Letter to Council Finance Committee on Need for Detailed Information re: “Large Emitter” Tax

Dear Councilmembers Francis, Pignataro, Peel, and Ohlson –

Representatives of the Fort Collins Sustainability Group (FCSG) met with members of the City climate team last Friday to discuss several issues, including potential ballot initiatives to raise funds for climate programs later this year.  We understand that staff will be bringing detailed information to you in April concerning a “Natural Gas as Proxy” tax that may apply progressively to relatively large greenhouse gas (GHG) emitters.  Although little detail is available at this point, the FCSG supports this approach from a conceptual standpoint.  We hope that you will ask staff to present you with equally detailed information on a “Large Emitter” tax  applying to all GHG emissions over 25,000 metric tons of equivalent CO2 per year as well.

We believe that a “Large Emitter” tax should be considered seriously for inclusion on the ballot next November for the following reasons:

  1. A “Large Emitter” tax would apply to fluorinated gases used in electronics manufacture, whereas a “Natural Gas as Proxy” tax would not.
  2. In 2021 (the last year for which data is available), the City’s largest fluorinated gas emitter, Broadcom, released the equivalent of 7% of ALL community GHG emissions.  That’s an enormous amount for a single company.*
  3. Nearly 90% of Broadcom’s reported emissions in 2021 were fluorinated gases, with the remainder resulting from fossil fuel combustion.  A “Natural Gas as Proxy” tax would therefore only apply to about 10% of Broadcom’s GHG emissions.
  4. While Broadcom’s emissions have been declining since 2016, at the 2020 – 2021 rate of decrease, it would take Broadcom seven more years to fall below the EPA’s definition of a “Large Emitter” (25,000 metric tons of equivalent CO2).  And there’s no guarantee that Broadcom’s emissions will continue to fall in the future.

Imposing a “Large Emitter” tax would help keep Broadcom focused on reducing its GHG emissions in addition to raising money over the near term for City climate programs.  We believe that it should be included as part of a suite of taxes to be placed on the ballot this fall to support City climate initiatives.  We also believe that inclusion of a “Large Emitter” tax and “Natural Gas as Proxy” tax on the ballot would allow relatively regressive taxes (such as an excise tax on alcohol, marijuana, and tobacco) to be lower than would otherwise be the case, and would thereby increase public support for all of the proposed climate-related taxes.

We therefore urge you to communicate to City staff that you want enough information on a “Large Emitter” tax to be provided at your April meeting to allow you to make an informed recommendation on a that tax to Council as a whole later that month.



Kevin Cross


Fort Collins Sustainability Group

P.O. Box 672

Fort Collins, CO  80522

Ph. 970-484-3141   https://focosustainability.org


*All information on Broadcom’s GHG emissions cited here can be found on this EPA webpage.


Author: Kevin Cross

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