What is credit trading?
Greenhouse gas credit trading in Colorado enables certain regulated companies to earn credits for reducing their greenhouse gas emissions below an established limit. Companies can then trade (buy or sell) these credits with other companies in a regulated market.
Colorado law allows specific economic sectors to use emissions credit trading to regulate greenhouse gases and achieve emissions reductions cost-effectively, often sooner and potentially more than companies could otherwise accomplish. Colorado designs and implements its emissions credit trading programs in alignment with state law and specific rules adopted by the Air Quality Control Commission. These programs aim to help address climate change, support the state’s economy, and protect local communities.
Credit trading helps address climate change by:
- Encouraging greenhouse gas emissions reductions at the lowest cost.
- Enabling the state to require and achieve earlier and potentially greater reductions in cumulative greenhouse gas emissions than companies could otherwise accomplish.
Credit trading is a tool that is used in certain contexts to help Colorado achieve its ambitious climate change goals outlined in the state’s Greenhouse Gas Pollution Reduction Roadmaps.
A few key terms used in credit trading programs include:
Carbon dioxide equivalent, or CO2e: A standardized unit of measurement that compares the global warming potential of different greenhouse gases. CO2e converts other greenhouse gases, such as methane and nitrous oxide, to an equivalent amount of carbon dioxide based on their respective global warming potentials over a specific time period, usually 100 years. This allows scientists and regulators to analyze greenhouse gas impacts through a standard unit.
Credit: A credit represents a reduction of one metric ton of CO2e beyond the emissions limit that a company is required to achieve.
- Note: In Colorado, all credits must represent reductions that have already happened. The state reviews the accuracy of reported data before issuing credits to a company that they can buy, sell, or retire early for compliance in a trading program. Credits differ from allowances and offsets, which are defined below.
Allowances: An allowance represents the right of a facility to emit a certain amount of greenhouse gases.
- Note: Colorado does not issue allowances. Allowances are different from credits. Allowances are used in the cap-and-trade programs of some other jurisdictions.
Offsets: An offset allows a company to invest in offsite greenhouse gas removal projects. The company can then count the emissions removed from the atmosphere through these projects towards its own emissions limit. Offsets projects can take place in other states or even other countries.
- Note: Colorado does not allow offsets in its credit trading programs. Not using offsets in Colorado helps ensure greenhouse gas reductions occur within Colorado and protect the air quality of Colorado’s communities.
Bank: A company can bank, or or hold on to, credits earned through onsite reductions in Colorado.
- Note: In Colorado, companies can bank credits for up to three years after those credits were first generated. At the end of the banking period, credits expire and may go toward the company’s individual emissions limit or remain unused. Unused credits, meaning credits not counted towards a company’s emissions limit, essentially represent more emissions reductions beyond what a company was required to achieve.
Carbon leakage: This term refers to when a company moves its operations out of the state to jurisdictions with less stringent environmental regulations. Carbon leakage can worsen overall climate impacts, cause job loss, and possibly increase the prices of products for consumers. Colorado aims to prevent carbon leakage through its policies and regulations, while still ensuring ambitious greenhouse gas reductions in the state and protecting clean air in local communities.
Real: Real greenhouse gas emissions reductions are those that:
- Result from an action or set of actions that can be shown or proven; and
- Are quantified using appropriate, accurate, and conservative methodologies.
Additional: Greenhouse gas emissions reductions that go beyond any reductions required by law, regulation, or legally binding mandate. In other words, additional reductions are more than required. This is also known as additionality.
Quantifiable: Greenhouse gas emissions reductions must be able to be reliably and accurately measured using numbers.
Permanent: The priority for permanence is to ensure that any credits awarded represent greenhouse gas emissions reductions that endure over time. Greenhouse gas emissions reductions either:
- Must not be reversible, meaning that they cannot be released back into the atmosphere through natural processes or human activities; or
- There must be mechanisms to replace any reversed emissions reductions.
Verifiable: The division can objectively certify that any reported emission reductions at a regulated source tied to greenhouse gas credits are well documented and transparent. This means that the Division can verify the emissions reductions are real and occurred for the relevant compliance year.
