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RACC conveners report progress, open questions on indirect‑sources (trip‑generator) work groups

May 02, 2025 | Regional Air Quality Council, Governor's Boards and Commissions, Organizations, Executive, Colorado


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RACC conveners report progress, open questions on indirect‑sources (trip‑generator) work groups
The Regional Air Quality Council’s indirect‑sources work groups reported on May 14 that they have formed four subgroups and met monthly since January to draft best practices and explore voluntary and regulatory options to reduce trips and on‑site emissions from facilities that generate or attract significant vehicle traffic.

Kira (RACC staff) summarized the structure and outreach: “We have four subgroups that have been meeting monthly since January,” she said, noting the groups have worked on draft recommendation options, reporting concepts and a “list of best management practices.” Conveners and industry participants have focused on airports, universities, entertainment and recreation venues, and logistics/warehousing facilities.

Board member Margo Melendez, a convener for one subgroup, said the airport and university use cases differ substantially and that participants are sharing existing sustainability and transportation plans. “Airports in particular have really pretty sophisticated plans in a lot of cases,” she said, adding that seasonality and facility diversity complicate a single template approach.

Mike (board member) and conveners emphasized the effort is exploratory. Dina, a convener, said the term “indirect source” has caused confusion and staff are shifting language toward “trip attractor and generator facilities” and “facility emission reduction plans.” Conveners reported that stakeholder engagement is growing but not yet comprehensive; several industry participants have asked for clarity about who would administer any program and how costs would be covered.

“That leads to concerns about fees,” Dina said. Conveners and staff confirmed RACC has volunteered to explore whether it could administer reporting or receive contractor funding, but they said legal and budget questions remain. Mike summarized options for administration: if the state adopted a regulatory requirement, the Colorado Department of Public Health and Environment (CDPHE) could administer it; alternatively the state could contract with RACC to perform intake and review work, with funding provided via the state or a regulated‑party fee.

On policy scope, conveners said the work group has not adopted a single approach. Meetings have explored voluntary best management practices, voluntary reporting to build data, and the potential for reporting requirements or regulatory controls if warranted. Entertainment‑venue convener Mike (venue subgroup) said venues have expressed interest in programs that reduce event‑day vehicle trips and improve customer experience, but that venues want evidence any required work would yield measurable emissions benefits.

Board members urged staff to plan facilitated workshops this summer to test menu items and to gather more stakeholders, including chambers of commerce, planners and MPOs, to improve turnout and practical recommendations. Several board members asked the operations committee to analyze RACC capacity and the cost to administer reporting and review if the work group ultimately recommends a mandatory approach.

Ending: Conveners said they will continue monthly meetings, bring updated best‑management practice lists back to the board and plan facilitated stakeholder workshops over the summer. Staff and conveners emphasized the work remains at an exploratory stage and that no regulatory decision has been made.

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