Colorado’s Regulation 7 Updates: What Upstream Operators Need to Know

Summary of the Rule

Colorado’s Regulation 7 updates represent a significant shift in the state’s approach to air quality and emissions management within the upstream oil and gas industry. As the state continues to set ambitious goals for reducing harmful emissions, these regulatory updates are a direct response to the increasing need for real-time, reliable, and comprehensive monitoring of air quality near production sites.

The previous version of Regulation 7, focused primarily on establishing the implementation of continuous air monitoring and reporting. The latest updates go beyond simple monitoring; they establish standardized plans and response levels across all operators, ensuring consistency in how air quality data is collected, reported, and acted upon. These changes also standardize continuous data collection, enact more rigorous response times, and enhanced system automation to align with the regulations purpose to reduce emissions. This shift reflects a broader trend in environmental regulation— continuous monitoring that ensures compliance in real-time and fosters transparency for both regulators and the public.

For upstream operators, these changes represent a higher level of scrutiny and a need for faster, more efficient compliance management. Non-compliance not only risks hefty penalties but also jeopardizes an operator’s environmental credibility. With a hard deadline of May 1, 2025, to meet these new standards, operators must act now to upgrade their systems, processes, and reporting mechanisms.

This blog breaks down the key updates to Regulation 7 and provides actionable insights on how operators can stay ahead of the curve and avoid costly violations.

What's Changed?

The state of Colorado is looking to standardize and improve data quality across all programs. Operators must meet new uptime and calibration requirements to ensure data accuracy and reliability. As such, changes to monitoring are outlined in the bullet points below.

1) Updated In-Field Monitoring Requirements

Uptime Requirements: As of May 1, 2025, all sensors and meteorological monitors must maintain at least a 75% data recovery rate for monitoring plans submitted after this date.
Pre-Field Calibrations:
- Monitors must be calibrated no more than 14 days before or upon installation at the monitoring site.
- If removed, recalibration must occur within 14 days before or upon reinstallation.
- Factory/lab-calibrated monitors must be calibrated within 60 days of installation/reinstallation and undergo a bump test upon setup.
Bump Testing:
- VOC and CH₄ monitors must be tested monthly (with at least 10 days between tests) using a 2-point bump test procedure.
- If a monitor fails, an in-field calibration must be performed, followed by a follow-up bump test.
- If it continues to fail, the sensor must be replaced or recalibrated and tested again.
Malfunctioning Monitors: Must be replaced within 14 days of failure.

2) Requirements for Automated Summa Canister Sampling

New requirements look to implement automated summa cannisters near residential units. The previous rule making did not mandate any automated sampling requirements. The following applies to sites near high-occupancy areas.

Any monitoring site within 2,000 feet of a residential or business unit, school, childcare facility, or high-occupancy building must include an automated summa canister sampling system
- The canister must:
  - Collect no longer than a one-hour sample upon detection of a monitored value exceeding site-specific response levels.
  - Be analyzed for at least BTEX (Benzene, Toluene, Ethylbenzene, Xylenes) and the possibility for other pollutants requested.

3) New Data Collection & Reporting Requirements

As of May 1, 2025, operators must continue to comply with monthly reporting and data submission along with additional requirements including:

Data Collection: All data must be reported in 1-minute intervals.
Reporting Format: Reports must be submitted monthly in a newly updated format approved by the Division.
New Report Format Includes:
- Well API Schedule: Detailed schedule for each well on-site.
- Data Analysis File: Updated data flags as defined by Colorado regulators.
- Exceedance Response Report: Documentation of alert exceedances, including:
  - Date and time of the event
  - Site activities during the exceedance
  - Actions taken and resolutions (if applicable)

Key Steps to Ensure Compliance

To stay compliant, operators must ensure continuous uptime for monitoring equipment, adhere to tighter calibration and testing schedules, and automate sampling processes—especially in high-occupancy areas. The introduction of stricter data reporting requirements will necessitate accurate, real-time submissions in new formats, along with detailed documentation of any exceedances and corrective actions. With the May 1, 2025, deadline rapidly approaching, operators should prioritize upgrading their monitoring solutions and compliance strategies to avoid penalties and support Colorado’s emissions reduction goals.

How Montrose, Sensible EDP and Real-Time Air Monitoring Can Help

Montrose’s Real-Time Air Monitoring Team has assisted multiple operators in Colorado and offers an end-to-end solution to help you meet the new continuous air monitoring requirements of Regulation 7 including:

Comprehensive Air Monitoring Services – Our Denver-based team works closely with regulators to develop site-specific monitoring plans that meet compliance requirements.
Continuous Sensor Monitoring & Compliance Management – We provide real-time alerts via text, email, and phone through the Sensible EDP™ platform, ensuring faster response times and uptime compliance.
Automated Summa Sampling & Laboratory Analysis – Montrose’s lab partner, Enthalpy Analytical, supports summa canister analysis for BTEX and other pollutants.
Regulatory Reporting Support – Our team manages monthly reporting, ensuring all submissions meet the latest compliance standards.
Additional Regulatory Support – Montrose’s stack testing and LDAR teams assist with other aspects of Regulation 7 compliance beyond continuous air monitoring.

Need help preparing for CO Regulation 7 compliance?

Request a demo or submit your question for our experts below.