Colorado’s decarbonization roadmap*

*And why the environmental community is at odds with the Polis administration

by Allen Best

From the Oct. 2, 2020, issue of Big Pivots.

The administration of Colorado Gov. Jared Polis on Wednesday issued the draft carbon reduction roadmap, identifying how state officials see Colorado going about decarbonizing the state’s economy as required by a 2019 law, HB 19-1261, the Climate Action Plan to Reduce Pollution. The draft roadmap and other documents can be seen on the Colorado Energy Office website. Here I deliver the takeaways in bite-size segments:

1) Colorado rocks

There’s much quibbling about whether this roadmap will get us where we need to go in a timely manner. Plenty of people think we need to accelerate.

Be very clear that Colorado has set out to create the Big Pivot in how we live and especially in how we produce and consume energy. The goals – 26% fewer economy-wide carbon emissions by 2025 compared to 2005 levels, 50% by 2030 and then 90% by mid-century –reflect the goals of the Paris climate accord. The Paris agreement reflected what scientists say we must do if we want to avoid the far worse impacts from a climate going as crazy as our most recent presidential “debate.”

This is a necessary war.

Why does it make sense for Colorado to embrace these goals when, say, Oklahoma does not? And why should the U.S. do so when India is still building coal plants?

Foolish naysaying. Leadership starts at home, and it will spread. Colorado leads the way in the nation’s interior. Colorado is in the front row along with California, New York, Massachusetts, and a few others.

Mostly the leaders of this are younger, but certainly not all, and they universally must be optimistic. During these dark, divisive times we have a new “greatest generation” effort that spans multiple generations.

Colorado has had a 2 degree F increase. Moffat County, in the state’s northwestern corner, where this photo was taken in August 2020, had the warmest August ever recorded and also among the driest. Photo/Allen Best

2) The slow bake

You’ve read this statistic before, but it bears repeating, as the 100-plus-page roadmap does: Colorado has warmed 2 degrees F on average in the last 30 years.

Colorado’s recent average summer temperatures are even higher than the extreme heat of the 1930s Dust Bowl. Peak runoff has been coming 1 to 4 weeks earlier. Warming temperatures and drier soils increase the likelihood of larger wildfires.

August was the hottest ever in Colorado, but 30 years from now these same temperatures will likely be viewed as relatively cool.

3) Why so long?

The law that launched this roadmap process was adopted in May 2019. The law spoke to the climate crisis. It demanded brisk action. Why has it taken so long to put this roadmap together?

One crucial task was to lay down the methodology for getting a strong handle on the emissions. The last inventory from 2015 was slippery, involving a lot of guesswork about emissions from the oil and gas sector, agriculture—well most everything except for the relatively few giant smokestacks.

The Air Quality Control Commission in May adopted regulations intended to deliver a clear picture of emissions. The adage behind this is that you can’t manage what you can’t measure. This closer study has revealed the conclusion that the oil-and-gas sector has been producing far more emissions than had been assumed.

And plans do take time to assemble. Consultants are hired, stakeholder meetings convened, and so forth.

Too long? That’s the argument from the environmental community, and we’ll get to that.

4) Where is the power?

The legislation delegated much of the power to achieve change to the Air Quality Control Commission and, by extension, the staff of the Colorado Department of Public Health and Environment. Perhaps just as important, if less officially so, is the Colorado Energy Office.

Together these are the main state agencies that put together this roadmap, with smaller if still important roles for the Colorado Department of Transportation, the Department of Agriculture, and others.

No less important, but in a different way, is the Colorado Public Utilities Commission. It has less discretion, but has a huge role in overseeing the decarbonization of electrical generation and also transportation and buildings.

5) Who are the faces?

Three individuals stand out in public presentations. First is Will Toor, who has a Ph.D. in physics but also spent a winter herding sheep in Moffat County. He has great band-width. He directs the Colorado Energy Office after a political career that included being mayor of Boulder and a Boulder County commissioner.

From CDPH&E there is John Putnam, the director of environmental programs, who formerly was managing partner of Kaplan Kirsch Rockwell, one of Denver’s major legal firms. Also a key figure, in my read, is Garry Kauffman, director of the Air Pollution Control Division.

I’ve left out a dozen names here that I’m aware of, and there might well be a dozen more unknown to me that are also crucial.

6) Source of emissions?

Electricity generation—primarily from coal plants—long stood as the No. 1 source, but this has been overtaken by transportation. Oil and gas production has figured in prominently, which is why recent rule-making before the Air Quality Control Commission matters so much.

7) The crucial choices?

The Polis administration has chosen to be somewhat cautious and methodical. The plan released on Wednesday hasn’t changed much in the last two or three months. It sees Colorado retiring most of its coal generation by 2030, even as the state takes rapid steps to electrify transportation and begins the hard work of electrifying, or at least decarbonizing, other sectors.

