Following a blitzkrieg of climate legislation in 2019, state agencies continue to push for new policies and regulations to meet the statutory goals of a 26% reduction in GHG emissions by 2025 and a 50% reduction by 2030, using 2005 as a baseline. Longer term, the goal is a whopping 90% reduction by 2050. CMA had received an early briefing by the Energy Office and followed this issue during the Air Quality Control Commission’s GHG subcommittee which appeared to focus primarily on transportation and buildings; public input was not accepted during those sessions.
During the past week, Governor Polis release a draft “Roadmap to GHG Reductions” for public comment. Deadline for comment is November 1, with a virtual “public listening session” on October 20 via Zoom. Information on that session is available on the Colorado Energy Office website.
The roadmap and its recommendations are extremely broad, encompassing all areas of Colorado’s economy including mining, oil/gas, transportation (transport of goods, individual travel, and fuels), land use planning, and agriculture. A chart of recommended short-term measures can be found on the Energy Office’s Google Drive and the Executive Summary.
The projections and recommendations were analyzed and modeled by a consultant, Energy + Environmental Economics or “E3.” Although the Energy Office touts the multiple presentations and outreach efforts to date, it is unlikely that the general public has any idea of what is to come if these recommendations are implemented through new regulations at the Air Quality Control Commission, PUC, CDOT, DOLA, Department of Natural Resources and Department of Agriculture. The plan is ambitious, aggressive, and expensive.
The analysis identified transportation as the largest generator of GHG emissions. Thus, following the 2019 adoption of a Zero Emissions Vehicle regulation by the Air Quality Control Commission for light duty vehicles, the Roadmap envisions widespread adoption of ZEVs for passenger use, as well as medium and heavy duty trucks. Embedded in this vision would be measures to make ZEVs financially available to lower income residents through “bonding mechanisms or other long-term sustainable revenue,” in specific recognition that the state General Fund cannot provide necessary resources. Permanent adoption of telecommuting, requirements for large employers to develop transportation demand management plans (such as providing transit passes), and expansion of transit systems are considered as potential regulations for 2021.
The electricity generation sector is the second largest GHG source. That sector is subject to the enforceable Clean Energy Plans, Regional Haze regulations, and other requirements with announced closures of most coal-fired power plants by 2030. The move to renewable energy will require massive additional infrastructure (wind, solar) to support not only the current uses but additional load created by electric vehicles and the Roadmap’s anticipated transition away from fossil fuels (natural gas and propane) as a heating source for water and buildings. The Roadmap acknowledges that this will require significant investment in battery storage as 2050 nears and that the challenges of residential heating in cold climates needs to be addressed.
Commercial buildings will see new requirements for benchmarking and reporting of energy use (legislation is anticipated in 2021) with additional performance standards to meet energy or carbon intensity targets. These programs would be supported by fees for service (by whom?) and fines for non-compliance.
Surprisingly, cap and trade was NOT recommended by the group, which acknowledged that carbon pricing required additional work on tax and economic modelling to “shift the tax burden from income to GHG pollution.”
If fully implemented, this plan would fundamentally change life for all Coloradoans. The report should be carefully read, and comment provided to the Polis administration. Comments may be submitted to email@example.com.