New York Finalizes the Mandatory GHG Reporting Rule – 6 NYCRR Part 253

On December 1, 2025, the New York State Department of Environmental Conservation (NYSDEC) finalized 6 NYCRR Part 253: Mandatory Greenhouse Gas Reporting Program (Reporting Program or Part 253). From April to July of 2025 NYSDEC received over 3,000 comments and addressed all comments in the Assessment of Public Comment document for the proposed Reporting Program. The Reporting Program will require companies that emit over 10,000 metric tons of carbon dioxide equivalent (MTCO₂e) to report greenhouse gas (GHG) emissions annually to NYSDEC. The first reporting period for this rule is January 1, 2026 through December 31, 2026, with the first submittal period scheduled for June 1, 2027.

How will the proposed reconsideration of the Federal Part 98 GHGRP affect Part 253?

On September 16, 2025, the United States Environmental Protection Agency (U.S. EPA) published a proposed rule to Reconsider the Greenhouse Gas Reporting Program (GHGRP) required in 40 CFR Part 98 under Docket No.EPA-HQ-OAR-2025-0186. Part 253 is heavily based on the Federal GHGRP under 40 CFR Part 98 but with some key differences. Refer to our previous blog on the differences between 40 CFR Part 98 and 6 NYCRR Part 253. In the Frequently Asked Questions document for the Reporting Program NYSDEC has outlined that the reconsideration of the Federal GHGRP will not affect the implementation of Part 253. NYSDEC sees the 40 CFR Part 98 references as static references that informed the development of the Part 253 provisions and does not plan to rely on future versions of 40 CFR Part 98. It is unclear if NYSDEC will document the historic version of 40 CFR Part 98 on the NYSDEC website.

What has changed from the proposed rule?

The overall rule has not changed significantly, but there are some key changes to note:

• Updated the definition of “Biomass-Derived Fuels” to include forest products manufacturing bioenergy feedstocks.
• Updated the definition for “Renewable Natural Gas” to include Biomethane and synthetic methane produced from biomass-derived CO₂ and renewable hydrogen.
• Updated the definition for “Transmission Pipeline” to include the Hinshaw exemption as referenced in section 1(c) of the Natural Gas Act (15 U.S.C. 717 et seq.) (2023).
• Postponed the deadline for third party verification for the first two years of reporting from August 10^th to December 1^st for Reporting years 2026 and 2027.
• Specified calibration postponements requests must be submitted before July 1, 2026 for the first reporting period.
• Requires that facilities which combust wood residuals must also report the state from which the wood was removed. Part 253 now states “The disclosure of the state where the wood was removed may be based on an annual percentage of New York and non-New York wood removals as identified by the same primary timber processer providing the wood residuals.”
• Facilities can exclude reporting of electricity purchased from the utility market.
• Facilities must submit a case-by-case demonstration under 253-2.7 to NYSDEC for fuels brought on-site that are not used for combustion. This submittal must include a mass balance or a metered flow measurement device to prove the fuels are converted into durable products and not combusted at the facility.
• Updated to default GHG emissions factors provided in Table 2-3 of the rule.
• Emissions Monitoring and Measurement Plan (EMMP) initial submittal is delayed until September 1, 2026 instead of March 1, 2026. These submittals are due every three years, so the second submittal will be March 1, 2029.

What is the reporting deadline?

The first reporting period is January 1, 2026 to December 31, 2026 but there are still some important reporting deadlines in 2026 to look out for. The key reporting deadlines are:

• July 1, 2026: Request for extension on calibration requirements due to potential issues with the calibration timeline.
• September 1, 2026: EMMP for applicable reporters under Sections 2.2 and 2.13 of the rule.
• December 31, 2026: Large emissions source’s GHG monitoring plan due to NYSDEC. This report is only submitted in future years if there are changes at the facility.
• June 1, 2027: First GHG emissions data report due for reporting year 2026. Annual GHG emissions reports are due each subsequent year on June 1^st.
• December 1, 2027 and 2028: Third party verification statements due for reporting year 2026 and 2027, respectively. For subsequent years, verification statements are due August 10. The deadline is changed for the third year of reporting, e.g., in 2029.

What should my facility do to prepare?

Facilities should initially assess their applicability to the rule and the associated calculation requirements. This evaluation is more important for smaller facilities that are not subject to the Federal GHGRP because they need to assess their current GHG emissions under the Part 253 Reporting Program. Facilities should begin gathering the required data for reporting 2026 GHG emissions, including, but not limited to, fuel usage records, carbon content information for specific fuels, throughput figures, and calibration documentation. Additionally, facilities are advised to develop comprehensive GHG monitoring plans to ensure compliance with the NY Reporting Rule.

ALL4 can help with identifying 6 NYCRR Part 253 applicability, developing GHG monitoring reports, and calculating GHG emissions. For inquiries about ALL4’s services or follow-up questions regarding Part 253 regulations, please contact Louise Shaffer at lshaffer@all4inc.com or your ALL4 project manager.