RFA: CFS can help Colorado reduce GHG emissions

The Colorado Energy Office recently accepted public comments on its draft Greenhouse Gas Pollution Reduction Roadmap, which details energy action steps the state can take to meet its near-term greenhouse gas (GHG) reduction goals.

The state aims to reduce GHG pollution by 26 percent by 2025, ramping up to 50 percent by 2030, when compared to baseline 2005 levels. A public comment draft of the roadmap was released on Sept. 30. The agency accepted comments through Nov. 1.

The draft roadmap, which spans nearly 175 pages, identifies transportation, electricity generation, oil and gas production and buildings as the largest sources of GHG pollution in Colorado. According to the roadmap, achieving the 2025 and 2030 GHG reduction targets is feasible with existing technologies, but will require actions and policies beyond those the state has already taken. In order to reach the goals, the agency said the state will have to rely on deep reductions in pollution from electricity generation by continuing to transition to renewables. Deep reductions in methane pollution from the oil and gas industry are also needed. The roadmap also identifies changes to transportation planning and infrastructure to reduce growth in driving as an important emissions reduction tool. Electrification of end uses in buildings and transportation would also be needed. To reach its GHG reduction targets, the state would also have to reduce methane emissions from landfills, sewage plants and other resources.

For transportation, the roadmap identifies three primary policy transitions that would be needed: Transitioning to close to 100 percent electric cars by 2050 and 100 percent market share for new vehicles sales of zero emissions trucks and buses by 2050; adopting lower carbon fuels, including advanced biofuels, renewable natural gas (RNG), and hydrogen for aviation and some heavy trucks; and expanding efforts in public transit, transportation demand management, and wise land use planning to reduce vehicle miles traveled.

For the waste sector, the roadmap calls for the state to create RNG incentives to help reduce emissions from landfills, sewage treatment plants, and agriculture.

In developing the roadmap, state agencies considered the implementation of a Clean Fuels Standard, but did not recommend that the CFS be part of the near-term action agenda for the state. Rather, the roadmap suggests further evaluation of a CFS.

The roadmap indicates that the Colorado Energy Office conducted a feasibility study in fiscal year 2019-’20 that examined a range of clean fuel standard scenarios that would achieve reductions in carbon intensity of up to 20 percent over 10 years. While the study concluded that a CFS was feasible, the agency said many questions remain unanswered. The Colorado Energy Office expressed concern about overlap or double counting emissions reductions from other light and heavy duty electrification efforts and from a CFS. In addition, the agency said modeling indicated that, at least for the first decade, the bulk of emission reductions would come from conventional biofuels. “The state has not had a comprehensive analysis or public process examining the tradeoffs involved with large scale use of conventional biofuels, so it seems premature to move forward with a CFS,” the agency said in the roadmap. “In addition, the compliance cost for a CFS would likely be passed along to consumers of high carbon fuels such as gasoline and diesel. It might be more appropriate in the near term to look at revenue mechanisms that directly support adoption of zero emissions vehicles.”

The Renewable Fuels Association is among the organizations that submitted comments on the draft roadmap. The RFA stressed that the internal combustion engine is “far from dead—the fuel just needs to be changed” with a low-carbon or clean fuel standard that can help Colorado slash greenhouse gas pollution.

“A properly designed, fuel neutral, LCFS or Clean Fuel Standard encourages GHG reductions via market forces,” RFA Vice President of Regulatory Affairs Kelly Davis wrote in comments submitted Friday. “LCFS/CFS programs are already in effect in California, Oregon and British Columbia, and have been discussed in other parts of the U.S., including Washington, New York and the upper Midwest. A science-based standard can drive technological innovation, stimulate investment in clean energy, reduce climate change emissions from the transportation sector, and decrease fossil fuel consumption.”

Davis also noted these programs “enable an increasingly diverse fuel supply, thus creating competition, encouraging innovation and developing greater market opportunities while improving air quality.”

Additional information on the draft roadmap is available on the Colorado Energy Office website.