U.S. EPA’s Proposed Reconsideration of the GHGRP

On September 16, 2025 the United States Environmental Protection Agency (U.S. EPA) published a proposed rule to Reconsider the Greenhouse Gas (GHG) Reporting Program (GHGRP) under Docket No. EPA-HQ-OAR-2025-0186. The proposed rule will remove most of the reporting requirements for almost all source categories including natural gas distribution industry segments under 40 CFR Part 98, Subpart W – Petroleum and Natural Gas Systems (Subpart W), then suspend all other reporting requirements under Subpart W. This coincides with the reconsideration of the 2009 Endangerment Finding, which classified GHG emissions as a threat to human health and welfare.

What Is the Federal GHGRP?

The Federal GHGRP was enacted in 2010 under 40 CFR Part 98 as part of the Clean Air Act (CAA). This reporting program requires manufacturing industries that emitted over 25,000 metric tons of carbon dioxide equivalent (MT CO₂e) annually or specific industries to report their direct GHG emissions from the facility on an annual basis. The emission from these more than 8,000 covered facilities accounts for over 50% of the United States’ total GHG emissions. The data from the GHGRP is used in the United States’ GHG inventory report each year, which is used for the country’s GHG reporting obligations under international treaties like the United Nations Framework Convention on Climate Change (UNFCCC) and the Paris Agreement. It is unknown how the proposed repeal will affect the status of the United States under international climate change treaties.

What Is Changing with This Proposal?

In short, 46 subparts of 40 CFR Part 98 would be removed entirely, and Subpart W would be partially removed. The following subparts are proposed to be permanently removed from the GHGRP:

• C (General Stationary Fuel Combustion Sources)
• D (Electricity Generation)
• E (Adipic Acid Production)
• F (Aluminum Production)
• G (Ammonia Manufacturing)
• H (Cement Production)
• I (Electronics Manufacturing)
• K (Ferroalloy Production)
• L (Fluorinated Gas Production)
• N (Glass Production)
• O (HCFC–22 Production and HFC–23 Destruction)
• P (Hydrogen Production)
• Q (Iron and Steel Production)
• R (Lead Production)
• S (Lime Manufacturing)
• T (Magnesium Production)
• U (Miscellaneous Uses of Carbonate)
• V (Nitric Acid Production)
• W (Petroleum and Natural Gas Systems – natural gas distribution industry segment only)
• X (Petrochemical Production)
• Y (Petroleum Refineries)
• Z (Phosphoric Acid Production)
• AA (Pulp and Paper Manufacturing)
• BB (Silicon Carbide Production)
• CC (Soda Ash Manufacturing)
• DD (Electrical Transmission and Distribution Equipment Use)
• EE (Titanium Dioxide Production)
• FF (Underground Coal Mines)
• GG (Zinc Production)
• HH (Municipal Solid Waste Landfills)
• II (Industrial Wastewater Treatment)
• JJ (Manure Management)
• LL (Suppliers of Coal-based Liquid Fuels)
• MM (Suppliers of Petroleum Products)
• NN (Suppliers of Natural Gas and Natural Gas Liquids)
• OO (Suppliers of Industrial Greenhouse Gases)
• PP (Suppliers of Carbon Dioxide)
• QQ (Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams)
• RR (Geologic Sequestration of Carbon Dioxide)
• SS (Electrical Equipment Manufacture or Refurbishment)
• TT (Industrial Waste Landfills)
• UU (Injection of Carbon Dioxide)
• VV (Geologic Sequestration of Carbon Dioxide with Enhanced Oil Recovery Using ISO 27916)
• WW (Coke Calciners)
• XX (Calcium Carbide Producers)
• YY (Caprolactam, Glyoxal, and Glyoxylic Acid Production)
• ZZ (Ceramics Manufacturing)

The reporting requirements for Subpart W, as established by the Inflation Reduction Act (IRA), cannot be entirely repealed due to the provisions set forth in the legislation. Therefore, U.S. EPA proposed to delay reporting of the following industry segments under Subpart W until reporting year (RY) 2034:

• Onshore petroleum and natural gas production
• Offshore petroleum and natural gas production
• Onshore natural gas processing
• Onshore natural gas transmission compression
• Onshore petroleum and natural gas gathering and boosting
• Onshore natural gas transmission pipelines
• Underground natural gas storage
• Liquefied natural gas (LNG) storage
• LNG import and export equipment

U.S. EPA is also proposing to extend the RY 2025 deadline from March 31, 2026 to June 10, 2026 to allow more time for the finalization of the proposed rule.

How Does This Affect My Facility?

There is a high potential that the repeal of the GHGRP will be in effect prior to the reporting deadline for RY 2025. If the proposed amendments are finalized, your facility will no longer need to comply with the recordkeeping and reporting requirements under the GHGRP going forward. Although for the time being, we recommend that your facility keeps up with all recordkeeping and reporting requirements outlined in the rule until the reconsideration is final.

Even though the Federal GHGRP may be repealed, it is important to monitor state GHG reporting requirements and understand their applicability to your facility. At present, California Oregon, and Washington have established GHG reporting requirements, with New York expected to implement similar regulations in the near future.

What Is Next?

We suspect U.S. EPA will move on this quickly, but we need to first see the decision on the 2009 Endangerment Findings. Nonetheless, it is anticipated that U.S. EPA’s final decision will be subject to litigation.

U.S. EPA is accepting public comments on the proposed rule through November 2, 2025, under Docket ID No. EPA-HQ-OAR-2025-0186. Comments can be submitted at https://www.regulations.gov/ or by mail. U.S. EPA is also holding a virtual public hearing on October 1, 2025.

Need Help Understanding How this Affects You?

If you are wondering how this interim final rule will affect your facility directly, please reach out to your ALL4 project manager or contact Louise Shaffer at lshaffer@all4inc.com.