EPA’s Greenhouse Gas Reporting Program

Updated March 20, 2023

EPA’s Greenhouse Gas Reporting Program

The U.S. Environmental Protection Agency’s (EPA’s)

Greenhouse Gas Reporting Program (GHGRP) requires

certain facilities to report their emissions of greenhouse

gases (GHGs). In addition, the GHGRP requires suppliers

of specific products, such as natural gas and petroleum, to

report the GHG emissions that would ultimately result from

the use of their products. Since 2011, the GHGRP has

collected annual emissions data from nearly 8,000 large

industrial facilities and other sources in the United States.

According to EPA, 85%-90% of annual man-made U.S.

GHG emissions have been reported under the program.

GHGRP Authorities and Purpose

The Consolidated Appropriations Act, 2008 (P.L. 110-161)

provided $3.5 million for EPA to develop and publish a rule

that would “require mandatory reporting of greenhouse gas

emissions above appropriate thresholds in all sectors of the

economy of the United States.” In the accompanying joint

explanatory statement, Congress directed EPA to “use its

existing authority under the Clean Air Act” to promulgate

this rule, and stated that EPA “shall have discretion to use

existing reporting requirements for electric generating units

under Section 821 of the Clean Air Act.” In its initial 2009

GHGRP rulemaking, EPA also cited Clean Air Act (CAA)

Sections 114 and 208 as providing “broad authority to

require the information mandated” by the reporting rule.

The GHGRP requires reporting from facilities in nearly all

categories of direct emissions sources and from suppliers of

certain fuels and industrial GHGs in the United States, but

does not impose emissions limits. The broad scope of

emissions data collected from these sources allows the

agency to assess trends in emissions over time and within

industry sectors for use in agency policy and programs. For

example, EPA uses the data in evaluating and implementing

GHG mitigation policies, including CAA New Source

Performance Standards and CAA voluntary GHG reduction

programs, among others. EPA states that the GHGRP is one

part of the overall U.S. effort to address climate change,

alongside other federal and state GHG emissions-related

programs. In addition, EPA uses the facility-level GHGRP

data to help prepare the agency’s annual Inventory of U.S.

Greenhouse Gas Emissions and Sinks, which is submitted

to the United Nations in accordance with the Framework

Convention on Climate Change.

Greenhouse Gas Reporting Regulations

In response to Congress’s directive, EPA released a final

rule, “Mandatory Reporting of Greenhouse Gases,” which

went into effect on December 29, 2009. The regulations

established in the rule require designated GHG source

facilities and specific product suppliers to report annual

GHG emissions and follow monitoring, verification, and

recordkeeping requirements.

EPA subsequently revised the 2009 rule to add technical

requirements and new categories of sources covered by the

regulations. For example, in 2010, EPA established two

new GHGRP source categories for facilities that inject

carbon dioxide (CO2) into underground formations. In total,

EPA has established 46 GHG source categories across a

wide range of economic sectors.

Subpart A of the Mandatory Reporting Rule (codified in 40

C.F.R Part 98) establishes general GHGRP reporting

requirements that apply to all covered facilities. In Subparts

B-UU, EPA has established separate requirements for most

GHG source categories based on the specific characteristics

of those sources. Each of these subparts contains a

methodology to be used to calculate total annual GHG

emissions for that source category, as well as tailored

requirements for monitoring, quality assurance, accounting

for missing data, recordkeeping, and reporting. For a few

source categories, such as motor vehicle manufacturers and

motor vehicle engine manufacturers, the 2009 rule added

new requirements to existing emissions reporting and

monitoring regulations.

Facilities Required to Report

GHGRP regulations generally apply to: (1) direct GHG

emissions sources that emit at least 25,000 metric tons of

CO2-equivalent (CO2e, the amount of CO2 emissions with

the same global warming potential as the number of metric

tons of another GHG) per year; (2) fuel and industrial gas

suppliers; and (3) facilities with underground CO2 injection

wells. Direct emission sources include stationary fuel

combustion facilities and industrial and chemical

production facilities. Some facilities are covered regardless

of whether they emit 25,000 metric tons of CO2e or more

per year, such as electricity generation facilities; facilities

engaged in aluminum production, ammonia manufacturing,

and cement production; and some municipal solid waste

landfills.

