U.S. EPA Greenhouse Gas Reporting Program (GHGRP) Amendment

Overview

The Greenhouse Gas Reporting Program (GHGRP), administered by the U.S. Environmental Protection Agency (EPA), has collected emissions data from major sources since the program's establishment in 2009. On September 9, 2025, however, EPA published a proposed rule under the Clean Air Act that would rescind or reduce reporting requirements for the large majority of covered sectors. Notably, the proposal would delay the reporting requirement for methane emissions from the oil and gas sector (Subpart W) until 2034. This policy shift is expected to have ripple effects on other programs that rely on GHGRP data, including Clean Air Act performance standard assessments, fee calculations for methane emission reduction programs, and carbon capture tax credit calculations under the Inflation Reduction Act. Within the oil and gas industry itself, views are mixed: some welcome the reduced reporting burden, while others call for maintaining the reliability of the underlying database.

Enforcement Timeline

2009: GHGRP program established

September 9, 2025: EPA publishes a proposed rule to rescind or reduce reporting requirements for most sectors, including a proposal to delay oil and gas sector methane reporting (Subpart W) until 2034

November 3, 2025: Public comment period closes

Within 2026: Final rule publication expected, though as of August 24, 2026, a specific publication date has not been confirmed

Related Regulations / Topics

U.S. EPA Greenhouse Gas Reporting Program (GHGRP) Reconsideration Proposal: Impact of the Loper Bright Ruling's Abolition of Chevron Deference

In April 2024, EPA under the Biden administration published an amended final rule for the GHGRP (Greenhouse Gas Reporting Program; 40 CFR Part 98), expanding reporting coverage for the oil and gas sector (Subpart W) and other industrial processes and tightening calculation methodologies (including introducing direct methane measurement requirements). However, in June 2024, the U.S. Supreme Court's decision in Loper Bright Enterprises v. Raimondo abolished the nearly 40-year-old "Chevron deference" doctrine—under which courts deferred to agencies' interpretations of their statutory authority—resulting in significantly heightened judicial scrutiny of EPA's interpretation of its own legal authority. In response, EPA under the Trump administration is preparing, in 2026, a revised proposed rule aimed at reconsidering the strengthened calculation requirements, including Subpart W, and reducing reporting burden, in a move to scale back its authority in order to avoid legal challenges in court.

Business Impact

Companies with U.S. manufacturing operations are likely to be relieved of the previously anticipated expansion of reporting requirements. At the same time, because other federal programs depend on GHGRP data—including the basis for calculating carbon capture tax credits under the IRA—companies should confirm whether the calculation methods for incentives they rely on will be affected. Oil and gas companies in particular are expected to see near-term reporting burdens eased significantly due to the extended delay of methane reporting requirements.

Official Sources & Reference Links

EPA (US Environmental Protection Agency) — Greenhouse Gas Reporting Program (GHGRP)