U.S. Greenhouse Gas Reporting Program: Overview and Considerations for Congress

U.S. Greenhouse Gas Reporting Program:

Overview and Considerations for Congress

September 11, 2026

Congressional Research Service

https://crsreports.congress.gov

R49348

SUMMARY

U.S. Greenhouse Gas Reporting Program:

Overview and Considerations for Congress

The U.S. Environmental Protection Agency (EPA) established the Greenhouse Gas Reporting

Program (GHGRP) in 2009 in response to a congressional directive mandating economy-wide

reporting of greenhouse gas (GHG) emissions. EPA described the program’s purpose as

gathering comprehensive emissions data to inform the development of future climate change

policies.

R49348

September 11, 2026

Kathryn G. Kynett

Analyst in Environmental

Policy

The GHGRP requires reporting from three broad groups of covered entities. Direct-emitting facilities in covered source

categories report the GHG emissions released directly from their on-site processes and fuel combustion. Suppliers of fuels

and industrial gases report the potential emissions associated with their products if combusted, released, or oxidized.

Facilities that inject carbon dioxide (CO2) underground must report the quantities of CO2 injected or sequestered

underground. Reporting is generally subject to emissions thresholds for both direct-emitting facilities and suppliers, primarily

a threshold of 25,000 metric tons of CO2 equivalent (MTCO2e) per year, although certain source categories are required to

report regardless of their emissions levels. There is no threshold for CO2 injection facilities, which must report all quantities

of CO2 sequestered or injected underground.

EPA began collecting GHGRP data in 2011 and has since collected data annually from approximately 8,000 direct-emitting

facilities, suppliers, and CO2 injection facilities nationwide. EPA states these data represent 85%-90% of annual U.S. GHG

emissions. The GHGRP requires covered entities to calculate and report annual GHG emissions using methodologies

specified in regulation, tailored to each source category. Covered entities must report data on the following GHGs: CO2,

methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), sulfur hexafluoride (SF6), perfluorinated compounds

(PFCs), and other fluorinated gases. The program also includes verification and recordkeeping requirements. EPA generally

makes reported emissions data publicly available. According to EPA, the GHGRP is the only national dataset containing

facility-level and economy-wide GHG emissions data. GHGRP data have been used across a range of federal activities,

including developing emissions standards, administering tax incentive programs, and implementing and enforcing

regulations. The data also inform EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks.

Different administrations have expressed varying views about whether, and to what extent, the Clean Air Act (CAA)

authorizes EPA to collect economy-wide GHG data. EPA established the GHGRP under CAA Section 114 information

collection authority, and under Section 821 for electric generating units specifically, following a directive in the Consolidated

Appropriations Act, 2008 (P.L. 110-161). Beginning in 2025, EPA initiated a series of actions to reconsider the scope and

requirements of the GHGRP. In its 2025 proposed rule, EPA asserts that Section 114 does not authorize continued economywide data collection, that the data are not needed to carry out the CAA, and that eliminating most reporting requirements

would relieve reporting entities of compliance costs. EPA estimates the proposal would produce significant cost savings for

reporting entities. Stakeholder positions on EPA’s proposal reflect a range of views. Some stakeholders support the proposal,

arguing that the program is burdensome and its costs outweigh its benefits, while others oppose it, arguing that the

standardized, facility-level GHG data provide essential benefits across the public and private sectors.

EPA’s reconsideration raises a number of policy questions for Congress. These include whether existing statutory authority

adequately supports the program as currently implemented, whether to retain these authorities, or whether to modify these

authorities. Congress may weigh the benefits of having standardized emissions data against the compliance costs for

reporting the data. Congress could address these questions through legislation or through oversight of EPA’s reconsideration

of the program.

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U.S. Greenhouse Gas Reporting Program: Overview and Considerations for Congress

Contents

Introduction ..................................................................................................................................... 1

2009 Rulemaking for Mandatory Reporting of Greenhouse Gases................................................. 2

Statutory Authority and Purpose ............................................................................................... 2

GHGRP Rule Regulatory Framework ....................................................................................... 4

GHGRP Rule Amendments ....................................................................................................... 4

Covered Entities and Source Categories ......................................................................................... 4

Direct-Emitting Facilities .......................................................................................................... 5

Suppliers of Fuel and Industrial Gases ...................................................................................... 6

CO2 Injection Facilities ............................................................................................................. 6

Excluded Sectors ....................................................................................................................... 6

Monitoring and Calculation Methodologies .................................................................................... 6

Continuous Emissions Monitoring Systems (CEMS) ............................................................... 7

Emission Factors ....................................................................................................................... 7

Mass Balance ............................................................................................................................ 8

Reporting Requirements and Enforcement ..................................................................................... 9

GHG Emissions Data Reported ................................................................................................ 9

Verification .............................................................................................................................. 10

Recordkeeping......................................................................................................................... 10

Enforcement ............................................................................................................................ 10

GHGRP Data ..................................................................................................................................11

Data Available ..........................................................................................................................11

Uses of GHGRP Data .............................................................................................................. 13

EPA Actions to Reconsider the GHGRP ....................................................................................... 16

Considerations for Congress.......................................................................................................... 17

Stakeholder Views ................................................................................................................... 18

Legislation ............................................................................................................................... 19

Oversight ................................................................................................................................. 20

Figures

Figure 1. Locations of Greenhouse Gas Reporting Program (GHGRP) Direct-Emitting

Facilities, by Quantity Emitted in 2023...................................................................................... 12

Figure 2. Annual Greenhouse Gas Emissions Reported Under the Greenhouse Gas

Reporting Program (GHGRP) Direct-Emitting Facilities, by Sector (2023) ............................. 13

Tables

Table A-1. Source Categories Required to Report Under 40 C.F.R., Part 98 ................................ 22

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U.S. Greenhouse Gas Reporting Program: Overview and Considerations for Congress

Appendixes

Appendix. Greenhouse Gas Reporting Program (GHGRP) Source Categories ............................ 22

Contacts

Author Information........................................................................................................................ 24

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U.S. Greenhouse Gas Reporting Program: Overview and Considerations for Congress

Introduction

In 2009, the U.S. Environmental Protection Agency (EPA) established the Greenhouse Gas

Reporting Program (GHGRP) in response to a congressional mandate to require mandatory,

economy-wide reporting of greenhouse gas (GHG) emissions.1 According to EPA, the GHGRP is

the only mandatory nationwide program that provides facility-level reporting of GHG emissions

from large industrial sources.2 EPA states that 85%-90% of annual human-caused (i.e.,

anthropogenic) U.S. GHG emissions have been reported each year under the program.3 With the

exception of certain data designated as confidential business information (CBI), GHGRP data are

publicly available.4 These data include annual emissions estimates for each reported GHG;

facility-level information, such as industry sector and location; and supplier-level information on

fuel and industrial gas quantities supplied.5

The GHGRP applies to certain industrial facilities in covered source categories that directly emit

GHGs from on-site processes, suppliers of fuels and industrial gases, and facilities that inject

carbon dioxide (CO2) underground for geologic sequestration or enhanced oil recovery. Reporting

is generally subject to emissions thresholds, which cover facilities emitting 25,000 metric tons or

more of CO2 equivalent (MTCO2e) per year and suppliers of products that would emit 25,000

MTCO2e or more per year if combusted, released, or oxidized.6 There are certain source

categories that do not have a reporting threshold, in part because nearly all facilities or suppliers

in those categories would exceed it. Facilities that inject CO2 underground are covered regardless

of the amount injected. Covered entities began reporting GHGRP data to EPA in 2011. Since then,

EPA has collected data annually from facilities, suppliers, and CO2 injection facilities nationwide.

In the most recent reporting year for which data have been published, 2023, approximately 8,000

direct-emitting facilities, suppliers, and CO2 injection facilities reported their emissions under the

program.7

Prior to the GHGRP, no comprehensive federal system existed for collecting facility-level GHG

emissions data. Reporting relied on state programs, voluntary initiatives, and private datasets that

used different reporting thresholds and data collection methodologies, which presented challenges

for constructing a comparable national dataset. In its 2009 Mandatory Greenhouse Gas Reporting

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

2 EPA, “GHGRP Reported Data,” updated January 29, 2026, https://www.epa.gov/ghgreporting/ghgrp-reported-data

(hereinafter EPA, “GHGRP Reported Data”).

3 EPA, “Reconsideration of the Greenhouse Gas Reporting Program,” 90 Federal Register 44591, September 16, 2025,

https://www.federalregister.gov/documents/2025/09/16/2025-17923/reconsideration-of-the-greenhouse-gas-reportingprogram (hereinafter EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591).

4 EPA, “Find and Use GHGRP Data,” updated December 23, 2025, https://www.epa.gov/ghgreporting/find-and-useghgrp-data.

5 Greenhouse gases (GHGs) reported under this program include carbon dioxide (CO ), methane (CH ), nitrous oxide

2

4

(N2O), sulfur hexafluoride (SF6), nitrogen trifluoride (NF3), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and

other fluorinated GHGs; see 40 C.F.R. §98.6.

6 Carbon-dioxide-equivalent (CO e) is a unit of measurement that expresses the warming effect of different GHGs in

2

terms of the amount of CO2 that would have the same warming impact. For the regulatory definition of the entities

required to report, see 40 C.F.R. §98.2.

