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Updated March 20, 2023

EPA's Greenhouse Gas Reporting Program

The U.S. Environmental Protection Agency's (EPA's)
Greenhouse Gas Reporting Program (GHGRP) requires
certain facilities to report their emissions of greenhouse
gases (GHGs). In addition, the GHGRP requires suppliers
of specific products, such as natural gas and petroleum, to
report the GHG emissions that would ultimately result from
the use of their products. Since 2011, the GHGRP has
collected annual emissions data from nearly 8,000 large
industrial facilities and other sources in the United States.
According to EPA, 85%-90% of annual man-made U.S.
GHG emissions have been reported under the program.
G HG RP Authorities and Purpose
The Consolidated Appropriations Act, 2008 (P.L. 110-161)
provided $3.5 million for EPA to develop and publish a rule
that would require mandatory reporting of greenhouse gas
emissions above appropriate thresholds in all sectors of the
economy of the United States. In the accompanying joint
explanatory statement, Congress directed EPA to use its
existing authority under the Clean Air Act to promulgate
this rule, and stated that EPA shall have discretion to use
existing reporting requirements for electric generating units
under Section 821 of the Clean Air Act. In its initial 2009
GHGRP rulemaking, EPA also cited Clean Air Act (CAA)
Sections 114 and 208 as providing broad authority to
require the information mandated by the reporting rule.
The GHGRP requires reporting from facilities in nearly all
categories of direct emissions sources and from suppliers of
certain fuels and industrial GHGs in the United States, but
does not impose emissions limits. The broad scope of
emissions data collected from these sources allows the
agency to assess trends in emissions over time and within
industry sectors for use in agency policy and programs. For
example, EPA uses the data in evaluating and implementing
GHG mitigation policies, including CAA New Source
Performance Standards and CAA voluntary GHG reduction
programs, among others. EPA states that the GHGRP is one
part of the overall U.S. effort to address climate change,
alongside other federal and state GHG emissions-related
programs. In addition, EPA uses the facility-level GHGRP
data to help prepare the agency's annual Inventory of U.S.
Greenhouse Gas Emissions and Sinks, which is submitted
to the United Nations in accordance with the Framework
Convention on Climate Change.
Greenhouse Gas Reporting Regulations
In response to Congress's directive, EPA released a final
rule, Mandatory Reporting of Greenhouse Gases, which
went into effect on December 29, 2009. The regulations
established in the rule require designated GHG source
facilities and specific product suppliers to report annual
GHG emissions and follow monitoring, verification, and
recordkeeping requirements.

EPA subsequently revised the 2009 rule to add technical
requirements and new categories of sources covered by the
regulations. For example, in 2010, EPA established two
new GHGRP source categories for facilities that inject
carbon dioxide (CO2) into underground formations. In total,
EPA has established 46 GHG source categories across a
wide range of economic sectors.
Subpart A of the Mandatory Reporting Rule (codified in 40
C.F.R Part 98) establishes general GHGRP reporting
requirements that apply to all covered facilities. In Subparts
B-UU, EPA has established separate requirements for most
GHG source categories based on the specific characteristics
of those sources. Each of these subparts contains a
methodology to be used to calculate total annual GHG
emissions for that source category, as well as tailored
requirements for monitoring, quality assurance, accounting
for missing data, recordkeeping, and reporting. For a few
source categories, such as motor vehicle manufacturers and
motor vehicle engine manufacturers, the 2009 rule added
new requirements to existing emissions reporting and
monitoring regulations.
Facilities Required to Report
GHGRP regulations generally apply to: (1) direct GHG
emissions sources that emit at least 25,000 metric tons of
CO2-equivalent (CO2e, the amount of CO2 emissions with
the same global warming potential as the number of metric
tons of another GHG) per year; (2) fuel and industrial gas
suppliers; and (3) facilities with underground CO2 injection
wells. Direct emission sources include stationary fuel
combustion facilities and industrial and chemical
production facilities. Some facilities are covered regardless
of whether they emit 25,000 metric tons of CO2e or more
per year, such as electricity generation facilities; facilities
engaged in aluminum production, ammonia manufacturing,
and cement production; and some municipal solid waste
landfills.
Suppliers covered by the regulations include suppliers of
coal and natural gas, suppliers of petroleum products, and
suppliers of CO2 and other industrial GHGs. CO2 injection
facilities include facilities with wells used to inject CO2 for
enhanced oil recovery and for permanent storage through
geologic sequestration. Some facilities have multiple GHG
sources and source categories and must report emissions for
all of these sources.
E missions Required to be Reported
The GHGRP regulations require facilities to report two
types of GHG emissions: (1) combustion emissions
resulting from burning fossil fuels or biomass (such as
wood or landfill gas); and (2) emissions from industrial
processes, such as those that occur as a result of

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