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Greenhouse Gas Energy Audits for Colorado Manufacturers

The Air Pollution Control Division (APCD) is working on a Greenhouse Gas (GHG) Audit Program that will focus on reducing GHG emissions from manufacturing facilities.  The program has been created in response to Colorado Revised Statute Section 25-7-102(2(g) which set the following goals for GHG reduction in the state:

  • 26% reduction by 2025
  • 50% reduction by 2030
  • 90% reduction by 2050

The audit program will be based on manufacturing facilities’ relative contribution, so large contributors to GHG emissions will be the focus of the program in the beginning.  Manufacturing facilities with direct emissions of equal to or more than 50,000 metric tons of CO2e per year through 2019 will be the affected facilities at first.  It is expected that the applicability will be lowered to smaller contributors in the future.   Facilities that will be excluded will be Oil and Gas, Landfills, Underground Coal Mines, Electric Generating Units and Food Processing Facilities.  Most of those types of sources are covered under separate regulations.

The audit program will require energy and emission control audits addressing GHG emissions from energy-intensive, trade exposed manufacturing facilities (EITEs) as well as non EITE facilities.  For EITEs it will require that the audit be done by a 3rd party every 5 years through 2035. Non EITE facilities will be required to implement management systems for energy and GHG emission reductions over a 5-year period.   APCD wants facilities to help decide what sources should be included in their own audit, with the focus being on the sources that have the most emissions.

The audit will help to establish GHG Best Available Control Technologies (BACT) and Best Available Energy Efficiency Practices (BAEEP). These will likely be set per facility instead of per industry.  The audit report should recommend a compliance process.  If sources do not meet GHG BACT and BAEEP, the commission will consider the regulatory requirements to further mitigate the costs of reducing emissions and provide incentives to reduce emissions.  APCD would also like to utilize existing programs like ISO.

APCD expects to have draft language for the audit program out by mid-February 2021.  In April there will be a request for a rulemaking and a rulemaking hearing in July.   For more information on the upcoming GHG audit program for Colorado manufacturer’s, go to the CDPHE website for the program:

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