What Happens If/When the GHGRP Goes Away?

Last month, US EPA proposed a rule to "reconsider" the Clean Air Act Greenhouse Gas Reporting Program or GHGRP. The proposed rule would remove obligations related to monitoring and reporting of specific air pollutants for most covered source categories.

The GHGRP (see 40 CFR Part 98) requires annual emissions reporting from industrial facilities in specific “source categories,” including electricity generation; manufacturing of some chemicals, acids, and raw materials; landfills; coal mines; fuel and gas suppliers; and carbon dioxide (CO₂) injection sites.



The GHGRP covers carbon dioxide, methane, nitrous oxide, various hydrofluorocarbons, and other emissions. Each listed substance is assigned a global warming potential (GWP) in 49 CFR Part 98 that reporting facilities to calculate their emissions' impact on the environment (compared to carbon dioxide). 

What Happens if the GHGRP Changes or Gets Eliminated?

First, if your state has a GHGRP program, it may remain in place. This means reporting is still required to the state, with or without a Federal GHGRP program. According to a study EPA conducted in late 2017, twenty-two states have some form of greenhouse gas reporting program in place, according to a mapping study EPA conducted at the end of 2017. Of those, 19 are mandatory programs and 3 are voluntary.  

If your state does not have a GHGRP program, you may be “off the hook” in the sense that reporting of greenhouse gas emission data is no longer due to EPA. Of course, there are many other reasons for industrial facilities to monitor air emissions, including GHG emissions. Business that operate outside the United States may have reporting obligations to other nations or bodies, e.g., the European Union.

GHG emissions data is often included in corporate sustainability or “ESG” reporting provided to investors, partners, and the public, as well. This information might be used within an organization to measure decarbonization efforts or other environmental initiatives.  

Also, one of EPA’s reasons for eliminating the GHGRP is that a substantial amount of the data collected is available to the agency through other reporting programs, such as the Toxics Release Inventory (TRI) program under EPCRA.