The Governor recently submitted the following letter to the RAQC which is the lead planning agency for the DMNFR.
It important to recognize that this letter has to be taken in the context of election year politics.
- “Should the state demonstrate that the control measures included in the SIP will result in the state achieving attainment without RFG, that RFG does not provide a benefit to Coloradans that outweighs the costs, or challenging economic scenarios exist at the time the use of RFGwould be put into effect by the EPA, the state will utilize available tools to avoid ineffective and costly measures. Further, the state also reserves the right to request that an assessment of attainment be conducted in the event that the state is in attainment and the RFG requirement does not apply. In the interim, the state of Colorado strives to exhaust other meaningful strategies to reduce ozone pollution in an attempt to avoid the federal requirement to use RFG.The final state implementation plan submittal to EPA should make reference to the following” (taken as an excerpt from the letter)
Of Note:
- Governor Polis made the decision, by himself, to hold Colorado citizens accountable for emissions that are not caused in Colorado. It is fully within our federal delegations power to protect Colorado citizens should they chose to act.
- If is a complete fallacy for the RAQC to assume that RFG use would be limited to the non-attainment area.
- CWPMA has received no assurances from any supplier that they have the capability and inventory to supply the Colorado Market during the summer months with RFG. (assuming Suncor would be forced to through the Permit Process).
- The Governors policy appointees at the RAQC seem to think this will only cost about .08 cents per gallon. Our most knowledge distributors are estimating a minimum of 50 cents per gallon not accounting for the differences in unbranded and non branded Rack .
- Not one person from the Governors policy team had reached out to CWPMA to ask for our input.
CWPMA and the wholesale and retail fuels industry should be very wary of this “letter".
More importantly and concerning is that the downgrade to severe non-attainment gives the EPA authority to implement Good Neighbor provisions under the Clean Air Act. This will harm Wyoming and Utah businesses and families by holding them responsible for contributory emissions. This is disingenuous when the total emissions that Wyoming and Utah contribute is less that 1% of the inventory.
The only reasoned solution would for our administration to follow the previous administration and apply for the 179 waiver which demonstrates the impact of emissions not caused in Colorado.
RAQC Amendments for Submission