HomeMy WebLinkAboutMemo - Mail Packet - 11/24/2020 - Memorandum From Michelle Finchum And Adelle Mcdaniel Re: Letter To State Re: Draft Ghg Pollution Reduction Roadmap
1 Includes Interim Utilities Executive Director Theresa Connor; Interim Director of Community Services John
Stokes; Director of Planning, Development, and Transportation Caryn Champine; Chief Sustainability Officer
Jacqueline Kozak Thiel; and Environmental Services Director Lucinda Smith
Sustainability Services
222 Laporte Ave
Fort Collins, CO 80521
970-221-6600
fcgov.com
MEMORANDUM
Date: November 17, 2020
To: Mayor and City Council
Thru: Darin Atteberry, City Manager
CAP Executive Team1
From: Michelle Finchum, Interim Climate Program Manager
Adelle McDaniel, Interim Sr. Sustainability Specialist
Re: Letter to State re: Draft GHG Pollution Reduction Roadmap
Purpose:
To provide Council an update on the City’s comments regarding the State’s Draft Greenhouse Gas
(GHG) Pollution Reduction Roadmap, which can be found at the link below.
https://drive.google.com/file/d/1lok5it22y_Eh0Fjp8ioT_BbPMC7zUJpZ/view
Background
The Roadmap was developed to meet the requirements of Colorado Revised Statute § 24-20-111, which
calls for development of a state climate plan setting forth a strategy to address climate change and
reduce greenhouse gas emissions while taking into account previous state actions and efforts.
The Draft GHG Pollution Reduction Roadmap represents a step forward for climate action and pollution
reduction planning at the state level, advancing Colorado’s policy and programmatic vision for pursuing
timely, enduring and equitable strategies. Ultimately, the Roadmap is intended to identify administrative,
regulatory, legislative, procurement, incentive-based, and other measures to reduce emissions in
different sectors of the state’s economy to achieve the 2025 and 2030 reduction goals in a cost-effective
and equitable way and to ensure that Colorado is on a path to meeting the 2050 GHG goals.
City Support
The City of Fort Collins submitted a letter of support for the State’s goals and efforts to reduce
greenhouse gas emissions that highlighted the following:
Alignment, support, and advocacy for an equity-centered approach to climate action.
Thoughts from our history of climate action and leadership regarding which strategies to include
in the Roadmap and how to implement them.
Encouragement to define commitments and specific, enforceable strategies to achieve GHG
reduction goals.
Dedication to partnership with the State to achieve these important goals.
Attachment: Letter to State re GHG Pollution Reduction Roadmap
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Sustainability Services
222 Laporte Ave
Fort Collins, CO 80521
970-221-6600
fcgov.com
To: Dan Gibbs, Executive Director, Colorado Department of Natural Resources
Kate Greenberg, Commissioner, Colorado Department of Agriculture
Shoshona Lew, Executive Director, Colorado Department of Transportation
Jill Ryan, Executive Director, Colorado Department of Public Health and Environment
Will Toor, Executive Director, Colorado Energy Office
From: Jacqueline Kozak-Thiel, Chief Sustainability Officer, City of Fort Collins
Date: November 10, 2020
Re: Letter of Support for State Greenhouse Gas Pollution Reduction Roadmap
The City of Fort Collins (the City) is writing to express our support for the State’s goals and efforts to
reduce greenhouse gas (GHG) emissions through the development of the GHG Pollution Reduction
Roadmap. In Fort Collins this year, the impacts of the Cameron Peak Fire have made it increasingly
evident that sweeping, timely action is needed to limit the worst effects of climate change, particularly
for frontline communities. We applaud the Governor's strong goals for emissions reductions and
advocate for strengthening commitments to clear, enforceable strategies, policies, and timelines on how
to achieve these goals while determining how to lead with equity in both process and outcome.
