06/19/2026
Comments to the Colorado APCD on its 2025 Greenhouse Gas Inventory Report
Energy Sector
The Colorado Coalition for a Livable Climate is concerned about the methodology used by the Air Pollution Control Division to calculate greenhouse gas emissions from the oil and gas sector.
In past reports, the APCD has used Colorado-specific data, which includes data from well operators and aerial flyovers. The aerial flyover data suggests that methane emissions are at least double the value used by the Environmental Protection Agency in its “Inventory of U.S. Greenhouse Gas Emissions and Sinks by State.”
In the 2025 Inventory Report, the APCD uses data from the EPA to determine methane emissions, not the APCD’s own data. This choice results in lower reported emissions from the oil and gas sector that would otherwise be the case, which seems to be tailored to serve political and economic agendas of powerful actors in Colorado, but not the truth.
Please explain why the APCD chose to use the EPA data for methane emissions from the oil and gas sector rather than its own data.
Thanks,
Kevin Cross, Convener
Colorado Coalition for a Livable Climate
2025 Colorado Statewide Inventory of Greenhouse Gas Emissions and Sinks Chapter 3: Energy DRAFT May 2026 Table of Contents Table of Contents 1 List of Figures 3 List of Tables 4 Acronyms and Abbreviations 5 3. Energy 7 3.1. Electric Power 15 3.1.1. Methodology 17 3.1.2. Uncertai...