October 20, 2025

EPA Proposal Would Eliminate Greenhouse Gas Reporting

EPA’s greenhouse gas reporting program (GHGRP) requires reporting on GHG data and other relevant information from large GHG emission sources, fuel and industrial gas supplies, and CO₂ injection sites. Regulators, the regulated community, and the public use the collected data to track facilities’ GHG emissions, identify opportunities to cut pollution, reduce energy consumption, and cut costs. However, on September 16, 2025, EPA proposed to remove nearly all greenhouse gas reporting program obligations for most sources under Part 98. [90 FR 44591]

The GHGRP was created in 2009 as mandated by the 2008 Consolidated Appropriations Act, and in part to fulfill U.S. obligations under the United Nations Framework Convention on Climate Change. Scrapping the program not only violates the congressional requirement and international agreement, but it also potentially endangers billions of dollars in business investment associated with carbon sequestration. EPA argues that since CAA Section 114(a)(1) [42 U.S.C. Section 7414(a)(1)] allows the agency to collect emissions data from sources but does not mandate doing so, collecting such data is unnecessary. [90 FR 44597] Following this logic, could EPA not eventually claim that data collection under NSPS and NESHAP is also unnecessary since those statutory sections (Sections 111 and 112, respectively) don’t contain their own data collection provisions?

If finalized, the rule would eliminate all GHG reporting requirements except for petroleum and natural gas systems under Part 98, Subpart W. The Subpart W reporting requirements would also be suspended until 2034 and not apply to the natural gas distribution industry. The 2034 reporting provision is mandated by the recently amended CAA Section 136(c) [42 U.S.C. Section 7436(g)]. Comments may be submitted through November 3, 2025 via Docket ID No. EPA-HQ-OAR-2025-0186.

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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.