7 EPA uses 2011 as the base year for trend analysis; some source categories began reporting in 2012 or later as the

program expanded. For more information on when different source categories started reporting, see Electronic

Greenhouse Gas Reporting Tool (e-GGRT), “Frequently Asked Questions: Q409. In What Year Was Each Source

Category Required to Begin Reporting,” updated September 23, 2019, https://uat.ccdsupport.com/faq/Q409. Reporting

year refers to the calendar year in which the emissions occurred. Under the GHGRP, covered entities report data for a

given calendar year to EPA by March 31 of the following year. In the February 2026 EPA direct final rule, the deadline

for reporting year 2025 data was extended from March 31, 2026, to October 30, 2026.

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rulemaking, EPA stated that the program’s purpose is to provide comprehensive and accurate data

to inform the development of future climate change policies.8 In addition, a range of federal

programs and policymakers use the data for various purposes, including setting emissions

standards, administering incentive programs, supporting voluntary initiatives, and informing

emissions inventories.

In March 2025, EPA announced it would reconsider a number of regulations and programs,

including the GHGRP, as part of a broader effort to eliminate regulatory obstacles and remove

unnecessary administrative burdens.9 In September 2025, EPA issued a proposed rule that would

permanently remove the majority of the GHGRP’s reporting requirements after reporting year

2024.10 In February 2026, EPA issued a direct final rule extending the reporting deadline for

reporting year 2025 from March to October of 2026 and stated its intent to address the “GHGRP

Reconsideration Proposal” in subsequent actions.11 No additional actions regarding the GHGRP

have been published as of the date of this report.

This report describes the GHGRP as structured based on existing regulations and how it has been

implemented historically. It also discusses covered entities and source categories; the

methodologies used to calculate and verify emissions; the processes for collecting, reporting, and

validating the data; enforcement; the GHGRP data collected; the uses of GHGRP data; EPA’s

recent actions to reconsider the program; and considerations for Congress.

2009 Rulemaking for Mandatory Reporting of

Greenhouse Gases

EPA promulgated the rule establishing the GHGRP in 2009. This section describes the program’s

statutory authority and purpose, the regulatory framework the rule established, and amendments

EPA has adopted.

Statutory Authority and Purpose

EPA established the GHGRP in response to a congressional directive. Specifically, the

Consolidated Appropriations Act, 2008 (P.L. 110-161) provided $3.5 million for EPA to develop

and finalize a rule that would “require mandatory reporting of greenhouse gas emissions above

appropriate thresholds in all sectors of the economy of the United States.”12 In the accompanying

joint explanatory statement, Congress directed EPA to “use its existing authority under the Clean

Air Act (CAA)” to promulgate this rule. In addition, Congress stated that EPA “shall have

discretion to use existing reporting requirements for electric generating units (EGUs) under

8 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 16448, 16456, April 10, 2009,

https://www.federalregister.gov/documents/2009/04/10/E9-5711/mandatory-reporting-of-greenhouse-gases (hereinafter

EPA, “Mandatory Reporting of GHGs,” 74 Federal Register 16448).

9 EPA, “EPA Launches Biggest Deregulatory Action in U.S. History,” press release, March 12, 2025,

https://www.epa.gov/newsreleases/epa-launches-biggest-deregulatory-action-us-history.

10 EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591.

11 EPA, “Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025,” 91 Federal Register

9712, February 27, 2026, https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reportingdeadline-under-the-greenhouse-gas-reporting-rule-for-2025 (hereinafter EPA, “Reporting Deadlines for 2025,” 91

Federal Register 9712).

12 P.L. 110-161, Division F, Title II—Environmental Protection Agency.

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Section 821.” Section 821 of the Clean Air Act Amendments of 1990 (P.L. 101-549) requires

electric generating units to report CO2 emissions to EPA under the Acid Rain Program.13

In response to Congress’s directive for economy-wide GHG reporting, EPA issued the Mandatory

Reporting of Greenhouse Gases rule (GHG Rule) codified in 40 C.F.R. Part 98 in 2009. In the

2009 rule preamble, EPA stated that the purpose of the GHGRP is to “provide comprehensive and

accurate data to inform the development of future climate change policies.” EPA further stated

that the data would “inform and be relevant to EPA carrying out a wide variety of CAA

provisions.”

In addition to Section 821 for EGUs, EPA cited CAA Sections 114 and 208 as providing “broad

authority to require the information mandated by this rule because such data will inform and are

relevant to EPA’s carrying out a wide variety of CAA provisions.” Section 114 authorizes EPA to

require certain persons (e.g., owners or operators of emissions sources) to provide information on

a one-time, periodic, or continuous basis for three statutory purposes. These purposes are

developing implementation plans or emissions standards under specified CAA provisions;

determining violations of those plans or standards; or carrying out “any provision” of the CAA

other than CAA provisions concerning manufacturers of new motor vehicles or new motor

vehicle engines.14

In the 2009 rule preamble, EPA stated that it expected GHGRP data to support various purposes,

such as decisions about which source categories to regulate; New Source Performance Standards

(NSPS); best available control technology determinations; cost-effectiveness analyses for

regulations; and research on nonregulatory strategies, such as energy conservation and fuel

switching.15 EPA also identified additional benefits of the program for federal, state, and other

entities, including supporting its annual Inventory of U.S. Greenhouse Gas Emissions and Sinks

(hereinafter referred to as the Inventory); supporting covered entities in identifying emissions

reduction opportunities; and aligning and coordinating federal data collection with existing state

and regional reporting programs to reduce duplicative reporting. EPA identified benefits to the

public as well, including transparency of GHG emissions and support for research through public

access to emissions data.

13 The joint explanatory statement accompanying the Consolidated Appropriations Act, 2008 (§4 of P.L. 110-161)

referred to Section 821 “of the Clean Air Act. [CAA].” Section 821 was enacted as a stand-alone provision of the CAA

Amendments of 1990 (P.L. 101-549) and set out as a note under 42 U.S.C. §7651k. In the CAA Amendments of 1990,

Section 821 directs EPA to require sources covered by the CAA Acid Rain Program to monitor and report CO2

emissions. The text of Section 821 contains two cross-reference errors that the U.S. Code codifiers flagged at 42 U.S.C.

§7651k: it refers to “Title V” (permits) instead of “Title IV” (the Acid Rain Program) of the CAA and to “Section 511”

(does not exist) when it should refer to “Section 412” (the Acid Rain Program’s monitoring requirements) of the CAA.

14 EPA cited Section 114 of Title I of the CAA as the authority for the GHGRP in the 2009 rule preamble. Section 114

authorizes EPA to compel “any person” subject to “any requirement” of the CAA—other than manufacturers of motor

vehicles or new motor vehicle engines—to provide “information as the Administrator may reasonably require.” The

provision identifies four categories of such persons: owners or operators of emissions sources; manufacturers of

process equipment; persons subject to any requirements of the CAA; and persons the Administrator believes may have

necessary information. Although EPA also cited Section 208 of the CAA, which provides EPA with parallel authority

over manufacturers of new motor vehicles and new motor vehicle engines under Title II of the CAA, 40 C.F.R. §98

does not have a subpart for motor vehicle and motor vehicle engine manufacturers.

15 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260, 56265, October 30, 2009,

https://www.federalregister.gov/documents/2009/10/30/E9-23315/mandatory-reporting-of-greenhouse-gases

(hereinafter EPA, “Mandatory Reporting of GHGs,” 74 Federal Register 56265). New Source Performance Standards

(NSPS) are emissions standards EPA sets under CAA Section 111 for new, modified, or reconstructed stationary

sources in listed source categories.

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GHGRP Rule Regulatory Framework

The 2009 GHGRP Rule, codified at 40 C.F.R. Part 98, established the reporting requirements and

the regulatory framework for the GHGRP, including the covered entities and source categories

initially subject to reporting; the emissions reporting requirements; the emissions monitoring and

calculation methodologies; the recordkeeping requirements; the data verification requirements;

and the enforcement provisions. Part 98 organizes reporting obligations by emissions source

category, with each source category representing a specific industry type or activity that results in

GHG emissions. Subpart A establishes general reporting requirements that apply to all covered

sources.16 Following Subpart A, the rule is organized into individual subparts (Subparts B through

ZZ).17 The requirements of the subparts are based on the unique characteristics of the source

category, including the chemical and physical processes that generate emissions, the specific

types of GHGs emitted, and the technical complexity involved in monitoring and calculating

emissions. Each subpart contains definitions, applicability criteria, and reporting thresholds (if

applicable), along with tailored methodologies for calculating annual GHG emissions and

requirements for quality assurance and recordkeeping.

GHGRP Rule Amendments

Since 2009, EPA has amended 40 C.F.R. Part 98 through a number of rulemakings.18 These

amendments have added or removed source category requirements and reported data elements

and have updated emissions calculation and monitoring methodologies. Additionally,

amendments have established or updated confidentiality determinations for certain data elements.

The confidentiality determinations establish whether specific reported data elements are publicly

available or protected as confidential information for business reasons.19 For example, the 2009

rule initially established Subparts A through PP, covering 29 source categories, with several

subparts reserved for later development. The GHGRP has since broadened its scope to 47 source

categories, extending to Subpart ZZ, as of August 2026. These source categories are listed in the

Appendix.20

Covered Entities and Source Categories

As introduced above, GHGRP requirements apply to three types of covered entities that meet

specific reporting thresholds: direct-emitting facilities, suppliers of fuel and industrial gases, and

CO2 injection facilities.

16 40 C.F.R. §98, Subpart A.