Suppliers covered by the regulations include suppliers of

coal and natural gas, suppliers of petroleum products, and

suppliers of CO2 and other industrial GHGs. CO2 injection

facilities include facilities with wells used to inject CO2 for

enhanced oil recovery and for permanent storage through

geologic sequestration. Some facilities have multiple GHG

sources and source categories and must report emissions for

all of these sources.

Emissions Required to be Reported

The GHGRP regulations require facilities to report two

types of GHG emissions: (1) combustion emissions

resulting from burning fossil fuels or biomass (such as

wood or landfill gas); and (2) emissions from industrial

processes, such as those that occur as a result of

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EPA’s Greenhouse Gas Reporting Program

transformation of raw materials during the production of

iron and steel, cement, or petrochemicals. Emissions due to

leaks or irregular releases (also known as “fugitive

emissions”) are also considered process emissions. Most

facilities are required to report total annual facility-level

emissions for each source category. Certain suppliers and

manufacturers (e.g., motor vehicles and vehicle engine

manufacturers) report emissions at a corporate level. See

Figure 1 for GHGRP reporting facility locations and

emission amounts.

Figure 1. Location and Total Reported Direct

Emissions from GHGRP Facilities (2021)

may take to verify the reported emissions. Annual reports to

EPA must include a GHG Monitoring Plan containing: (1)

the job titles for those responsible for emissions data

collection; (2) an explanation of emissions data collection

processes; and (3) descriptions of the procedures and

methods used for quality assurance, maintenance, and

repair of continuous monitoring systems. The regulations

provide that EPA may review certification statements and

GHG reports, conduct facility audits, and review other

“credible evidence” to verify the accuracy and

completeness of emissions reporting. EPA also verifies

emissions data through automated checks of reports for

errors before and after they are submitted.

GHGRP regulations also require that Subpart RR facilities

(injecting CO2 for underground geologic sequestration)

have an EPA-approved monitoring, reporting, and

verification (MRV) plan.

Reporting and Recordkeeping Requirements

Owners or operators of covered facilities must submit

annual reports to EPA on emissions from the prior calendar

year. Owners or operators must keep the records for at least

three years, including annual GHG reports, the Monitoring

Plan, the data used to calculate GHG emissions, the

calculations and methods used, test results, and

maintenance records for continuous monitoring systems.

Issues for Congress

Source: CRS, adapted from EPA FLIGHT database, accessed March

16, 2023.

Covered facilities must report data on the following GHGs:









CO2;

Methane (CH4);

Nitrous oxide (N2O); and

Hydrofluorocarbons (HFCs), sulfur hexafluoride (SF6),

perfluorinated compounds (PFCs), and other fluorinated

gases.

For 2021 (the most recent data available) 7,608 direct

emitters reported emitting 2.7 billion metric tons of CO 2e.

Also in 2021, 966 suppliers, 87 CO2 injection facilities, and

9 facilities injecting CO2 solely for geologic sequestration

reported data to EPA.

Requirements for Calculating Emissions

EPA has established different methodologies for measuring

combustion emissions, process emissions, and suppliers of

fuels and GHGs. Facility owners and operators are required

to use the calculation methodologies in the relevant subpart

to determine annual emissions for each source category.

Monitoring and Verification Requirements

The GHGRP regulations include general monitoring

requirements for owners and operators and actions EPA

Congress may consider several policy issues related to

GHGRP statutory authority and regulatory oversight.

Congress may consider how the application and scope of

GHGRP regulations align with EPA’s stated goal of

enhanced understanding of GHG emissions in the United

States now and in the future. For example, policymakers

could consider expanding the scope of sources required to

report and/or adjust the emissions reporting threshold for

particular sources.

Congress may consider whether EPA resources are

adequate and being used efficiently to carry out the

GHGRP under the CAA. Some analysts expect that the

number of facilities required to report will expand in the

future, particularly for CO2 underground injection facilities.

Policymakers may consider the implications of potentially

increased data collection and verification responsibilities on

EPA capacity and resources.

Congress may also consider how GHGRP data might

inform future legislative efforts. EPA has now collected 10

years of data on direct GHG emissions, fuel and GHG

suppliers, and industry-specific emissions trends.

Policymakers may consider how this information, as well as

future GHGRP data, could be used in potential future

legislation relating to GHG mitigation or climate change

policy.

Angela C. Jones, Analyst in Environmental Policy

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IF11754

EPA’s Greenhouse Gas Reporting Program

Disclaimer

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