“Under current policies and with pre-covid assumptions, the state is on a trajectory to achieving approximately half the level of emission reduction needed to meet the 2025 and 2030 reduction goals,” the report says. “Additional actions are needed to get all the way there.”

Those additional actions are all important, but they amount to tweaking. Getting to the goals can be achieved with existing technologies, the report says.

Environmental groups fundamentally disagree. They want bold action, either by pushing for decarbonization of electrical generation even more rapidly or by adopting economy wide mechanisms like cap and trade or a carbon tax.

8) Areas of agreement

The Polis administration and environmental groups agree that we will be shifting to a more electrified world in the next 30 years. We will drive electric cars and even electric trucks (although there’s perhaps room for hydrogen), and live in homes absent gas-fired hot-water heaters. But how to get there?

Even within this fundamental agreement there are disagreements about pace. Consider Xcel Energy, which would seem to be a clear winner in the electrify-everything theme. In fact, it has warned on several occasions against getting in too much of a hurry.

Just a few weeks ago, the National Parks Conservation Association proposed requiring oil and gas companies to electrify engines used in compression. Xcel—backed by the Colorado Rural Electric Association—said that this shift would require more electricity than the infrastructure could provide. It favors a slower pivot.

9) Pick up the pace

Beginning in February, Conservation Colorado and other environmental groups began grumbling that the Polis administration was moving too slowly. In June, WildEarth Guardians filed suit against the Polis administration. Stacy Tellinghuisen from Western Resource Advocates addressed a subcommittee of the Air Quality Control Commission late in the summer.

Their message was consistent: Polis administration, you need to pick up the pace. And Air Quality Control Division in particular, you need to examine some bigger, bolder ideas.

In July, I talked with Pam Kiely, from the Environmental Defense Fund, after a subcommittee of the Air Quality Control Commission had met to kick around what was needed.

“At its essence, this is an air pollution problem,” she pointed out. And the law identifying the targets directed the “expert regulatory commission to use its expertise to employ strategies to ensure and guarantee reductions in pollution. It’s been over year, and I think it’s time for them to get serious.”

In these public meetings, John Putnam had frequently cited constraints in staffing. Kiely conceded the restraints, but argued that the allocated staffing of 6.4 full-time employees only forced the state agencies to “allocate their time wisely,” to “get the most done for the buck.

Kiely cited regulations adopted by the Air Quality Control Commission in June that crimp substantially the hydrofluorocarbons, a small but powerful greenhouse gas emitted from refrigerating units, aerosols, and other applications. Fine, said Kiely. EDF supported this. But by 2030 this secures a reduction of 1.5 million metric tons relative to the gap that needs to be bridged of 45 million metric tons of carbon dioxide equivalent gases. (The draft plan looks to bridge the gap in other ways, too).

She said lacking in the state’s preliminary roadmap were “concrete and enforceable limits.” Those same words were repeated again and again during summer, and then once again this week as environmental groups reacted to the draft plan.

10) Legislators speak

Several state legislators have spoken before the Air Quality Control Commission—and hence the staff—in May and successive months.

Said House Speaker KC Becker:  HB 1261 accompanied by SB 96, both adopted in 2019, provide “expansive authority and clear direction specifically to this Commission to develop the regulations we need… Policies that do not guarantee quantifiable and enforceable emission reductions are not ‘consistent with’ the goals laid out in statute…. the AQCC has the sole responsibility to adopt the backstop regulations to guarantee we hit our targets.”

Two other legislators, Faith Winter and Dominique Jackson, also spoke at Air Quality Control Commission meetings.

11) Strong backstop

Western Resource Advocates submitted comments to the Colorado Energy Office in late July that adhered to the same theme. These strategies and goals are nice—but they’re not enforceable, said Stacy Tellinghuisen and Erin Overturf.

Instead, WRA and others asked for what is sometimes called a backstop authority, a carbon tax or something similar. Only with that backstop device could there be certainty of the private sector – whether automobiles or coal plants – taking the necessary action to achieve the goals.

Western Resource Advocates, in a July 31 letter, articulated at length the organization’s position. It used the changes in the electricity sector in the last 15 years.

This is from the Oct. 2, 2020, issue of Big Pivots. If you want to be on the subscription list, go to BigPivots.com

“The renewable energy standard, energy efficiency standard, and legislation to accelerate coal plant retirements have driven the development of new technologies and significantly reduce the cost of clean energy. As a result, today the electricity sector is poised to voluntarily reduce its emissions,” the letter said. “Now, policy is needed to drive similar innovation and cost declines in other sectors of the economy.”