17 40 C.F.R. §98, Subparts B through ZZ. Note that Subparts B, J, M, and KK of 40 C.F.R. §98 are currently (as of

August 2026) “Reserved,” a designation used in the C.F.R to indicate that a specific subpart is being held to maintain

the integrity of the alphabetical sequence if a subpart was proposed previously and not finalized or if reporting

functions were merged elsewhere.

18 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260; EPA, “Rulemaking Notices for

GHG Reporting,” updated February 27, 2026, https://www.epa.gov/ghgreporting/rulemaking-notices-ghg-reporting

(hereinafter EPA, “Rulemaking Notices for GHGRP”); and EPA, “Historical Rulemakings,” updated June 30, 2025,

https://www.epa.gov/ghgreporting/historical-rulemakings (hereinafter EPA, “Historical Rulemakings”).

19 EPA, “Rulemaking Notices for GHGRP”; EPA, “Historical Rulemakings.”

20 For more information on when each subpart began reporting under the program, see EPA, “Resources by Subpart for

GHG Reporting,” updated August 26, 2025, https://www.epa.gov/ghgreporting/resources-subpart-ghg-reporting.

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Direct-Emitting Facilities

Covered facilities that directly emit GHGs from on-site sources (Subparts C through II, SS, and

TT) include stationary fuel combustion units that burn fuels to produce electricity, steam, or heat,

as well as industrial and chemical production facilities that emit GHGs as byproducts of

manufacturing processes or raw material transformation.21 Examples of the latter include cement,

glass, and lime manufacturing; aluminum, iron, steel, and ferroalloy production; fluorinated gas

production; and chemical production processes such as adipic acid, ammonia, nitric acid, and

hydrogen manufacturing. Waste management, including municipal solid waste landfills and

industrial wastewater treatment facilities, is also covered under direct-emitting facilities.

Petroleum and natural gas systems (Subpart W) are defined in a unique way in that they cover an

entire industry supply chain.22 Subpart W is divided into industry segments along the petroleum

and natural gas supply chain, including onshore and offshore production, processing,

transmission, storage, and distribution, as well as imports and exports.23 These segments are not

separate source categories; rather, they define how a covered “facility” is delineated within

Subpart W, which, in turn, determines how applicability of the requirements and the reporting

threshold are assessed.

While the 25,000 MTCO2e threshold applies to most direct-emitting facilities, certain source

categories are “all-in,” meaning they are required to report regardless of their emissions levels.

EPA designated these categories based on analysis showing nearly all facilities in these sectors

already exceed the 25,000 MTCO2e threshold or fall only “marginally below” it. This “all-in”

approach was designed to simplify applicability determinations for facilities while producing

similar data as would be produced using a fixed reporting threshold. These source categories

include electricity generation facilities, petroleum refineries, and facilities for chemical

production, aluminum production, cement production, lime manufacturing, and soda ash

production. In addition, certain natural gas suppliers, industrial gas producers, CO2 producers,

petroleum product refiners, and coal-based liquid fuel suppliers are also “all-in.”24 Some covered

entities may fall under multiple source categories and must report emissions from all applicable

activities. In addition, applicability for some source categories is determined by equipment

capacity throughput or design capacity rather than by emissions levels.

For direct-emitting facilities subject to the emissions threshold, whether the 25,000 MTCO2e

threshold for reporting is met is determined by aggregating emissions across all applicable source

categories within a facility’s boundary.25 For example, a facility whose emissions from individual

21 E-Greenhouse Gas Reporting Tool (e-GGRT), “Q423. What Is the Difference Between Direct Emitters, Suppliers,

and CO2 Injection Facilities,” updated September 23, 2019, https://uat.ccdsupport.com/faq/Q423? (hereinafter eGGRT, “What Is the Difference Between Direct Emitters, Suppliers, and CO2 Injection Facilities”).

22 EPA, “Subpart W – Petroleum and Natural Gas Systems,” updated May 7, 2026, https://www.epa.gov/ghgreporting/

subpart-w-petroleum-and-natural-gas-systems.

23 Subpart W is composed of 10 industry segments: onshore petroleum and natural gas production; offshore petroleum

and natural gas production; onshore natural gas processing; onshore 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; and natural gas distribution. See 40 C.F.R.

§98.230(a).

24 For more information, see EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 16448, 16528,

and; EPA, “Mandatory Greenhouse Gas Reporting Rules: EPA’s Response to Public Comments: Volume No. 2;

Selection of Reporting Thresholds, Greenhouse Gases, and De Minimis Provisions,” September 2009,

https://www.regulations.gov/document/EPA-HQ-OAR-2008-0508-2259.

25 40 C.F.R §98.2.

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source categories fall below the 25,000 MTCO2e threshold is required to report if the combined

emissions for those individual source categories exceed the 25,000 MTCO2e threshold.

Suppliers of Fuel and Industrial Gases

Suppliers of fuel and industrial gases (Subparts LL through QQ) include suppliers of natural gas,

petroleum products, CO2, and other industrial gases (e.g., hydrofluorocarbons).26 Suppliers are

entities that introduce fuels or industrial gases into the economy that, when combusted, released,

or oxidized, result in GHG emissions above applicable thresholds. The emissions associated with

these products do not occur at the supplier’s reporting location. Instead, they occur at the

locations where the products are ultimately combusted, released, or oxidized. Suppliers determine

whether they meet the reporting threshold by evaluating the potential emissions for each source

category of fuel or industrial gas that they supply independently.27

CO2 Injection Facilities

Facilities that inject CO2 into underground wells (Subparts RR, UU, and VV) include those

operating wells used for enhanced oil recovery and for permanent CO2 storage through geologic

sequestration.28 These facilities report regardless of the amount of CO2 injected, and which

subpart applies depends on the type of injection activity.

Excluded Sectors

EPA excludes reporting for certain sectors that may emit GHGs. In particular, EPA excluded

emissions from agriculture, land use, and forestry from the program, noting that these emissions

are often diffuse and that the available methods to estimate facility-level emissions would be

technically and practically difficult to implement.29 Additionally, the GHGRP is designed for

tracking anthropogenic emissions, meaning emissions that occur from sources such as wetlands

are not captured under the program.

Monitoring and Calculation Methodologies

The GHGRP requires covered entities to adhere to specific GHG monitoring and calculation

methodologies prescribed in 40 C.F.R. Part 98. Monitoring methodologies specify the data that a

covered entity must collect, the methods it must use to collect the data, and how often it must do

so. Calculation methodologies provide the equations that covered entities use to derive reported

GHG emissions (for direct emitters) or CO2 injection volumes (for CO2 injection facilities) based

on data generated by their monitoring activities. For suppliers, calculation methodologies provide

the equations to determine the potential GHG emissions of products entering the economy based

on production, import, or export records. Covered entities must use a methodology prescribed for

their source category. Depending on the subpart, there may be multiple methodologies available

from which to choose.

26 E-GGRT, “What Is the Difference Between Direct Emitters, Suppliers, and CO

2 Injection Facilities.”

27 40 C.F.R. §98.2.

28 E-GGRT, “What Is the Difference Between Direct Emitters, Suppliers, and CO

2 Injection Facilities.” For more

information, see CRS Report R46757, Reporting Carbon Dioxide Injection and Storage: Federal Authorities and

Programs, by Angela C. Jones; and CRS Report R46192, Injection and Geologic Sequestration of Carbon Dioxide:

Federal Role and Issues for Congress, by Angela C. Jones.

29 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 16448, 16466.

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Part 98 Subpart A sets the general monitoring requirements that apply to all subparts, including

requiring covered entities to develop and maintain a monitoring plan. The monitoring plan must

describe how the covered entity will meet the GHGRP’s monitoring requirements, including

identifying the monitoring methodologies, monitoring equipment, quality assurance procedures,

and the personnel responsible for data collection and quality assurance. In addition, Subpart RR

requires facilities that inject CO₂ for underground geologic sequestration to develop and

implement an EPA-approved monitoring, reporting, and verification (MRV) plan.30 These plans

describe site-specific monitoring activities to track the movement and containment of injected

CO2 and to ensure that CO2 volumes associated with injection and storage are accurately

contained and quantified. Facilities must submit a proposed MRV plan to EPA and receive

approval before reporting under the subpart and submit a revised plan if material changes occur.

The MRV plan itself is not filed with the annual report, but the annual report must identify the

date EPA approved the most recent plan.

Subparts C through ZZ prescribe the monitoring and calculation methodologies specific to each

source category by subpart.31 There are three approaches to monitoring and calculating emissions:

continuous emissions monitoring systems (CEMS), emission factors, and mass balance methods.

Each of these three approaches includes monitoring and calculation components. The calculation

methodologies depend on the data generated by the monitoring method. A number of subparts

provide alternative monitoring and calculation methodologies and allow covered entities to select

from among them. Covered entities may select a methodology based on factors specific to their

operations, such as existing monitoring equipment and available data sources. In some cases, a

single facility may use more than one of these approaches, applying different methods to different

emissions sources.

Continuous Emissions Monitoring Systems (CEMS)

CEMS are instruments installed at the stack, the structure through which a facility combusting

fuels or conducting industrial process releases exhausts gases (i.e., emissions) to the atmosphere.

