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ECMC enforcement unit reports 54 orders resolved, highlights enforcement approach and public-project penalties

Energy and Carbon Management Commission · February 11, 2026

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Summary

Enforcement manager Jeremy Farrin and adviser Annie Shaver told the commission the unit resolved 54 orders and 87 notices last year, described coordination with other agencies, outlined staffing additions, and highlighted public‑project penalty outcomes including a $95,000 donor award to Rocky Mountain Raptor Project.

The Energy and Carbon Management Commission received an annual enforcement report on Feb. 11 detailing the unit's approach, recent caseload and examples of public‑project penalties assigned in lieu of monetary collections.

Jeremy Farrin, enforcement manager, said enforcement aims to deter violations and bring operators into compliance through outreach, corrective actions and, when necessary, formal orders and penalties. He described coordination across internal units (financial assurance, engineering, environmental, compliance, planning/permits) and with state and federal agencies such as CDPHE, the State Land Board and BLM. Farrin cited a recent judicial appeal in the Renegade matter as an example addressing concurrent jurisdiction over flaring and related regulation.

Farrin said the unit's published annual report (posted in January) summarizes orders and penalties; the presentation highlighted 54 orders resolved and 87 notices noted in the report. Annie Shaver, enforcement adviser, provided staffing updates: hires include Autumn Trish and Casey Wolverton (recently returned), and Brandon Fletcher is set to start next week. Shaver described recent rule changes that aligned enforcement remedies with statute and an upcoming guidance update tied to legislative audit work.

Shaver described enforcement "waves" and batch processing for specific compliance areas and pointed to operator submissions of testing data: she said about 12,372 Bradenhead (operator integrity) tests were submitted via bulk upload and that missing tests declined from 616 in 2023 to 489 in the initial 2025 report. She noted an upcoming wave related to Form 1b annual registration, fees and insurance.

On public‑project penalties, Shaver highlighted two 2025 examples: Evergreen Natural Resources' assessed penalty supported expansion and maintenance of the City of Trinidad's reservoir, and Noble Energy agreed to donate $95,000 to the Rocky Mountain Raptor Project for facility repairs and veterinary care. Shaver said public projects are evaluated for public health, safety and environmental benefit, and preferred to have geographic nexus to affected communities.

Commissioners thanked Farrin and Shaver for the briefing; no substantive votes or new enforcement directives were issued.