Enforceable: All participants and credits are subject to and must comply with the legal requirements of the credit trading program rules with oversight by the entity administering the program, in this case, the State of Colorado.
There are two main types of credit trading programs:
- Baseline-and-credit.
- Cap-and-trade.
Baseline-and-credit
Colorado follows a baseline-and-credit approach. This approach provides credits to companies only if they lower their onsite emissions below their specific emissions limit established in statute or regulation. In other words, companies can only earn credits by doing more than required by law.
Companies can then sell credits earned to other companies in the sector. The companies buying credits are typically those that cannot fully achieve their emissions limits through onsite emissions reduction measures.
By using credit trading programs within specific sectors instead of across the entire economy, Colorado ensures that greenhouse gas reductions happen within each regulated sector. This targeted approach means communities affected by emissions from these sectors will see more locally focused efforts to reduce pollution, leading to better air quality.
Cap-and-trade
Colorado does not follow a cap-and-trade approach. This approach allocates or auctions a certain amount of allowances to companies equal to the number of metric tons of carbon dioxide equivalent the companies are allowed to emit. If a company’s emissions exceed its allowances, it must purchase additional allowances equal to its excess emissions. Companies must then surrender allowances equal to their total emissions during the compliance period. Some markets that use this approach recognize offsets as a compliance mechanism for regulated entities.
How does credit trading work in Colorado?
Companies subject to Air Quality Control Commission regulations that include a credit trading option contribute to Colorado’s climate goals. By allowing credit trading, Colorado can set more ambitious emissions reduction targets for an entire sector.
- Companies that can reduce emissions at a low cost are encouraged to do more than they are required to under state law. This is because they can generate and then sell credits to other companies that cannot reduce their own emissions as quickly or cost-effectively.
- Credit-purchasing companies can buy credits to help meet their greenhouse gas emissions reduction requirements. These companies still contribute to Colorado’s climate goals through the additional work of credit-generating companies.
Credit trading makes it possible to set more ambitious sector targets and reduce overall economic impact. Colorado’s credit trading system provides companies with flexibility in meeting their emissions limits to help keep Colorado businesses running and protect jobs.
In Colorado, companies can only earn credits if they lower their onsite emissions below the specific emissions limit established in statute or regulation. In other words, companies in the state can only earn credits by doing more to reduce their emissions than what is required by law.
In Colorado, companies can only trade credits with other Colorado companies regulated within the same sector per either the Air Quality Control Commission Regulation Number 22 or Regulation Number 27. This approach ensures that reductions in greenhouse gas emissions and other air pollutants happen locally in Colorado and benefit Colorado communities.
Colorado is also committed to protecting disproportionately impacted communities and local air quality. The state continues to explore ways to pair credit trading and associated greenhouse gas emissions reductions with other air pollution reductions.
By using credit trading programs within specific sectors instead of across the entire economy, Colorado ensures that greenhouse gas reductions happen within each regulated sector as directed by relevant state law. This targeted approach means communities affected by emissions from these sectors will see more locally focused efforts to reduce pollution, leading to better air quality in their communities, and encourage earlier and deeper emissions reductions.
Currently, credit trading for greenhouse gas emissions in Colorado involves two key sectors: 1) natural gas distribution and 2) industrial and manufacturing. Only certain Colorado projects, utilities, and facilities may participate in these Colorado credit trading markets per the relevant state regulations.
Natural gas distribution
Gas distribution utilities must reduce greenhouse gas emissions by at least 4% by 2025 and 22% by 2030, compared to a 2015 baseline. Subject to approval of their clean heat plans, gas distribution utilities can buy credits to achieve up to 1% of the 4% required by 2025, and 5% of the 22% required by 2030. A 2021 law requires Colorado to design and implement a credit trading program for this sector.
Industrial and manufacturing
Colorado must reduce its greenhouse gas emissions to meet its statewide emission reduction targets. The industrial and manufacturing sector must reduce greenhouse gas emissions by at least 20% by 2030, relative to a 2015 baseline.
