Oil and gas greenhouse gas intensity program

Overview

In July 2023, the Colorado Air Quality Control Commission adopted the greenhouse gas intensity verification rule. In May 2024, the Air Pollution Control Division published the oil and natural gas methane intensity verification protocol. The new rule and protocol define how certain oil and gas facilities must:

• Calculate their greenhouse gas intensity.
• Monitor operations to ensure compliance with intensity standards.
• Keep records to accurately account for emissions from their operations.

The protocol focuses on the verification and reporting of methane emissions and calculated greenhouse gas intensities as required by Regulation  7, part B, sections VIII.F. and VIII.G.

All upstream segment owners or operators (production and pre-production) subject to Regulation 7, part B, section VIII must participate and adhere to the instructions and requirements in the protocol, regardless of size.

The intensity requirements work to reduce emissions from 2025 through 2030. Intensity refers to a facility’s ratio of greenhouse gas emissions over the amount of oil and gas it produces. Operators with new facilities that began operation in 2023 are subject to stricter intensity targets as required in Regulation 7, part B, section VIII.C.

The protocol explains how operators must:

• Create a measurement-informed inventory of methane emissions.
  • Option 1: Implement an operator-specific program.
  • Option 2: Apply a division-developed state default factor.
• Account for the measurement-informed inventory and other greenhouse gas emissions in their intensity calculations.
• Develop and implement the processes and compliance requirements for an operator-specific verification program, if the operator chooses to establish such a program. 

The protocol also defines how the air division monitors methane emissions, generates state default factors, and reviews and approves operator-specific verification programs. The division will review the protocol annually and update this web page with the final documents.

Annual state default intensity verification factors and reports

The division must publish one or more state default intensity verification factor(s) starting in 2024, by December 31 of each year through 2029 according to Regulation 7 part B section VIII.F.3.a. Intensity operators must apply a state default intensity verification factor to their Oil and Natural Gas Annual Emissions Inventory Report (ONGAEIR) methane emissions unless the operator elects to use an operator-specific program pursuant to Section VIII.F.3.b. The state default intensity verification factor is developed to account for the difference, if any, in monitored methane emissions and reported methane emissions. It is also used to calculate greenhouse gas intensity.

Reporting year 2025 emissions: Due June 30, 2026

The state default intensity verification factor is 1.164 throughout all regions for implementing the intensity verification rule in 2025. The 2025 state default intensity verification factor report provides more detail on the development of this factor. The 2025 ONGAEIR production and pre-production workbooks due June 30, 2026 are subject to this program. The division will apply the state default factor to the reported and validated methane emissions after submission for operators that are not implementing an operator-specific program. Operators implementing an operator-specific program will report their emissions as directed by the division in accordance with the results of the operator’s program.

Reporting year 2026 emissions: Due June 30, 2027

The state default intensity verification factors are presented by intensity region.

Table 1. Reporting year 2026 Colorado state default intensity verification factors.

The Denver-Julesburg region is defined as Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Jefferson, Larimer, and Weld counties. The Piceance region is defined as  Garfield, Mesa, and Rio Blanco Counties. The remaining region includes the rest of Colorado excluding tribal lands.

The 2026 state default intensity verification factor report will be published by March 2026. The division will offer additional guidance for how the 2026 factor will be applied to the reported emissions due by June 30, 2027.

Greenhouse gas intensity reporting forms

Greenhouse gas intensity plans must be submitted according to Regulation 7, part B, section VIII.E.2. The air division requires information from all Colorado oil and gas companies to understand asset ownership and controlling interest status throughout any given reporting year. The information is to facilitate proper implementation of several recent Air Quality Control Commission rulemakings for Regulation 7, part B.  The regulation requires intensity operators to submit annual verifications on a division-approved reporting form summarizing the intensity operator’s greenhouse gas intensity plan implementation during the preceding calendar year. Targets for new facilities started in 2023.

You must use the division-approved spreadsheets available on this web page as required by the regulation. The division will not accept submissions with spreadsheets that are not approved by the division.

All intensity operators must submit annual verifications by June 30 of the following year beginning with 2025 emissions.

Completed forms must be emailed to cdphe_apcd_ei@state.co.us.

The division approved guidance documents and templates for the 2026 greenhouse gas intensity plans and 2025 annual verification will be available by March 2026. For more information, view the February Air Quality Control Commission hearing.

Public participation opportunities

The division will hold a webinar in early 2026 on the GHG intensity plan, annual verification form, and state default factor report. This web page will be updated with meeting information once finalized.

For more opportunities to join upcoming public participation opportunities, view our web page.

News releases

July 20, 2023: Colorado adopts first-of-its-kind measures to verify greenhouse gas emissions from certain oil and gas sites

Contact us

Questions? Email cdphe_apcd_ei@state.co.us with  "GHG intensity verification" in the subject line.

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