On September 18, 2026, the Colorado Air Quality Control Commission (Commission) unanimously adopted rules designed to further reduce emissions of methane and volatile organic compounds (VOCs) from oil and gas operations across Colorado and fully implement federal requirements under the U.S. Environmental Protection Agency’s (EPA) 2024 methane regulations. With this vote, Colorado became the first state in the nation to fully adopt the existing-source methane standards for oil and gas operations established under the 2024 federal regulations. This was the third and final Colorado rulemaking to incorporate these federal standards into state law, completing an effort that began in February 2025. Implementation of the 2024 EPA methane standards in Colorado through 2038 are estimated to reduce methane emissions by approximately 30,000 metric tons each year, which has the equivalent climate impact of taking a half-million cars off the road and preventing enough natural gas waste to meet the heating and cooking needs of over 20,000 homes.
Kaplan Kirsch represented the Environmental Defense Fund (EDF), an international environmental organization, in successfully advocating for these nation-leading regulations. Kaplan Kirsch attorneys Tom Bloomfield and Sarah Judkins led the Firm’s work for EDF, which involved drafting briefs, presenting live testimony, and negotiating rule language ultimately adopted by the Commission.
Among other provisions, EDF advocated for, and the Commission adopted, the Air Pollution Control Division’s proposal to extend certain federal requirements, including monitoring requirements for enclosed combustion devices, to all oil and gas sources, including those beyond the facilities covered by the federal regulations. These expanded monitoring requirements will help ensure that enclosed combustion devices across Colorado function properly and effectively control methane emissions. EDF also supported the Division’s proposal to extend federal requirements for closed vent systems and covers to all storage tanks subject to state regulation, a proposal that the Commission adopted. Together, these provisions go beyond the federal baseline and are expected to further reduce emissions of methane and VOCs across Colorado. EDF also supported other Commission-adopted provisions aligning Colorado’s regulations with EPA requirements.
Kaplan Kirsch attorneys have extensive experience appearing before the Commission and representing clients in a range of air quality, climate, and environmental compliance matters in Colorado and other states.
