In the 2019 legislative session Colorado passed House Bill 19-1261, the Climate Action Plan to Reduce Pollution (“Climate Action Plan”), which includes targets for reducing statewide greenhouse gas pollution 26% by 2025, 50% by 2030, and 90% by 2050 from 2005 levels.[1] To ensure that Colorado continues to make progress toward these targets, Governor Polis directed state agencies to develop a comprehensive Greenhouse Gas Pollution Reduction Roadmap (“GHG Roadmap”). The GHG Roadmap delivers a list of near-term actions the state will pursue over the next one to two years to make significant progress toward the 2025 and 2030 Climate Action Plan goals. The GHG Roadmap also analyzes further actions that can help put the state on a solid path to meeting the 2050 goal. A Version 2.0 of the GHG Roadmap is currently being prepared for release in draft in early 2024.
GHG Roadmap Ver. 1.0
The first GHG Emission Reduction Roadmap (Version 1.0) was prepared in draft in September of 2019 and finalized in January of 2020. Though primarily authored by Will Toor of the Colorado Energy Office and John Putnam of the Colorado Department of Public Health and Environment (“CDPHE”), it represents the work of many state agencies also including the Colorado Departments of Agriculture, Natural Resources, and Transportation. Additional support for the GHG Roadmap Ver. 1.0 was provided by the Department of Local Affairs, the Colorado Resiliency Office, and the Office of Just Transition. Colorado hired Energy + Environmental Economics (“E3”), a leading national consulting firm with expertise in GHG modeling, to develop a model of the state’s economy-wide emissions by sector. Technical staff from the Climate Change Unit at the CDPHE provided additional analysis of projected emissions reductions from near term policy recommendations.
The GHG Roadmap team constructed a Reference Case, which represents a projection of the state’s GHG emissions based on policies that were in place prior to 2019. The Reference Case assumes no new policies or actions to reduce emissions. That assessment found that the four largest emitting sectors were the same in 2020 as 2005. In 2020, transportation displaced electricity generation as the largest source of pollution. Electricity generation, oil and gas production, and fossil methane use in the residential, commercial, and industrial sectors remain the other three largest emitters.
While the state has made significant progress toward meeting the 2025 and 2030 goals, the analysis showed that additional actions are needed to reach the targets. E3 modeled an illustrative scenario, the HB 1261 Targets Scenario, to represent one approach Colorado could take to meet the Climate Action Plan targets through 2050. Based on these analyses, the GHG Roadmap proposes administrative, regulatory, legislative, procurement, incentive-based, and other measures to reduce emissions in different sectors of the state’s economy to achieve GHG pollution reductions in a cost effective and equitable way. The GHG Roadmap describes actions Colorado has taken to address climate change, analyzes the current trajectory for GHG emissions, and presents a suite of actions the state can pursue in the near term to make progress toward the Climate Action Plan goals.
The GHG Roadmap’s key findings for the state’s 2050 goals include:
- All sectors of Colorado’s economy will need to achieve reductions of 90-100%;
- The state’s 2 largest utilities will need to meet demand with zero-carbon electricity by 2050, with smaller utilities reducing GHG emissions by 80%;
- The transportation sector will need to be close to 100% electric vehicles (EVs) on the road by 2050;
- Achieving the 2050 goal will require further technical innovation such as green hydrogen, long duration energy storage, carbon capture and storage, and advanced biofuels;
- In the buildings sector full decarbonization by 2050 is based on a large-scale shift to the use of electric heat pumps, powered by zero carbon electricity, for space and water heating;
- Land conservation, restoration, and climate-adaptive ecosystem management will be critical
- for maintaining and enhancing resilient carbon sequestration on natural and working lands; and
- In agriculture, the development of markets that pay producers for ecosystem services may be an increasingly important tool.
