DENVER — On Monday, 350 Colorado and the Colorado Sierra Club along with the Colorado Coalition for a Livable Climate, EcoCycle, Clean Energy Action, Resilient Denver and the San Luis Valley Ecosystem Council submitted a joint comment to Colorado’s Air Pollution Control Division (APCD) on the 2021 Draft Greenhouse Gas Emissions Inventory. The joint comment applauds the APCD for its work in creating the 2021 Draft Greenhouse Gas Emissions Inventory, while highlighting several critical opportunities to strengthen this foundational climate document.

“The Draft 2021 GHG Inventory is a strong start, but misses several critical opportunities to provide policymakers and the general public with more information,” said 350 Colorado Climate Policy Analyst Duncan Gilchrist.

Organizations and technical experts from across the state echoed a concern of the APCD itself, pointing out that the Inventory Report relies heavily on estimates in place of concrete, Colorado-specific data.

“Whether the issues are large, such as the stunning uncertainties in leakage from natural gas extraction and distribution, or local such as methane emissions from municipal waste, it is critical for Colorado to capture data on every potential carbon source, and every potential carbon sink. And it is our job as citizens to help Colorado do that well,” said President of Heron Scientific Seth Miller who helped lead the technical analysis of the draft inventory.

Further, signatories of the joint comment submitted to APCD emphasized that the Inventory Report does not accurately reflect the full climate footprint of Colorado’s oil and gas industry. The draft inventory excludes emissions data from our state’s exported, combusted oil and gas.

 “As we work to cut carbon pollution in Colorado, we must recognize the impact that fossil fuels extracted here but transported and burned outside Colorado have on the climate. The state’s greenhouse gas inventory should reflect those emissions so we can meaningfully take action on climate,” said Sierra Club of Colorado Deputy Director Emily Gedeon.

Further signatories requested an explanation as to why the current Inventory Report assumes that oil and gas emissions will dramatically decrease over the next decade, while simultaneously assuming production will dramatically increase.

The joint comment also raises concern that in place of a ‘business as usual’ emissions scenario, the Draft Inventory simply uses Colorado’s aspirational emissions reduction targets as future projected emissions. Given that our state has yet to adopt policies that would achieve emissions cuts at necessary speed and scale, presenting aspirational emissions reductions as our current trajectory gives policymakers and the public at large the impressions that we are on track to meet our targets. Multiple ‘emissions gap’ analyses by Colorado climate groups indicate that this is not the case.

Groups expressed appreciation to Colorado’s Air Pollution Control Division for their important work on this front and hope that the final draft will incorporate the recommendations that were made.

If you are interested in reviewing the 2021 Greenhouse Gas Inventory you can do so here. If you are interested in reviewing the Joint Comment, you can do so here.

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Quote deck:

“As we highlight in this report, national surveys show that 5% of oil and gas extraction operations release 50% of the sector’s methane emissions. Colorado needs to do more than simply estimate what ’typical’ oil and gas operators emit; we must monitor every site if we are to establish an accurate accounting of our state’s contribution to climate change.”

• Seth Miller, President, Heron Scientific

“As Jews and Christians celebrate Passover and Easter, we recount sacred stories of loss, resistance to a life-destroying systems, and eventual freedom for human communities and Creation. Improving Colorado’s GHG Inventory procedures is challenging. Yet, accurately counting the loss—all the harmful GHG emitted—empowers Colorado to transition to more life-giving, sustainable ways of living that frees future generations from the worst ravages of climate change.”

• Rev. Amy Petré Hill, Founder, MHI Ministries