By Katie Schneer for EDF and to the Colorado Air Quality Control Commission.
Climate change is a problem of cumulative emissions—a meaningful discussion of this is lacking in the GHG Roadmap, but should be a central consideration shaping the Commission’s regulatory agenda.
The precise quantity of emissions in any specific year is a much less relevant metric for climate impact, than the cumulative impact of GHG emissions adding up over time. Achieving reductions consistent with our climate goals means a consistent and persistent march downward over the upcoming decade.
Achieving the climate targets in 2025, 2030, and 2050 can have very different implications for climate change depending on when we make reductions, and how persistent these reductions are over time.
As an example, take any near-term action that’s proposed in the roadmap or that the Commission is considering. That policy, implemented in 2022 or 2023—or 2025 or 2027, is unlikely to have the same climate impact as the same policy implemented in 2020 or 2021. That’s because, in the meantime, GHG are being emitted and are building up in the atmosphere.
To minimize climate impacts, we need to minimize cumulative emissions, which means reducing as early as possible.
Colorado’s climate laws recognized the importance of this: laying out a clear timeline for proposed regulations, and underscoring the importance of having concrete rules and regulations in place swiftly.
Moreover, shaping the just and equitable transition that Colorado’s climate statute requires demands aggressive early action, and a policy framework that is capable of incentivizing even more action in the near-term than we may be able to currently envision. The longer we wait, the more disruptive these changes will be. One of our main takeaways from the Roadmap draft that has important implications for the Commission is that it’s lacking a concrete, near-term regulatory agenda that’s capable of meeting the climate targets swiftly.
Without that policy specificity regarding the regulatory tools that are capable of driving the needed reductions, there’s also no specificity on WHEN the reductions will occur.
The final roadmap should recognize the importance of near-term reductions, should look at reductions through a cumulative lens as is standard practice when evaluating GHG reductions in other jurisdictions given the nature of this pollutant, and then use that lens to inform specific, urgent actions to reduce emissions.