Environmental groups are wanting to add the "social cost of carbon" to state rules. A mismatch between what CPR tells the public vs. corporate sponsors? RTD and a free hour on records requests.

Environmental groups are wanting to add the "social cost of carbon" to state rules.

I got the rulemaking announcement linked first below in an email. A bunch of environmental groups are asking the state's Energy and Carbon Management Commission (ECMC) to do a rulemaking and, quoting the announcement, add a rule to "... evaluate and address the Social Cost of Carbon in all Cumulative Impacts analyses."

Golly, that sounds an awful lot like policymaking, what on earth is an unelected board doing making those kinds of decisions? Ah, but you forget that in Colorado, much of our policy, much of the rules of our economy, is made by faraway, unaccountable political appointees.

Before looking in on the rulemaking itself and how you can speak up for sanity, let's back up a step and talk about the social cost of carbon. I put a link to a Wikipedia explainer second below if you want an overview and jumping off point.

The short version is this. One of the main arguments made in favor of adding an extra (estimated) cost to things for the greenhouse gases involved in their manufacture, transport, etc. is the concept that some benefit from the aforementioned economic activity, but we all pay for the greenhouse gases left over.

The theory is that the ill effects of climate change put costs on those who weren't involved in the transaction (or who were). The thinking behind adding a social cost of carbon to transactions is that this cost can be borne up front and then the economic transactions can better reflect the true cost of the activity.

Perhaps, an advocate might say, this charge up front would drive different decisions than we see now.

I'll give you an analogy. If you've bought paint recently, depending on type and where you bought, you may have noticed a disposal fee on your receipt. That fee is there to cover the cost of the proper disposal of the paint. Same goes for oil changes, tires, you get the idea.

You paid extra in advance to help defray the cost of dealing with the waste later. You paid the "true" cost. Whether this caused a change in your behavior after is debatable, but it is a reminder that the things you bought have an impact on the environment and can't just be put down a drain or heaped up in the woods somewhere.

Besides this being an imperfect analogy, I hope you noticed a critical difference between the paint and greenhouse gases the cost to safely dispose of a given quantity of a given kind of paint is known. The cost to dispose of oil and tires is too. There are companies in that line of work who know how to price it based on all the market inputs needed.

No one, no matter who it is, and no matter how many degrees or letters follow their name, knows the price of one unit of carbon. We cannot predict with certainty what one more ton of greenhouse gasses will do or where.

The cost of carbon is a made up number. It's a price imposed on something by someone. Letting a government body, especially an unelected one, arbitrarily do things like this is a bad idea. It's bad policy. It will have economic consequences, which, for a number based on nothing, ought to ring of foolishness.

Returning to the announcement of the rulemaking, I linked to the public notice of the hearing third below. There are a couple of things to note if you, like me, find this objectionable enough to speak up.

1. The deadline for public comment is on June 6th.

2. Unfortunately, there is no way to sign into the rulemaking hearing and speak your public comment, this one is written comment only.** When you fill out the form, it will ask you for the docket number. Use docket number 250500081.

My written comment follows the links. If you find it helpful, please feel free to use any part of it in your own advocacy.

**If you do file written comment, you can attend the June 18th meeting and then, if the committee has a question for you about your comment, you can then respond to the question.

https://content.govdelivery.com/accounts/CODNR/bulletins/3e1443f

https://en.wikipedia.org/wiki/Social_cost_of_carbon

https://oitco.hylandcloud.com/unityform/UnityForm.aspx?key=UFKey


My Comment:

To the Colorado Energy and Carbon Management Commission. My name is Cory Gaines. I am a resident of Logan County. I write today with comment regarding the application for a Social Cost of Carbon rulemaking requested by Wildearth Guardians et. al. (Docket Number 250500081).

Let me first state that in addition to sending this to you, I am going to publicly publish this letter.

I write today in opposition to the proposed rulemaking.

Let us put aside the fact that such weighty decisions, decisions that stand to have gigantic consequences for so many in this state, should be made (to the extent that such intrusions into the market should be made by government at all) by elected officials accountable to those that are affected as opposed to unelected boards.

Let us focus in on the request made by Wildearth et. al.

Stripped of the jargon in their request, what you're asked to do is to fix a price on something. This will be a price that will have social and economic consequences. Said another way, you're being asked to do something that will affect lives and livelihoods in Colorado.

Prices for things, their value, is normally set by the aggregation of many, many single decisions made by distinct individuals. Not so here if you do as the requesting parties ask.