Very specifically, WRA asked for concrete and specific strategies. The group also pointed out that the state lacks the tools to ensure that Tri-State, Platte River Authority, and other providers achieve those 80% reductions. The law only applies to Xcel (which provides more than 60% of the state’s electricity).

Tri-State has not announced its plans regarding the Laramie River Station at Wheatland, Wyo. It’s a major source of power for its Colorado cooperative members. Photo/Allen Best

12) Speaking of Tri-State…

It closed its plant at Nucla in September 2017 and also one at Escalante, N.M., a few weeks ago. And yes, all three units at Craig will be shuttered by 2030, as per an announcement in June.

Will they actually be closed?

The economics of energy suggest that yes, absolutely, Tri-State will close them. How can it afford to keep burning expensive coal when wind and solar are so much cheaper. And that’s one of the assumptions of the roadmap and the officials who put it together.

But there’s a big question mark about imported power into Colorado, particularly from the Laramie River Station in Wyoming.

In a filing at the PUC, Western Resource Advocates concludes that the existing plants will reduce Tri-State’s carbon emissions by only 34% as compared to 2005 levels. Duane Highley, on a recent webinar, said that Tri-State has its work cut out to get beyond 50% renewables. (He sees creation of a regional transmission organization, or something similar, as being crucial; Matt Gerhart from the Sierra Club points out that Colorado Springs Utilities did not predicate closing of its coal plants by 2025 on anything else happening).

13) The soft stick

The state’s roadmap said that achieving the 2025 and 2030 goals will “require additional policies beyond the actions the state has already taken.”

Details get sparse, although on page 25 there’s a paragraph that points to something of a soft stick. SB 19-236 permits any utility to file a Clean Energy Plan with the State’s PUC that proposes to reduce carbon emission 80% by 2030. If so, and the plan is approved by the PUC, the utility is generated a “safe harbor” from additional regulation by the Air Quality Control Commission.

There are many more ambitions and small steps involving transportation and building electrification, even in the agriculture sector. Some are underway, others only now getting started. But specific proposed actions are largely lacking.

14) Big bang for the buck

On Tuesday, the Sierra Club and the National Resources Defense Council issued a lengthy report that was prepared by Evolving Energy and Grid Lab. See the report overview here.

One big takeaway is that the biggest bang for the buck to be had was pushing electric utilities to decarbonize even more rapidly, upwards of 98% and 99% by 2030.

The big question is how. Xcel Energy in 2018 famously pledged 80% reduction by 2030 using existing technologies, a pledge now put into law. There has been much debate about just how close to 100% it, and other utilities, can get during this decade.

The Sierra Club’s Matt Gerhart says the PUC has ample legal authority to require early closure of coal units. Plus, he says, the

AQCC has broad legal authority under HB 19-1261, and that authority extends to imposing emission limits and ordering units such as coal units to shut down.  So the AQCC could also order coal units to shut down early. The AQCC’s authority extends to all electric utilities in the state, including utilities that are not regulated by the PUC (such as Platte River Power Authority and Colorado Springs Utilities).

I am struck by a comment that State Sen. Chris Hansen made at a recent meeting. An engineer by training, he said he believes it’s possible to get to 90% more easily than has commonly been believed. “I think we will surprise ourselves,” he said.

“I have seen a lot of really great modeling of around 90% to 93% renewable penetration without any significant energy problem,” he said. “I’m very bullish on getting in the low 90%’s much quicker. It’s the last 5% or 6% that are in question.”

This new report also calls for dramatic changes in transportation, with the majority of new cars and trucks of all weights being electric by 2034, up from fewer than 2% of sales in 2018. The influence of California should be noted. Gov. Gavin Newsom last week announced a ban on most sales of internal combustion vehicles by 2035. Maybe there is hope for Colorado electrifying more rapidly.

This report also calls for decreasing emissions from the building sectors by at least 9 to 14% from 2005 levels by 2030. It calls for 55% of new homes to be all-electric by 2025 and envisions a mandate for all all-electric homes by the early 2030s.

15) What they said

In various ways, most of the environmental groups had much the same thing to say this week. Consider Howard Geller, at the Southwest Energy Efficiency Project. He said the roadmap:

…“correctly identifies energy efficiency and electrification as key tools to cut pollution across Colorado. Reducing energy waste and shifting from fossil fuels to increasingly clean electric power will protect our climate, improve our health, and save us money. However, many of the proposed actions in the Roadmap are not fully fleshed out. We look forward to working with Governor Polis and his appointees to ‘put more meat on the bones’ and strengthen the Roadmap before it is finalized.”

16) Travel brochure

Jeremy Nichols, of WildEarth Guardians, spoke in metaphor in his criticism. “It’s less of a road map and more a destination vacation brochure. It’s great if we get there. But it does not explain to me or to Colorado how we are actually going to get there.”

