Posted on May 5th, 2023


As Colorado seeks to address the climate challenges of our time, we appreciate efforts to adopt solutions that positively impact our state. However, we have serious concerns surrounding several of the “emerging” technologies being promoted; in particular, carbon capture and sequestration, direct air capture, hydrogen, and nuclear. We are troubled by the lack of risk-analysis, cost-analysis, and impact-analysis being done in these sectors. We are also concerned that the pursuit and/or adoption of these technologies may further delay action to reduce emissions by redirecting resources and investment away from viable solutions that already exist, such as wind, solar, conservation, and stable energy-storage. We ask for a more rigorous evaluation of emerging technologies than has been presented so far, and for careful re-consideration before pursuing them further.

Carbon Management 

We are concerned that “novel” carbon management methods such as Direct Air Capture and Carbon Capture are unlikely to achieve meaningful CO2 reduction at the levels needed to meet our future climate goals. Currently these strategies are prohibitively expensive and unproven on a widely deployed scale. Even if backed by substantial funding, effective implementation would require decades of research and development – a luxury we do not have. Furthermore, we are concerned that novel carbon management strategies could extend the life cycle of the fossil fuel industry by continuing dependence on oil and gas rather than phasing them out. We ask for climate mitigation efforts focused on stopping the production and consumption of fossil fuels, while also promoting growth in “conventional” carbon dioxide removal methods such as reforestation, ecosystem restoration and agroforestry.


Our findings indicate Colorado should only put resources toward green hydrogen, which is produced by splitting the water molecule and uses 100% renewable energy. Blue hydrogen is produced from methane and creates more GHG emissions per unit of energy than burning coal, diesel, or fossil gas. The federal definition of “clean” hydrogen includes blue hydrogen, as does Colorado’s hydrogen roadmap, hydrogen hub and HB23-1281. Hydrogen produced from methane pollutes communities, perpetuates fossil fuel extraction, and increases GHG emissions. Even green hydrogen should be used sparingly. It is inefficient, costly and unsafe in sectors such as vehicles, building heating, and power generation. Hydrogen is only economical in difficult to decarbonize sectors such as maritime shipping, aviation and industrial processes. In developing technological solutions, Colorado should pursue green hydrogen as defined by the International Energy Agency, and should not continue to include blue hydrogen in its energy roadmap or future legislation.


While proponents of nuclear energy claim that it is a clean and carbon-free energy source, research indicates otherwise. The development of nuclear reactors and the mining of raw materials like uranium are highly carbon intensive. The generation of nuclear power creates dangerous waste that remains radioactive for thousands of years, and no sustainable solutions exist for long term storage. Nuclear power plants also pose grave risks to surrounding communities because damage from natural or human related accidents would be catastrophic. Nuclear power is the most water-intensive form of power generation. A single 300 megawatt plant requires hundreds of millions of gallons of water per day. Nuclear power is not competitive in cost or time of deployment, and “advanced nuclear plants,” including Small Modular Reactors, are so far an unproven technology. Marginalized communities surrounding nuclear power plants have been linked to higher rates of cancer, and historically bear a disproportionate burden of the environmental and health impacts of uranium mining.  

Carbon Management

Overview: Carbon Management refers to a suite of emerging technologies that aim to reduce carbon emissions by developing financially and environmentally sustainable mitigation strategies. While there is a place for carbon management in the IPCC Assessment’s plan for addressing climate change, it is important to highlight that these technologies provide widely variable advantages and disadvantages. We give an overview of some of the most frequently discussed carbon management technologies here, while also highlighting some of our concerns.

Carbon Dioxide Removal

The 2023 IPCC AR6 Synthesis Report states that negative emissions will be necessary in order to keep warming under 1.5°C. Carbon Dioxide Removal (CDR), both in its “conventional” and “novel” forms, will be required to meet this goal, especially to counterbalance hard to abate emissions in aviation, shipping and industry. Even so, it must be stressed that no form of CDR, even at scale, will allow us to meet our climate goals without timely and aggressive cuts to GHG emissions. CDR should not be viewed as a “free pass” to continue burning fossil fuels at current (or increasing) levels.

Novel CDR includes means such as Direct Air Capture (DAC), biochar, and enhanced rock weathering. DAC has received much of the focus in this sector, although it still lacks sufficient attention in scientific literature. DAC involves pulling CO2 directly from the air and then sequestering it in geological formations or reusing it. Currently, novel CDR provides less than .002 GT/CO2e per year reduction.

  • DAC is extremely expensive. Cost estimates vary widely – between $250-600 per ton of CO2 captured. Even after extensive research and development, research indicates the cost is unlikely to fall below ~ $100 per ton of CO2 captured. To reach the IPCC’s minimum recommendation of removing 2 Gigatons/CO2e per year, at the current minimum cost of $250 per ton, a 500 billion dollar annual investment would be required. 
  • Even with significant support, DAC will take several decades to be environmentally viable at the scale needed. DAC would need to increase efficiency and scale up in size at a rate of 10,000 times current levels by 2030 to fit into GHG reduction goals. 
  • Separating CO2 from the air is an energy intensive process, requiring 1200 kilowatt hours per ton of CO2. If DAC activities are powered by fossil fuels, the process holds little value due to the reintroduction of GHGs. 

