ECMC staff on June 25 presented its 2024 annual cumulative impacts report, summarizing oil and gas activity, air and water findings, wildlife habitat disturbance and data‑quality gaps that need attention before next year’s report.

The presentation, led by ECMC cumulative impacts staff, showed that 58 oil and gas development plans were approved in 2024 (up from 45 in 2023) and that because plans may contain multiple locations there were 117 approved OGDP locations in 2024 (up from 71). Staff described regional patterns of activity — new locations on the East and Southeast Plains, helium projects in Las Animas County, and the first OGDP locations in Jackson County’s North Park basin.

Key findings

- Water estimates vs. actuals: Staff compared operators’ form 2b estimates with later form 5 and 5a drilling/completion actuals for a sample of fully reported locations and found systematic differences. In some Front Range and West Slope locations estimated freshwater use was underreported while recycled water was sometimes overestimated. Staff said the sample is still small (20 fully reported locations in 2024) and outliers can skew results, but recommended additional scrutiny and new reporting from the recently updated produced‑water rules and forms (form 7 and form 47) to improve estimates in future reports.

- Air quality and ozone: ECMC summarized Colorado Department of Public Health and Environment (CDPHE) findings that updated greenhouse‑gas modeling (Greenhouse Gas Roadmap 2) shows the state closer to reduction targets; CDPHE also noted a hotter and drier 2024 ozone season and out‑of‑state wildfire smoke contributions. Staff highlighted AQCC measures adopted in December 2023 to reduce oil and gas emissions, including in‑use requirements for nonroad engines during ozone season and a NOx intensity program.

- Habitat, siting and infrastructure disturbance: The report documents a trend in the Front Range toward siting in less oil‑dense areas but with an increase in disturbance inside high priority habitats (HPH). In 2024, 44% of locations were within HPH and most construction/infrastructure disturbance in HPH occurred on the Front Range. Staff attributed the increase to approval of several large multi‑location OGDPs in previously undeveloped rural areas that required new access roads, pipelines and utilities.

- Disproportionately impacted communities (DI communities): Staff found more than twice as many locations in DI communities in 2024 compared with 2023; part of that increase reflected a 2023 change in the DI definition that mapped new census blocks as DI, while some new sites were genuinely in previously undeveloped DI areas.

- Informed consent off‑ramp: ECMC examined use of the 604(b) off‑ramps (informed consent, preliminary siting through a CAP/CDP, equipment distance criteria, and substantially equivalent findings). In 2024, informed consent (604(b)(1)) was the second most common off‑ramp overall and was used twice as often in DI community locations as other off‑ramps.

Staff recommendations

ECMC recommended a set of operational and data improvements including: clearer guidance for form 2b submissions to harmonize estimate methodologies, using the updated form 7 and 47 data once available, expanding reclamation staff and collecting acreage in inspections, and developing shared data exchanges with CPW to track compensatory mitigation payments. Staff also proposed continued interagency work to align geographic operating area definitions (county vs basin), and additional attention to minimizing impacts and increasing outreach to DI communities.

Speakers and next steps

Sabrina Trask (cumulative impacts and energy transition manager) and Steven (Stephen/Steven) Schwartz/Shore (cumulative impacts supervisor) presented the report, credited cross‑agency contributions from CDPHE and CPW authors for parts of the document, and asked commissioners for topic suggestions for the 2025 report. Commissioners asked for more detail on reclamation acreage, days of high‑intensity activities in HPH timing windows, and granular local‑government reporting options. Staff said it aims to issue form 2b guidance later this year and to incorporate new produced‑water reporting in the 2025 report.

No formal action was required; the report will inform ECMC permitting and monitoring.