Colorado Adopts GHG Intensity Verification Rule

Introduction

As a part of the Colorado Public Health and Environment’s (CDPHE) Pollution Reduction Roadmap, published in January 2021, the state has been taking action to reduce greenhouse gas (GHG) emissions. Recently on July 20^th 2023, the Colorado Air Quality Control Commission unanimously approved a new greenhouse gas intensity verification rule which sets standards on how oil and gas facilities must monitor, track and calculate GHG emissions. This verification plan is a part of a Colorado GHG intensity target, which sets numerical limits of carbon dioxide equivalent (CO2e) emissions per barrel of oil produced. The state’s overarching roadmap plans to reduce GHG emissions by 50% in 2030 compared to 2005 levels. The verification rule is codified in Regulation 7, Part B, Section VIII.F and will take effect at the start of 2025 when the first greenhouse gas intensity target comes into effect.

Does This Apply to Me?

The greenhouse gas intensity verification rule applies to “intensity operators”, meaning a person or entity that operates upstream segment activities or equipment, where upstream segments include the following processes in the oil and gas industry:

• Exploration – geological and physical surveys
• Extraction – drilling (boreholes and wells)
• Production – primary, secondary, and tertiary recovery

What Does This Mean?

It is clear that CDPHE is taking action as planned in their 2021 Roadmap. Starting in 2025, when the intensity standards are set, facilities must develop an emissions inventory that demonstrates compliance with the new intensity standards. For facilities subject to these new intensity standards, it is imperative that they maintain an accurate and up to date emissions tracking tool to demonstrate compliance with the intensity standards.

CDPHE will also develop and release protocols (including approved measurement strategies and default intensity verification factors). Keeping a close eye on these protocol updates will help ensure your compliance tool is as efficient and accurate as possible. Any revisions to the protocols will be published by June 30^th of the calendar year preceding the verification year. Record keeping requirements require the following documentation be kept on hand for a minimum of 5 years and available upon CDPHE request:

• Records created by the measurement strategy. The CDPHE Air Pollution Control Division has defined a measurement strategy as one that is informed by direct measurements of GHG emissions from a regional, local, stationary source, or an air pollution source monitoring of methane emissions, and optionally through parametric monitoring (monitoring of regional, local, stationary source, or air pollution source monitoring of pressure, temperature, flow rate, control efficiency, or other operational characteristics)
• Records of calibration and maintenance of equipment
• Records of inventory submissions to certified third party auditors
• Reports created by certified third party auditors
• Actions taken by certified third party auditors

ALL4 can help create standard operating procedures for emissions tracking and recordkeeping to ensure that your facility’s compliance with this new rule is a smooth process.

What Can I Do?

CDPHE will continue to update verification protocols as they come out. Following their website as well as ALL4 published articles on this topic will keep you up to date on any new guidance or standards that CDPHE releases. If you need assistance setting up the tools to comply with this new rule, or if you have any questions regarding the new rule, please contact Evan Mia at emia@all4inc.com or 610-422-1162.