Colorado Oil and Gas Methane Intensity Verification Protocol

Under Colorado law, upstream oil and gas operators are required to report their methane emissions and calculated GHG intensities on an annual basis. Methane emissions must be calculated through the creation of a measurement-informed methane inventory. The Oil and Natural Gas Methane Intensity Verification Protocol ("Protocol"), issued in April 2024 by the Colorado Air Control Pollution Division, provides guidance on how oil and gas operators in Colorado are expected to calculate and report the upstream methane intensity of their operations. 

The Protocol provides upstream operators with two options for creating a measurement-informed inventory: 

• State Default Factors: Operators can use default factors developed by the State of Colorado. The Protocol sets out how these default factors are calculated by the Colorado Air Control Pollution Division. In particular, the Protocol specifies that these default factors are derived from region-wide measurement campaigns, accounting for uncertainty. 
• Operator-Specific Intensity Verification Programs: As an alternative to the State's default factors, operators can choose to develop and implement their own operator-specific intensity verification program. For calendar years 2025 and 2026, operators that choose to develop their own program must ensure that the program adheres to one of three measurement strategies developed by the Air Control Pollution Division, namely: (1) stationary methane monitoring sensors operating on a near-continuous basis; (2) aerial surveys with a frequency of 2 times per year and with a detection capacity of at least 3 kg/hr; or (3) a combination of stationary methane monitoring sensors and aerial surveys. Beginning in calendar year 2027, operators will have the option to continue using one of the three division-developed measurement strategies, or to develop their own measurement strategy. A measurement strategy developed by an operator must be reviewed and approved in advance by the Division and must adhere to certain minimum requirements in terms of measurement technology, coverage, frequency, extrapolation, quality control and records. All emissions reported through an operator-specific program must be verified by a certified third-party auditor. 

The Protocol also identifies a number of voluntary initiatives (e.g., MiQ, OGMP 2.0, Equitable Origin, etc.) that can be relied upon by upstream operators to inform their measurement strategy. However, the Protocol specifies that none of these voluntary initiatives currently satisfies all requirements of the Protocol, meaning no initiative can count as an operator-specific program for the moment.  

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