EPA Proposes to Cancel Greenhouse Gas Reporting Program Public Comment DEADLINE TBD

September 17, 2025

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by Erin Krueger (Biomass Magazine) The U.S. EPA on Sept. 12 released a proposed rule to end the Greenhouse Gas Reporting Program. If finalized, the proposal would remove reporting obligations for most large facilities, all fuel and industrial gas suppliers, and CO2 injection sites.

Development of EPA’s GHGRP was mandated by Congress as part of the Fiscal Year 2008 Consolidated Appropriations Act. The agency in 2009 released a final rule implementing the program, with data collecting beginning the following year.

The GHGRP currently collects GHG data from 47 source categories. More than 8,000 facilities and suppliers in the U.S. are required to calculate and submit data on their GHG emissions annually. Many ethanol plants and other biorefineries are among the facilities currently subject to the GHGRP.

Annual data collected under the program has historically been released in October. The EPA most recently released data collected under the GHGRP on Oct. 15, 2024. The release included data on 2023 CO2 sequestration volumes at operational carbon capture and sequestration (CCS) projects at three U.S. ethanol plants, including those operated by Red Trail Energy, Blue Flint Ethanol, and ADM.

The EPA on March 12, 2025, announced plans to reconsider the GHGRP. The agency on Sept. 12 announced the release of a proposed rule that aims to amend the GHGRP to remove all GHG reporting requirements, except those subject to the Waste Emissions Charge, which is a fee established by the Inflation Reduction Act to tax methane emissions from the oil and gas industry that exceed certain thresholds. The One Big Beautiful Bill Act, however, amended U.S. law so that WEC now applies only to emissions reported for calendar year 2034 and later.

In announcing its plans to end the GHGRP, the EPA said its review determined there is no requirement under Clean Air Act section 114(a) to collect GHG emission information from businesses. The agency also said that continuing the ongoing, costly data collection is not useful to fulfill any of the agency’s statutory obligations.

The proposed rule is set to be published in the Federal Register on Sept. 16, officially opening a 47-day comment period. Stakeholders are encouraged to submit comments within 30 days to best be assured of consideration. The EPA also announced plans to hold a virtual public hearing 15 days after publication of the proposed rule in the Federal Register.

The Carbon Capture Coalition is slamming the proposed rule for engendering billions of dollars in investments in CCS technologies.

“Today’s announcement from the US Environmental Protection Agency (EPA) regarding the repeal of certain subparts of the Greenhouse Gas Reporting Program (GHGRP) will not advance carbon storage – something EPA Administrator Zeldin has publicly supported,” said Jessie Stolark, executive director of the CCC. “By canceling subparts of the GHGRP that are inextricably linked to the election of the federal Section 45Q tax credit, this proposed rule endangers billions of dollars in investments from American businesses in these technologies.

“EPA’s GHGRP, along with the Class VI injection well program, serves as the regulatory backbone of the carbon management industry, underpinning the integrity, transparency, and accountability of the 45Q tax credit in the United States. Following bipartisan reforms to the tax credit in 2018, members of the Carbon Capture Coalition worked extensively to develop consensus recommendations to the Department of the Treasury and the Internal Revenue Service (IRS) on regulations governing the election of 45Q. These recommendations ultimately aimed to uphold the need for project developers to report volumes stored in saline geologic formations under EPA’s GHGRP subpart RR.

“Regulations promulgated in 2021 by Treasury and the IRS ultimately reflected the Coalition’s recommendation for project developers to establish monitoring, reporting, and verification (MRV) programs for geologic storage, and reaffirmed the reporting requirements for secure geologic storage through subpart RR of the GHGRP,” Stolark continued. “Regulations require taxpayers claiming the 45Q tax credit for secure geologic storage to demonstrate the amount of CO2 stored using the GHGRP reporting mechanism, which provides important public transparency and accountability for the tax credit. Today, these reporting mechanisms enjoy broad support and buy-in across the carbon management industry and stakeholder community.

“These regulations have been working as intended since the issuance of final guidance in 2021, and dozens of companies have approved MRV files from the US EPA and are familiar with reporting volumes stored under subpart RR, without issue. Carbon management project developers have already invested an estimated $77.5 billion in capital expenditures across the nation in existing and near-term projects. This amount is far more than the $2.4 billion in savings cited by EPA in their announcement ending 46 of the 47 subparts of the program. Relevant subparts of the GHGRP are mission-critical to the business plan for those projects and remain crucial components to electing the 45Q tax credit – ensuring that these projects and investments translate into corresponding jobs and additional economic benefits. Therefore, it is not an understatement that the long-term success of the carbon management industry—and the significant economic and environmental benefits it fosters across the country—rests on the robust reporting mechanisms in place through the US EPA.