Nichols said he wants the state to be careful about how it invests its time and energy in trying to deliver complex solutions. He wants to see the effort focused on further scrubbing carbon emission from electricity, much like the Sierra Club/NRDC report advocates.

State Sen. Chris Hansen

17) Filling the legislative gaps

Certainly, there are other legislators in Colorado than Chris Hansen interested in energy—and it runs across the aisle. I’m thinking of Kevin Priola, a Republican from Adams County and ardent supporter of vehicle electrification. But Hansen has had his fingers on nearly all the important legislation.

During the last legislative session, Hansen had several bills that got waylaid by covid. One of them involved transmission, another to put a greenhouse gas accounting into the choice of materials used to construct buildings.

Another bill would institute a renewable natural gas standard, similar to that adopted for electricity, to accelerate efforts to capture methane from dairies, landfills, and wastewater treatment plants. This would reduce methane emissions and also supplant a certain amount of demand for natural gas obtained by drilling.

Hansen has a long list, and he’s only one legislator. When I talked to him in July, he also made a point of saying he favors incentive. We at that point were talking about the agricultural sector.

18) And local governments?

I called Jacob Smith, the former mayor of Golden who now leads the Colorado Communities for Climate Action. That group has had a strong presence of local officials testifying from metropolitan Denver to the Western Slope at AQCC meetings.

Without the state actually knowing how it will achieve the targets, he said, the Polis administration is taking tools off the table such as the idea of cap-and-trade, a device that has been used by California.

“We hear the state talking about wanting to go back to get more clarity (from the Legislature), and the response you hear from legislators is that you don’t need more clarity. The language is very clear. You have the responsibility and the authority to take the state to the targets.”

On Tuesday, the Colorado Communities for Climate Action sent a letter to Polis that had none of the strong language of Smith, but did have signatures of more than 100 members of town and city councils and county commissions from the Front Range westward, among them:

Earle Bidez, Minturn mayor pro tem; Todd Brown, Telluride mayor pro tem; Hilary Cooper, San Miguel commissioner; Thomas Davidson, Summit County commissioner; Kim Langmaid, Vail mayor pro tem; Sonja Macys, Steamboat Springs City Council; Dave Munk, chair of the Holy Cross Energy Board of Directors; Greg Poschman, Pitkin County commissioner; Teak Simonton, Eagle County treasurer; Lauren Simpson, Arvada City Council; and Torre, mayor of Aspen.

Colorado’s state government will host a public listening session on Tuesday, Oct. 20, from 5:30 p.m. to 8:30 p.m. MDT via Zoom. State leaders will give an overview of the roadmap report and state climate equity work and will listen to questions and input. Registration is required  REGISTER HERE.

This story was originally published in the Oct. 2, 2020, issue of Big Pivots. To get on the mailing list, go to BigPivots.com

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Allen Best

1 thought on “Colorado’s decarbonization roadmap*”

  1. Colorado’s GHG roadmap focuses almost exclusive on wellhead emissions for the oil and gas sector. It ignores life cycle GHGs of oil and gas developed in Colorado. End use emissions — what comes out of the tailpipe or the power plant smokestack — accounts for approximates 80% of life cycle GHGs for this sector.

    The “wellhead approach” to oil and gas would be akin to a scenario where 80% of GHGs from the transportation sector in Colorado were emitted from passenger cars – but state policy chose to focus exclusively on the 20% of GHGs coming from commercial trucks. Even if we got trucking GHGs down 90 or 99%, we would have ignored 80% of total transportation sector emissions.

    The Roadmap acknowledges that all sectors have an important role to play for the state to meet our 90% reductions by 2050 goal. But it is silent on the fact that if we mine coal or oil or gas that cancels out GHG reductions progress in Colorado – we will have ultimately failed future generations to the same extent as if we failed to reduce in-state emissions.

    The Roadmap needs to be informed by a comprehensive, life-cycle approach. Driving from Denver to Grand Junction is a trip of close to 250 miles. If we drive an EV for the first 70 miles (28% of the trip) to Frisco, and switch over to a gas-guzzling SUV rental for the next 180 miles – our total emissions will be far greater if we’d driven a high-mpg passenger car for the entire trip. If the Chevy Suburban gets (an optimistic) 20 mpg, we burned 9 gallons of gas that could have been avoided with an EV charging station in Frisco.

    The wellhead emissions approach ignores the forest of end-use emissions by focusing on a few ornamental trees that the equivalent of wellhead emissions.

    Life cycle analysis should be used for all energy sources and all sectors of the economy. Meeting Colorado’s goal of 90% GHG reductions by 2050 requires honest accounting and grappling with the hard issues. That includes ramping down oil and gas as part of a just transition that puts workers to work in the clean energy sector.

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