EPA Mandatory Greenhouse Gas Reporting Program

The EPA Greenhouse Gas Reporting Program (GHGRP) requires approximately 8,000 large industrial facilities to measure and report their greenhouse gas emissions to EPA annually under 40 CFR Part 98. Covering facilities responsible for roughly 85–90% of U.S. industrial GHG emissions, the program feeds the public FLIGHT database (Facility Level Information on GHGs Tool) — the most comprehensive record of facility-level U.S. industrial GHG emissions available. GHGRP is a disclosure rule, not a performance standard: facilities must accurately report emissions using EPA-approved methodologies, but the program does not cap, limit, or penalize those emissions.

Current Rule (2026)

What This Rule Does

Since 2010, large industrial facilities in the United States have been required to measure and report their greenhouse gas emissions to EPA under the Greenhouse Gas Reporting Program (GHGRP), codified at 40 CFR Part 98. The program covers approximately 8,000 facilities across more than 40 industrial sectors — together responsible for about 85–90% of all U.S. industrial greenhouse gas emissions. The data flows into EPA's public FLIGHT database (Facility Level Information on GHGs Tool), making it the most comprehensive public record of facility-level U.S. industrial GHG emissions in existence.

The program does not cap, limit, or penalize emissions — it is a reporting and disclosure rule, not a performance standard. Facilities above the reporting threshold must measure their GHG emissions using EPA-approved methodologies, submit annual reports by March 31 of each following year, and maintain records for at least three years. EPA verifies reported data against other regulatory submissions and facility characteristics but does not independently audit every facility.

Part 98 is organized around source categories: each Subpart (C through ZZ, using letter and double-letter designations) covers a specific industrial sector and specifies how to calculate and report emissions from that sector's unique processes. Subpart C (General Stationary Fuel Combustion) covers emissions from boilers, heaters, and other combustion devices and applies to almost every facility above the threshold. Sector-specific Subparts then add additional reporting requirements for the emissions specific to that industry's processes — cement kilns releasing CO₂ during calcination, coal mines releasing methane from coal seams, semiconductor fabs releasing fluorinated gases during etching, and so on.

Key Provisions

Applicability and Threshold (Subpart A)

• § 98.1–98.6 — Facilities must report if they contain a unit subject to a listed source category (Subpart B lists applicable categories) AND their total facility emissions exceed 25,000 metric tons CO₂ equivalent (MTCO₂e) per year; "facility" means all contiguous or adjacent stationary sources under common ownership or control
• Suppliers of fossil fuels (Subparts LL, MM, NN) report on the carbon content of fuels delivered to the economy (an "upstream" calculation), not on their own combustion emissions; this captures emissions that would ultimately occur from fuel use

General Stationary Fuel Combustion (Subpart C)

• § 98.30 — Covers all stationary combustion devices (boilers, heaters, kilns, dryers, turbines, engines) that combust solid, liquid, or gaseous fuels
• § 98.31 — Facilities must report if they contain one or more stationary fuel combustion sources with a combined annual heat input above the applicable threshold
• § 98.32 — Must report CO₂, CH₄, and N₂O mass emissions from each combustion unit
• § 98.33 — Calculation methods: (1) Tier 1 (default emission factors by fuel type), (2) Tier 2 (fuel-specific higher heating values and emission factors), (3) Tier 3 (Continuous Emission Monitoring System data), (4) Tier 4 (fuel flow plus molecular composition); higher tiers are required for units above certain size thresholds
• § 98.34 — Monitoring requirements: large units (>250 MMBtu/hr) must use CEMS or fuel flow meters with periodic fuel sampling; smaller units may use fuel billing data and default factors
• § 98.36 — Data reporting: annual report must include unit-by-unit emissions, fuel type and consumption quantities, monitoring method used, missing data periods, and calculation parameters

Sector-Specific Source Categories (Selected)

