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Overview
In 2025, Earthworks conducted 323 surveys at 195 oil and gas facilities in Colorado with an optical gas imaging (OGI) camera. The facilities we surveyed represent the entire oil and gas production and processing supply chain, including: well sites, compressor stations, bulk storage terminals, wastewater disposal sites, pipeline stations, and gas plants.
We observed emissions consisting of climate-warming methane and other dangerous, ozone-forming volatile organic compounds (VOCs) during 70 of those surveys at 55 different facilities. These emissions were the result of inefficient combustion processes, malfunctioning or leaking equipment, intentional releases including during maintenance operations, and pre-production activities like drilling and fracking.
In our 2022, 2023, and 2024 summaries of OGI survey findings, we indicated that we typically identify emission events during 20-25% of our surveys and at roughly 25-35% of the facilities we survey on an annual basis. 2025 follows this trend, as we documented the release of harmful pollutants during approximately a fifth of our surveys and at over a quarter of the facilities we surveyed.
Current regulations prohibit pollution from: leaks and malfunctions, equipment where pollution is required to be mitigated, and certain wasteful activities like routine venting. However, pollution from equipment like flares and from activities involving maintenance or drilling and fracking is not directly prohibited. We only share our observations of pollution with Colorado’s Air Pollution Control Division (APCD) when these observations indicate:
- A potential regulatory compliance issue
- A possible equipment malfunction or leak
- And/or warrant further investigation
In 2025, we shared 47 of our 70 observations of pollution with APCD, as well as a few with the Energy and Carbon Management Commission. A majority of these observations consist of pollution from malfunctioning equipment where combustion occurs, such as flares and engines, or uncontrolled pollution from storage tanks, which is unchanged from past years.
Signs of Continued Progress
What has changed is the response from regulators, continuing and expanding on a positive trend we celebrated in last year’s summary. This year, nearly half of the observations of emission events that Earthworks shared with regulators, 22 of 47, resulted in on-the-ground inspections by regulatory staff.
Some of these inspections were conducted merely to ensure that a repair reported by an operator was effective and that emissions had ceased. In other cases, these inspections represented thorough investigations of a facility that turned up additional issues with permits and/or equipment, or they were conducted in response to ongoing community concerns about specific facilities.
Overall, the number of such inspections demonstrates an increased responsiveness from regulatory staff and an intent to take community concerns and evidence seriously.
Additionally, 19 of our 47 observations resulted in operators making repairs or replacing malfunctioning equipment. Encouragingly, the majority of these self-reported corrective actions were corroborated during on-the-ground inspections by regulatory staff.
Alongside community partners, we have long advocated for robust enforcement of air quality rules. We know that when regulators show up in response to community concerns:
- Operators who may be in violation of those rules are more likely to be caught
- Issues that lead to pollution are more likely to be corrected
- And communities are more likely to place their trust in rules that are meant to protect their health and environments.
Investment in on-the-ground enforcement is also crucial in positioning regulators to be more agile and responsive as new opportunities arise to hold the oil and gas industry accountable for harmful pollution. Regulators must now consider how significant emission events are tracked from space via tools such as Planet Lab’s Tanager-1 methane observing satellite and the associated Carbon Mapper analytic data portal, as well as how new insights are being gathered on possible health risks associated with such emissions events using tools like PSE Healthy Energy’s Methane Risk Map.There are opportunities to leverage these new technologies and tools for enforcement and oversight, but only if regulatory agencies are able to effectively respond.
The Work Ahead
While we hope to track continued progress in enforcement in the year ahead, it is important to remember that in Colorado, and throughout the US, significant emissions from oil and gas facilities are still permitted to occur outside of regulatory oversight and compliance frameworks.
For instance, in 2025, some of the most shocking OGI evidence we gathered of pollution from oil and gas facilities in Colorado identified emission events that occurred as a result of blowdowns. A blowdown is an intentional, pressurized release of emissions directly into the atmosphere from equipment or a facility as part of a maintenance operation, during emergencies, or sometimes merely as a result of overpressurization in gas pipelines. Though often intense, high volume releases, these events can be short-lived and are therefore not always accurately accounted for in emissions reporting. They are also often allowable, as they are associated with maintenance and emergency situations.
The OGI observation shared below showcases the plume of emissions from a blowdown at a gas plant that is located a few miles east of the town of Frederick. This blowdown lasted for approximately a half hour, during which time the plume of pollution escaping from the valve on the plant and into the atmosphere was so extensive and traveled over such a distance that we could not capture it all on film from our vantage point a few hundred yards away. Here is the full video for more context.
It was by far the most significant emission event we documented in 2025 in Colorado, and it was not prohibited by current rules or regulations.
In addition, recent efforts by Colorado to obtain more accurate measurements of emissions from the oil and gas sector in the state have confirmed that large, periodic emissions events like blowdowns are not accurately captured in emissions estimates reported by operators. These intense emissions events are underreported and result in the actual emissions that the state has measured from oil and gas facilities being at least TWO TIMES as large as what the industry reports.
There are steps that Colorado could take to require more reporting of blowdowns and mandate that operators do more to route these emissions to control devices like flares rather than release them into the atmosphere. These are common sense proposals that have already been developed by the Regional Air Quality Council and presented to the state in their Control Strategy Blueprint. These steps have not been taken yet.
While we continue to advocate for regulators to take community concerns seriously and prioritize on-the-ground inspections of oil and gas facilities, Colorado must also continue to empower regulators by ensuring that all harmful oil and gas pollution is subject to strict rules and oversight.
Colorado has made a lot of progress in the more than ten years that we have been on the ground documenting the implementation of new air quality rules and regulations for the oil and gas industry. We are always pleased to share the signs of this progress when they are evident in our data.
Even so, there is still much work yet to be done in order to truly protect communities and hold the industry accountable for their continued impacts on health and the environment.