“We are encouraged that CDPHE is developing guidance that includes the expertise of their modeling staff,” Chandra Rosenthal, head of the Rocky Mountain PEER Council, said in an email. “However, in the current draft there are a couple of provisions that are backdoor exits for industry.”
For example, an applicant can opt out of the modeling review by implementing a plan to monitor emissions to show it is in compliance, Rosenthal said. “It is allowing the construction to go forward and hoping that it will not exceed standards with after-the-fact monitoring.”