Media Contact:
Justin Wasser, jwasser@earthworks.org
DENVER, CO — In a bold call for climate accountability, WildEarth Guardians and a coalition of public health, environmental justice, and climate advocacy groups have formally petitioned the Colorado Energy and Carbon Management Commission (ECMC) to start measuring the true cost of oil and gas production on our climate.
The petition demands that the ECMC adopt the “social cost of carbon”—a well-established metric that translates greenhouse gas emissions into real-world economic and health damages. Despite a growing body of state laws requiring climate considerations in fossil fuel permitting, the ECMC continues to approve new oil and gas projects—over 1,150 wells in 2024—without quantifying their climate impacts.
“Oil and gas production – just producing the stuff – is the third largest source of greenhouse gas emissions in the state. But the agency in charge is turning a blind eye to those emissions as they continue to permit thousands of new wells,” said Katherine Merlin, staff attorney with WildEarth Guardians. “Using the social cost of carbon is standard practice for other agencies in Colorado. It’s time the ECMC caught up. This is about protecting public health and safeguarding our future.”
The social cost of carbon (SCC) assigns a dollar value to the harm caused by each ton of carbon pollution, capturing impacts such as extreme weather, declining air quality, and public health costs. Colorado’s Department of Public Health and Environment and Public Utilities Commission already use the SCC in their decision-making. Yet ECMC—the agency responsible for regulating oil and gas development—has failed to do the same.
Under the proposed rule, companies seeking oil and gas permits would be required to calculate the SCC associated with their operations, including emissions from leaks, engines, flaring, truck traffic, and other sources. Much of this data is already collected; the petition simply calls for it to be reported in a more meaningful and consistent way. This would also strengthen the state’s
Cumulative Impacts Data Evaluation Repository, a system critics say is plagued by transparency and quality issues.
“This is about fairness and honesty,” said Rebecca Sobel, Campaign Manager at WildEarth Guardians. “The Commission uses the social cost of carbon to justify carbon capture plants in communities already overburdened by pollution. But when it comes to drilling? They turn a blind eye. That double standard must end.”
The petition emphasizes that under state laws SB 19-181 and HB 24-1346, the ECMC has a legal obligation to evaluate climate impacts quantitatively and to address those impacts to avoid, minimize, and mitigate harm to public health, safety, and welfare.
“This rule isn’t radical—it’s common sense,” said Sobel. “If the Commission continues permitting pollution without considering the cost, the public will keep paying the price.”
The petition will be considered by the five ECMC commissioners, and a public hearing will be held to determine whether the Commission will proceed with the requested rulemaking process. The notice of the public hearing will likely be made available on the ECMC website at ecmc.state.co.us within the next few weeks.
A coalition including WildEarth Guardians, 350 Colorado, Earthworks, Black Parents United Foundation, Physicians for Social Responsibility—Colorado, GreenLatinos, Sierra Club Colorado, Larimer Alliance for Health, Safety and the Environment, and Womxn from the Mountain submitted the petition.
The full petition is available here.
Additional Quotes from Petitioners:
“We already see the costs of climate change to individual Coloradans harmed by fire, floods and extreme heat, and the costs to our outdoor recreation and agriculture, but what we don’t know is how much that cost would be increased by each new well being proposed – the social cost of carbon would give us that information. ECMC has already decided to look at the social cost of carbon to assess the benefits of sequestration, so obviously it can and should be used to assess harm. We deserve to know.”
– Heidi Leathwood, Climate Policy Analyst, 350 Colorado
“It is hard to see how ECMC can claim to be fulfilling its mandate to protect Coloradans’ health and their environment without considering costs. The social cost of carbon is a straightforward and widely used measure of the costs of greenhouse gas emissions. We urge the ECMC to start using this measure when permitting new oil and gas facilities.”
– Ramesh Bhatt, Chair, Colorado Sierra Club Conservation Committee
“We need to use all the available resources at our disposal as Colorado grapples with the impacts of a climate crisis, like fires, floods, and extreme weather. The true cost of drilling oil and gas
wells includes impacts to health, quality of life, value to property and harms to farmers. It is time ECMC begins using the social cost of carbon as a tool to evaluate decisions on oil and gas in Colorado.”
– Andrew Forkes-Gudmundson, Senior Manager for State Policy, Earthworks
“As a sociologist, I tend to look at the big picture. The social cost of carbon tells a much truer story about what extractive industries really cost us. These companies use our roads and water—sometimes for free, or at steep discounts—even though they use way more than most. They also rely on an education system that keeps getting its funding cut, but still manages to supply them with skilled workers.
Then there’s the pollution. The environmental damage they cause leads to all kinds of health problems—cancer, deaths, chronic diseases, reproductive and breathing issues, you name it. These health issues don’t just affect individuals. Sometimes the bills are so high that people go bankrupt, and it all adds up to a huge burden on our healthcare system. Plus, when people are sick, kids can’t go to school and parents can’t work, which makes life even more unstable for families.
Looking at things from a systems perspective makes it a lot clearer: the true cost of carbon is much higher than it looks on paper.”
– Rachael Lehman, Environmental Justice Program Coordinator, Black and Brown Parents United Foundation
“The Larimer Alliance for Health, Safety, and the Environment calls for the inclusion of social costs of continued carbon emissions in cumulative impact analyses. As the Energy and Carbon Management Commission is still charged with protecting the health and environment of our communities, a serious evaluation of the impacts of ongoing oil and gas development is critical. Social costs are not just measured in the immediate health outcomes of frontline communities or the degradation of natural areas and watersheds. Everything from children’s success in schooling to the lowering of real estate values in those affected areas creates social impacts that need to be taken into consideration.”
– Ed Behanm, Member, The Larimer Alliance for Health, Safety and Environment
“The Western Slope is alarmingly and disproportionately warming compared to the rest of Colorado. It is time to stop ignoring the GHG emissions impacts in oil and gas permitting applications. Communities have been experiencing the damaging and costly impacts of GHG emissions on their health, environment and quality of life for too long. The social cost of carbon puts a quantifiable number to those impacts and it is a necessary and imperative step forward.” – Natasha Léger, Executive Director, Citizens for a Healthy Community
