February 10, 2026
Earthworks appreciates the opportunity to provide comments on the proposed revisions to Regulation 7 to continue the process of aligning Colorado’s rules with the U.S. Environmental Protection Agency’s (EPA) 40 C.F.R. Pt. OOOOc.
Earthworks is a nonprofit organization committed to working with frontline communities to address the adverse impacts of mining and energy development on public health and the environment while promoting sustainable solutions. For more than 10 years, Earthworks staff have worked on the ground with local partners across the US and the world to use FLIR G-Series optical gas imaging (OGI) cameras to expose harmful hydrocarbon pollution from oil and gas facilities. This extensive field experience and our strong relationships with communities impacted by oil and gas production and processing guides our advocacy and informs our engagement with local, state, and federal regulators and lawmakers. We strive for reformed policies and stricter rules that put the lives of people before the interests of industry.
Since 2014, Earthworks has worked with partners across the US to raise public awareness about methane pollution from the oil and gas industry and to advocate for federal methane standards. After the EPA finalized New Source Performance Standards OOOOb and OOOOc targeting methane emissions in the oil and gas sector in 2024, we have advocated for states such as Colorado to move promptly to implement the new standards at the state level. We were supportive of the February 2025 revisions to Regulation 7 that initiated this process and adopted a new aggressive timeline for the statewide phase out of gas-emitting pneumatic controllers from oil and gas facilities. Those revisions encouragingly put Colorado on track to accomplish this goal ahead of the 2029 deadline set by the EPA rule. Similarly, we support the Air Pollution Control Division’s (APCD) current proposed revisions to Regulation 7.
The Air Quality Control Commission (AQCC) should adopt APCD’s revised proposal in full. The proposed revisions are sensible and necessary to ensure state-level alignment with the EPA rule. In particular, we support the direct requirement of certain best management practices in the transmission and storage segment as is required by OOOOc. We have long maintained that operators should be required to adopt the best practices and technologies available to them to reduce emissions and protect public health and the environment. These are necessary outcomes of air quality regulation. They should never be contingent on an operator’s discretion…