Yesterday, in Part 1, we traced how Colorado got quietly rewired:
- from voters rejecting Prop 112…
- to SB19-181 passing anyway…
- to statewide GHG targets…
- to “roadmaps” that turned climate goals into marching orders…
- to SB21-260, welding transportation funding to climate policy.
Today isn’t about another bill.
Today is about one rule – written in the middle of COVID, on glitchy Zoom calls and muted microphones – that quietly changed how every major transportation decision in Colorado gets made:
The Greenhouse Gas (GHG) Transportation Planning Standard.
On paper, it sounds dry and technical.
In reality, it is the choke collar on our road system.
And I know that not because I read it in a white paper – but because I spent months of my life fighting it.
1. A Rule Born in a Pandemic – and Written Over a Mute Button
Remember where we were when this thing was being cooked up:
- COVID had emptied out the Capitol and meeting rooms.
- Everything moved to online “stakeholder” meetings.
- SB21-260 had just passed, telling CDOT and the Transportation Commission to “align transportation planning with state climate goals.”
So, while normal people were trying to keep their jobs, kids, and businesses afloat, CDOT and the TC were quietly assembling a rule that would:
- Force every long-range transportation plan to model GHG emissions,
- Require agencies to hit specific reduction targets, and
- Push them toward transit and “mode shift” projects instead of road capacity.
And they did it all under the friendly, focus-grouped label of a:
“Robust stakeholder process.”
Let me tell you what that looked like from my side of the screen.
2. What the Rule Actually Does – in Plain English
Before I get to the politics, here’s the core of the GHG rule, without the bureaucratic frosting:
- CDOT and the big metro planning organizations (MPOs) have to create long-range transportation plans.
- Under the new rule, they must run those plans through a computer model that estimates the GHG emissions.
- The rule sets emissions reduction targets for different years (2030, 2040, 2050). If a plan doesn’t “comply,” they have to:
- Change the plan to add more transit, infill, bike/ped, or other “mode shift” projects (think LOTS of added expense), or
- Create a mitigation action plan explaining what they’ll do to make the numbers work (think some added expense), or
- Risk having certain funding streams restricted or delayed (think getting no money at all).
In practice, this means:
- Highway expansion now comes with a climate penalty.
- Transit and density projects come with a climate bonus.
So if you’re an MPO or CDOT planner sitting at a desk and you have two options:
- Add lanes to I-25 (which they claim (a concept called “induced demand” which I simply reject on its premise) increases vehicle miles traveled and emissions, or
- Fund a bus rapid transit line, a bike corridor, and some “infill” planning,
The rule nudges you hard toward the second. Not because of safety, congestion, or economic impact – but because the math on the spreadsheet looks cleaner and steers funds toward what the Gov and his enviro buddies want you to do – get out of cars, alter your lifestyle, and ride their money-losing transit.
That’s the design.
That’s not conspiracy; that’s how they sell the rule themselves.
3. The “Stakeholder Process” Where the Outcome Was Already Written
Now, let’s talk about those infamous stakeholder meetings.
On the surface, it looked great:
- Dozens of online sessions.
- Local officials, business leaders, freight, agriculture, counties, cities, MPOs – all invited.
- We all got our three minutes to tell them how this was wrong (of course, the enviro-activists like Elise Jones flooded the robust stakeholder meetings with their performative troupe of micro-activists and said they loved the idea).
- The phrase “we value your input” was used so often it could’ve been on a drinking game card.
I showed up.
Over and over.
They ignored me.
As a Weld County Commissioner.
As chair of the North I-25 coalition.
As someone representing people who live on these highways, not just model them.
We argued:
- That I-25 is already dangerously congested.
- That our region is growing fast and actually needs more capacity, not less.
- That you cannot simply “mode-shift” your way out of freight and long-distance commutes in a state like Colorado.
- That tying every project to climate modeling turns vital safety and mobility projects into political footballs and adds unnecessary expense.
And what did it feel like on the other side of the screen?
Like talking to people who were half-listening while they doom-scrolled the socials.
The junior staffers were there, cameras off, dutifully logging comments so someone could later claim a “robust stakeholder process.”
But you could tell – in the pacing, the tone, the canned responses – that the destination was already locked in:
- The Governor’s Roadmap had already said transportation must be a climate tool.
- SB21-260 had already told CDOT to write a rule that reduces GHG.
- Environmental advocacy groups were already lined up in favor and ready to flood the comment record with support.
We weren’t writing policy together.
We were play-acting participation while a pre-written outcome marched toward adoption.
That’s what Polis perfected:
Process as performance.
4. When “Public Comment” Becomes a Numbers Game
To be clear: a lot of people did comment. The official record brags about the volume and the support.
You know why?
Because advocacy organizations, 501(c)3’s and dot-orgs who make a career out of this enviro-grift – the same ones who helped write the Roadmap and pushed SB21-260 – ran organized campaigns:
- Mass emails
- Template talking points
- Coordinated testimony, even offering King Soopers gift cards to those who would read their scripts
So the written record shows:
- Hundreds, even thousands of comments,
- A strong majority in favor of the rule,
- And a handful of outnumbered local governments, business groups, and regular citizens raising red flags.
On paper, that turns into:
“The public strongly supports the GHG Planning Standard.”
In reality, it was:
- Professionally organized advocates vs.
- Working people and local officials trying to squeeze in real concerns between everything else they’re responsible for.