• Subpart W (Petroleum and Natural Gas Systems) — covers extraction wells, gathering pipelines, processing plants, transmission compressor stations, and distribution systems; requires measurement of methane emissions from equipment leaks, venting, and flaring; the 2024 amendment (89 FR 31708) significantly expanded monitoring requirements for well sites and compressor stations
• Subpart C (Stationary Combustion), Subpart D (Electricity Generation) — cover the electric power sector's combustion emissions
• Subpart FF (Underground Coal Mines) — methane liberated from coal seams during mining; mines above 36,500 tons of coal produced annually must report
• Subpart I (Electronics Manufacturing) — fluorinated GHG emissions from semiconductor, MEMS, and display manufacturing; covered gases include NF₃, SF₆, and numerous HFCs and PFCs used in plasma etching and chemical vapor deposition processes
• Subpart JJ (Manure Management) — methane and nitrous oxide from confined animal feeding operations with large manure management systems; covers the agricultural sector's significant GHG contribution
• Subparts RR, VV (Geologic Sequestration) — report CO₂ injected into geologic formations for sequestration; tracking ensures stored carbon remains sequestered and doesn't leak back to atmosphere

How It Affects You

If you operate an industrial facility above 25,000 MTCO₂e/year: Annual GHG reporting is a federal legal obligation. The March 31 deadline is firm — late or missing reports trigger penalties under the Clean Air Act. Failure to use EPA-approved calculation methodologies is a reporting violation. Retain monitoring data, fuel records, and calculation worksheets for at least three years. Large facilities with combustion units over 250 MMBtu/hr must verify their reporting against CEMS data; smaller facilities typically use fuel billing records and default emission factors.

If you are in oil, gas, or coal: The GHGRP Subpart W oil and gas reporting requirements were substantially expanded by a 2024 final rule. Upstream oil and gas operators now face more granular monitoring requirements for well site emissions, compressor station venting and leaks, and gathering pipelines. These reporting data directly inform EPA's monitoring of methane — a GHG 80 times more potent than CO₂ over 20 years — and connect to EPA's methane emission standards under the Clean Air Act's New Source Performance Standards (40 CFR Part 60 Subpart OOOOa/OOOOb).

If you want to understand a facility's environmental impact: EPA's FLIGHT tool (available at ghgdata.epa.gov) provides searchable access to reported GHG data for every reporting facility in the country. You can search by facility, state, sector, or greenhouse gas type, and download annual emissions data going back to 2010. GHGRP data is used by investors, community groups, journalists, academic researchers, and state and local governments to assess industrial GHG emissions. The data is also used in EPA's national GHG inventory.

If you are a small business or agricultural operation: The 25,000 MTCO₂e threshold is genuinely meaningful — small businesses rarely trigger GHGRP reporting obligations. For context, 25,000 MTCO₂e per year is roughly equivalent to the annual emissions of 5,000 passenger vehicles. Most small manufacturers, commercial buildings, and farms are well below this threshold. Agricultural operations are specifically addressed: livestock and crop production are generally not directly covered by GHGRP (though manure management at very large CAFOs is), and agricultural CH₄ and N₂O are tracked in the national inventory through other methods.

Statutory Authority

This rule implements:

• 42 U.S.C. § 7401 (Clean Air Act) — The foundational Clean Air Act authority; EPA promulgated the GHGRP under its general authority to gather information necessary for administering the Act and in response to Congressional direction in the FY2008 Consolidated Appropriations Act requiring a mandatory GHG reporting system

Recent Rulemakings

• 89 FR 31708 (April 2024) — "Subpart W" comprehensive revision: significantly expanded monitoring and reporting requirements for petroleum and natural gas systems, requiring more granular measurement of methane from well sites, compressor stations, and processing plants; also updated calculation methodologies for storage tanks and other equipment; one of the largest GHGRP amendments since the program's inception
• 74 FR 56374 (October 2009) — Original GHGRP rule, establishing the program framework, threshold, source categories, and calculation methodologies; first reports due for calendar year 2010 emissions
• 75 FR 74488–79157 (2010) — Multiple companion rules adding new source categories (electronics manufacturing, manure management, geologic sequestration) to the original framework

