{"id":20960,"date":"2021-01-29T13:40:32","date_gmt":"2021-01-29T18:40:32","guid":{"rendered":"http:\/\/blogs.edf.org\/climate411\/?p=20960"},"modified":"2025-12-03T12:41:54","modified_gmt":"2025-12-03T17:41:54","slug":"measuring-the-true-impact-of-colorados-climate-delay-a-pathway-for-curbing-pollution-part-3","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/climate411\/2021\/01\/29\/measuring-the-true-impact-of-colorados-climate-delay-a-pathway-for-curbing-pollution-part-3\/","title":{"rendered":"Measuring the true impact of Colorado\u2019s climate delay: A pathway for curbing pollution (Part 3)"},"content":{"rendered":"

After Colorado legislators passed landmark climate legislation in 2019, which included a statutory mandate directing the\u00a0Air Quality Control Commission (AQCC)\u00a0to adopt rules and regulations to reduce statewide emissions, the state has yet to adopt a policy framework capable of getting the job done. This three-part series explores the impact of Colorado\u2019s delay, analyzing the impact on total emissions and the state\u2019s ability to meet its own climate targets.<\/em><\/p>\n

Colorado\u2019s policy action is nowhere close to living up to its climate commitments. As we\u2019ve illustrated in Part 1<\/a> and Part 2<\/a> of this series, the state is far off track from meeting its own climate goals, even accounting for all current policies and <\/em>recently announced<\/em><\/a> coal plant retirements. <\/em>And the recently released final Roadmap<\/a> doesn\u2019t include a comprehensive and specific regulatory agenda that will secure the needed reductions. Without urgent action, climate pollution will continue building up in the atmosphere and will wreak further environmental, health and economic havoc on Coloradans.<\/p>\n

But in the face of this immense challenge, the Air Quality Control Commission (AQCC)\u2014the regulatory body responsible for ensuring Colorado meets its targets\u2014has an opportunity to get the state on the right course. The Commission is already overdue on its responsibility to evaluate options and then propose a regulation or suite of regulations to meet its statutory climate targets. A recent EDF petition for an enforceable, declining emission limit<\/a> could help the AQCC deliver concrete climate progress on an urgent timeline, while improving health and equity across the state.<\/strong><\/p>\n

<\/p>\n

Roadblock on the \u201cRoadmap\u201d<\/strong><\/h3>\n

Analysis recently released by EDF includes the most recent industry announcements<\/a>, reveals that Colorado will reduce greenhouse gas (GHG) emissions from 2005 levels by only 7-16% in 2025 and 19-26% in 2030 \u2013 falling far short of the 26% reduction required in 2025 and the 50% reduction required in 2030.<\/strong> A concrete policy framework is urgently needed to drive measurable and enforceable reductions that can get Colorado on track with its goals.<\/p>\n

On January 14, the Polis administration shared a plan to tackle the state\u2019s climate pollution through its \u201cGreenhouse Gas Pollution Reduction Roadmap<\/a>.\u201d Although this document is packaged as a plan to reduce GHG emissions as required by House Bill 1261, <\/a>it still doesn\u2019t detail a comprehensive regulatory agenda that is capable of securing the needed reductions.<\/strong> This was the same issue with the Draft Roadmap released back in September. To the extent that AQCC regulations are outlined, critical details such as which entities are regulated, what they are required to do, and over what timeline, are lacking.<\/p>\n

Instead, the \u201cRoadmap\u201d suggests a set of strategies that lack the specificity and enforceability to ensure, even if taken collectively,<\/em> the state meets its targets in 2025 and 2030. The Roadmap\u2019s strategies are largely based on incentives, voluntary commitments from industry and performance-based standards\u2014tools that can importantly spur technological innovation, but do not limit the total level of pollution. With the sizeable emissions gaps that Colorado faces, the state can\u2019t afford to take any chances\u2014it needs to put enforceable limits on pollution that guarantee<\/em> a safer and healthier future.<\/strong><\/p>\n

How a limit on climate pollution could slash Colorado\u2019s emissions quickly<\/strong><\/h3>\n

Last month, EDF filed a petition<\/a> for rulemaking at the AQCC proposing the Colorado Greenhouse Gas Program\u2014a framework that would place a declining limit on emissions, securing the pollution reductions required by Colorado statute. The regulation proposed by EDF would work hand-in-hand with any sector-specific policies adopted by the Commission or other state agencies, and would provide a backstop that guarantees the needed emission reductions are achieved. In addition to the overall limit on emissions, the proposal would create strict annual limits for facilities that contribute to the pollution burden on disproportionately impacted communities.<\/p>\n

The EDF proposal would prevent an estimated 215 million metric tons CO2<\/sub>e from entering the atmosphere between 2022 and 2030<\/strong>. Those reductions are consistent with meeting Colorado\u2019s 2025 and 2030 reduction goals, and the steep and persistent pollution reduction pathways identified by the Intergovernmental Panel on Climate Change (IPCC) to avoid the most extreme effects of climate change.<\/p>\n

EDF\u2019s proposal sets a \u201cbudget\u201d for allowable levels of greenhouse gas emissions each year. This budget would decline annually, in line with meeting the statewide targets. By requiring the pollution sources (power plants, factories, etc.) covered by the program to hold an \u201callowance\u201d for every ton of carbon dioxide equivalent (CO2<\/sub>e) they emit, these sources must reduce emissions or purchase enough allowances to cover their emissions. With the supply of allowances constrained and declining, the program would ensure that pollution is reduced over the decade.<\/p>\n

Although Colorado emissions sources currently pollute for free, greenhouse gases are costly to Colorado communities and the planet. This framework not only limits pollution, but it ensures the true cost of this pollution is better reflected.<\/p>\n

Ensuring health and equity is front and center<\/strong><\/h3>\n

Many communities of color and low-income communities in Colorado bear the brunt of toxic air pollution, health hazards like contaminated soil and extreme weather because polluting facilities are unjustly sited near them. And they often lack community infrastructure, such as quality health care and housing, to cope with these impacts. As frontline community leaders and allies have reiterated in a recent statement<\/a>, Colorado must center its climate action on equity, health, and safety\u2014while developing policies in partnership with frontline communities.<\/p>\n

Colorado is bound \u2013 morally and by law — to prioritize frontline communities in shaping climate action. In H.B. 1261<\/a>, the legislature codified emission reduction mandates alongside principles of equity and climate justice, requiring the AQCC to \u201cinclude strategies designed to achieve reductions in harmful air pollution affecting [disproportionately impacted] communities.\u201d Unfortunately, the state is falling behind on this mandate too.<\/p>\n

EDF\u2019s proposed regulation strives to offer concrete ideas for how to make meaningful progress\u2014both through reinvestment and through stricter compliance.<\/p>\n

Under the proposal, the polluters causing the most damaging impacts to Colorado communities can\u2019t just keep polluting; the program ensures their emissions will go down too. EDF\u2019s regulation would establish a facility-specific limit<\/a> for any emitter that adversely affects disproportionately impacted communities through local air pollutants or cumulative air pollution impacts. These facilities would be subject to an annual emission limit<\/a> that would decline each year in line with the state\u2019s climate targets.<\/p>\n

Overall, the health gains from EDF\u2019s proposal could be immense: A Draft Economic Impact Analysis<\/a> shows how it could drive significant reductions in local air pollutants across the state:<\/p>\n