The Transportation Commission, all appointed by (and can be removed by) the Gov anyway, saw a stack of glowing comments and a handful of skeptics and did what everyone already knew they were going to do:
They passed the rule.
5. What It Means for I-25, Weld County, and the Rest of Us
Since then, every major plan touching I-25 and the North Front Range has had to live inside this rule:
- More hoops to jump through for capacity projects.
- Much more expense (think $90 million in “multi-modal hubs” between Highway 119 in Longmont and Centerra in Loveland)
- More pressure to add transit (which unreliably serves a microcosmic few) and “mitigation” even where it doesn’t match reality on the ground.
- More leverage for state-level appointees and staff to say, “That doesn’t score well under the GHG standard – do something else – or nothing at all.”
And remember:
- Nobody voted on this rule directly.
- It wasn’t on a ballot.
- Most people who sit in traffic on I-25 every day have never even heard of it.
Yet it quietly determines what gets built, what gets delayed, and what never leaves the drawing board.
6. Why Part 2 Matters
Part 1 showed you the big picture: how Colorado’s system was rewired around climate mandates.
Part 2 shows you the mechanism: a single rule, written during a pandemic, pushed through via “robust stakeholder process,” that now steers billions of dollars and every major transportation plan in the state.
In Part 3, we’ll look at who was cheering this on and feeding it – the Advocacy–Democrat complex that lives off this machinery: the nonprofits, appointees, and professional activists for whom these rules aren’t remote abstractions, but career grift.
Because if you want to understand why your highway hasn’t kept pace with your life, you need to know not just what rule is in charge – but who built the world that made it inevitable.
📚 About This Bibliography
If you’ve made it this far, you’re already doing more homework than most people in Denver ever expected you to. Good.
What follows isn’t light reading, but it’s important. These are the official documents, presentations, and advocacy pieces that show:
- how SB21-260 tied transportation money to climate policy,
- how the GHG Transportation Planning Standard was designed and sold,
- how CDOT and the Transportation Commission describe the rule,
- and how advocacy groups helped flood the “public comment” record with support.
You don’t have to read every link.
But if you’ve ever thought, “Surely they wouldn’t actually design a system that punishes highway projects in the name of climate math…” – these are the receipts.
Skim the fact sheets, glance at the slide decks, and you’ll see exactly what I’ve been describing in Part 2:
A rule written during COVID, blessed by a “robust stakeholder process,” that now quietly controls what gets built on Colorado’s roads.
Then, when someone tells you this is all conspiracy or exaggeration, you’ll have something better than outrage.
You’ll have evidence.
SB21-260 – Transportation Funding & Climate Ties
Bill summary (official):
https://leg.colorado.gov/bills/sb21-260
Case study on SB21-260 (fees, $5.3–5.4B, new enterprises):
https://transportationinvestment.org/wp-content/uploads/2022/04/CO-Case-Study-FINAL.pdf
Governor’s office press release highlighting climate/air quality and funding structure:
https://governor.colorado.gov/press-release/governor-polis-signs-transportation-bill-into-law
CDOT GHG Transportation Planning Standard – Core Docs
CDOT’s main GHG rule page (overview, intent, links to rule language):
https://www.codot.gov/programs/environmental/greenhousegas
Fact sheet summarizing the GHG Transportation Planning Standard:
https://www.codot.gov/programs/environmental/greenhousegas/assets/ghg-standard-fact-sheet.pdf
Full adopted rule (Transportation Commission Rule 2 CCR 601-22 – Greenhouse Gas Pollution Reduction Planning Standard):
https://www.codot.gov/programs/environmental/greenhousegas/assets/adopted-ghg-rule-dec-2021.pdf
Colorado Carbon Reduction Strategy (explains how the GHG rule shapes planning & projects):
https://www.codot.gov/programs/environmental/greenhousegas/assets/colorado-carbon-reduction-strategy-repaired.pdf
Legislative / Technical Presentations on the Rule
CDOT/TC presentation to legislature summarizing requirements,
targets, and “robust public engagement” claims:
https://leg.colorado.gov/sites/default/files/images/environmental_justice_and_ghg_planning_standard_presentation_11-17-21.pdf
Summary slide deck on GHG Planning Standard, including modeling, mitigation,
and note that “vast majority of comments supported the rule”:
https://www.codot.gov/programs/environmental/greenhousegas/assets/ghg-planning-standard-presentation.pdf
Public Comment & “Stakeholder Process”
CDOT GHG rulemaking comment page (shows volumes of written comments,
hearing info, etc. – good for documenting how they tout the process):
https://www.codot.gov/programs/environmental/greenhousegas/ghg-planning-standard-rulemaking
Example of advocacy group guidance on submitting supportive comments
and testimony (shows coordinated nature of “public input”):
https://www.swenergy.org/colorado-ghg-transportation-planning-standard-action-alert
(If broken, search “SWEEP GHG transportation planning standard action alert”)
Broader Context – Transportation as Climate Tool
Colorado GHG Pollution Reduction Roadmap (2021) – transportation
section describing VMT reduction, “mode shift,” and using planning
to cut climate emissions:
https://spl.cde.state.co.us/artemis/govmonos/gov112g832021internet/
CDOT policy docs tying the GHG rule + Carbon Reduction Strategy
to the state’s HB19-1261 climate targets:
https://www.codot.gov/programs/environmental/greenhousegas/assets/ghg-crs-faq.pdf
