ECMC’s cumulative‑impacts report: more wells plugged than started, recycled water use falls as emissions and water demand shift by basin

Sabrina Trask, manager of ECMC’s Cumulative Impacts and Energy Transition Unit, presented the agency’s 2025 annual cumulative impacts report, telling attendees the report examines trends by operating area and compares operators’ permit estimates with later reported actuals.

The report covers 48 OGDPs approved in 2025 comprising 81 locations. Steven Schwarz, the agency’s cumulative impacts supervisor, said the agency recorded over a thousand wells plugged in 2025 and that plugging outpaced new activity: “That’s a really important takeaway … more wells are being plugged than are being approved,” he said. The Front Range accounted for the largest share of approvals and of freshwater use tied to completions.

Why the comparisons matter: ECMC collects estimates in the Form 2B and reviews CI analyses that accompany OGDPs to track what operators propose versus what happens in the field. “We do not regulate air pollution emissions or air quality. That is the agency that does that—APCD,” Trask said, explaining ECMC’s role is evaluative and focused on avoidance, minimization and mitigation rather than setting emission limits.

Key findings
- Basin differences: The Front Range had the most approvals and the highest freshwater demand—ECMC reported about 300 million barrels (roughly 12.6 billion gallons) of freshwater tied to Front Range completions in 2025—driven by longer horizontal laterals that increase water needs per well. Dan Sharon, the CI and emissions specialist, said per‑well pre‑production estimates of CO2, NOx, methane, VOCs and formaldehyde rose in the Front Range due to longer completions and associated engine use.
- Recycled water decline: Statewide planned recycled produced‑water use fell to an all‑time low in the most recent reporting period (staff attributed much of that decline to Front Range projects that planned no recycled water), though ECMC found that actual recycled usage on average can exceed what was proposed at times.
- West Slope shifts: Moving from directional to more horizontal wells increased estimated emissions and per‑well water use in the West Slope; planned recycled water use there also fell. ECMC staff flagged the new produced‑water rules that took effect in 2026 as a likely influence on future project planning.
- Eastern Plains: The basin saw growing helium‑targeting projects and an increase in HAPs tied to proposed tanks; absolute water volumes there remain much lower than Front Range totals.

Commission and staff takeaways
ECMC staff recommended improving the Form 2B to collect clearer data, developing automated tracking for plugging commitments that are listed as beneficial impacts in OGDPs, and providing Commission guidance on “how much impact is too much” to clarify expectations around trade‑offs in approvals. The Commission will consider staff’s questions about impact thresholds in a future session.

What happens next
ECMC will continue to compare operators’ Form 2B estimates with APCD reported actuals to refine its assessment methods, and staff said they will seek stakeholder input on research priorities such as assessing no‑net‑negative outcomes for Class 6 projects in disproportionately impacted communities. The agency also plans improvements to public access—plain‑language summaries and dashboards—so local governments and the public can more easily see proposed versus actual outcomes.