Although some novel CDR technologies are promising, we do not agree with the current push for increased implementation of DAC. DAC lacks effectiveness and the long term viability needed to be a significant part of our GHG reduction goals. Investing large amounts of energy and financial capital into DAC is likely to prove unwise given the landscape of more accessible solutions and the dwindling window of opportunity for decreasing emissions.

Conventional CDR includes removing carbon through “natural” methods such as coastal ecosystem restoration, reforestation, agroforestry and soil carbon sequestration, all of which also enhance biodiversity and ecosystem functions. We advocate for additional research and legislation focussed on conventional methods of CDR. 

  • “There is substantial mitigation and adaptation potential from options in agriculture, forestry and other land use… that could be upscaled in the near term across most regions (high confidence). Conservation, improved management, and restoration of forests and other ecosystems offer the largest share of economic mitigation potential…”(2023 IPCC report). 
  • Conventional CDR methods also increase and enhance ecosystem services like local air quality improvements, opportunities for recreation, and health of the local ecosystems. It is estimated that additions to ecosystem services could add over $30 trillion dollars per year to the global economy.
  • Ecosystem services also correlate with social benefits like therapeutic services, spiritual connections, and social satisfaction. 
  • Conventional CDR currently provides the removal of 2 Gigatons/CO2e per year.

Carbon Capture and Sequestration (CCS)

CCS aims to reduce carbon emissions by capturing them, mainly from industrial facilities and power plants, while redirecting them from entering the atmosphere. CCS has become a frequent topic of discussion as a possible tool for meeting greenhouse gas reduction targets and mitigating the effects of climate change. In 2022, the federal Inflation Reduction Act earmarked billions of dollars of funding for CCS by incentivizing these technologies through the introduction of sizable tax credits.

Before moving forward with CCS, we believe the following factors should be considered:

Although carbon management technologies appear to align with the wider goal of addressing climate change, this growing field is rife with unknowns. DAC and CCS are decades away from wide scale implementation, and their ability to effectively limit carbon emissions is a point of concern. Moving forward with these strategies would include deferring much needed resources from areas such as solar and wind infrastructure, building out electric power distribution systems, scaling up transportation charging networks, enhancing innovations in rechargeable battery technologies, and increasing energy efficient housing. Moving forward with the implementation of DAC and CCS risks extending the lifespan of the fossil fuel industry – a move that puts us in grave risk of not meeting our climate targets.

Further recommended reading on carbon management



Oil and gas companies, along with utilities that are fossil fuel intensive, created the “Clean Hydrogen Future Coalition” in 2021, urging the Biden administration to increase policy support for a wide range of hydrogen uses. Gas companies are testing the use of hydrogen blended with natural gas. Colorado has a Hydrogen Roadmap for development of hydrogen in Colorado and is involved in planning for a regional hydrogen hub. It is time to take a closer look at the long term implications of hydrogen.


Depending on how it is produced, hydrogen may have some promise in the future in reducing emissions from hard to decarbonize sectors. However, currently at least 99% of the hydrogen being produced actually increases greenhouse gas emissions. The development of “green” hydrogen is in its early stages and still extremely expensive. For all but the most difficult to decarbonize sectors, solar and wind power are more fitting energy sources. Hydrogen is not a good replacement for fossil gas in home use or in generating electricity; it would increase cost and safety concerns while decreasing efficiency.

The facts about hydrogen:

Colorado’s “Low-Carbon Hydrogen Roadmap” recommends pilot projects to blend hydrogen in existing infrastructure to streamline the permitting processes. Developing pilot projects that burn hydrogen for power generation in existing gas turbines and use Colorado’s existing gas storage facilities creates serious public health and safety concerns due to Hydrogen’s chemical composition. This Roadmap is largely for the development and use of “blue” hydrogen, since “green” hydrogen is still too expensive. We believe these factors warrant further consideration before Colorado continues to expand hydrogen production and infrastructure.


With thanks to Susan Saadat and Sara Gerson, the authors of the report Reclaiming Hydrogen for a Renewable Future, from Earthjustice’s Right to Zero campaign. Many of the facts and studies cited above come from this report. 

Nuclear Power and Small Modular Reactors


Nuclear energy is frequently touted by industry advocates as a low-carbon energy source to transition away from fossil fuels. While nuclear proponents have claimed that nuclear power is an attractive energy alternative for coal-transitioning communities such as Pueblo, Moffatt and Routt counties, nuclear proposals have received a great deal of backlash from frontline communities. In 1979, Colorado experienced its first failed attempt at nuclear, with the Fort St. Vrain power plant. Fort St. Vrain was so fraught with operational problems that it had to be shut down after a decade to cut financial losses. Over 14 tons of toxic waste are still being stored at that plant 33 years later. In Pueblo, there is a strong community-led effort to halt proposals to replace the “Comanche 3” coal plant with twelve NuScale Small Modular Nuclear Reactors (SMRs). In 2011, a similar attempt to bring nuclear power to Pueblo was rejected due to community concerns in wake of the Fukushima-Daiichi disaster. 

We believe Colorado’s troubled history with nuclear power, in addition to the concerns outlined below, should be considered before policymakers pursue experimental nuclear technology for Colorado’s coal-transitioning communities. 

Overview of Our Concerns Regarding Nuclear Power and Small Modular Reactors: