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 accepted public comments through August 12, 2024. For additional background information, explore a summary document of the technical working group process that helped inform the guidance.
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 division to create an operational greenhouse gas credit trading system by the end of 2024. The commission also directed the 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
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.
Past public opportunities
The division hosted a public meeting on the GEMM greenhouse gas credit trading guidance in 2024. The public meeting agenda included:
- Updates on the technical working group’s progress, concepts, and recommendations.
- Opportunity for public feedback.
- Answers to participants’ questions.
July 2024
A second meeting was originally scheduled for November 6, 2024. The meeting is canceled because there were no significant updates or changes made since the previous public meeting. Stakeholders and community members are encouraged to review the July meeting materials and email any questions or comments to climatechange@state.co.us.
The 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.
Helpful Resources
- GEMM 1 Rule web page.
- Air Quality Control Commission Regulation 27 (Greenhouse Gas Emissions and Energy Management for the Manufacturing Sector).
Key Legislation
- Climate Action Plan To Reduce Pollution (House Bill 19-1261) (GEMM 1 directive on pages 9-10).
- Colorado Environmental Justice Act (House Bill 21-1266) (GEMM 2 directive pages 34-37).
- Executive Order B 2021 01.
Contact us
Questions? Email climatechange@state.co.us.
Stay in touch: Sign-up for email updates from the Air Pollution Control Division for information on future air quality rulemakings and explore upcoming public participation opportunities.