CEMS directly measure GHG emissions by measuring the concentrations and flow rates of the

gases. CEMS provide continuous measurements by sampling the gas automatically on a fixed,

repeated schedule. Direct-emitting facilities use CEMS where emissions are concentrated at a few

stacks and the volume of emissions is large enough to make continuous measurement both

technically and economically feasible. For example, an electricity generation or manufacturing

facility may use CEMS instruments installed directly at a stack to automatically sample exhaust

gases, including GHGs, directly measuring their concentration and flow rate as they are released

to the atmosphere. In general, the GHGRP requires direct-emitting facilities to use CEMS for

units that are already required to report data using CEMS under other programs, such as EPA’s

Acid Rain Program, NSPS, or State Implementation Plans. For direct-emitting facilities that do

not have CEMS installed, reporters have the choice to either install one or use emission factors or

mass balance methodologies.

Emission Factors

When direct measurement is not practical or when EPA does not consider it to be cost-effective,

covered entities can calculate emissions using emission factors. Emission factors offer a way to

estimate emissions that are difficult to measure directly by using data for an activity that is more

30 40 C.F.R. §98.448. For more information, see CRS Report R46192, Injection and Geologic Sequestration of Carbon

Dioxide: Federal Role and Issues for Congress, by Angela C. Jones.

31 See 40 C.F.R. §98.3(e). See individual source category subparts for applicable calculation methodologies.

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easily measurable. To apply this method, covered entities measure the activity producing

emissions, such as the amount of fuel consumed or the amount of material processed, and then

multiply those amounts by the corresponding emission factor. An emission factor represents the

quantity of GHGs emitted per unit of activity (e.g., kilograms of GHG emitted per British thermal

unit [Btu] of fuel consumed). The emission factors are provided by the EPA.32 Covered entities

use emission factors across a broad range of source categories, particularly where emissions are

diffuse, intermittent, or derived from widely distributed fuel supplies and raw materials. For

example, an onshore petroleum and natural gas facility uses emission factors to estimate diffuse

methane leaks from thousands of pipe valves, intermittent venting events during equipment

maintenance, and emissions from variable, distributed fuel sources across a production basin.33

Mass Balance

Mass balance methods estimate emissions by tracking the quantity of carbon (or other GHGs,

where applicable) entering and leaving a process. The amount of carbon that enters a process or

system but does not leave in the products, byproducts, or waste is assumed to be the emissions

released to the atmosphere. Covered entities may use mass balance where material inputs and

outputs can be quantified through measurement. A direct-emitting facility that produces steel, for

example, measures the carbon content and weight of its feedstocks (e.g., iron ore, coal) entering

the process and the carbon retained in its product (steel), and in its byproducts and waste (e.g.,

steel slag and furnace dust). Any carbon that is not accounted for is assumed to have been

released to the atmosphere as GHG emissions. While this method is most commonly used to track

carbon, covered entities apply this mass balance principle to calculate emissions of other

greenhouse gases, such as fluorinated GHGs (HFCs, for example).

Suppliers also use mass balance methods to calculate emissions. Unlike direct-emitting facilities

that track physical process waste on a factory floor, a supplier—such as a natural gas distribution

company—applies mass balance principles to its product inventory accounting. The facility relies

on transaction records to balance the bulk volume of fuel entering its system against the volumes

delivered to market. It then applies standard emission factors to those verified delivery totals to

calculate the potential emissions that will occur when that fuel is eventually combusted by end

users.

Similarly, a CO2 injection facility applies mass balance principles to its underground storage

accounting. The facility relies on custody transfer records and precision flow meters to balance

the bulk volume of CO2 received via transport pipelines against the metered quantities injected

deep underground, subtracting any volumes recycled back out of an oil well or lost to surface

venting. This mass balance calculation allows the operator to accurately determine the net

quantity of CO2 stored. Unlike direct-emitting facilities and suppliers—which report GHG

emissions—CO2 injection facilities report the amount of avoided GHG emissions.

32 EPA, “GHG Emission Factors Hub,” updated January 12, 2026, https://www.epa.gov/climateleadership/ghg-

emission-factors-hub.

33 “Onshore petroleum and natural gas production” is a specific industry segment within Subpart W (Petroleum and

Natural Gas Systems).

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Reporting Requirements and Enforcement

After monitoring and calculating emissions, covered entities must report their data to EPA,

maintain supporting records, and verify the accuracy of the data they submit. This section

describes those requirements and also provides information about enforcement.

GHG Emissions Data Reported

The GHGRP requires covered entities to submit annual reports to EPA regarding their emissions,

supplied quantities, and injected quantities of GHGs. Their reports must account for annual totals

of CO2, methane (CH4); nitrous oxide (N2O); sulfur hexafluoride (SF6); and hydrofluorocarbons

(HFCs), perfluorocarbons (PFCs), and other fluorinated gases that are GHGs (e.g., nitrogen

trifluoride [NF3] and hydrofluorinated ethers [HFEs]). 34

In addition to GHG emissions data, covered entities must provide information about the type of

reporting entity they are and their operations. Subpart A establishes universal reporting

requirements that apply to all covered entities. For example, all covered entities must provide

their parent company, location, and industry sector. In addition, all covered entities must report

the methods and methodologies they used to calculate their GHG quantities and emissions. They

must also provide more granular data, including underlying data inputs used in those equations to

calculate the GHG quantities and emissions they report.

The specific GHG quantities and emissions data and the supporting information that covered

entities are required to report depend on whether they are a direct-emitting facility, supplier, or

CO2 injection facility and on the applicable subparts. Owners and operators of direct-emitting

facilities report total annual emissions at the facility level for each applicable subpart.35 They

disaggregate these emissions by GHG and by subpart (e.g., individual unit, process line, or

industry segment).

Suppliers of fuels and industrial gases typically report at the corporate level, although some

entities, such as natural gas distribution companies, report at the state level.36 While both types of

suppliers ultimately calculate their totals in MTCO2e, their reporting formats differ. Industrial gas

suppliers (for example, companies that produce or import bulk chemical gases or bulk CO2)

report the potential GHG emissions from the gases they introduce into the economy. They are

also required to itemize the MT and MTCO2e for each individual gas (such as HFCs, PFCs, SF6,

N2O, NF3, or HFEs). By contrast, fuel suppliers (such as petroleum refineries and natural gas

distributors) report the potential CO2 emissions that would result from the complete downstream

combustion of their products. Unlike chemical suppliers, they do not itemize data by individual

gas types, providing instead a single, aggregated total in MTCO2e.

Owners and operators of facilities that inject CO2 underground report at the facility level, tracking

the total mass of CO2 received for subsurface injection. For each applicable subpart, they must

report the annual quantities of CO2 received, injected, and transferred.

34 EPA, “Mandatory Reporting of GHGs,” 74 Federal Register 16448, 16453.

35 In addition to reporting specific emissions for the subpart applicable to their industrial process, direct-emitting

facilities generally burn fuel for power or heat under subpart C (General Stationary Fuel Combustion). They must

report their emissions related to their industrial processes according to the applicable subpart for those processes

separately from their combustion emissions. Since subpart C applies across all source categories, emissions data

reported under Subpart C represent total combustion emissions across all source categories.

36 EPA, “Scope of Emissions Covered in GHGRP.”

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Verification

Subpart A of the GHGRP rule includes actions EPA may take to verify the reported emissions.37

The rule provides 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.38 EPA also verifies emissions data through automated checks of reports.39

After receiving GHG reports, EPA conducts a multistep verification process intended to support

data accuracy, completeness, and internal consistency.40 The system applies validation checks,

such as assessing whether quarterly data aggregate to annual totals and whether reported values

fall within expected physical ranges. If potential issues are identified, EPA may contact the

covered entity, which may respond by explaining why the flagged issue does not constitute an

error or by correcting the data and resubmitting the annual GHG report.

Recordkeeping

The GHGRP requires covered entities to retain records supporting the data submitted in their

annual reports.41 Specifically, covered entities must keep records for at least three years from the

date of each annual report submission and make them available to EPA upon request. Required

records include a list of the units, operations, processes, and activities for which GHG emissions

or supplied quantities were calculated, and any measured parameters used to derive the reported

values. Covered entities must also retain documentation of the calculation methodologies,

equations, and calculations applied, including any change in methodology during the reporting

period; the results of required quality assurance and quality control activities, certification tests,

performance tests, and audits; and maintenance, calibration, and operational records for CEMS

and other measurement equipment. In addition, covered entities must keep copies of each

submitted annual GHG report and the accompanying signed certification statement, as well as any

additional records specified in the subpart applicable to their source or supply category.

Enforcement

Under the GHGRP rule, any violation of a requirement of Part 98 constitutes a violation of the

CAA, and each day of a continuing violation constitutes a separate violation. Violations include

failure to report required emissions data, failure to collect or monitor data needed to calculate

emissions, failure to follow specified calculation methodologies, and failure to maintain required

records. EPA’s verification and audit authority under the GHGRP rule supports identification of

potential violations.42 EPA may pursue identified violations through administrative actions,

including notices of violation and administrative compliance orders, or through civil judicial

actions seeking penalties or injunctive relief. In addition to establishing the violation types, the

EPA’s verification and audit authority under the rule supports proactive compliance oversight.43

37 40 C.F.R. §98.3.

38 40 C.F.R. §98.3(f).

39 40 C.F.R. §98.5(b).

40 EPA, “GHGRP: Emission Calculation Methodologies.”

41

40 C.F.R. §98.3(g).

42 40 C.F.R. §98.8(h).

43 40 C.F.R. §98.8(f).

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GHGRP Data

This section describes the data the GHGRP has historically made available to the public, and the

selected use cases of data by federal agencies.

