Dear Mayor Arndt and Councilmembers Gutowsky, Pignataro, Canonico, Potyondy, Ohlson, and Francis –
At your work session on Tuesday, May 13th, you will consider an item titled “Council Priority Update: Reduce Climate Pollution and Air Pollution Through Best Practices, Emphasizing Electrification.” The meeting packet includes one mention of a Large Methane User Fee, which the Fort Collins Sustainability Group and seven of our community partners have been urging you ask staff to study in time to hold a vote on such a policy before the end of 2025. That mention reads as follows: “Staff are exploring if and how a proposal for a Large Methane User Fee (LMUF) complements the policies that are already under development to determine impact, efficacy, and timing, in addition to the trade-offs that may exist if such a policy was to be implemented.”
Our understanding is that the City will need to take additional measures beyond those outlined in the roadmap presented to you by staff on October 11th, 2022 to reach the 2026 and 2030 climate pollution reduction goals. More specifically, it appears that the shortfall will be 7% in 2026 and 10% in 2030 in the absence of further actions in addition to those described in the roadmap. The roadmap included both Building Performance Standards (BPS) and enhanced Building Energy Codes for new construction.
We developed the Large Methane User Fee concept in response to the need for additional actions. We believe a Large Methane User Fee would complement and strengthen the proposed BPS policy, which the FCSG enthusiastically supports. There are three reasons for that. First, the LMUF would apply to building categories excluded from the proposed BPS policy, notably manufacturers. Second, it would offer a carrot for making energy upgrades, not just a stick. And finally, it would nudge building owners to electrify their buildings, which BPS does not do.
As recognized by City Council and staff, electrification is often better from a climate perspective than just reducing overall energy use. For instance, either replacing gas-fired boilers used to heat a building with more efficient boilers OR replacing those boilers with electric heat pumps would reduce energy use. However, the heat pump option would result in deeper greenhouse gas reductions over time as our electricity supply becomes more and more renewable.
Adopting an LMUF policy concurrently or shortly after adoption of a BPS policy would improve decision-making by building owners subject to the LMUF, both with respect to the climate and their “bottom lines.” Waiting to adopt a LMUF policy would likely result in worse decisions and complaints. And not adopting a LMUF would increase the probability that building owners not subject to BPS would avoid their responsibility to help the community achieve its climate goals.
At the work session this Tuesday, we encourage you to ask staff the following questions:
- Are the estimates made in 2022 of the shortfalls between the community’s climate pollution reduction goals and its performance still valid?
- If so – or if the estimated shortfalls have increased – does staff have additional concrete measures for your consideration to achieve those goals?
Unless staff has concrete alternative measures that council can put in place to achieve our 2026 and 2030 goals, we respectfully ask that you direct them to give the LMUF concept a thorough vetting and to come back to you with a proposed policy at a subsequent work session that could be adopted later this year, before the next council is seated. The City declared a climate emergency in 2019, and the climate crisis proceeds apace. Later would be too late.
Sincerely,
Kevin Cross
Convener
Fort Collins Sustainability Group
P.O. Box 672
Fort Collins, CO 80522
Ph. 970-484-3141 https://focosustainability.org
