Colorado’s GHG Intensity Program applies a statewide default verification factor to scale ONGAEIR-reported methane toward measurement-informed totals. [1] That multiplier is a population-level correction, calibrated to the average gap between reported and measured methane across all Colorado operators. [1] The default factor does not distinguish operators whose reporting already tracks their measured emissions from those whose reporting undercounts more heavily.

An operator whose own reporting gap is smaller than that statewide average is therefore over-corrected under the default. The uniform factor adds more methane to its reported total than its own measurements would support.

Regulation 7, Part B, Section VIII provides a pathway to replace that default with an operator-specific factor derived from an operator’s own monitoring data. [1] Qualifying requires sustained, verifiable monitoring that meets CDPHE’s approval criteria, and the cost of standing up that monitoring is high.

Quick Answer: To replace the state default intensity verification factor with an operator-specific factor, submit a monitoring plan under Regulation 7, Part B, Section VIII. [1] The plan must show your proposed factor rests on measurement data representative of your facility population. [1] CDPHE reviews and approves the plan before the factor takes effect. [1]

This post is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel or a compliance professional for guidance specific to your operations and jurisdiction.

New to the program? Start with Colorado Reg 7 GHG Intensity: How the Verification Factor Works for how the factor is calculated.

Contents

How to Qualify: Step-by-Step

Regulation 7, Part B, Section VIII lets operators petition CDPHE for an operator-specific intensity verification factor that replaces the statewide default in the intensity calculation. [1]

Step 1: Determine whether the program fits your portfolio. Operator-specific monitoring tends to pencil out for operators with many geographically concentrated facilities whose own measurements would show a smaller reporting gap than the statewide factor assumes. The reporting reduction from a lower factor scales with the gap between the default and operator-specific multipliers.

Success indicator: You can estimate the dollar value of the reduction using the sensitivity analysis in this series’ second post and weigh it against monitoring program costs.

Step 2: Design a monitoring plan that meets CDPHE requirements. The plan must specify monitoring methodology, spatial and temporal coverage, quality assurance procedures, and a data submission schedule. [1] It must cover a statistically representative sample of the operator’s facilities. [1] A hand-picked subset of best performers is unlikely to pass review.

Success indicator: Your sampling design spans the ages, types, and operating conditions across your full portfolio, not just your newest or best-maintained sites.

Decision branch: If your facilities are concentrated and operationally similar, a single monitoring method may suffice. If your portfolio spans basins or facility types, consider a blended approach, described in the monitoring categories below.

Step 3: Submit the monitoring plan to CDPHE for review. An operator-developed measurement strategy must be submitted to CDPHE by March 31 of the year before the operator intends to use it. [1] The Division then reviews it within 90 days, and may approve it, require revisions, or deny it. [1] A denied strategy leaves the operator on the statewide default factor or a Division-developed strategy for that year. [1]

Success indicator: CDPHE acknowledges receipt and does not request a fundamental redesign of the monitoring approach.

Step 4: Execute the monitoring program and submit data on schedule. Once approved, the operator must keep monitoring at the agreed cadence and submit data per CDPHE’s schedule. [1] Because an approved strategy must be reviewed annually and kept current, an operator that lets its monitoring lapse risks reverting to the statewide default factor.

Success indicator: Every scheduled campaign is completed and submitted on time with full QA/QC documentation.

What “Representative” Means in Practice

Representativeness means the monitored sample mirrors the operator’s full facility population rather than its best-performing sites. CDPHE has not published a fixed sample-size formula for a representative monitoring campaign. The methodological burden falls on the operator, and homogeneous portfolios are easier to defend than portfolios spread across basins. A defensible design stratifies facilities by age, equipment type, and production tier, then samples across each stratum. Documenting why the chosen sample represents the whole portfolio matters as much as the measurements themselves.

Which Monitoring Categories Apply to CDPHE Operator-Specific Programs?

Four categories of monitoring technology qualify, each with different detection thresholds, cost structures, and regulatory-acceptance considerations. The right choice depends on the operator’s portfolio, including its size, geography, and facility mix.

The table below summarizes how the categories compare on detection sensitivity, temporal coverage, cost structure, and the portfolios they suit.

Monitoring categoryDetection thresholdTemporal coverageCost structureBest-fit portfolio
Continuous sensors~1–10 kg/hrReal-time, continuousFixed per-site, ongoingHigh-risk or high-value facilities
Aerial / mobile surveys~1 to 30+ kg/hr by sensorEpisodic, per campaignPer-campaign, scales with densityGeographically concentrated pads
Satellite~100–500 kg/hrPeriodic overpassesLowest per-site marginal costBroad screening of the largest sources
Physics-based modelingNot applicable; expected rangesOn-demandPer-analysisAny portfolio, as a cross-check

How Do Continuous Sensor Networks Perform?

