Thank you for the opportunity to submit comments on the Colorado Air Pollution Control Division (the Division)’s 2021 Greenhouse Gas Inventory Report (the Inventory). We appreciate that the Division has moved to annual revisions of the Inventory (as opposed to the previous 5-year intervals), which will provide for more detailed and regular tracking of emissions trends over time.
Earthworks is a national nonprofit organization committed to protecting communities and the environment from the impacts of mining and energy development while seeking sustainable solutions. For nearly 30 years, we have fulfilled our mission by working with communities and grassroots groups to reform government policies, improve corporate practices, influence investment decisions, and encourage responsible materials sourcing and consumption.
Earthworks’ comments are focused on the section of the Inventory related to the oil and gas sector and the imperative of making the Inventory more comprehensive and publicly available. The following recommendations will allow CDPHE to more accurately track the greenhouse gas (GHG) emissions from oil and natural gas production so that state agencies, researchers, and the public can properly assess Colorado’s progress towards its emission reduction goals. Importantly, the state will need to adjust emission reduction goals and regulations if CDPHE and other agencies find that existing measures are falling short.
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