Data Available

EPA is required to make the emissions data reported under the GHGRP publicly available except

for data designated as confidential business information (CBI).44 As noted above, the GHGRP’s

dataset contains facility-level GHG emissions data from large industrial sources across the United

States. EPA has historically provided public access to GHGRP data through resources on its

website through its web-based data platform, Facility Level Information on GreenHouse Gases

Tool (FLIGHT). FLIGHT provides facility-level GHGRP data in maps, tables, charts, and

graphs.45 Users can view the data geographically, filter by various reporting characteristics, view

information for individual facilities and suppliers, and download data. For example, publicly

available GHGRP emissions data include total facility-level emissions by gas (e.g., CO₂, CH₄,

N2O, and fluorinated gases) and by source category for each reporting year.

EPA has collected GHG emissions data through the GHGRP annually since 2011. Because the

dataset spans multiple years, the data can be used to analyze changes in GHG emissions over time

for individual facilities and sectors. In addition, the dataset can be used to analyze variation in

GHG emissions across facilities, within industries, and across geographic areas.

See Figure 1 for the quantity of emissions from direct-emitting facilities by location for 2023 (the

most recent year for which data are available).

44 Section 114(c) of the Clean Air Act (42 U.S.C. §7414(c)) states that any information obtained under Section 114

shall be available to the public, except data qualifying as confidential business information (CBI), and states that CBI

protections shall not apply to emissions data.

45 EPA, “Find and Use GHGRP Data,” updated December 23, 2025, https://www.epa.gov/ghgreporting/find-and-useghgrp-data.

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Figure 1. Locations of Greenhouse Gas Reporting Program (GHGRP) DirectEmitting Facilities, by Quantity Emitted in 2023

Source: CRS, created from the U.S. Environmental Protection Agency’s Facility Level Information on

GreenHouse Gases Tool (FLIGHT) database, accessed March 2, 2026.

Notes: This map shows the locations of direct-emitting facilities. The size of a circle corresponds to the quantity

of emissions reported by that facility for 2023. Facilities in Puerto Rico, the U.S. Virgin Islands, Guam, American

Samoa, and other U.S. territories are included in the reported data and statistics but are not shown on the map.

In 2023, 7,544 direct-emitting facilities reported to the GHGRP emitting 2.58 billion MTCO2e

collectively.46 The power plant sector reported the largest share of direct emissions, at 1.47 billion

MTCO2e, followed by petroleum and natural gas systems, at 322 million MTCO2e.47 See Figure

2 for annual GHG emissions reported by direct-emitting facilities under the GHGRP by sector for

2023. 48

46 EPA, “GHGRP Reported Data.” These statistics include facilities located in Puerto Rico, the U.S. Virgin Islands, and

Guam. The GHGRP applies in U.S. territories under 40 C.F.R. §98.6.

47 EPA, “EPA Releases 2023 Data Collected Under Greenhouse Gas Reporting Program,” press release, October 15,

2024, https://www.epa.gov/newsreleases/epa-releases-2023-data-collected-under-greenhouse-gas-reporting-program.

48 A map of supplier locations is also available on EPA’s Facility Level Information on GreenHouse Gases Tool

(FLIGHT) tool, providing information based on where the suppliers’ facilities are located—not the location where their

products are ultimately used and GHGs emitted. See EPA, “GHGRP Reported Data,” last accessed August 8, 2026,

https://www.epa.gov/ghgreporting/ghgrp-emissions-location.

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In addition to direct-emitting facilities, in 2023, 995 suppliers reported the potential emissions

associated with the fuels and industrial products they place into the economy.49 In addition, 81

CO2 injection facilities reported the quantities of CO2 they received and injected underground.50

Figure 2. Annual Greenhouse Gas Emissions Reported Under the Greenhouse Gas

Reporting Program (GHGRP) Direct-Emitting Facilities, by Sector (2023)

Source: CRS, created from the U.S. Environmental Protection Agency’s Facility Level Information on

GreenHouse Gases Tool (FLIGHT) database, accessed May 10, 2026.

Notes: This figure shows annual greenhouse gas (GHG) emissions reported by direct-emitting facilities under

the GHGRP, aggregated by sector and expressed in carbon dioxide equivalent (CO2e). This metric is a unit of

measurement that expresses the warming effect of different GHGs in terms of the amount of CO2 that would

have the same warming impact. The nine sectors above are composed of multiple subparts EPA has aggregated

into sector totals. For a breakdown of the subparts that make up these sectors, see Table A-1. Emissions

reported above include those from facilities in Puerto Rico, U.S Guam, American Samoa, and other U.S.

territories.

Uses of GHGRP Data

In the 2009 rulemaking establishing the GHGRP, as described above, EPA stated the GHGRP

would provide “economy-wide data on facility-level (and in some cases corporate-level) GHG

emissions” that are “comprehensive and accurate” and would be “[e]ssential for informing many

49 While EPA provides total emissions from direct-emitting facilities, and while it provides potential emissions data for

individual suppliers, it does not typically aggregate or report total potential emissions from suppliers alongside them.

One reason they do not do this is that the emissions that suppliers report are potential emissions, and further, those

emissions may not occur in that reporting year. In addition, EPA protects supplier data as CBI because total emissions

statistics could be used to determine how much product a company is supplying compared to their competitors.

50 While individual facility profiles in FLIGHT display the total mass of CO₂ received for injection, the EPA does not

publish facility-specific data for the actual volumes injected, treating that operational data as CBI. Instead, the EPA

publishes these metrics as a separate, sector-wide national aggregate rather than including them with direct atmospheric

MTCO₂e emissions totals.

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future climate change policy decisions.”51 EPA stated it designed the GHGRP to generate data

that could inform a range of future climate policy options, including legislation, regulations,

economic incentives, voluntary initiatives, emissions inventories, and research.52

EPA identified expected applications of the data under the CAA in both regulatory and

nonregulatory contexts, including setting GHG emissions limits through NSPS and voluntary

programs. Further, EPA stated the data could inform future legislation from Congress, citing “a

carbon tax, or cap-and-trade program” as examples.53 EPA also identified ways the data would

benefit federal activities beyond the CAA, including improving the Inventory.54 The Inventory is

EPA’s annual accounting of human-caused GHG emissions and removals (i.e., sinks) across U.S.

economic sectors, which EPA has historically prepared under reporting commitments to the

United Nations Framework Convention on Climate Change. EPA also identified the benefits of

the GHGRP’s “consistent, verified, national dataset” to policymakers outside EPA, states, and the

public.55

Since program data were first reported in 2011, GHGRP data have been used to inform and

implement various federal policies and programs. The following are selected examples that

illustrate federal applications of GHGRP data and their reporting framework. They are not

intended to provide a comprehensive account of all applications. Additional details on the uses of

GHGRP data in these applications are beyond the scope of this report.

•

•

•

NSPS and Emissions Guidelines. EPA has used GHGRP data to develop and

revise NSPS for oil and natural gas facilities, fossil-fuel-fired power plants, and

municipal solid waste landfills.56 GHGRP data were used to characterize baseline

emissions, evaluate the necessity of emissions standards, and model the costeffectiveness of requirements, such as leak detection and repair.57

Methane Waste Emissions Charge (WEC). CAA Section 136 directs EPA to

impose and collect a WEC, sometimes referred to as a methane fee, based on

methane emissions reported under the GHGRP.58 The WEC is statutorily linked

with the GHGRP, as it applies to specific types of oil and natural gas facilities

that are required to report their GHG emissions to the GHGRP.

HFC Phasedown Under the American Innovation and Manufacturing (AIM)

Act of 2020.59 The EPA uses GHGRP data in its activities to document,

implement, and enforce the phasedown of HFCs under the AIM Act, including to

establish production and consumption baselines, calculate annual company

51 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260.

52 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260, 56369.

53 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260, 562369.

54 EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2022, 2024 (hereinafter EPA, 2024 Inventory).

EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260, 56265.

55 EPA, “Mandatory Reporting of Greenhouse Gases,” 74 Federal Register 56260, 56360.

56 See 40 C.F.R. §60, Subparts OOOOa, OOOOb, and OOOOc (oil and natural gas); Subparts TTTT, TTTTa, and

UUUUb (fossil-fuel-fired electric generating units); and Subpart XXX (municipal solid waste landfills).

57 EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591.

58 For more information, see CRS Report R48475, Inflation Reduction Act Methane Emissions Charge: Overview and

Developments, by Jonathan L. Ramseur.

59 P.L. 116-260, Division S, §103. For more information on the HFC phasedown, see CRS In Focus IF11779,

Hydrofluorocarbon Phasedown: Background and Issues Facing Congress, by Kathryn G. Kynett and Kristen Hite.

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•

•

allowances, and develop sector-based restrictions on the use of HFCs.60 EPA has

also used GHGRP data to track compliance with HFC phasedown requirements

and to support enforcement actions.61

Federal Tax Credits. GHGRP reporting is incorporated into the administration

of a number of federal tax credits. Taxpayers claiming the Internal Revenue Code

Section 45Q carbon sequestration credit must comply with specified GHGRP

reporting requirements as a condition of demonstrating secure geologic storage.62

Combustion and gasification facilities seeking Sections 45Y and 48E clean

electricity credits may use GHGRP data to demonstrate zero-emissions status.63

GHGRP data are also incorporated into the lifecycle emissions models used to

determine the value of Section 45V clean hydrogen production credits.64

Voluntary Initiatives. EPA has used GHGRP data to support voluntary

programs, including the Landfill Methane Outreach Program, which identifies

candidate landfills for gas-to-energy development, and the Natural Gas STAR

program, which uses reported data to identify cost-effective methane reduction

technologies for the oil and gas sector.65

In addition to federal applications, GHGRP data have been used by a range of other stakeholders.

