EPA’s Greenhouse Gas Reporting Program
Updated March 20, 2023
EPA’s Greenhouse Gas Reporting Program
The U.S. Environmental Protection Agency’s (EPA’s)
EPA subsequently revised the 2009 rule to add technical
Greenhouse Gas Reporting Program (GHGRP) requires
requirements and new categories of sources covered by the
certain facilities to report their emissions of greenhouse
regulations. For example, in 2010, EPA established two
gases (GHGs). In addition, the GHGRP requires suppliers
new GHGRP source categories for facilities that inject
of specific products, such as natural gas and petroleum, to
carbon dioxide (CO2) into underground formations. In total,
report the GHG emissions that would ultimately result from
EPA has established 46 GHG source categories across a
the use of their products. Since 2011, the GHGRP has
wide range of economic sectors.
collected annual emissions data from nearly 8,000 large
industrial facilities and other sources in the United States.
Subpart A of the Mandatory Reporting Rule (codified in 40
According to EPA, 85%-90% of annual man-made U.S.
C.F.R Part 98) establishes general GHGRP reporting
GHG emissions have been reported under the program.
requirements that apply to all covered facilities. In Subparts
B-UU, EPA has established separate requirements for most
GHGRP Authorities and Purpose
GHG source categories based on the specific characteristics
The Consolidated Appropriations Act, 2008 (P.L. 110-161)
of those sources. Each of these subparts contains a
provided $3.5 million for EPA to develop and publish a rule
methodology to be used to calculate total annual GHG
that would “require mandatory reporting of greenhouse gas
emissions for that source category, as well as tailored
emissions above appropriate thresholds in all sectors of the
requirements for monitoring, quality assurance, accounting
economy of the United States.” In the accompanying joint
for missing data, recordkeeping, and reporting. For a few
explanatory statement, Congress directed EPA to “use its
source categories, such as motor vehicle manufacturers and
existing authority under the Clean Air Act” to promulgate
motor vehicle engine manufacturers, the 2009 rule added
this rule, and stated that EPA “shall have discretion to use
new requirements to existing emissions reporting and
existing reporting requirements for electric generating units
monitoring regulations.
under Section 821 of the Clean Air Act.” In its initial 2009
GHGRP rulemaking, EPA also cited Clean Air Act (CAA)
Facilities Required to Report
Sections 114 and 208 as providing “broad authority to
GHGRP regulations generally apply to: (1) direct GHG
require the information mandated” by the reporting rule.
emissions sources that emit at least 25,000 metric tons of
CO2-equivalent (CO2e, the amount of CO2 emissions with
The GHGRP requires reporting from facilities in nearly all
the same global warming potential as the number of metric
categories of direct emissions sources and from suppliers of
tons of another GHG) per year; (2) fuel and industrial gas
certain fuels and industrial GHGs in the United States, but
suppliers; and (3) facilities with underground CO2 injection
does not impose emissions limits. The broad scope of
wells. Direct emission sources include stationary fuel
emissions data collected from these sources allows the
combustion facilities and industrial and chemical
agency to assess trends in emissions over time and within
production facilities. Some facilities are covered regardless
industry sectors for use in agency policy and programs. For
of whether they emit 25,000 metric tons of CO2e or more
example, EPA uses the data in evaluating and implementing
per year, such as electricity generation facilities; facilities
GHG mitigation policies, including CAA New Source
engaged in aluminum production, ammonia manufacturing,
Performance Standards and CAA voluntary GHG reduction
and cement production; and some municipal solid waste
programs, among others. EPA states that the GHGRP is one
landfills.
part of the overall U.S. effort to address climate change,
alongside other federal and state GHG emissions-related
Suppliers covered by the regulations include suppliers of
programs. In addition, EPA uses the facility-level GHGRP
coal and natural gas, suppliers of petroleum products, and
data to help prepare the agency’s annual Inventory of U.S.
suppliers of CO2 and other industrial GHGs. CO2 injection
Greenhouse Gas Emissions and Sinks, which is submitted
facilities include facilities with wells used to inject CO2 for
to the United Nations in accordance with the Framework
enhanced oil recovery and for permanent storage through
Convention on Climate Change.
geologic sequestration. Some facilities have multiple GHG
sources and source categories and must report emissions for
Greenhouse Gas Reporting Regulations
all of these sources.