Continuous monitors place fixed sensors at or near facility boundaries to detect methane in real time. [2] Point-in-space sensors typically detect down to roughly 1 to 10 kg/hr. [2] Cost is per-site and ongoing: hardware and connectivity create a fixed cost per facility that scales with facility count.

Continuous data gives high temporal resolution, but separating real emission events from sensor noise, weather artifacts, and neighboring-source interference takes documented quality controls.

When Do Aerial and Mobile Surveys Fit?

Aerial surveys use aircraft-mounted sensors, typically imaging spectrometers or lidar, to detect and quantify plumes from above. [2] Detection thresholds vary widely by sensor and altitude. The most sensitive low-altitude lidar systems reach roughly 1 to 3 kg/hr at 90% detection in independent controlled-release tests. [3] Aircraft imaging spectrometers typically sit around 10 kg/hr, and high-altitude platforms higher still. [4] Coverage is broad per campaign but episodic: a quarterly overflight captures four snapshots a year.

Cost is per-campaign rather than per-site, so a single flight covering many facilities lowers per-facility cost as density rises. DJ Basin operators with concentrated pads benefit more than operators with facilities scattered across counties.

What Can Satellite Monitoring Detect?

Satellite platforms detect methane plumes from orbit using shortwave-infrared (SWIR) spectrometry. [5] Commercial high-resolution satellites report facility-attribution thresholds of roughly 100 to 500 kg/hr. [6] Public instruments such as Sentinel-5P TROPOMI cover more ground but at coarser resolution. [5]

Satellites offer the broadest coverage at the lowest per-site marginal cost, but their higher detection thresholds miss the smaller sources ground-based and aerial methods catch. Satellite thresholds sit well above the emission rates that dominate a facility population. Satellite detections alone are therefore unlikely to form the representative sample CDPHE’s review requires.

How Does TetraSoft Complement Operator Monitoring Data?

TetraSoft’s emissions reporting software and estimation are built on MAES. [7] MAES was developed at Colorado State University and UT Austin through the EEMDL initiative, and TetraSoft uses it under a partnership with CSU. [7] For operators pursuing the operator-specific route, TetraSoft builds a Measurement-Informed Inventory (MII). [8] We combine an operator’s field-measured data with MAES using a peer-reviewed methodology, deriving the operator’s own, defensible verification factor. [8] An operator pursuing the operator-specific program needs both the monitoring data and a reporting platform that can apply the resulting factor correctly across its portfolio.

MAES generates physics-based expected emission ranges for specific facility types and configurations, which can serve as a plausibility check. [7] Monitoring results that fall far outside the MAES range for a facility type warrant a look before submission to CDPHE.

When Does Operator-Specific Monitoring Pencil Out?

The economics favor large, concentrated portfolios that already report a smaller methane gap than the statewide factor assumes. Three variables drive the decision: facility count, the gap between the default and operator-specific factors, and annual monitoring cost. The larger the facility count and the factor gap, the more the program pays off.

The break-even point is where the annual cost of monitoring equals the avoided cost of excess reported emissions under the default multiplier. Above that point, each additional facility and each widening of the factor gap increases the net return.

Smaller portfolios have a different calculus rather than a closed door. With fewer facilities, the fixed costs of program design, verification, and CDPHE submission spread across a smaller base. That raises the value of a careful monitoring mix, and of starting with a targeted, lower-cost method.

The math is portfolio-specific. Large DJ Basin operators with hundreds of concentrated pads are the most straightforward candidates.

A concentrated smaller operator with a real reporting gap can still come out ahead. TetraSoft can help model the break-even before an operator commits to a program.

Small operators, those under 45 kBOE of annual production, also gained time. [9] An April 2026 revision (adopted February 20, effective April 14) moved their intensity compliance target to 2030. [9] That widens the window for deciding whether an operator-specific program pays off.

We break down that revision and what it means for timing in What Colorado’s 1.164 Verification Factor Costs Operators.

The operator-specific route is optional; the intensity program itself is not. [1] Covered operators must participate in the program, but they can always stay on the statewide default factor rather than develop their own. [1] An operator whose own measurements would imply a factor above the default is not required to adopt it. Declining the operator-specific route simply leaves the statewide default factor in place. The monitoring data still exists, though, and could be subject to disclosure in other regulatory or legal contexts.

Troubleshooting: Common Pitfalls in Operator-Specific Applications

Three pitfalls most often sink operator-specific applications: unrepresentative sampling, missed campaigns, and undocumented QA/QC. CDPHE has not published a public list of denied operator-specific applications or rejected monitoring plans. Operators should expect scrutiny on each of these fronts.

Unrepresentative Sampling Fails Review

A monitoring plan covering only the operator’s newest, best-maintained facilities will likely not survive CDPHE review. The sampling design must reflect the full spread of facility ages and operating conditions across the portfolio.

Missed Campaigns Forfeit the Factor

Operators who commit to a monitoring cadence and then miss campaigns risk losing their approved factor. Building schedule margin into the plan guards against weather cancellations and equipment downtime.

