Agency presents 2025 cumulative‑impacts report, flags Front Range emissions and heavy water use

Sabrina, director of the Cumulative Impacts Unit at the Energy and Mineral Impact Assistance State Advisory Committee, presented the agency’s 2025 annual cumulative‑impacts report and walked attendees through methods the agency uses to evaluate proposed oil, gas and energy development projects.

The report covered 48 approved oil and gas development plans (OGDPs) in 2025 that together accounted for 81 project locations statewide. "En 2025 se aprobaron 48 OGDPs que abarcan 81 emplazamientos en todo Colorado," Sabrina said as she summarized statewide approvals and the unit’s role in reviewing impacts.

The staff identified the Front Range operating area as the most active region. Presenters said total estimated emissions statewide declined versus 2024, but certain pre‑production emissions per well rose in 2025. Daniel, the unit reviewer for emissions, told participants the agency detected increases in estimated per‑well emissions of CO2, NOx, methane and volatile organic compounds associated with completion and termination operations that rely on large diesel engines.

Water use emerged as a major finding: staff estimated completions in 2025 would consume about 300 million barrels of water (roughly 12.6 billion gallons). "Estos pozos horizontales requieren una media de más de 400,000 barriles de agua para la terminación de cada pozo," the presenter said; staff also reported the statewide proportion of recycled or produced water used for completions reached a record low of 5.2% in 2025.

The report breaks the state into six operating areas and highlights regional differences: a shift from directional to longer horizontal wells in mountain areas increased per‑well water use and estimated emissions, while plains areas saw increased HAP emissions associated with planned tank installations and helium projects.

Staff emphasized the two primary review tools: Form 2B (a data collection form the agency uses to gather operator estimates) and the required cumulative impact analysis (a more detailed 40–80 page document with maps and narratives under rule 315B). Sabrina noted Form 2B is intended mainly for data gathering while the cumulative impact analysis attaches to a permit and can include operator commitments that become binding if the commission approves the application.

Among the report’s recommendations, the agency plans to update Form 2B to capture more useful data, develop automated tracking for wells planned for plugging, and consider issuing guidance to clarify what level of impact should be considered excessive rather than initiating a formal new rule. Sabrina said staff will continue collaborating with other agencies, local governments and tribal partners to refine approaches and to inform commission priorities.

The presentation concluded with an invitation for community input: staff provided QR links and said they will accept detailed, specific comments tied to rules (for example, potential operator noncompliance with rule 315 or inadequacies in a Form 2B submission). The agency also noted the annual report helps other state actors (including the Air Pollution Control Division) and local governments identify trends and regulatory gaps.