In response to Congress’s directive, EPA released a final
rule, “Mandatory Reporting of Greenhouse Gases,” which
Emissions Required to be Reported
went into effect on December 29, 2009. The regulations
The GHGRP regulations require facilities to report two
established in the rule require designated GHG source
types of GHG emissions: (1) combustion emissions
facilities and specific product suppliers to report annual
resulting from burning fossil fuels or biomass (such as
GHG emissions and follow monitoring, verification, and
wood or landfill gas); and (2) emissions from industrial
recordkeeping requirements.
processes, such as those that occur as a result of
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EPA’s Greenhouse Gas Reporting Program
transformation of raw materials during the production of
may take to verify the reported emissions. Annual reports to
iron and steel, cement, or petrochemicals. Emissions due to
EPA must include a GHG Monitoring Plan containing: (1)
leaks or irregular releases (also known as “fugitive
the job titles for those responsible for emissions data
emissions”) are also considered process emissions. Most
collection; (2) an explanation of emissions data collection
facilities are required to report total annual facility-level
processes; and (3) descriptions of the procedures and
emissions for each source category. Certain suppliers and
methods used for quality assurance, maintenance, and
manufacturers (e.g., motor vehicles and vehicle engine
repair of continuous monitoring systems. The regulations
manufacturers) report emissions at a corporate level. See
provide that EPA may review certification statements and
Figure 1 for GHGRP reporting facility locations and
GHG reports, conduct facility audits, and review other
emission amounts.
“credible evidence” to verify the accuracy and
completeness of emissions reporting. EPA also verifies
Figure 1. Location and Total Reported Direct
emissions data through automated checks of reports for
Emissions from GHGRP Facilities (2021)
errors before and after they are submitted.
GHGRP regulations also require that Subpart RR facilities
(injecting CO2 for underground geologic sequestration)
have an EPA-approved monitoring, reporting, and
verification (MRV) plan.
Reporting and Recordkeeping Requirements
Owners or operators of covered facilities must submit
annual reports to EPA on emissions from the prior calendar
year. Owners or operators must keep the records for at least
three years, including annual GHG reports, the Monitoring
Plan, the data used to calculate GHG emissions, the
calculations and methods used, test results, and
maintenance records for continuous monitoring systems.
Issues for Congress
Congress may consider several policy issues related to
GHGRP statutory authority and regulatory oversight.
Congress may consider how the application and scope of
GHGRP regulations align with EPA’s stated goal of
Source: CRS, adapted from EPA FLIGHT database, accessed March
enhanced understanding of GHG emissions in the United
16, 2023.
States now and in the future. For example, policymakers
could consider expanding the scope of sources required to
Covered facilities must report data on the following GHGs:
report and/or adjust the emissions reporting threshold for
CO
particular sources.
2;
Methane (CH4);
Congress may consider whether EPA resources are
Nitrous oxide (N2O); and
adequate and being used efficiently to carry out the
Hydrofluorocarbons (HFCs), sulfur hexafluoride (SF
GHGRP under the CAA. Some analysts expect that the
6),
perfluorinated compounds (PFCs), and other fluorinated
number of facilities required to report will expand in the
gases.
future, particularly for CO2 underground injection facilities.
Policymakers may consider the implications of potentially
For 2021 (the most recent data available) 7,608 direct
increased data collection and verification responsibilities on
emitters reported emitting 2.7 billion metric tons of CO
EPA capacity and resources.
2e.
Also in 2021, 966 suppliers, 87 CO2 injection facilities, and
9 facilities injecting CO
Congress may also consider how GHGRP data might
2 solely for geologic sequestration
reported data to EPA.
inform future legislative efforts. EPA has now collected 10
years of data on direct GHG emissions, fuel and GHG
Requirements for Calculating Emissions
suppliers, and industry-specific emissions trends.
EPA has established different methodologies for measuring
Policymakers may consider how this information, as well as
combustion emissions, process emissions, and suppliers of
future GHGRP data, could be used in potential future
fuels and GHGs. Facility owners and operators are required
legislation relating to GHG mitigation or climate change
to use the calculation methodologies in the relevant subpart
policy.
to determine annual emissions for each source category.
Monitoring and Verification Requirements
The GHGRP regulations include general monitoring
Angela C. Jones, Analyst in Environmental Policy
requirements for owners and operators and actions EPA
IF11754
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EPA’s Greenhouse Gas Reporting Program
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