Colorado’s Greenhouse Gas (GHG) Intensity Program continues to reshape how upstream oil and gas operators manage and report emissions. Rather than regulating total emissions alone, the state uses an intensity‑based approach, tying greenhouse gas output directly to production. With 2026 marking a key reporting year, operators should understand how the program works and where to find the official requirements.
What “GHG Intensity” Means in Colorado
GHG intensity is calculated as total greenhouse gas emissions divided by oil and gas production. This structure is intended to reduce methane and CO₂ emissions while allowing operators flexibility to scale production, provided emissions per unit decline over time. The program supports Colorado’s Greenhouse Gas Pollution Reduction Roadmap, which sets progressively tighter targets for the oil and gas sector through 2030.
Who Is Subject to the Program
The GHG intensity requirements apply to upstream oil and gas owners and operators, including exploration, drilling, and production activities. The rules are codified under Regulation 7, Part B, Section VIII, with verification requirements adopted in 2023. These requirements are separate from, but complementary to, Colorado’s broader greenhouse gas reporting rules under Regulation 22.
GHG Intensity Plans
Each covered operator must maintain a GHG Intensity Plan describing how emissions and production are calculated, how intensity is determined, and how records are maintained. The goal is consistency, transparency, and the use of measurement‑informed inventories rather than estimates alone.
Compliance Options
Operators can meet verification requirements in one of two ways:
- Operator‑specific measurement programs
Operators may use their own emissions monitoring strategies, incorporating tools such as continuous monitors, aerial surveys, satellite data, or optical gas imaging. These programs must meet state protocols and are subject to CDPHE review and approval. - State default intensity verification factors
Operators may instead rely on state‑developed default factors based on CDPHE monitoring and statewide data. This option reduces complexity but offers less operational customization.
Annual Verification Reporting
Operators must submit annual GHG intensity verification reports documenting emissions, production volumes, calculated intensity, and supporting data. Some operators are required to obtain third‑party verification, and CDPHE may use its own monitoring data to validate reported results.
What Matters for 2026
CDPHE has issued updated guidance for the 2026 reporting cycle, making it a significant compliance milestone. For 2026:
- GHG intensity plan and annual verification reporting workbooks are available
- Annual verification reports are due June 30, 2026
- Updated state default intensity verification factors have been published
Operators should confirm they are using the current CDPHE templates and protocols, as these materials are updated periodically.
Official 2026 Requirements and Resources
CDPHE maintains a centralized page with current requirements, reporting tools, and verification guidance for the GHG intensity program, including the 2026 cycle. View Colorado’s 2026 GHG intensity plans and annual verification reporting requirements: here
