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Stakeholders urge removal of energy‑cost appendices, saying cost method biases against electrification
Summary
Multiple public commenters — health professionals, local officials, environmental groups and former legislators — urged the board to remove optional appendices that allow energy‑cost based compliance, saying the approach understates health and social costs and could reintroduce a bias toward fossil fuels.
Speakers from health, local government, environmental and advocacy groups urged the Colorado Energy Code Board to remove appendices CL and RM, which would allow energy cost–based compliance as an alternative to the board’s proposed site‑energy targets.
Dr. Kate Jennings, an internal medicine physician, told the board that on‑site combustion of fuels “cost Colorado about $2,000,000,000 in health care impacts per year and is responsible for 180 early deaths.” She and others said the appendices do not account for those health costs, social cost of carbon, or fuel‑price volatility.
Tracy Burnett, who identified herself as a former state representative and a prime sponsor of HB 22‑1362, said the statute’s intent was to reduce greenhouse gas emissions and noted the Legislature allocated grants to foster electrification. She urged the board to remove the energy‑cost appendices because, in her view, they “are biased toward buildings using fossil fuels.”
Darlon Chung, a resident and founder of a decarbonization firm, described a local all‑electric neighborhood that later backslid toward gas when developers changed and said “codes that are firmly focused on decarbonization” prevent that backsliding.
Advocates recommended keeping the code’s electric‑preferred, fuel‑neutral approach in the main code and leaving cost‑based energy methods out of the model code to avoid a patchwork of local adoption that could favor fossil fuels in jurisdictions that adopt the appendices.
Board staff noted the appendices are optional but acknowledged some board members and members of the public were concerned the appendices could undermine the code’s electric‑preferred goals.
