On September 12, 2025, EPA proposed to eliminate GHG reporting requirements for all source categories and suspend requirements until reporting year 2034 for oil and natural gas sources that are currently subject to Subpart W, despite the program’s role in providing data to EPA and a range of other federal, state, and industry efforts. Well-designed and effective regulations require accurate and transparent data. The Greenhouse Gas Reporting Program (GHGRP), established by EPA in 2009 consistent with congressional direction, forms the bedrock of greenhouse gas reporting from industrial sources in the US.
The GHGRP elicits comprehensive, transparent, and comparable GHG emissions data, with companies in a sector reporting the same way using industry-standard methodology rather than a piecemeal voluntary system. If EPA finalizes the proposal and ends GHG data collection, it will undercut the expertise and decision-making ability of EPA and hamper emissions reporting, tracking, and mitigation efforts by states and the private sector. That result would be consistent with the Trump administration’s effort to undermine and eliminate key sources of data that allow regulators and communities to make informed decisions.
In this paper, we review the fundamental uses of GHGRP data and evaluate EPA’s response to those uses. We then turn to EPA’s legal justification for ending the program, which relies on a novel, narrow interpretation of EPA’s data collection authority under Clean Air Act section 114.