States have incorporated elements of the GHGRP into their own reporting programs and use the

data to develop GHG inventories, track progress toward emissions reduction targets, and inform

policy design.66 Local governments and communities have used the data to identify nearby

60 For information regarding use of GHGRP data to determine HFC production and consumption baselines, and

allowances, respectively, see EPA, “Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and

Trading Program Under the American Innovation and Manufacturing Act,” 86 Federal Register 55140, October 5,

2021, https://www.federalregister.gov/d/2021-21030/p-320; and 86 Federal Register 55144, October 5, 2021,

https://www.federalregister.gov/d/2021-21030/p-356. For information regarding the use of GHGRP data for sectorbased HFC restrictions, see EPA, “Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain

Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020,” 86 Federal

Register 76747, December 15, 2022, https://www.federalregister.gov/d/2022-26981/p-222.

61 EPA, “Enforcement of the Greenhouse Gas Reporting Program: HFC Importers,” updated September 16, 2025,

https://www.epa.gov/enforcement/enforcement-greenhouse-gas-reporting-program-hfc-importers.

62 26 C.F.R. §1.45Q-3(b)(1). See 26 C.F.R. §1.45Q-3(b)(2) (allowing compliance for these developers by reporting

under CSA Group [CSA]/American National Standards Institute [ANSI] International Standards Organization [ISO]

27916:19); EPA, “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas

Reporting Rule,” 89 Federal Register 31802, April 25, 2025, https://www.federalregister.gov/documents/2024/04/25/

2024-07413/revisions-and-confidentiality-determinations-for-data-elements-under-the-greenhouse-gas-reporting

(establishing Subpart VV as a mechanism for the reporting required under that standard).

63 Internal Revenue Service (IRS), “Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity

Investment Credit,” 90 Federal Register 4006-4127, January 15, 2025, https://www.federalregister.gov/documents/

2025/01/15/2025-00196/section-45y-clean-electricity-production-credit-and-section-48e-clean-electricity-investmentcredit.

64 IRS, “Section 45V Clean Hydrogen Production Tax Credit,” 90 Federal Register 2224, January 10, 2025,

https://www.federalregister.gov/documents/2025/01/10/2024-31513/credit-for-production-of-clean-hydrogen-andenergy-credit.

65 EPA, “Landfill Methane Outreach Program,” updated January 22, 2026, https://www.epa.gov/lmop; EPA,

“Natural Gas STAR Program and Methane Mitigation,” updated February 9, 2026, https://www.epa.gov/natural-gasstar-program/natural-gas-star-program-and-methane-mitigation.

66 For examples of state and local governments’ use of GHGRP data in developing GHG inventories and climate action

plans, see EPA, “GHG Inventories Searchable Table,” updated January 22, 2025, https://www.epa.gov/inflationreduction-act/ghg-inventories-searchable-table. For examples of state incorporation of GHGRP methodologies and

requirements into state reporting programs, see, for example, Cal. Code Regs. Tit. 17, §95100(c); 5 Colo. Code Regs.

§1001-26.

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emissions sources and inform local planning efforts.67 Researchers have used GHGRP data to

analyze emissions trends, evaluate policy effectiveness, and develop emissions models.68 Private

entities use the data for corporate emissions disclosures, investment assessments, and to

demonstrate the GHG intensity of products.69

EPA Actions to Reconsider the GHGRP

In March 2025, EPA Administrator Lee Zeldin announced the agency would reconsider a number

of regulations and programs, including the GHGRP.70 In September 2025, EPA issued a proposed

rule to permanently remove GHGRP reporting obligations for 46 of the program’s 47 source

categories. For the remaining source category, Petroleum and Natural Gas Systems (Subpart W),

EPA proposed to permanently remove the natural gas distribution segment from GHGRP

reporting and to suspend reporting requirements for the other nine segments until reporting year

2034.71 In the proposed rule, EPA states it is reconsidering the GHGRP in response to Executive

Order (E.O.) 14154 and E.O. 14192, which direct agencies to eliminate regulatory obstacles

hindering domestic energy production and to eliminate 10 existing rules for every new rule

issued.72 EPA asserted the GHGRP imposes “significant costs” on entities that are required to

report under the program and that its proposal would remove unnecessary administrative burdens

from a program that does not directly improve public health or air quality.73

EPA provided two legal arguments as the basis for its proposed rule. First, EPA argued that CAA

Section 114 does not authorize the program as presently constituted for sectors not subject to

CAA Section 136 (Subpart W). EPA argued that Section 114 is best read as authorizing

information collection with a “closer nexus” to specific CAA regulatory purposes rather than

ongoing economy-wide reporting.74 EPA acknowledged that this interpretation “represents a

change from prior GHGRP rulemakings.”75

67 Comments of the States of California et al., Docket ID No. EPA-HQ-OAR-2025-0186, 2025.

68 Lavendar Yang et al., “The Real Effects of Mandatory CSR Disclosure on Emissions: Evidence from the Greenhouse

Gas Reporting Program,” National Bureau of Economic Research, Working Paper 28984, July 2021,

https://www.nber.org/papers/w28984; Benjamin Stark et al., “Investigation of U.S. Landfill GHG Reporting Program

Methane Emission Models,” Waste Management, vol. 186 (2024), pp. 86-93, https://www.sciencedirect.com/science/

article/abs/pii/S0956053X24003234.

69 Comments of the American Petroleum Institute, EPA-HQ-OAR-2025-0186-0464, 2025; Comments of the U.S.

Chamber of Commerce, EPA-HQ-OAR-2025-0186-0852, 2025.

70 EPA, “Administrator Zeldin Announces 31 Historic Actions to Power the Great American Comeback,” press release,

March 12, 2025, https://www.epa.gov/newsreleases/epa-launches-biggest-deregulatory-action-us-history.

71 EPA’s proposal to suspend Subpart W reporting requirements until January 1, 2034, and remove reporting

requirements for the natural gas distribution segment, aligns with CAA Section 136, as revised in P.L. 119-21, the 2025

budget reconciliation measure commonly referred to as the One Big Beautiful Bill Act (OBBBA). The OBBBA

amended CAA Section 136 to delay the implementation of the Waste Emissions Charge (WEC) until 2034. The WEC

program lists specific industry segments subject to the fee, and Natural Gas Distribution is not one of them. If EPA’s

rule is finalized as proposed, there would be no reporting obligations under Subpart W for reporting years prior to

2034; beginning January 1, 2034, all Subpart W segments, except Natural Gas Distribution, would again be subject to

program requirements.

72 Executive Order 14154, “Unleashing American Energy,” 90 Federal Register 8353, January 29, 2025. Executive

Order 14192, “Unleashing Prosperity Through Deregulation,” 90 Federal Register 9065, February 6, 2025. EPA,

“Reconsideration of the GHGRP,” 90 Federal Register 44591, 44594.

73

EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591, 44595.

74 EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591, 44596.

75 EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591, 44596.

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Second, EPA argued that even if such statutory authority exists, the Administrator could exercise

their discretion to discontinue the program on the basis they no longer believe the information is

necessary to carry out the provisions of the CAA. EPA acknowledged GHGRP data are currently

being used or have been used by EPA and other federal agencies and stated such uses have been

for purposes other than those enumerated in CAA Section 114, and therefore do not serve an

underlying statutory purpose under the CAA. EPA stated that data needed for specific future

regulatory purposes could be collected on a more targeted basis if and when that need arises,

rather than through ongoing economy-wide reporting.

EPA asserted that eliminating reporting requirements would result in cost savings for covered

entities. EPA estimated the annualized cost savings to be approximately $303 million per year in

total across all source categories (in 2024 dollars).76 EPA attributed approximately $256 million

of these annual savings to entities covered by Subpart W.77 According to EPA, these cost savings

reflect compliance costs for covered entities based on annualized capital costs (e.g., monitoring

equipment purchases and installation) and ongoing operational costs (e.g., monitoring equipment

maintenance).

Considerations for Congress

EPA’s proposal to reconsider the GHGRP raises a number of policy and oversight questions for

Congress. Congress could consider a number of policy options regarding the future of the

GHGRP. Congress could take no action, in which case the future of the program may be

determined by EPA through the rulemaking process. Members could express their support or

opposition to EPA’s proposal through resolutions, as some Members have done.78 Congress could

consider legislation explicitly addressing the authorities for the program. For example, if

Congress prefers to discontinue the program, it could enact legislation eliminating the program

and its reporting requirements. Alternatively, if Congress prefers the program to continue, it could

consider providing further direction to EPA in statute regarding the purpose of the program and its

scope. Congress could also conduct oversight of EPA’s implementation of the program and any

final rule. In weighing these options, or in considering oversight of the program, Congress may

find it useful to consider the range of stakeholder views and previously introduced legislation.

