Colorado Coalition for a Livable Climate

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

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.

Call on PERA to Protect Coloradans by Curbing Fossil Fuel Investments

This past week 350 Colorado and the Fossil Free PERA campaign teamed up with allies in Canada to call out harmful fossil fuel investments made by both Colorado and Canadian pension funds that are directly and adversely impacting Colorado communities.

Colorado’s pension fund Public Employees Retirement Association (PERA), which manages the pensions of half a million current and former state employees, is investing Coloradans’ public money in problematic fossil fuel companies such as Suncor and Extraction Oil and Gas, both under scrutiny for harming local communities through dangerous pollution violations, particularly near lower income communities and communities of color.

To highlight the negative impacts of these investments, 350 CO and Fossil Free PERA launched a video from impacted Coloradans to PERA members, which was highlighted in last week’s Boulder Weekly article. You can watch the video and share here: https://www.youtube.com/watch?v=QUQTXo4kNa4&feature=youtu.be&emci=68fe6308-e9fc-ea11-96f5-00155d03affc&emdi=ba9e7430-ebfc-ea11-96f5-00155d03affc&ceid=3949405

Here’s how you can take action now:

· Call on PERA to invest public funds in ways that are not only financially viable long-term, but also support the public good. Send a letter to PERA here, calling on PERA to protect Coloradans’ health and safety by curbing fossil fuel investments. Send your letter now and share with your networks: https://secure.ngpvan.com/s9DNFRTMxEuSi6789-MFRw2?emci=68fe6308-e9fc-ea11-96f5-00155d03affc&emdi=ba9e7430-ebfc-ea11-96f5-00155d03affc&ceid=3949405

· Learn more about the issue and share: Check out the Fossil Free PERA website at http://www.FossilFreeCOPERA.org

Please join in calling on PERA Board, leadership and staff to curb fossil fuel investments that are harming public health and fueling the climate crisis, to tackle climate-related financial risk and begin the process of divesting from fossil fuels, and to proactively plan for the energy transition to renewable energy. Our public money should not be invested in companies which are adversely impacting our public health and safety.

With gratitude,

Deborah and the 350 Colorado Team

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 <DNR_COGCC.Rulemaking@state.co.us>

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 https://www.safeandhealthyco.org/email-signup  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.

Sincerely,

COLORADO COALITION FOR A LIVABLE CLIMATE

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