The City recognizes the importance and urgency of reducing greenhouse gas pollution in Colorado,
nationally and internationally. The Roadmap is an important step that provides a general sense of how
to achieve the carbon pollution reductions needed. We are aligned with these goals, and we believe that
our lessons learned from the past 20 years of climate action, as well as our current experience with a
joint update to our Climate Action Plan, Energy Policy, and Road to Zero Waste, can provide the State
helpful insights as it undertakes this critical work. We are highly interested in and committed to
strengthening partnerships between the State and local governments in this work.
Equity:
We celebrate the State’s inclusion of an equity statement in the Roadmap, as the City is also working to
acknowledge the role of government in creating and perpetuating systems of oppression and racism,
and is committed to dismantling those same systems. However, we are concerned that while the
Roadmap discusses equity, it does not specify how equitable processes and outcomes will be ensured
through this effort.
Equity in process. At the City, we consider equity in process to mean that everyone has meaningful
opportunities to engage and provide input in City processes. By ensuring that everyone has a seat at the
table and is heard, equitable outcomes are more possible. Some ways we have begun this work are to
build strong partnerships with community leaders; to undertake a stakeholder mapping exercise to
identify those with limited power in current dominant systems but who are highly impacted by decisions
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made; and to identify and work to mitigate barriers to participation, particularly those in the way of
historically underrepresented groups.
Equity in outcome. We consider equity in outcome to mean that everyone benefits from the result of
the plan or policy; for example, everyone benefitting from a carbon neutral Colorado would be equity in
outcome. One important step toward this goal would be to identify who in our state is currently most
impacted by climate change and to choose appropriate strategies to pursue based on their input and
benefit.
Additionally, our philosophy in updating the City’s Climate Action Plan, Energy Policy, and Road to Zero
Waste is that focusing on and prioritizing first what community members need to thrive and then
aligning action to reduce emissions, save energy, and eliminate waste will lead to a more feasible and
more equitable plan.
We encourage the State to be transparent about what its commitment is in this space and to keep
working towards equity in both process and outcome as the Roadmap is finalized and implemented.
Built Environment:
We strongly support the inclusion of commercial building benchmarking and performance standards in
the Roadmap. The City began a similar program, the Building Energy and Water Scoring ordinance, in
2018, requiring the phased reporting of all commercial buildings over 5,000 square feet by 2022. For
residential buildings, the City also offers the Epic Homes program for energy efficiency upgrades with
comprehensive energy assessments, rebates, an indoor environmental quality study and attractive
financing options, of which the Colorado Energy Office has been an important partner. Epic Homes also
includes a certificate with the pre- and post-upgrade Department of Energy’s Home Energy Score.
Programs like this are expected to lower the cost of utility bills for businesses and residents and create
opportunities for valuing efficiency in the marketplace, in addition to progressing climate action. We
anticipate opportunities to align data and reporting tools between the three Colorado communities with
existing benchmarking programs, including Fort Collins, with potential state requirements.
We strongly support the targets for building efficiency shell improvements that are included in the HB-
1261 Scenario. We encourage expansion on the strategies and tactics necessary to achieve these results
in the Roadmap. While the noted modernization of gas efficiency programs is helpful, the scale of the
proposed outcome of 100% improvements to new and existing buildings cannot be accomplished
through this mechanism.
Net Zero Codes Roadmap for Jurisdictions. Since Colorado is a home-rule state, building codes are
determined by jurisdictions. However, some jurisdictions use outdated or minimal codes energy
efficiency building codes. Including a roadmap and outreach materials aimed at building departments
for net zero new construction by 2030, 2035, or 2040 would help create alignment and action across the
state. The State could set a policy to adopt the latest, most efficient energy codes, which would help
contractors who service multiple jurisdictions. Tools such as ordinance and/or code language based on
the International Code Council, energy code trainings, and outreach to the local building community (all
funded by the Colorado Energy Office) would benefit every community.
