By: Laurie Anderson, Colorado Field Organizer, Moms Clean Air Force
Date: October 16, 2023
About: Greenhouse Gas Intensity Verification Protocol
To: Colorado Air Pollution Control Division (APCD)
My name is Laurie Anderson. I am here today speaking as an impacted resident and also a Colorado field organizer for Moms Clean Air Force—a community of 1.5 million moms and dads united against air pollution—including the urgent crisis of our changing climate—to protect our children’s health.
I am here again speaking tonight because this rule and the guiding protocols are crucial, and we need to get this right. As Coloradans, we are proud to be leading the way on solutions to reduce methane pollution. We have strong support in our state for achieving our statutorily required greenhouse gas reductions, but most families are going about their busy lives without a keen eye on the real work that needs to be done and is being done. We recognize that there is highly technical work underway that will be Colorado’s guiding light to hitting those goals, and we are truly grateful for that work. With strong protocols, Colorado will continue to be a national leader on what is truly achievable and a role model for others to follow.
People living near these industrial operations want to know how much pollution is being emitted in their communities, near their homes and where their children are playing outside. The state has made numerous commitments to directly impacted (DI) communities to reduce the impacts of pollution in their communities. To do this, we must have accurate data that is collected by actively measuring and accounting for that pollution.
The final protocol must contain enough information and guidance to ensure that operators are able to implement methane measurement programs that capture accurate and useful emissions data. Preapproved measurement programs must be fully vetted by the division for scientific validity. Methane pollution is incredibly harmful and yet, up until the passing of the Verification Rule, has never been routinely tracked or measured. With a scientifically robust protocol and accurate measurement data, this past omission can finally be rectified, and public trust will be regained.
The protocol must be clear on how the division will evaluate whether the program deployed, whether preapproved or not, was appropriate for the site.
Auditing is also critical to ensuring accurate measurements and building public trust. The protocol must provide clarity on how the division will maintain authority and oversight of the auditing process, including how it will determine the independence and credibility of third-party auditors.
Ensuring the annual methane emissions default factor is robust is also critical. If the default factor approach isn’t sound, this becomes a major loophole for operators and may risk the effectiveness of the entire Verification Rule.
Trust will be built over time as frontline communities, and those most impacted, see the accurate and precise results of third-party monitoring. Accountability and transparency are absolutely necessary to build that trust.
The sooner the requirements take effect, the sooner the benefits, but it needs to be done right. We look forward to strong reporting and auditing requirements that provide the necessary feedback so we know the rule is effective, and if not, we can quickly correct course. Mostly, we look forward to seeing the overall GHG emissions declining.