Expected Changes to Oil & Gas Rules, Coming September 2020

Colorado's air rules for oil & gas sources (Regulation 7) are constantly changing. Here's the latest on the changes we're expecting for rulemaking scheduled for later this year. As of now (June 2020), these are only expected changes and are not required yet.

There are several drivers for these changes, including legislature from the 2019 legislative session (SB19-181, SB19-069, and HB19-1261), the national ozone standard, the regional haze rule, and nitrogen deposition at Rocky Mountain National Park. These are the same items that drove the modification to the regulation last year, and we expect more changes moving beyond 2020.

The main changes being discussed for this year's rulemaking involve the following:

• Statewide controls of NOx from natural gas engines over 1,000 HP
• Statewide ambient air monitoring at well production facilities during the following times:
  
  • Before activity (baseline)
    
  • During drilling through flowback (pre-production)
    
  • During early production
• Statewide controls on pre-production (flowback) tanks/vessels
• Statewide controls on tanks and liquid loadout at certain water disposal/injection facilities
• Colorado emissions report expanded to include common greenhouse gasses (carbon dioxide and nitrous oxide)

Colorado's air rules are already very stringent. If you need help understanding existing or upcoming rules, please feel free to contact us for a free virtual consultation.