76 For more information on EPA’s 2025 regulatory impact analysis, see EPA, “Impacts of Reconsideration of the

GHGRP,” September 2025, Docket ID No. EPA-HQ-OAR-2025-0186. As part of the 2009 rulemaking, EPA estimated

total annualized costs of approximately $168 million (in 2006 dollars) for the first year of the program. EPA has since

amended the program’s reporting requirements through multiple rulemakings and estimated the incremental burden of

those changes in corresponding information collection analyses. The baseline for EPA’s 2025 analysis “reflects the

cumulative effect of implementing reporting requirements and the recently finalized amendments” with costs updated

to the 2024 labor rates and dollar values. The 2009 estimates therefore are not directly comparable to current cost

estimates. For more information, see EPA, “Regulatory Impact Analysis for the Mandatory Reporting of GHG

Emissions,” EPA–HQ–OAR–2008–0508, October 2009.

77 Of the $256 million in annual Subpart W cost savings, $3 million is permanently eliminated due to the elimination of

reporting requirements for the natural gas distribution segment. EPA estimates that the remaining $253 million in

annual compliance costs will be reintroduced beginning in the 2034 reporting year, when data collection resumes for

the other nine suspended industry segments. For more information, see EPA, “Impacts of Reconsideration of the

GHGRP,” Docket ID No. EPA-HQ-OAR-2025-0186, September 2025.

78 For example, H.Res. 1245 was introduced in the 119th Congress and expressed congressional support for the GHGRP

program.

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Stakeholder Views

Stakeholders provided input during the public comment period for EPA’s proposed rule to

reconsider the GHGRP. These public comment letters reflect a range of perspectives. These views

were often related to the benefits of the program, the costs of the program, and whether the

benefits outweigh the costs. Selected topics of discussion and stakeholder views are described in

this section to illustrate the issues stakeholders have raised that Congress may wish to consider.79

Some stakeholders oppose EPA’s proposal, arguing that the benefits of the GHGRP justify

continuing the program. These stakeholders include certain state officials, environmental

organizations, industry coalitions, and companies that rely on GHGRP data for policy design,

business reasons, or tax credits. They argue that the standardized, facility-level, economy-wide

data GHGRP provides are valuable and should continue to be collected. For example, some

contend that federal, state, and local policymakers use the data to develop, implement, and

enforce their programs—including EPA’s Inventory specifically—and that these uses of the data

justify continuing the program.80 In addition, some argue that the GHGRP provides important

benefits for the private sector. For example, they contend that investors use GHGRP data to assess

their risk related to climate change, and companies use the data to disclose their GHG emissions

and to benchmark their emissions, and emissions associated with, the use of their products.81

Additionally, stakeholders argue that private entities depend on GHGRP data and its framework

to claim federal tax credits for carbon sequestration (Section 45Q), clean electricity (Sections 45Y

and 48E), and clean hydrogen (Section 45V), and that EPA’s proposal could affect private

investments and delay projects.82

Other stakeholders who support EPA’s proposal generally argue that the benefits of the GHGRP

do not justify the compliance costs. These stakeholders include certain state officials, oil and gas

producers, and policy organizations that assert EPA imposes undue regulatory burdens with its

implementation of the GHGRP. Some stakeholders supporting the proposal argue that EPA has

made limited use of the data for regulatory purposes under the CAA and that uses outside those

purposes do not justify the costs of continuing mandatory reporting.83 EPA cited compliance costs

to reporting entities as part of the rationale for its proposal to reconsider the GHGRP.84 EPA

concluded that the proposal would result in significant cost savings for GHGRP reporting entities.

Some agree that EPA’s proposal would relieve businesses of a costly and burdensome

79 CRS reviewed public comments submitted to Docket ID No. EPA-HQ-OAR-2025-0186 and selected letters that

reflect recurring themes and represent a range of stakeholder perspectives. The comment letters cited in this section are

illustrative, rather than comprehensive, and are not intended to characterize the number or proportion of commenters

holding a particular view. To search and view public comments on EPA’s proposed rule, see Regulations.gov,

“Reconsideration of the Greenhouse Gas Reporting Program,” Docket ID No. EPA-HQ-OAR-2025-0186,

https://www.regulations.gov/docket/EPA-HQ-OAR-2025-0186/comments.

80 Comments of the States of California et al., Docket ID No. EPA-HQ-OAR-2025-0186, 2025; Comments of EDF,

NRDC, et al., EPA-HQ-OAR-2025-0186-0327, 2025; Comments of the Environmental Data and Governance Initiative

(EDGI), EPA-HQ-OAR-2025-0186-0859, 2025; Comments of the Center for Climate and Energy Solutions (C2ES),

EPA-HQ-OAR-2025-0186-0413, 2025.

81 Comments of the American Petroleum Institute, EPA-HQ-OAR-2025-0186-0464, 2025; Comments of the U.S.

Chamber of Commerce, EPA-HQ-OAR-2025-0186-0852, 2025.

82 Comments of the Bipartisan Policy Center, EPA-HQ-OAR-2025-0186-0224, 2025; Comments of the Carbon

Capture Coalition, EPA-HQ-OAR-2025-0186-0442, 2025; Comments of EDF, NRDC, et al., EPA-HQ-OAR-20250186-0327, 2025; Comments of the Fertilizer Institute, EPA-HQ-OAR-2025-0186-0474, 2025.

83 Comments of the Attorneys General of North Dakota et al., EPA-HQ-OAR-2025-0186-0811, 2025; Comments of the

American Energy Institute and Heartland Institute, EPA-HQ-OAR-2025-0186-0480, 2025.

84 EPA, “Reconsideration of the GHGRP,” 90 Federal Register 44591, 44595.

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regulation.85 They point to the recurring costs of monitoring, emissions calculations, reporting,

data verification, and recordkeeping. In addition, they argue that these costs are more burdensome

for small- and mid-sized operators. They also argue that the program requires reporting from

numerous small or marginal sources whose emissions are negligible relative to costs of reporting

them.86 Further, they argue that the compliance burden reduces the competitiveness of domestic

producers.87

Stakeholders also debated whether the proposal would produce cost savings as large as EPA

estimates in its proposal. Some stakeholders argue that EPA’s estimates of cost savings are

overstated.88 Others argue that eliminating program requirements could potentially add

compliance costs rather than reduce them. The GHGRP currently serves as a centralized reporting

framework that certain state programs and other data users rely on. Some stakeholders argue that

states would likely expand or establish their own reporting requirements. Covered entities

operating in multiple states could then be required to report separately, under differing rules, in

each jurisdiction rather than under a single national framework.89 In addition, some stakeholders

contend that because EPA’s estimates rely on annualized capital costs, these estimates count the

costs of monitoring systems that covered entities have already installed.90 Further, they argue that

in some cases, covered entities must keep monitoring and reporting GHG emissions to comply

with other programs, including mandatory state and regional GHG reporting programs. 91

Stakeholders also argue that in the absence of a standardized federal framework, private entities

and other stakeholders could face higher costs to procure data and secure independent third-party

verification of their GHG data.92

Legislation

Members of the 118th and 119th Congresses have introduced various bills related to the GHGRP.

Most of these bills were introduced prior to EPA’s proposal reconsidering the GHGRP and would

build on or modify the program. These bills illustrate certain policy options available to Congress,

including proposals that would expand the program, narrow it, or otherwise modify the program

to support specific purposes.

Congress could expand the scope of the program, such as by adding requirements or guidance for

additional data to be reported. For example, the Crypto-Asset Environmental Transparency Act

(S. 661, H.R. 1460; 118th Congress) would have revised Part 98 to add cryptocurrency mining as

85 Comments of the Attorneys General of North Dakota et al., EPA-HQ-OAR-2025-0186-0811, 2025; Comments of the

American Energy Institute and Heartland Institute, EPA-HQ-OAR-2025-0186-0480, 2025.

86 Comments of CrownQuest Operating, LLC, EPA-HQ-OAR-2025-0186-0238, 2025; Comments of the American

Energy Institute and Heartland Institute, EPA-HQ-OAR-2025-0186-0480, 2025.

87 Comments of the Prime Mover Institute, EPA-HQ-OAR-2025-0186-0482, 2025.

88 Comments of R Street Institute, EPA-HQ-OAR-2025-0186 0260-2025; Comments of SEMI, EPA-HQ-OAR-20250186-0237, 2025; Comments of the U.S. Chamber of Commerce, EPA-HQ-OAR-2025-0186-0852, 2025; Comments of

Business Roundtable, EPA-HQ-OAR-2025-0186-0452, 2025.

89 Comments of SEMI, EPA-HQ-OAR-2025-0186-0237, 2025; Comments of the U.S. Chamber of Commerce, EPAHQ-OAR-2025-0186-0852, 2025; Comments of Business Roundtable, EPA-HQ-OAR-2025-0186-0452, 2025.

90 Comments of the American Petroleum Institute, EPA-HQ-OAR-2025-0186-0464, 2025.

91 Comments of SEMI, EPA-HQ-OAR-2025-0186-0237, 2025; Comments of the U.S. Chamber of Commerce, EPAHQ-OAR-2025-0186-0852, 2025; Comments of Business Roundtable, EPA-HQ-OAR-2025-0186-0452, 2025.

92 Comments of EDF, NRDC, et al., EPA-HQ-OAR-2025-0186-0327, 2025; Comments of EDGI, EPA-HQ-OAR2025-0186-0859, 2025; Comments of C2ES, EPA-HQ-OAR-2025-0186-0413, 2025.

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a new source category.93 As another example, the SCOPE Act (S. 3928, H.R. 7684; 119th

Congress) would direct EPA to develop voluntary guidance for facilities covered under Part 98 to

calculate and report their scope 3 (value-chain) emissions—building on the program’s existing

source category definitions and reporting framework rather than expanding its mandatory

requirements.94

Congress could also narrow the scope of the program by continuing some level of GHG data

collection that is less comprehensive or frequent, or otherwise narrower than the current program.

