Colorado's regulated utilities, beginning in 2021, will need to submit a clean-energy plan with their electric resource plan filings to show their progress in reducing greenhouse gas emissions below statutorily required levels.
The new requirement is the result of SB 236, which in 2019 directed the Air Pollution Control Division of the Colorado Department of Public Health and Environment to participate in the ERP proceedings at the Colorado Public Utilities Commission in order to verify that the plans result in an 80-percent reduction in carbon dioxide emissions from the utility by 2030, relative to 2005 levels. The state's Air Quality Control Commission at its monthly meeting Oct. 22, held remotely, discussed the draft CEP guidance.
"With each CEP that's filed, we believe we'll get better clarity on emissions because these filings require the utilities to project their load needs and their resources through 2030," Josh Korth, a lead technical analyst with the CDPHE, said.
Utilities will input data on their generation assets, projected retail sales, projected wholesale contract sales, and projected emissions releases from transmission and distribution systems. The CEP also prevents "double counting" of emissions from utilities that supply electricity through a wholesale contract to other utilities that then sell it as retail by allowing utilities to remove emissions associated with those contracts.
Tri-State Generation and Transmission Association, a 43-member wholesale cooperative that operates in four states and has 17 Colorado members, in Oct. 16 comments filed to the AQCC expressed concern that this would give "retail utilities . . . unilateral ability to adjust a wholesale utility's baseline."
Xcel Energy-Colorado in Oct. 16 comments to the AQCC suggested the commission identify a "comprehensive equitable attribution policy" to track emissions reductions in one sector that might cause higher emissions in another—for example, net economywide emissions reductions due to widespread electrification, which could increase emissions from the electricity sector.
The commission also heard from two experts regarding the link between COVID-19 and air pollution.
Anthony Gerber and James Crooks from Denver research hospital National Jewish Health in their presentation to the commission reviewed multiple studies showing that short- and long-term exposure to air pollution impacts susceptibility to COVID-19, the disease caused by the novel coronavirus. They said the link is to be expected, as there is a well-established link between pollution and other chronic illnesses, such as chronic respiratory disease.
Crooks discussed three articles published since the start of the pandemic which indicate that as long-term air-pollution exposure increases, so does mortality from COVID-19. Emory University researchers on Sept. 21 published a study finding that nearly 10 percent of COVID-19 deaths in the United States, around 14,000, could have been avoided if there had been a reduction in air pollution. Separate studies also found that short-term exposure to pollution increased COVID-19 mortality.
While researchers need to examine the issue further using alternative study designs, "the studies we have so far are about the best we can reasonably hope for on a short notice," Crook said.
Many questions remain, such as whether air pollution could also increase viral spread. It is hypothesized that the virus might "hitch a ride" on airborne pollution particles, using them to travel farther distances or remain in the air for a longer period. Scientists do not yet have a good understanding of whether wildfire smoke increases susceptibility to the coronavirus. "But it probably can't be that big," Crooks said, pointing to decreases in COVID-19 rates in California during the September weeks when wildfire smoke was at its highest concentration.
Also at the meeting, Gov. Jared Polis commended the commission's work and emphasized its importance to achieving the state's GHG emissions-reduction goals.
"We in our nation have no shortage of challenges to confront, whether it's COVID-19, whether it's the wildfires that are raging across Grand County and other parts of Colorado, but despite these challenges we need to make sure that we never take our eye from the ball of the climate crisis," he said. "Our commitment to renewables, to climate action, to clean air, will not waver."