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Transportation:
Electrification of Transportation. Like the State, the City also has ambitious goals for an electric vehicle
transition. We encourage the State to consider an earlier target year for electrifying transportation and
having the appropriate infrastructure in place, as transportation is and will increasingly be a large sector
of Colorado’s emissions. The joint movement of renewable electricity and transportation electrification
by 2040 instead of 2050 would be transformative for our State and our residents. Additionally, State-
level planning and activity is critical for local governments like Fort Collins to make meaningful progress,
as many residents require reliable, convenient access to charging infrastructure beyond our city
boundaries.
Alternative Transportation. Electrification is one important tool to reduce emissions from
transportation, in a suite that includes transportation demand management, community design, and
alternate modes, as noted in the Roadmap. We strongly support increased evaluation and consideration
of these strategies in addition to EVs, as we have significant experience in this area and have seen the
positive impacts for our community. For example, the City’s Transportation Master Plan describes our
vision of a multi-modal transportation system that reduces the focus on and necessity of single-
occupancy vehicles (SOVs). While reducing emissions, moving away from dependence on SOVs also
reduces costs and increases wellbeing for community members. Direction from the state level on these
strategies could also help close the gap on regional non-SOV transportation.
Oil and Gas:
The Roadmap supports implementation of Senate Bill 181 related to oil and gas emissions, through
updates in rulemakings through the Colorado Air Pollution Control Commission (APCC) and the Colorado
Oil and Gas Conservation Commission (COGCC). Per the City’s Legislative Policy Agenda, the City
supports air pollutant reductions, and is actively engaged in these rulemaking discussions. The City is
also looking at increased local controls, in consideration of new local authority granted through SB-181.
Once these rulemakings are complete, it will be important through the GHG Framework to ensure that
O&G emissions are well characterized and that reductions proposed are sufficient to meet GHG goals.
Waste:
Though waste is responsible for a small portion of the state’s overall GHG emissions, reducing waste can
reduce upstream, supply chain emissions, the magnitude of which is perhaps best illustrated by a
consumption-based inventory. Additionally, diverting material from the landfill through composting
programs directly contributes to reducing landfill emissions, and reducing waste going to the landfill in
general has significant environmental benefits. In the City, we are considering climate action and waste
reduction together, as they are interrelated and both important in our community. Having additional
consideration and strategy identification for waste reduction in the Roadmap would provide benefit
towards reducing emissions and supporting communities in taking stronger action.
Inventory, Forecast, and Modeling:
From our history of climate action work, we know intimately the challenges of GHG inventories,
forecasts, and models and can also speak to their necessity. Principally, we have learned the following:
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• Alignment between creation of a recent inventory and forecast and a planning process is helpful
to ascertain areas of focus and have an accurate starting point for strategy development,
• Modeling each strategy or policy’s impact towards goals is crucial to prioritize and determine
appropriate action, as well as to reflect on if progress occurs where expected,
• Identifying and assessing impacts across emissions, costs, individual health, community climate
resilience, and social wellbeing are important for prioritizing and making progress on strategies,
as well as communicating the reasons for undertaking such strategies,
• These tools can point to necessary changes to current strategies, highlighting the strong benefits
of a living, amendable document that can afford agility in a time when this is needed to achieve
aggressive goals.
Thank you for providing us the opportunity to be involved in the Roadmap and to help propel us
towards a healthier, safer, and more equitable Colorado. The City of Fort Collins would like to extend its
appreciation and support of the State’s work and to urge definition of commitments towards specific
policies and timelines that will hold all of us accountable for the wellbeing of residents of Colorado and
the world. We look forward to partnering with you to achieve our shared goals. Please reach out to me
directly with any questions or any opportunities for us to further our involvement and support.
Sincerely,
Jacqueline Kozak-Thiel
Chief Sustainability Officer
City of Fort Collins, CO
DocuSign Envelope ID: 0BC94283-F429-4612-B3BD-3F074C25C30B