Sierra Club Beyond Coal.

“We cannot wait another five years for PRPA to aggressively pursue a transition away from fossil fuels. The time is now to get serious about how local communities can move towards a future where households, cities and towns are powered by clean energy. It’s what is best for our economy, our environment, and the health and prosperity of future generations. The point is that PRPA can do better when it comes to strategic planning with the planet in mind,” said Abby Driscoll of Sustainable Resilient Longmont.

“In late 2018, the PRPA board set a goal of 100% renewable electricity by 2030. In early 2020, PRPA staff seems to have concluded that achieving 100% renewable electricity cannot be done reliably or cost effectively, using a combination of incomplete and faulty assumptions in its IRP analysis. Given that we’re facing a climate emergency, this is unacceptable. PRPA staff needs to try harder to achieve the goal set by its board and owner communities,” said Kevin Cross with the Fort Collins Sustainability Group.


Northern Colorado Partners for Clean Energy (NCP4CE) is a coalition of organizations in the four municipalities that own the Platte River Power Authority (PRPA).  We have a shared goal of transitioning PRPA to 100% renewable electricity by 2030. NCP4CE is a committee of the Colorado Coalition for a Livable Climate, but retains autonomy with regard to its work with the PRPA and all local initiatives. The member organizations of the NCP4CE are: 350 Northern Colorado, Colorado Renewable Energy Society, Colorado Sierra Club, Community for Sustainable Energy,, Environment Colorado, Estes Valley Clean Energy Coalition, Fort Collins Sustainability Group, Renewables Now Loveland, Sustainable Resilient Longmont, Transition Fort Collins. For more information please visit

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