Concerns of various commenters on GHG Roadmap 1.0 included that:
- It endorses large scale electrification and prescribes solutions 30 years into the future based on uncertain or non-existent technologies;
- It is aspirational, prescriptive, and inflexible rather than pursuing cost-effective measures in an iterative process;
- As a result, it vests greater power in electric utilities which simply pass costs on to consumers and stifle lower-cost outcomes that competition would encourage;
- It employs an accounting scheme that is fundamentally flawed;
- It relies on proprietary models of the State’s contractor, E3, the algorithms for which were not disclosed publicly; and
- It did not pursue a robust stakeholder and public participation process for such a transformational energy policy document.
GHG Roadmap Ver. 2.0
The state is now working to update the Greenhouse Gas Pollution Reduction Roadmap (“Roadmap 2.0”), including an updated inventory of emissions and a new set of Near-Term Actions that will guide implementation in the state. The State is soliciting written comments, holding open meetings and conducting sector roundtables in connection with the GHG Roadmap 2.0 update. The sector-specific roundtables concern topics including major sources of emissions in the transportation, electricity generation, oil and gas, industry, building energy use, land use and agriculture sectors. More information is available on the Colorado Energy Office website at: https://energyoffice.colorado.gov/climate-energy/ghg-pollution-reduction-roadmap-20.
Initial written comment on the planned GHG Roadmap Ver. 2.0 update was due by September 15, 2023. Among the concerns raise in initial public comment are:
- The need to prioritize feasibility and resource availability in Colorado’s Clean Energy Planning for 2040;
- The need to decarbonize Colorado’s electric grid before requiring or incentivizing widespread electrification of various sectors of the Colorado economy so as to avoid leakage and increased scope 2 emissions;
- Promoting the robust yet streamlined processes necessary to modernize permitting and siting of renewable energy generation and transmission projects on State lands;
- Including renewable natural gas (“RNG”) in the development of a circular clean energy economy in Colorado, in addition to proposed clean energy/battery recycling and waste stream measures identified;
- Facilitating the implementation of carbon dioxide removal (“CDR”) strategies including carbon capture, utilization and sequestration (“CCUS”) is essential for industry to reduce GHG emissions efficiently and cost-effectively, especially while awaiting the development of more renewables powering the grid;
- Rethinking proposed oil & gas sector strategies to avoid technology preferences being established in policy and regulations, and to also avoid unnecessarily combining GHG reduction and conventional air pollutant emissions mitigation strategies, as these are fundamentally different (global vs. local) and difficult to regulate together in a balanced way as recognized recently by the Colorado Air Quality Control Commission in the adoption of GEMM 2 rules last month;
- Developing a strategy for Urban Freight that is not exclusively based on electrification, especially for heavy-duty and long-haul vehicles; and
- Considering the unique needs of rural communities alongside actions that will benefit urban areas when developing Roadmap 2.0, especially with respect to possible strategies like expanded fare-free transit, since rural communities typically lack robust transit systems.
Preparation of GHG Roadmap 2.0 in draft for public comment is expected to occur by January of 2024. This policy document is crucial to the State’s approach to reducing emissions from all sectors of the state’s economy. As such, it is incumbent on industry, community and civic leaders and other stakeholders for each sector to be aware of the very significant likely consequences of the strategies to be adopted in GHG Roadmap 2.0. Once again, there is a lot of relevant information available on the Colorado Energy Office website at: https://energyoffice.colorado.gov/climate-energy/ghg-pollution-reduction-roadmap-20 , and may also be addressed and updated on the websites of other involved state agencies including CDPHE, CDOT (https://www.codot.gov/programs/research/pdfs/other-reports/colorado-greenhouse-gas-pollution-reduction-roadmap ), DNR and DOA.
[1] The 2050 target in the Climate Action Plan has since been modified from 90% to 100% by subsequent legislation, S.B. 23-016, concerning Greenhouse Gas Emission Reduction Measures, codified at C.R.S. § 25-7-102(g)(I)(F).