Recent Developments

• Subpart W methane expansion (April 2024): EPA's comprehensive revision of Subpart W (petroleum and natural gas systems) — the largest GHGRP amendment since the program's inception — significantly expanded monitoring requirements for the oil and gas sector. The rule requires more direct measurement (rather than calculation from engineering estimates) at well sites, compressor stations, and processing facilities, and updates methodologies for equipment leak detection. The expansion was driven by satellite and aerial measurement data showing that engineering-based emission estimates significantly undercount actual methane emissions.
• GHGRP as foundation for methane fee: The IRA's methane charge (effective 2024 for emissions above waste reduction standards) relies on GHGRP-reported data as the basis for fee calculation. Petroleum and natural gas facilities that exceed per-facility methane thresholds owe per-metric-ton charges under the Waste Emissions Charge. GHGRP data accuracy has direct financial consequences for covered facilities, increasing the stakes of the Subpart W methodological updates.
• Trump EPA methane charge rollback: The Trump EPA announced its intent to rescind or significantly narrow the IRA methane waste emissions charge in 2025, arguing it imposes undue costs on domestic energy production. If the methane fee is eliminated, GHGRP's role as a mandatory compliance trigger would be reduced, though the reporting program itself (authorized separately under the Clean Air Act) would remain. The methane fee rollback effort faced Congressional and legal obstacles given the IRA's statutory structure.
• GHGRP data quality and verification: EPA GHGRP data is publicly available on its emissions tracking website (ghgdata.epa.gov) and is widely used by climate researchers, investors (for Scope 3 supply chain emissions), and environmental advocacy organizations. The reliability of GHGRP data — particularly for oil and gas methane — has been questioned given the reliance on engineering calculations rather than direct measurement. The Subpart W revision is intended to close this gap.

DOE Voluntary Greenhouse Gas Reporting Program

Before EPA established mandatory GHG reporting in 2009, the Department of Energy operated a parallel voluntary reporting program under 10 CFR Part 300 — the General Guidelines for the Voluntary Reporting of Greenhouse Gases, implementing Section 1605(b) of the Energy Policy Act of 1992 (42 U.S.C. § 13385). The DOE voluntary program allowed companies and organizations to register their emission reductions in a federal database, creating a historical record of voluntary climate action. Key features of the DOE program that differ from EPA's mandatory GHGRP:

• Voluntary vs. mandatory: any entity could participate in the DOE program; participation was not required regardless of size or emissions level; EPA's GHGRP applies mandatorily to facilities above the 25,000 metric ton CO₂e threshold
• Entity-level vs. facility-level reporting: the DOE program accepted reporting from entire organizations (§ 300.3) rather than facility-by-facility reporting as EPA's GHGRP requires; this allowed companies to aggregate reductions across all operations
• Emission reductions focus: the DOE program's original purpose was to document voluntary emission reductions and establish a baseline registry; EPA's GHGRP measures absolute emissions regardless of trend
• Certification and verification: certified reports under § 300.10 were signed by a senior official; independent third-party verification was encouraged but not required (§ 300.11)
• Entity registration: approved reports were entered into a federal registry of entity emission reductions (§ 300.12), intended to give voluntary early movers a recognized record should future mandatory reporting or carbon trading create value for early reductions

The DOE voluntary program was significantly less influential than EPA's GHGRP because the lack of a mandatory carbon price or regulatory use for the registered reductions gave companies limited incentive to participate beyond reputational benefit. The program was effectively superseded by EPA's mandatory GHGRP and remains on the books but has seen minimal activity since EPA's program became the primary federal GHG data collection mechanism. The GHGRP's FLIGHT database is the authoritative source for U.S. industrial facility-level GHG data; the DOE voluntary registry does not feed into FLIGHT.

Pending Action

The Trump EPA's effort to rescind or narrow the IRA methane waste emissions charge — which relies on GHGRP data — is the central pending regulatory action affecting this program. If the methane fee is eliminated through rulemaking or Congressional action, GHGRP's financial consequences for oil and gas facilities would be reduced, but the underlying reporting requirements (authorized under Clean Air Act § 114) would remain unless separately rescinded. EPA's unified regulatory agenda includes potential modifications to GHGRP reporting thresholds and methodology for sectors where the administration has identified burden reduction opportunities. Investors and financial institutions using GHGRP data for climate disclosure should monitor any proposed changes to reporting scope or verification requirements.