“As the EPA’s proposed rule moves forward for public comment, the Carbon Capture Coalition’s more than 100 members, representing industry, labor, and environmental and energy policy organizations, will be eager to respond and demonstrate the intrinsic role relevant subparts of the GHGRP play in the commercialization of this important industry,” Stolark added. “Make no mistake, should this proposed rule be finalized as is, the fate of hundreds of announced carbon management projects nationwide and the billions of dollars in capital investments and corresponding jobs will be on the line.”

A full copy of the proposed rule is available on the EPA website. READ MORE

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EPA Releases Proposal to End the Burdensome, Costly Greenhouse Gas Reporting Program, Saving up to $2.4 Billion (U.S. Environmental Protection Agency)

Excerpts from U.S. Environmental Protection Agency: Today (September 12, 2025), in accordance with President Trump’s Day One executive orders, U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin announced a proposed rule to end the burdensome Greenhouse Gas Reporting Program (GHGRP), saving American businesses up to $2.4 billion in regulatory costs while maintaining the agency’s statutory obligations under the Clean Air Act (CAA). Unlike other mandatory information collections under the CAA, the GHGRP is not directly related to a potential regulation and has no material impact on improving human health and the environment. If finalized, the proposal would remove reporting obligations for most large facilities, all fuel and industrial gas suppliers, and CO2 injection sites.

“Alongside President Trump, EPA continues to live up to the promise of unleashing energy dominance that powers the American Dream. The Greenhouse Gas Reporting Program is nothing more than bureaucratic red tape that does nothing to improve air quality,” said EPA Administrator Zeldin. “Instead, it costs American businesses and manufacturing billions of dollars, driving up the cost of living, jeopardizing our nation’s prosperity and hurting American communities. With this proposal, we show once again that fulfilling EPA’s statutory obligations and Powering the Great American Comeback is not a binary choice.”

By reducing the overall regulatory burden, current regulated parties will be able to focus compliance expenditures on actual, tangible environmental benefits. As the agency continues to Power the Great American Comeback, this proposal represents a significant step toward streamlining operations, cutting unnecessary red tape, unleashing American energy, and advancing EPA’s core mission of protecting human health and the environment.

The GHGRP requires 47 source categories, covering over 8,000 facilities and suppliers in the U.S. to calculate and submit their greenhouse gas (GHG) emissions reporting annually. Following a careful review, EPA proposed that there is no requirement under CAA section 114(a) to collect GHG emission information from businesses nor is continuing the ongoing costly data collection useful to fulfill any of the agency’s statutory obligations. Therefore, EPA is proposing to remove all GHG reporting requirements, except for those subject to the Waste Emissions Charge (WEC).

CAA section 136 only requires data collection for segments of subpart W (petroleum and natural gas systems) subject to the WEC. On July 4, 2025, President Trump signed the One Big Beautiful Bill Act, which amended CAA section 136(g), so that the WEC now applies to emissions reported for calendar year 2034 and for each year thereafter. In accordance with the law, EPA will not be collecting subpart W data until 2034.

EPA will initiate a public comment period to solicit input. Further information on the public comment process and instructions for participation will be published in the Federal Register and on the EPA website.

For more information on the proposed rule and how to comment, please see EPA’s fact sheet here.

Background

On March 12, 2025, Administrator Zeldin announced that the agency was reconsidering the GHGRP. This was announced in conjunction with a number of historic actions to advance President Trump’s Day One executive orders and Power the Great American Comeback. While accomplishing EPA’s core mission of protecting human health and the environment, the agency is committed to fulfilling President Trump’s promise to unleash American energy.

Congress authorized funding for the creation of the GHGRP in the Fiscal Year 2008 Consolidated Appropriations Act. The Obama EPA promulgated the program and began collecting data in 2010. The GHGRP currently requires reporting of GHG data from certain large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites.

November 18, 2024, the Biden EPA issued the final WEC rule to implement the 2022 Inflation Reduction Act’s methane tax provisions. Congress amended the CAA by adding section 136, “Methane Emissions and Waste Reduction Incentive Program for Petroleum and Natural Gas Systems.” Among other things, CAA section 136 (c)-(g) required EPA to impose and collect a waste emission charge on methane emissions that exceeded specified thresholds from applicable facilities that reported more than 25,000 metric tons of carbon dioxide equivalent (MTCO2e) of GHGs under the petroleum and natural gas systems subpart W source category.

On March 14, 2025, President Trump signed a joint resolution of disapproval under the Congressional Review Act, disapproving the November 2024 final WEC rule. READ MORE