Blog by: Chasity Peters

On September 12, 2025, the Environmental Protection Agency (EPA) announced it intends to permanently remove reporting requirements under the Greenhouse Gas Reporting Program (GHGRP) for nearly all facilities after the 2024 reporting year.[1] The GHGRP was promulgated under the Clean Air Act and requires greenhouse gas producing facilities to report emissions annually to the EPA for compilation into public datasets.[2] The GHGRP was introduced as a way to accumulate data regarding emissions to inform legislators and experts about greenhouse gas production to allow for informed decision-making on ways to reduce emissions.[3]

The proposed rule intends to not only limit but eliminate reporting requirements for industries responsible for a significant portion of greenhouse gas production in the United States.[4] The EPA states there is no statutory requirement for industries and facilities outside of subpart W of the GHGRP to report this information and have consequently determined that reporting by those facilities is no longer necessary.[5] Subpart W includes onshore and offshore natural gas and petroleum production, onshore natural gas transmission, and a few other closely related facility types.[6] Among the 46 facility types that would no longer be required to report greenhouse gas emissions under the proposed rule are power plants, hydrogen production facilities, petrochemical manufacturing facilities, petroleum refineries, coal mines, and carbon dioxide suppliers.[7]

According to the most recent GHGRP data available from 2023, 2758 million metric tons of CO2e were reported by 7544 facilities required to report under this program.[8] Of the 2758 million metric tons, only 12.5% were reported by subpart W facilities.[9] This means that under the proposed rule, it is likely that more than 87% of greenhouse gasses emitted by polluting facilities in the future will go unreported.[10] Without this data, policymakers and experts may not be able make educated choices about how to improve air quality, make conscious choices for environmentally sound policies, or fully understand the pollutants entering our atmosphere for future scientific research.

The suggested rationale behind this change is the proposition that these requirements are cumbersome and costly for those required to report.[11] The EPA touts that this rule will save American businesses up to $303 million each year until 2034.[12] The problem with this claim, however, is that without research and major reform, climate change will cost Americans far more than these proposed savings could counterbalance over the coming years. Experts estimate that climate change costs the world $16 million an hour.[13] In less than one day, climate change takes from the global economy what the EPA suggests limiting reporting would save industry moguls in one year.[14] Increased energy prices from grids working harder, damages from natural disasters, rising insurance prices, and impacted natural resource production from ecosystem changes are all costing consumers more each year.[15]

Climate change is costly. Choosing to end a program that allows experts and policymakers to study the sources of a major contributor in greenhouse gasses will be even costlier. Greenhouse gas production is inextricably linked to climate change, leading to a rise in average surface temperature which over time can lead to more severe storms, higher sea levels, and changes in precipitation patterns.[16] In fact, the EPA has called greenhouse gas accumulation the “most significant driver of observed climate change since the mid-20th century.”[17] Climate change contributed to natural disasters such as drought, extreme tropical cyclones, and wildfires that cost the American people $746.7 billion in the from the years 2020 to 2024 alone.[18]

When major contributors to greenhouse gasses are left unreported, there is no longer accountability. Without accountability, producers have no incentive to limit their production, meaning that production will likely increase. Greenhouse gasses stay in the atmosphere for hundreds of years, creating a cumulative effect.[19] As greenhouse gasses are allowed to accumulate unchecked, climate change is allowed to worsen and will continue to cost the American people billions of dollars each year.

The EPA claims that “red tape” and a few million dollars saved are valid justifications for ruling that the largest producers of greenhouse gasses in the United States are no longer required to report their emissions.[20] Surely, the owners of these facilities are happy with this new rule, but it comes at a cost to the American people. If this regulation is allowed to be implemented, Americans, as well as the rest of the world, will suffer for it.

The information that researchers and policymakers are losing cannot feasibly be gathered without the cooperation of these facilities. Without these reporting requirements, actors will be working on limited information. Decisions made without necessary information cannot be an effective method of preventing future effects of climate change and the accompanying costs. It is important that the EPA recognizes the value in the data that is being collected and continue to require reporting, even if allowing facilities to emit greenhouse gasses unchecked may ease a bureaucratic burden. The EPA’s decision to end GHGRP reporting requirements will save negligible amounts of money for a few select people while costing the American people billions.

[1] Reconsideration of the Greenhouse Gas Reporting Program, 90 FR 44591 (Sept. 16, 2025).

[2] Mandatory Greenhouse Gas Reporting, 40 CFR Part 98 (Oct. 30, 2009).

[3] Fact Sheet - Proposed Rule: Reconsideration of the Greenhouse Gas Reporting Program, EPA, https://www.epa.gov/system/files/documents/2025-09/reconsideration-of-ghgrp-proposal-fact-sheet.pdf, (Last visited Sep 29, 2025) [https://perma.cc/GD28-KK3X].

[4] Id.

[5] Id.

[6] Id.

[7] Id.

[8] GHGRP Reported Data – National Highlights, EPA, https://www.epa.gov/ghgreporting/ghgrp-reported-data (Last visited Sep 29, 2025) [https://perma.cc/8WVN-2V7D].

[9] 2023 Greenhouse Gas Emissions from Large Facilities, EPA Facility Level Information on Greenhouse Gasses Tool, (Data Accessed Sep 28, 2025) [https://perma.cc/JU32-ARZK].

[10] Id.

[11] Supra note 1.

[12] Id.

[13] Rebecca Newman & Illan Noy, The Global Costs of Extreme Weather that are Attributable to Climate Change, Nature Communications, 14 Art. 6103 (2023) https://doi.org/10.1038/s41467-023-41888-1 [https://perma.cc/QA75-77H2].

[14] Id.

[15] Robert Hart, Climate Change Will Cost Global Economy $38 Trillion Every Year Within 25 Years, Scientists Warn, Forbes, https://www.forbes.com/sites/roberthart/2024/04/17/climate-change-will-cost-global-economy-38-trillion-every-year-within-25-years-scientists-warn/ (Apr 17, 2024) [https://perma.cc/8ULF-F48U].

[16] Climate Change Indicators: Greenhouse Gases, EPA, https://www.epa.gov/climate-indicators/greenhouse-gases (Last visited Sep 29, 2025) [https://perma.cc/Z54H-UTLC].

[17] Id.

[18] Billion-Dollar Weather and Climate Disasters – United States Summary, NOAA Nat. Centers for Env’t Information, https://www.ncei.noaa.gov/access/billions/state-summary/US (Data Accessed Sep 29, 2025) [https://perma.cc/BAW6-9EG4].

[19] Energy and the Environment Explained -Greenhouse Gases and the Climate, US Energy Information Admin., https://www.eia.gov/energyexplained/energy-and-the-environment/greenhouse-gases-and-the-climate.php (Last visited Sep 12, 2025) [https://perma.cc/2ZCU-7GGW].

[20] Supra note 3.