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Greenhouse gas credit trading for GEMM

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On this page: Technical working group | Past public participation opportunities | Upcoming public meetings | Helpful Resources

Please note: If you would like to request a Spanish interpretation, please email cdphe_apcd_outreach@state.co.us.

Tenga en cuenta: Si desea solicitar interpretación al español, envíe un mensaje por correo electrónico a cdphe_apcd_outreach@state.co.us.

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Update: Draft GEMM greenhouse gas credit trading guidance open for public comment through August 12, 2024.

The Air Pollution Control Division released the GEMM greenhouse gas credit trading guidance draft on July 12, 2024 and will accept public comments through August 12, 2024. For additional background information, a summary document of the technical working group process that helped inform the guidance is available.

Send written comments on the greenhouse gas credit trading system to climatechange@state.co.us. Include “GEMM Credit Trading public comment” in the subject line. Explore tips for making effective public comments.

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Technical working group

The Colorado Air Quality Control Commission adopted the Greenhouse Gas Emissions and Energy Management for Manufacturers Phase 2 rule (GEMM 2) in October 2023. The commission directed the Air Pollution Control Division to create an operational greenhouse gas credit trading system by the end of 2024. The commission also directed the Air Pollution Control Division to engage in a stakeholder process or technical working group.

The division created and convened a technical working group in 2024 to focus on:

  • Reconciling how greenhouse gas credits generated by GEMM 1 facilities might interact with greenhouse gas credits generated by GEMM 2 facilities. 
  • Potential pathways and feasibility for trading between GEMM 1 and GEMM 2 facilities.
  • Identifying appropriate protections for disproportionately impacted communities.

The division intends to publish final guidance by the end of 2024.

The division is grateful for the technical working group’s diverse expertise in carbon accounting and trading, industrial feasibility, and environmental justice. Their expertise helped inform balanced and comprehensive recommendations for the greenhouse gas credit trading system guidance. All technical working group members graciously volunteered their time.

  • Dallas Burtraw, Resources for the Future
  • Stefano Declara, International Carbon Action Partnership
  • Carolyn Fischer, World Bank Development Economics Research Group; Resources for the Future; and Vrije Universiteit Amsterdam
  • Brent Fitzgerald, ACR at Winrock International
  • Trevor Laroche-Theune, International Carbon Action Partnership
  • Clayton Munnings, Elevate Climate, Carbon Quality Lab, PhD student with UC Berkeley
  • Nancy Seidman, Regulatory Assistance Project 
  • Wil Mannes, Colorado Energy Office 
  • Rosemarie Russo, Commerce City and Denver University
  • Brian Bunte, Anthesis Group
  • Adam Devoe, DeVoe Law, LLC and GEMM 1 Facility Counsel (GCC/Evraz)
  • Ana Gutierrez, Womble Bond Dickinson and GEMM 2 Facility Counsel (Leprino)
  • Emily Mehlhop, Anthesis Group
  • Peter Omasta, GCC 
  • Kori Andrews, Cemex 
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Past public participation opportunities

The technical working group’s meetings were open to the public, and recordings are posted below. The meetings primarily focused on technical discussions among the working group members.

Recordings of previous meetings

Written public comments

Send written comments on the greenhouse gas credit trading system to climatechange@state.co.us. Please include “GEMM Credit Trading Public Comment” in the subject line. 

Explore tips for making effective public comments.

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Upcoming public meetings

The division will host two public meetings on the GEMM greenhouse gas credit trading guidance in 2024. During these sessions the division will:

  • Share the technical working group’s progress, concepts, and recommendations.
  • Provide opportunity for public feedback.
  • Answer questions. 

Register below to join each meeting: 

The Air Pollution Control Division also shares upcoming public participation opportunities on its website. The division will seek public input before it proposes any future rules to the commission. 

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Helpful Resources

Key Legislation