Brandon Brown: Testimony for the 2035 Clean Heat Targets Rulemaking at the PUC, 9/18/25

Hello Fellow Coloradans,

My name is Brandon Brown, I’m currently living in Denver with an extensive background in litigation, environmental science, and geospatial tech.

I’m here to testify today because Colorado doesn’t have time for halfway measures dressed up as progress. The state’s legislature already laid down the path with SB 21-264: utilities were told to cut emissions 4% by 2025 and 22% by 2030. Now we’re at the next turning point, 2035, and the current proposal on the table is just 31%. This leaves us with more to lose than to gain.

Let me be clear: 31% is not leadership. It’s not science-based. It’s not enough for our communities that are already struggling to build resilience against wildfires, feeling our summers get hotter, and watching our families struggle to stay healthy inside homes still burning gas.

Colorado MUST maintain its leadership edge. That means a minimum of 55% cuts in emissions by 2035. Anything less fails to fully consider the science and the law. Colorado needs to continue paving the way forward for binding emissions reduction targets at 2040, 2045, and 2050 that take us to zero gas utility emissions by mid-century. Otherwise we are punting the costs, the harm, and the consequences downfield to my generation and the next.

Let’s be honest: so-called “recovered methane” and hydrogen blending are not solutions. They are industry delay tactics. Recovered methane still leaks, and the Commission itself has previously found it’s not cost-effective compared to building electrification. Emission reductions from recovered methane need to remain capped at 5%. No expansion, no loopholes.
The weakened proposal to drop targets to 31% in response to industry pushback is a step backward. Federal rollbacks of clean energy tax credits are not an excuse for Colorado to abandon its statutory climate goals or its ardent leadership. When Washington caves to polluters, it’s important for us to stand up for Coloradans’ health, safety, and sovereignty.

We are already feeling the impacts of climate change in Colorado: extreme heat, worsening ozone pollution, more destructive wildfires, declining snowpack, drought, and flash flood risks. Communities across the state are living with the same reality: from the Marshall Fire to the Boulder Creek Flood, to challenges maintaining the Colorado River Compact. The science, the law, and Coloradans lived experience call for drastic emissions cuts: right here, right now.

Colorado’s families deserve better. Beneficial electrification from ground-coupled and air-source heat pumps deliver real solutions that cut costs, mitigate emissions, and keep people safe in extreme heat and cold. This approach reduces reliance on gas infrastructure, lowers indoor and outdoor air pollution, and aligns with statewide climate law. This is a wise course of action.

The PUC now has the stark opportunity to set strong and realizable guardrails, not weak compromises. Colorado deserves clarity, accountability, and a future free from gas. The atmosphere doesn’t negotiate, and neither should we. Thank you.

Brandon Brown is the owner of Sustainable Geospatial and a consultant for PSR Colorado.