Regulatory Alert: EPA’s Reconsideration of the Greenhouse Gas Reporting Program

September 15, 2025

Alert of regulatory changes or proposed changes for municipalities and industry.

 

40 CFR Part 98
[EPA-HQ-OAR-2025-0186; FRL-12720-01-OAR]
RIN 2060-AW76

On September 12, 2025, the U.S. Environmental Protection Agency (EPA) proposed permanently removing program obligations for 46 of 47 Greenhouse Gas Reporting Program (GHGRP) source categories. Under the proposal, facilities, suppliers, and underground injection sites under these 46 source categories would no longer report to the EPA after the reporting year 2024.

EPA states it has reviewed the legality of the GHGRP and determined that there is no statutory requirement to collect greenhouse gas (GHG) emissions information for sectors other than the petroleum and natural gas source category (subpart W) segments subject to the Waste Emissions Charge (WEC).

The GHGRP requires reporting GHG data from large sources and suppliers across various industry sectors. The GHGRP collects greenhouse gas data from 47 source categories and currently has several years of data from these sources, including reports from more than 8,000 direct emitters and suppliers of GHGs. Among others, these include electrical generation, many production and manufacturing plants, solid and industrial waste landfills, geologic carbon dioxide sequestration and carbon dioxide injection, industrial wastewater treatment, and manure management.

Continued GHG Reporting

Most businesses and services will likely continue reporting, since they already have the technology in place and get a positive return on investment. Many organizations use these data in their sustainability/climate reporting, including measuring progress on meeting GHG reduction goals. Importantly, data collection allows them to identify and proactively act on operational issues, creating more efficiency. Finally, some states have a mandatory GHG program requiring reporting utilizing the federal criteria, so organizations will continue reporting to comply with state and local regulations. Many have found that providing the reports helps them remain good community stewards, show transparency in environmental programs, and avoid nuisance complaints.

For example, many landfills use data collection to balance the wellfield. A balanced wellfield optimizes GHG collection, which lowers odors and nuisance complaints, provides a safer working environment, and results in a steadier flow of better quality methane to enable a greater return on investment in Renewable Natural Gas plants.

Subpart W

EPA’s proposed amendments consist of two parts. First, the EPA proposes to permanently remove program obligations for facilities in the natural gas distribution segment. Under the proposal, facilities in the natural gas distribution segment of subpart W would no longer report to the EPA after the reporting year 2024.

Second, for the remaining nine segments of subpart W, EPA is proposing to suspend program reporting requirements until the reporting year 2034.

If Finalized as Proposed

No industries need to submit reports with 2025 data. However, EPA proposes extending the March 31, 2026, reporting deadline until June 10, 2026. If finalized before March 31, 2026, this extension would allow EPA time to issue a final rule before the regulatory deadline for reporting year 2025.

Public Hearings

EPA will hold a virtual public hearing for the proposed action 15 days after publication of this proposal in the Federal Register. Further details about the public hearing, including registration, will be available at https://www.epa.gov/ghgreporting/rulemaking-notices-ghg-reporting

EPA will accept comments for 47 days after publishing the proposal in the Federal Register.

Submit comments, identified by Docket ID No. EPA-HQ-OAR-2025-0186, using one of the following methods:

  • Go to https://www.regulations.gov/ and follow the online instructions to submit a comment.
  • Mail: U.S. Environmental Protection Agency, EPA Docket Center, Docket ID No. EPAHQOAR-2025-0186, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
  • Hand/Courier Delivery: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. The Docket Center’s hours of operation are 8:30 a.m.-4:30 p.m., Monday-Friday (except federal holidays).

Greenhouse Gas Reporting Resources

 

 

Posted by Diane Samuels at 3:04 pm
SCS Address

Corporate Headquarters

3900 Kilroy Airport Way Suite 300
Long Beach, CA 90806

Telephone

1 (800) 767-4727
1 (562) 427-0805 | FAX
Contact Us

Required Posting
Send us a message
×