For example, Congress could raise reporting thresholds, reduce the number of source categories

that are required to report, or reduce the amount or type data they are required to report. For

example, the MERP Clarifications Act (S. 514; 119th Congress) would narrow methane reporting

by exempting certain smaller facilities from Subpart W requirements.

Congress could also modify the program to support specific purposes, such as international trade.

Standardized and verified data that can support estimating the GHG intensity of U.S. goods are

increasingly relevant to trade policy. This may be particularly significant as carbon border

adjustment mechanisms—a charge on imports tied to the GHG emissions associated with

producing certain goods—are implemented abroad.95 The Clean Competition Act (S. 3523, H.R.

6787; 119th Congress), for example, would require covered domestic industries to report

information under the GHGRP to establish the carbon-intensity baselines for a U.S. carbon border

charge.

Oversight

Congress could also conduct oversight of EPA’s reconsideration of the GHGRP. Members have

expressed their positions through resolutions and oversight letters.96 In considering these

questions, Congress could seek additional information from EPA to inform its determinations.

For example, Congress could examine how the proposed reconsideration would affect federal

programs, regulations, and tax incentives that rely on GHGRP data. In addition, Congress could

examine the compliance cost estimates at issue—both the burden that reporting entities have

described and the savings EPA projects from its proposal—and clarify the extent to which

93 Cryptocurrency mining is the process of verifying cryptocurrency transactions, securing a blockchain network, and

releasing new coins into circulation. For more information, see CRS Report R48914, Cryptocurrency Mining and the

Electricity Sector, by Corrie E. Clark.

94 The Scope 1, Scope 2, and Scope 3 framework originates with the Greenhouse Gas Protocol, a voluntary corporate

accounting standard developed by the World Resources Institute (WRI) and the World Business Council for

Sustainable Development for corporate GHG reporting and disclosure. Scope 3 emissions, sometimes referred to as

value-chain emissions, encompass the entire lifecycle of a product or service, tracking GHG emissions from both

upstream suppliers (e.g., raw material extraction and logistics) and downstream users (e.g., customer product usage and

end-of-life disposal). Unlike Scope 1 and 2 emissions, which isolate direct emissions and purchased electricity, valuechain reporting tracks emissions through every phase where economic value is added. See WRI, “Greenhouse Gas

Protocol,” https://www.wri.org/initiatives/greenhouse-gas-protocol.

95 Comments of the Bipartisan Policy Center, EPA-HQ-OAR-2025-0186-0224, 2025; Comments of Business

Roundtable, EPA-HQ-OAR-2025-0186-0452, 2025; Comment of Exxon Mobil Corporation, EPA-HQ-OAR-20250186-0847, 2025. For more information on carbon border adjustments mechanisms, see CRS Report R47167, Border

Carbon Adjustments: Background and Developments in the European Union, by Jonathan L. Ramseur, Brandon J.

Murrill, and Christopher A. Casey.

96 For example, Members have sent joint oversight letters to EPA emphasizing the program’s role in industrial market

competitiveness and statutory compliance; see U.S. Senate Committee on Environment and Public Works Democratic

Staff, Letter to Lee Zeldin, EPA Administrator, “Reconsideration of the Greenhouse Gas Reporting Program,” May 7,

2025, https://www.epw.senate.gov/public/index.cfm/2025/5/whitehouse-demands-epa-halt-plans-to-dissolvegreenhouse-gas-reporting-program.

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reported costs are attributable to the GHGRP. Similarly, Congress could examine the extent to

which the benefits stakeholders attribute to the program depend on the GHGRP itself rather than

on data available from other sources. Such oversight could help resolve the questions

stakeholders have raised regarding the program’s authority, benefits, and costs.

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Appendix. Greenhouse Gas Reporting Program

(GHGRP) Source Categories

Table A-1. Source Categories Required to Report Under 40 C.F.R., Part 98

Subpart

Subpart Name

Reporter

Type

Sector

A

General Provisions

n/aa

n/aa

B

Reserved

n/ab

n/ab

C

General Stationary Fuel Combustion

Direct Emitter

Multiple Sectorsc

D

Electricity Generation

Direct Emitter

Power Plants

E

Adipic Acid Production

Direct Emitter

Chemicals

F

Aluminum Production

Direct Emitter

Metals

G

Ammonia Manufacturing

Direct Emitter

Chemicals

H

Cement Production

Direct Emitter

Minerals

I

Electronics Manufacturing

Direct Emitter

Other

J

Reserved

n/ab

n/ab

K

Ferroalloy Production

Direct Emitter

Metals

L

Fluorinated Gas Production

Direct Emitter

Chemicals

M

Reserved

n/ab

n/ab

N

Glass Production

Direct Emitter

Minerals

O

HCFC–22 Production and HFC–23 Destruction

Direct Emitter

Chemicals

P

Hydrogen Production

Direct Emitter

Chemicals

Q

Iron and Steel Production

Direct Emitter

Metals

R

Lead Production

Direct Emitter

Metals

S

Lime Manufacturing

Direct Emitter

Minerals

T

Magnesium Production

Direct Emitter

Metals

U

Miscellaneous Uses of Carbonate

Direct Emitter

Multiple Sectorsc

V

Nitric Acid Production

Direct Emitter

Chemicals

W

Petroleum and Natural Gas Systems

Direct Emitter

Petroleum and Natural Gas Systems

X

Petrochemical Production

Direct Emitter

Chemicals

Y

Petroleum Refineries

Direct Emitter

Refineries

Z

Phosphoric Acid Production

Direct Emitter

Chemicals

AA

Pulp and Paper Manufacturing

Direct Emitter

Pulp and Paper

BB

Silicon Carbide Production

Direct Emitter

Chemicals

CC

Soda Ash Manufacturing

Direct Emitter

Minerals

DD

Use of Electric Transmission and Distribution

Equipment

Direct Emitter

Other

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EE

Titanium Dioxide Production

Direct Emitter

Chemicals

FF

Underground Coal Mines

Direct Emitter

Other

GG

Zinc Production

Direct Emitter

Metals

HH

Municipal Solid Waste Landfills

Direct Emitter

Waste

II

Industrial Wastewater Treatment

Direct Emitter

Waste

JJ

Manure Management

—d

—d

KK

Reserved

n/ab

n/ab

LL

Suppliers of Coal-Based Liquid Fuels

Supplier

Coal-Based Liquid Fuel

MM

Suppliers of Petroleum Products

Supplier

Petroleum Product

NN

Suppliers of Natural Gas and Natural Gas Liquids

Supplier

Natural Gas Suppliers

OO

Suppliers of Industrial Greenhouse Gases (GHGs)

Supplier

Industrial Gas Suppliers

PP

Suppliers of (CO2)

Supplier

CO2 Capture, Supply, and Underground

Injection

QQ

Imports and Exports of Equipment Pre-Charged

with Fluorinated GHGs or Containing Fluorinated

GHGs in Closed-Cell Foams

Supplier

Equipment Pre-Charged with Fluorinated

GHGs

RR

Geologic Sequestration of CO2

CO2 Injection

Geologic Sequestration of CO2

SS

Electrical Equipment Manufacture or

Refurbishment

Direct Emitter

Other

TT

Industrial Waste Landfills

Direct Emitter

Waste

UU

Injection of CO2

CO2 Injection

CO2 Capture, Supply, and Underground

Injection

VV

Geologic Sequestration of CO2 with Enhanced

Oil Recovery Using ISO 27916

CO2 Injection

—e

WW

Coke Calciners

Direct Emitter

—f

XX

Calcium Carbide Production

Direct Emitter

—f

YY

Caprolactam, Glyoxal, and Glyoxylic Acid

Production

Direct Emitter

—f

ZZ

Ceramics Manufacturing

Direct Emitter

—f

Source: The subpart and subpart names are from 40 C.F.R. Part 98. The nine sector names shown here are

those used by the U.S. Environmental Protection Agency (EPA) for data display purposes in their Facility Level

Information Green House Gases tool. The reporter type is for the purposes of this report and is consistent with

how EPA describes the three types of covered entities these subparts fall under.

Note: The sector categories shown in Figure 1 are consistent with this Appendix.

a. Subpart A contains the general provisions of the GHGRP, which apply to all facilities and suppliers subject

to Part 98.

b. Subparts B, J, M, and KK of 40 C.F.R. are designated “Reserved.” A reserved designation holds a subpart

letter used in the C.F.R to indicate that a specific subpart is being held to maintain the alphabetical sequence

if a subpart was proposed previously and not finalized, or if reporting functions were merged elsewhere.

c. Emissions from Subpart C and U are distributed across sectors.

d. Subpart JJ is in force in 40 C.F.R. Part 98 but EPA does not actively implement it due to a recurring

congressional appropriations restriction prohibiting the expenditure of funds for this purpose. See

Consolidated Appropriations Act, 2024, P.L. 118-42.

e. EPA does not assign Subpart VV a sector name in FLIGHT.

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f.

Subparts WW, XX, YY, and ZZ were added to the GHGRP in 2024 and apply beginning with reporting year

2025. EPA has not assigned sector categories to these subparts in FLIGHT.

Author Information

Kathryn G. Kynett

Analyst in Environmental Policy

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan

shared staff to congressional committees and Members of Congress. It operates solely at the behest of and

under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other

than public understanding of information that has been provided by CRS to Members of Congress in

connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not

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