Taking the Guesswork out of Methane Pollution Reporting: Colorado Publishes Nation-Leading Verification Protocol

May 2, 2024

Jack Alber, (415)-530-7042, [email protected]

Today, Colorado's Air Pollution Control Division published the final 2024 Intensity Verification Protocol - a document providing guidance to oil and gas producers on how to comply with the state's GHG Intensity Verification Rule that the Air Quality Control Commission adopted last year. The Verification Rule sets requirements for measurement, reporting and verification of emissions designed to help ensure compliance with pollution limits the Colorado General Assembly established in 2021. This protocol is a first-of-its-kind document requiring best-practice approaches to designing measurement strategies using direct measurement technologies to quantify methane emissions from production sites. Per the Verification Rule, the protocol will be reviewed by APCD annually and updated to keep pace with rapidly improving measurement technologies and scientific understanding of methane emissions.

"The Polis administration and APCD deserves praise for setting a high bar for how we can best harness science to verify reductions in oil and gas methane pollution," said Nini Gu, Regulatory and Legislative Manager, Environmental Defense Fund. "Colorado was the first state in the nation to set strict limits on methane emissions and with today's action becomes the first state in the nation to require that measurement-based emissions reporting be used to demonstrate compliance with those limits. Global gas markets are demanding lower methane intensity from natural gas, and as gas importers and exporters work through the challenges of MRV to prove up claims of low intensity, eyes will once again turn to Colorado for example."

The protocol, effective in 2025, outlines key components and considerations that would impact the effectiveness and reliability of any direct measurement program. These components include ensuring that technologies used in a direct measurement program are adequately validated; demonstrating that technologies are appropriate for the sites where they are deployed; identifying and understanding the sources of uncertainty and transparent recordkeeping and reporting. The protocol also provides a framework for continuous improvement in the future.

Over the next two years, APCD will need to implement and enforce the protocol in order to determine improvements the AQCC and APCD will consider in 2026.

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