Undocumented QA/QC Sinks the Plan

Raw monitoring data without documented quality controls is unlikely to satisfy CDPHE’s review. Each submission should carry sensor calibration records alongside documentation of detection thresholds and how false positives were excluded.

Frequently Asked Questions

Does CDPHE publish a list of approved monitoring technologies for operator-specific programs?

CDPHE does not maintain a published list of pre-approved monitoring technologies for operator-specific verification factor programs under Regulation 7, Part B, Section VIII. The operator’s monitoring plan must justify the chosen technology’s fitness for the application. [1] Operators bear the burden of showing their approach produces data of sufficient quality and representativeness.

Have any Colorado operators publicly disclosed their approved operator-specific factors?

No Colorado operator has publicly disclosed an approved operator-specific verification factor as of July 2026. The route is newly available, with operator-developed strategies first usable for the 2027 reporting year. [1] CDPHE does not publish approved factors in its public ONGAEIR dataset. Operators considering the program should contact CDPHE directly for any available precedent or guidance.

Can an operator combine multiple monitoring methods in a single CDPHE application?

Regulation 7 does not prohibit combining monitoring methods in a single operator-specific application. A blended approach, for example continuous monitors on highest-risk facilities and quarterly aerial surveys elsewhere, can strengthen the representativeness argument. The plan must describe how data from different methods will be integrated and quality-controlled.

Once approved, is an operator-specific factor fixed, or can it change over time?

An operator-specific factor is tied to ongoing monitoring rather than set once. Regulation 7 requires approved measurement strategies to be reviewed annually and updated as needed, with program audits in 2025, 2027, and 2030. [1] In practice, a factor rests on the most recent representative monitoring. Material changes in a portfolio or its emissions can move the number a later submission supports.

How long does approval take, and when can an operator first use its own factor?

An operator-developed measurement strategy is due to CDPHE by March 31 of the year before intended use. [1] The Division reviews it within 90 days and either approves it, requires revisions, or denies it. [1] Operator-developed strategies are first usable for the 2027 reporting year. [1] Operators should build the design and measurement lead time into that submission calendar.

The exact provision governing operator-developed measurement strategies is Colorado Regulation 7, Part B, Section VIII.F.3 (5 CCR 1001-9). [1]

Key Takeaways

  • Colorado’s default verification factor is a single statewide multiplier, so it over-corrects operators whose own reporting gap is smaller than the statewide average.
  • Regulation 7, Part B, Section VIII.F.3 lets an operator replace that default with a factor built from its own monitoring data. [1]
  • Strategies are due March 31 of the year before use, reviewed within 90 days, and first usable for the 2027 reporting year. [1]
  • The monitoring sample must represent the full facility population, and an approved factor requires annual review to stay in force. [1]
  • The program pays off most for large, concentrated portfolios with a real reporting gap, though a targeted method can make it work for smaller operators too.

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References

  1. CDPHE, Colorado Regulation 7, Part B, Section VIII.F.3, operator-specific program provisions (5 CCR 1001-9), Colorado Secretary of State, https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2341&deptID=16&agencyID=7&seriesNum=5+CCR+1001-9.
  2. METEC (Methane Emissions Technology Evaluation Center), Colorado State University, controlled-release evaluation results for continuous and aerial methane detection technologies, https://metec.colostate.edu/.
  3. Bell et al. 2022, Elementa 10(1):00080, aircraft-based LiDAR single-blind controlled release.
  4. El Abbadi et al. 2024, Environ. Sci. Technol. 58(22), single-blind aircraft-based methane sensing evaluation.
  5. European Space Agency, Sentinel-5P TROPOMI mission specifications (SWIR methane retrieval), https://sentinels.copernicus.eu/web/sentinel/missions/sentinel-5p.
  6. published commercial satellite-operator specifications; thresholds vary by platform and atmospheric conditions.
  7. Mollel et al. 2025, ACS ES&T Air 2(5):723–735, DOI 10.1021/acsestair.4c00168 - peer-reviewed mechanistic emission-estimation model underlying MAES, developed at Colorado State University and UT Austin through the EEMDL initiative, https://pubs.acs.org/doi/10.1021/acsestair.4c00168.
  8. Santos et al. 2025, ACS ES&T Air 2(8):1598–1611, DOI 10.1021/acsestair.5c00089 - peer-reviewed measurement-informed inventory (MII) methodology from the CSU/EEMDL group, https://pubs.acs.org/doi/10.1021/acsestair.5c00089.
  9. CDPHE / AQCC, Colorado Regulation 7 revision adopted February 20, 2026 (effective April 14, 2026): revised GHG intensity timeline moving operators under 45 kBOE/yr to a 2030 compliance target, 5 CCR 1001-9, https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2341&deptID=16&agencyID=7&seriesNum=5+CCR+1001-9.