Comments on the Draft Climate Plan

By the Fort Collins Sustainability Group
November 12, 2008

The Fort Collins Sustainability Group (FCSG) has reviewed the draft Climate Plan discussed at the City Council Work Session on October 28th.   We have also reviewed a summary of the differences between that document and the Climate Task Force recommendations prepared by  Lucinda Smith on November 6th.

We are disappointed that the draft Climate Plan would only achieve 55 – 80% of the 2012 greenhouse gas emissions reduction intent adopted by City Council in Resolution 2008-051, even if all recommended strategies were to be implemented.   We believe that several of the proposed strategies in the draft Climate Plan need to be strengthened, and that several strategies need to be added.   We offer the following list of changes and additions that we believe will enable the City to reach the 2012 intent:

  1. Fort Collins  Utilities should implement energy efficiency and conservation programs resulting in a 1.75% annual decrease in electric energy use for 2010 through 2020.   Electric energy used to charge electric vehicles should be exempted from this requirement.
    1. a. The draft plan only calls for a 1.0% annual electric energy decrease through 2020.  This goal should be contrasted with the goal set by the Sacramento Municipal Utility District of a 1.5% annual decrease in electric energy use for ten years, and with the goal set by Efficiency Vermont of a 1.75% decrease in electric energy use for two years. The goal we propose would establish Fort Collins Utilities as a (if not THE) national leader in reducing customer energy consumption. It would also help realize City Council’s goal of stimulating the local economy, expressed in Resolution 2007-015, by promoting business activity focused on delivering energy-efficient products and services.
    2. b. The FCSG recognizes the desirability of shifting from gasoline powered vehicles to hybrid or electric vehicles and therefore believes that electricity used to charge electric vehicles should be exempted from the annual reduction goal.  The benefit in lower overall greenhouse gas emissions associated with the use of electric vehicles should be quantified in the annual progress reports to be prepared for Council.
    3. c. The FCSG acknowledges that it will take some time to put public and private programs in place to realize this aggressive reduction goal.  We therefore believe that the 2009 electric energy decrease goal should be 1.0% to allow public and private programs to ramp up to meet the goal for 2010 through 2020.
  2. The city’s recycling program should be enhanced to include commercial customers in the  Ft.  Collins  “Pay as You Throw” ordinance by the end of 2009.
    1. a. This strategy was included in the set of recycling strategies proposed by the Climate Task Force, but removed by City Staff from the 2012 estimate.   It was replaced by a less impactful “cardboard ban” that is described as “a simpler, more cost-effective way to achieve a major increase in diversion.”   Currently, the set of strategies included under the heading “Recycling – Push Towards 50% Diversion Goal” will only achieve 30% to 60% of the greenhouse gas emissions reductions identified under this heading by the Climate Task Force.   We need to do better than this, and can do so by reinstating the “Pay as You Throw” recommendation for commercial customers.
  3. The city should provide an enhanced combination of utility incentives and Zilch loans to people whose houses fail to meet minimum energy performance standards, in order to upgrade home energy performance.  This program should be put in place by the end of 2009.
    1. a. This strategy should replace the “Time of Sale Energy Conservation Ordinance” proposed by the Climate Task Force.   The FCSG recognizes the burden that would be placed on homeowners by forcing them to implement energy efficiency upgrades paid for out-of-pocket prior to selling their homes.   We believe that this proposed strategy offers an alternative path to upgrading the energy performance of less efficient homes.   Funds for accomplishing these upgrades could be provided through a combination of an electric rate increase for the highest usage tier, the natural gas franchise fee, and the existing ZILCH revolving fund loan program.
    2. b. Substandard home energy performance should be determined by voluntary low cost home energy assessments provided through Fort Collins Utilities.   These assessments were part of the original set of recommendations set forth by the Climate Task Force.
  4. Fort  Collins  Utilities should provide incentives for individual renewable energy projects, such as roof-mounted photovoltaic systems.
    1.  a. This strategy was recommended by the Climate Task Force, but is not included in the draft Climate Plan.   Since the Climate Task Force completed its study, Congress has enhanced the residential federal income tax credit for renewable energy systems.   A small Fort Collins Utilities program could help promote and leverage the federal income tax credit.
  5. As a last resort,  Fort Collins should purchase carbon offsets through the  Colorado  Carbon Fund to meet the 2012 emissions reduction goal.
    1. a. The FCSG strongly believes that city resources should be used to enhance the local economy and quality of life while reducing greenhouse gas emissions to the fullest extent possible.   However, we recognize that it may be necessary to purchase carbon offsets or renewable energy credits (RECs) in order to meet the 2012 reduction intent.   Carbon offsets offered by the Colorado Carbon Fund are significantly cheaper than RECs, and will result in some funds being returned to the community.   However, we believe that no carbon offsets should be purchased prior to the first biennial performance review in the spring of 2011.
    2. b. It may be possible to fund the purchase of carbon offsets through an electric rate increase for the highest usage tier.

Achieving the 2012 greenhouse gas emissions reduction intent would require reducing emissions by 485,000 tons of CO2(e) per year.   The gap between reductions that can be delivered by the Climate Plan in its current form and this figure is 107,000 – 217,000 tons/year.   Based on city documents, we estimate that adopting the first four changes and additions to the current package listed above would result in the following approximate net additional reductions:

   StrategyAdditional reduction, tons CO2(e)
Increase energy efficiency and conservation program goals35,000
Commercial “Pay as You Throw” ordinance129,500
Energy performance upgrades for substandard homes5,500
Incentives for individual renewable energy projects2,000
Subtotal:172,000

Comparing the subtotal in the table above to the gap, it appears that the City would have to purchase 0 – 45,000 tons worth of carbon offsets in order to achieve the 2012 reduction intent, depending on the performance of all other strategies.   At $20/ton, the 2012 cost to the city of these offsets would be $0 – $900,000.

We urge the City of  Fort Collins to include the strengthened and additional strategies outlined above in the final version of the Climate Plan.

Respectfully submitted by:

The Fort Collins Sustainability Group

John Anderson

Kevin Cross

Phil Friedman

Deanna Kowal

Eric Levine

Reiner Lomb

Author: Rick Casey

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