Aligned with Colorado’s statewide targets, large energy-intensive, trade-exposed facilities must reduce greenhouse gas emissions by 5% more than their audited Greenhouse Gas Best Available Emissions Control Technologies and Energy Best Management Practices. Aligned with Colorado’s industrial and manufacturing sector target, other large industrial facilities must reduce greenhouse gas emissions by at least 20% by 2030, relative to a 2015 baseline. This goal is one of the country’s most ambitious industrial sector greenhouse gas emissions reduction targets.
A 2019 law and a 2021 law — the Colorado Environmental Justice Act — allow Colorado to design and implement a credit trading program to help achieve these reduction targets cost-effectively.
Colorado further refines its existing credit trading programs through laws and regulations. The state applies lessons learned from its credit trading programs and those of other jurisdictions.
Credit trading programs in Colorado
The CDPHE Air Pollution Control Division manages the Greenhouse Gas Crediting and Tracking System. In 2023, the division began operating the credit trading system for gas distribution utilities. The division began operating the credit trading system for eligible industrial and manufacturing sector companies in late 2024.
Public information on market participants registered in the system is available via Colorado’s Public Access Viewer.
Market participants can find the link to the system and detailed information on how to use the system on the Greenhouse Gas Crediting and Tracking System web page.
Recovered methane
The recovered methane branch of the Greenhouse Gas Crediting and Tracking System began operating in 2023. This branch allows eligible recovered methane projects to generate and sell credits to gas distribution utilities operating in Colorado. The utilities can use the credits toward a portion of their Clean Heat Plan obligations. Per the Colorado Air Quality Control Commission Regulation No. 22, these credits can only be sold to gas distribution utilities with Clean Heat Plan requirements outlined in Senate Bill 21-264. The credits must be generated pursuant to the relevant protocols outlined in Section I.C. of the recovered methane rule.
All projects must be located in Colorado. With these projects, this recovered methane is supplied to customers for heating purposes. Without these projects, methane would have escaped into the atmosphere. These projects therefore provide a net benefit for the climate and Colorado communities by replacing geological gas otherwise supplied by gas distribution utilities. By including these eligible projects, the division is also able to encourage greenhouse gas emissions reductions in different sectors, such as Colorado’s agriculture sector, which may pursue voluntary projects to reduce methane emissions.
For more information on Colorado’s recovered methane rule see the Recovered Methane Rule web page.
Industrial and manufacturing
The industrial and manufacturing branch of the Greenhouse Gas Crediting and Tracking System became operational in November 2024. This branch is for facilities covered by the Greenhouse Gas Emissions and Energy Management for Manufacturing Phase 1 and Phase 2 rules. The rules are known as GEMM 1 and GEMM 2.
Guidance for: EITE (GEMM 1) and GEMM 2 Greenhouse Gas Credit Trading
Because GEMM 1 and GEMM 2 facilities have different emissions reduction requirements, the Air Quality Control Commission directed the division to engage in a stakeholder process or technical working group 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 hosted a public meeting on this GEMM greenhouse gas credit trading guidance in July 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
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.
In 2024, the division proposed new measures to reduce greenhouse gas emissions from the midstream oil and gas segment of the industrial and manufacturing sector. The proposal includes a credit trading program which may expand the existing industrial and manufacturing branch of Colorado’s Greenhouse Gas Crediting and Tracking System.
Greenhouse Gas Crediting and Tracking System
Visit the Greenhouse Gas Crediting and Tracking System web page to access the system and associated resources.
Public information on the Greenhouse Gas Crediting and Tracking System
The following search criteria is available:
- To find the unique identification number of a registered entity, select “CDPHERM Environmental ID Form Query” in the dropdown.
- To view additional information on registered entities, select “CDPHECATS AIR GHG Credit Trading Entity Search” in the dropdown.
- Type the company name into the appropriate search field to see information on a specific company. Type an asterisk into the company name search field to see all entries.
Contact us
Questions? Email climatechange@state.co.us with "GHG credit trading" in the subject line.
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