If any of you are old enough to remember the Soviet Union, I'm sure you remember how well things worked when prices and values were set by central bodies. Do you think you'll be able to do better?

Further, I would like to point you to the fact that unlike other negative externalities that we might fix a price to, the social cost of carbon is ill-defined. There is no way around this. It is a number that someone made up, and is thus a product of their assumptions, their perspectives, their time.

How are you to fairly say that one person's number, then, has more truth to it than another's? How can you fairly claim to know the price?

In the absence of knowledge, of the ability to be fair, and in the interest of not further damaging the state's economy, the only thing to do is to not play the game that Wildearth et. al. would have you play.

I urge you to tell them you are not going to add this nebulous "price" to things in our state.

Thank you.

Cory

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A mismatch between what CPR tells the public vs. corporate sponsors?

I've done a fair bit lately on public media, defunding of same, etc. As part of the research on that stuff, I came across something that made me do a double take.

If you were a company, foundation, or similar seeking to underwrite or sponsor (advertise) on CPR, you might end up at the page linked first below. If you go and look at it yourself, you won't see anything surprising.

It's CPR extolling the benefits your organization stands to get from working with them.

Of special note, however, is what I attached in screenshot 1.

Quoting the ad copy: "Through sponsorship marketing campaigns, you’ll reach well‑educated decision‑makers with the purchasing power to act on your messages." Good news to be sure. Who wouldn't want to draw in educated and well to do customers?

Now let's turn to the face that CPR presents to the public to help encourage those public dollars to keep coming. The second link below is to a CPR press release about the importance of continued public funding to public media.

I'll leave it to you to read the whole thing, but a quote will give you a sense of what's there:

"Funding public media ensures all Coloradans have access to lifesaving emergency information, proven educational resources for children and families and local news you can trust."

Now these two aren't entirely contradictory, but I think you now understand the picture of hte mismatched socks at the top: something doesn't synch up here.

On the one hand, you've got wealthy, self-actualized charge-takers. On the other a benighted, rudderless mass. Both are somehow CPR's demographic.

So are the 72% of CPR listeners, those who make $100K or more and have college degrees or higher, somehow unable to access and/or understand the news without public media? Unable to get emergency alerts?

Is it perhaps that the other 28% are shoeless ne'er do wells without college degrees that have to be helped by the taxpayer? Meaning the other 78 can figure it out, but the rest (or a portion of the rest) can't?

Something here doesn't quite add up.

https://cpr.marketenginuity.com/

https://www.cpr.org/press-release/psa-funding-public-media-ensures-coloradans-access-to-emergency-alerts-educational-resources-and-local-news

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RTD and a free hour on records requests

I'm catching up on some things that were put on the back burner at the end of the legislative session and the end of the Spring 2025 semester.

I'd written in the past about RTD's proposed policy of giving an EXTRA free hour (you get one free hour by CORA law already) to records requests. That policy passed (see the op ed by board members Kathleen Chandler and Chris Nicholson below). I am glad. I wholeheartedly agree with the quote below from the op ed:

"These records are created with public dollars. Taxpayers fund the salaries, software, and systems that produce them. Asking the public to pay again—especially when the request is meant to inform others or improve services—is an unnecessary hurdle that discourages engagement."

More details on the policy can be found in the op ed if you'd like them. There's one other pertinent detail I'd like to mention before moving on. I spoke, remotely, at an RTD board meeting about this policy as it was working its way from its initial form to the current form. I have also emailed with Mr. Nicholson and Mrs. Chandler. Mr. Nicholson and I didn't agree on everything as the policy evolved, but that disagreement is not the point.

The point is that there was actual meaningful discussion and genuine citizen involvement.

This has not happened in all the times I've spoken in front of unelected boards. I'm sure there's been some disagreement. I'd like to hope there's been some changing of minds. There has not once been an unelected board member or department head that's communicated with me, either during or after a meeting where I spoke.

Some of the difference is a reflection of how Mrs. Chandler and Mr. Nicholson view the proper functioning of government. I appreciate that, and thank them for it.

But I ask you whether or not they would be as interested if they were not elected. If I had to bet based on my experience with other boards, I would bet no.

This is why it's critical for citizens like you and I to watch for and speak against efforts to put more decisions in the hands of unelected boards. If you would like to keep some modicum of power over your government it's critical.

https://completecolorado.com/2025/05/02/rtd-extra-no-cost-hour-open-records-requests/