September 10, 2026
Air Quality Control Commission
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, EDO-AQCC-A5
Denver, Colorado 80246
Re: Regulation Number 7—Oil & Gas Operations
Dear Commissioners:
As individuals and organizations deeply committed to improving air quality and protecting public health in Colorado, we write in strong support of the Air Pollution Control Division’s (“the Division”) proposal to finish adopting the EPA's 2024 methane standards for existing sources (NSPS OOOOc) into Regulation 7. This is the third and last in a series of rulemakings around the adoption of the EPA methane standards, with the previous two unanimously approved by the Commission. The September 2026 rulemaking gives the Commission the opportunity to make Colorado the only state in the country to fully integrate the 2024 federal standards into state-level regulations, expanding Colorado’s legacy as the national leader on reducing oil and gas methane pollution.
As the Denver Metro/North Front Range (DMNFR) region continues to struggle with severe ozone nonattainment, strengthening Regulation 7, Colorado’s primary regulation for controlling air pollution from oil and gas operations, is critical. We greatly appreciate the Commission’s commitment to clean air and action over the years to enact and strengthen regulations to cut emissions, improve air quality, and address the region’s severe ozone challenges—including being the first state to adopt key OOOOc provisions starting in February of 2025.
Colorado can continue to be an example for other states to follow. This is especially important during a time when the Trump administration strives to erode environmental protections, including those around methane and air pollution. Even as we write this letter, EPA is actively gutting the 2024 Methane Rule, which sets consistent national standards for oil and gas methane emissions on both state and tribal levels. We expect federal rollbacks to culminate in a final rule announcement later this year that would eliminate most of the expected benefits from the Biden-era rule. And make no mistake—industry is watching. A loosening of the federal standards means less accountability for oil and gas companies even as their profits rise. The best thing states can do to protect their residents and own best interests is to enshrine these soon-to-be-lost federal protections into state-level regulations.
The Division’s proposed Regulation 7 update for the September 16-18 AQCC rulemaking will finish out the series of state rulemakings that fully integrate federal protections from the 2024 EPA Methane Rule and ensure they are enjoyed by all Coloradans. This will help safeguard our health and climate even as the federal government forfeits its responsibility to protect Americans.
We are asking the Commission to support two critical provisions in the proposed rule:
- Maximize methane and co-pollutant emissions reduction: The Commission should leverage this rulemaking to maximize the reduction of methane emissions and co-pollutants. One pathway is by extending requirements for closed vent systems (CVSs), covers, and enclosed combustion devices (ECDs) to ALL facilities covered under Regulation 7, and not limit requirements to just facilities covered by the EPA’s OOOOc. Doing so would not only capture emissions reduction benefits from more facilities, but also reduce confusion for operators by providing regulatory uniformity, which can improve compliance and operational consistency. Should the Commission consider any narrowing of applicability, please ensure that those changes do not result in a rule that is less effective at reducing oil and gas emissions pollution. Further, the Commission should require that emissions controls are well designed and deployed for effectiveness.
- Ensuring no erosion of venting/flaring standards: The Commission should adopt the Division’s Statement of Basis and Purpose (SBAP) language in its final proposal which will clarify that operators must comply with the more stringent Energy & Carbon Management Commission (ECMC) rules that prohibit routine venting and flaring.
The science is clear: methane emissions from all sources, including oil and gas operations, are responsible for about a third of the climate change we’re experiencing today, and cutting those emissions is the best way to slow the rate of climate change in our lifetime.
In addition, reducing methane emissions also reduces ozone forming co-pollutants, improving air quality and helping Colorado make progress toward attaining federal ozone standards in the DMNFR nonattainment area. Reducing ozone is critical to safeguarding the health of Colorado communities, as unhealthy ozone levels can lead to breathing problems, worsen existing lung disease, and harm overall well-being. With Colorado experiencing over 60 days of unhealthy ozone levels this year, among the worst conditions on record, it is more important than ever to focus on cutting ozone forming pollution because, although we cannot control the heat and sunshine, we can control the emissions that contribute to ozone formation.
Again, we thank the Commission for its past actions to protect all Coloradans from the harmful effects of methane and co-pollutant emissions, even in the face of strong pushback from the federal government and special interests. Approving these provisions that strengthen Regulation 7 will help protect our families and communities, and we urge their adoption. Let’s finish the job.
Sincerely,
Sean Mitchell MSN, APRN-BC
Alliance of Nurses for Healthy Environments, Colorado
Lois Vanderkooi
Broomfield Health and Safety First
Caitlin Maeve
Executive Director
Colorado Rising
Ramesh Bhatt, PhD.
Chair
Colorado Sierra Club Conservation Committee
Christiaan van Woudenberg
Editor-in-Chief
Erie Protectors
Leslie Robinson
Chair
Grand Valley Citizens Alliance
Patricia Garcia-Nelson
CO Fossil Fuels Just Transition Advocate
GreenLatinos
Christo Luna
Colorado State Director
Mi Familia Vota
Laurie Anderson
Colorado Field Organizer
Moms Clean Air Force
Ryan Huggins
Executive Director
San Juan Citizens Alliance
Emily Hornback
Executive Director
Western Colorado Alliance
Jessica Pace
Interim Executive Director
Western Leaders Network