Last year, legislation was passed in Colorado to begin addressing Colorado’s contribution to the climate crisis and curbing emissions that not only contribute to climate change, but also adversely impact air quality and contribute pollution harmful to respiratory health. The proposed Colorado GHG Reduction Roadmap released on Sept. 30th is a start, but to achieve the goals of HB 19-1261 and eventually more aggressive goals that climate science and justice demand, more specific policies and enforcement will be needed. 

The droughts and wildfires that have turned our skies orange are a reminder that addressing climate change and ensuring a habitable climate requires us to actually transition off of fossil fuels in the near future. Colorado has not met federal air quality standards for over a decade, and the AQCC is still lagging in meeting its statutory requirement to develop rules that will enable Colorado to meet new GHG emissions reduction goals passed by the legislature. 

With the Governor’s Colorado Greenhouse Gas Pollution Roadmap, the state has the opportunity to make critical changes in GHG emission reductions and be a part of the solution in safeguarding our health and air quality. Yet in order to do this, the Roadmap must include far stronger sector-specific targets, policies, and enforcement to protect the environment and climate justice to successfully implement necessary and rapid climate solutions. Despite the potential for bold climate action that the Roadmap represents, the protections and emission reduction goals laid out in the Roadmap must be more ambitious, equitable, quantifiable, and enforceable, and these guiding principles should be directly reflected in the outcomes of the Roadmap. 

Currently, there is no reference to how the Roadmap will develop enforceable measures to monitor and reduce emissions from oil and gas extraction. By enforceable, we mean specifics outlining which entities are being regulated, what pollutants are being regulated, at what level of stringency pollutants are being regulated, and how third party monitoring of emissions will be conducted. Having clear, enforceable limits for various industries to reduce GHG emissions are necessary in order to lock in reductions, and there must be meaningful consequences for polluters when proposed rules are violated.

Furthermore, 350 Colorado is concerned that the current proposed plan in the Roadmap does not align with a 66% likelihood of meeting the IPCC’s goal of staying below 1.5C, which requires 100% GHG emissions by 2036. With current statewide efforts for reducing GHGs, our state is not even on track for a 50% chance of avoiding climate catastrophe. While the plan considers reducing upstream and downstream operation leak rates, it ignores the reality that adequately addressing climate change and ensuring a habitable climate requires us to actually transition off of fossil fuels in the near future and stop bringing online new fossil fuel development. A rapid phase off of fossil fuels needs to be considered in developing key strategies for reaching GHG reductions. There are significant disparities between strategies proposed in the Roadmap for GHG reductions and what is outlined by the IPCC as necessary for a 66% chance of keeping global temperatures rise below 1.5C. 

350 Colorado recommends a 10% per year phase out of all new oil and gas permitting to ensure that Colorado’s emissions reductions align with IPCC goals. We believe that having a total phase out of new fossil fuel development by 2030 outlined in the Roadmap will serve as a catalyst for a just transition, which is another reason why equity must be baked into the rules, rather than it being an afterthought. We are encouraged to see a commitment to a just transition away from coal toward a renewable-energy future written into the Roadmap, and we encourage this just transition to be extended to all fossil fuels. In addition to this, we recommend that “Renewable Natural Gas” (RNG) not be used as a bridge fuel to replace a portion of the fossil-based gas as is suggested in the Roadmap. Investments in RNG will likely simply greenwash and extend the use of fossil gas, when Coloradans would ultimately be better served by a fossil fuel phase out and placing those investments in 100% clean renewable energy.

The proposed emission reduction targets laid out in the Roadmap are far too low, especially in regard to the oil and gas sector, the electric sector, and in regard to the phase out of coal-fired power plants. Currently, the Roadmap proposes for the oil and gas sector a 33% reduction in total emissions by 2025 and a 50% reduction by 2030. For the electric sector, the Roadmap proposes 80% pollution reductions by 2030. For both of these sectors, we believe that the emission reductions fall short. 

In terms of the electric sector, we recommend 70% emissions reductions by 2025 compared to 2005, and 98% by 2030. In terms of the oil and gas sector, we recommend a 45% reduction in oil and gas emissions by 2025 and 90% by 2030. In order to reach these goals, as we have previously stated, we strongly recommend a 10% reduction per year in new oil and gas permitting, for a total phase out of permitting by 2030. We also recommend a phase-out of coal-fired power plants by 2025. 

350 Colorado is also deeply concerned that the Roadmap does not start with an accurate baseline of emissions, especially methane from the oil and gas industry. A more thorough GHG inventory is needed using best available technologies including top down atmospheric measurements. Recent research on the air quality impacts of oil and gas development in Colorado shows a worrying spike in global methane emissions over the last decade from fracking in North America, primarily the U.S., and Colorado is the sixth most fracked state. Research from Cornell indicates that methane emissions are likely 2-4 times higher than current estimates from the shale oil and gas industry. While the Roadmap is correct in stressing the important role that minimizing the release of methane from the oil and gas industry plays in reaching statewide emission reduction targets, emission estimates of methane and other GHGs are far higher than industry estimates. 

In addition to top-down atmospheric monitoring, we recommend that continuous emissions monitoring at all polluting sites be conducted by an independent third party with methods and expertise suitable to measure a higher dynamic range and with high time resolution in order to ensure that methane is in fact being reduced at the required rate and to hold polluters accountable. This information should be made available to the public online in real time. We see no way that emission reduction targets will be reached unless accurate, continuous emissions monitoring that requires the simultaneous monitoring of VOCs, methane, and BTEX are written directly into the Roadmap. While having E3 data used to develop the Roadmap available to the public is a step in the right direction, this transparency should be extended toward making real-time emissions monitoring data available to the public. 

We encourage the APCD (Air Pollution Control Division of the Department of Public Health and Environment) to make available to the public the reports that will be presented to the AQCC on current and projected GHG inventories. The Roadmap should also address the loopholes created from the AQCC’s latest Regulation number 7, which opts for industry self-reporting and optional, ‘flexible’ monitoring of key oil and gas pollutants. These recently adopted rules do not adequately implement SB 19-181, and given that rulemakings are a main mechanism proposed for ensuring emission reductions, we call for the Roadmap to address any loopholes that result from current and subsequent rulemakings conducted by the AQCC and COGCC.

In summation, 350 Colorado believes that far stronger and bolder protections must be written into the Roadmap in order to ensure that it serves as a solution in safeguarding our health, safety, air quality and climate. The protections and emission reduction goals outlined in the Roadmap must be more ambitious, equitable, quantifiable, and enforceable, and these principles must guide the outcomes of the Roadmap. We are also concerned that the current proposed emissions targets outlined in the Roadmap do not align with either a 66% or even 50% chance of meeting the IPCC’s goal of staying below 1.5C global temperature rise. We call for a total phase out of new fossil fuel development by 2030 as both a necessity for maintaining a habitable planet for generations to come, as well as improving air quality, addressing environmental injustice, and serving as a catalyst for a just transition. Additionally, in order to meet ambitious emissions reduction targets, we must start with an accurate baseline that is measured using the best available technologies, including third-party top down atmospheric measurements and continuous monitoring with this data available to the public in real time online. The fossil fuel industry must not be allowed to self-regulate and self-report. Colorado must properly study and assess the full impact of the oil and gas industry and begin the transition away from oil and gas, in order to both reduce VOC emissions statewide and address the full climate footprint of this state. Amidst wildfires, a statewide drought and serious air quality issues, there is no time to lose to begin making progress toward taking bold climate action to ensure a liveable planet and future.