Why the Oil Industry Needs the Greenhouse Gas Reporting Program
When Environmental Protection Agency (EPA) Administrator Lee Zeldin announced “the largest deregulatory action in U.S. history” in March, EPA indicated it will reconsider the Greenhouse Gas Reporting Program (GHGRP)—the most comprehensive national inventory of greenhouse gas data in the world. As with several other proposed changes to EPA regulations, this could have negative implications for the oil and gas sector. The GHGRP is an essential way for companies to report their emissions, benchmark their performance, demonstrate improvements in emissions intensity, and meet growing demands from investors, customers, and, potentially, international regulations.
Origins of the GHGRP
EPA is reconsidering the “Mandatory Reporting of Greenhouse Gases” rule of 2009 as well as subsequent amendments. The agency suggests that revisions to the GHGRP could streamline the reporting requirements to “find efficiencies and lower burden on reporters.” It remains unclear how dramatically EPA may scale back the program, but a major overhaul may be imminent. ProPublica and the New York Times report that EPA may eliminate reporting requirements for nearly all industries. Zeldin’s radical deregulatory agenda at EPA reflects a broader effort by the Trump administration to shrink the “administrative state.” Already EPA pushed back this year’s GHGRP reporting deadline. The agency also failed to publish its most recent Inventory of Greenhouse Gas Emissions and Sinks, which was shared by Environmental Defense Fund in May only after the NGO filed a Freedom of Information Act request to force its release.
The GHGRP was created to provide a comprehensive summary of U.S. GHG emissions. In 2008, Congress directed EPA to develop a rule that would require reporting of GHGs from all sectors of the economy, and in the 2009 law establishing the GHGRP, EPA cited two sections of the Clean Air Act that provided statutory authority to collect emissions data. Over time, EPA created 46 different source categories for GHGs across various industries, and it has established separate reporting requirements (Subparts B-UU) for most sources, including monitoring, record keeping, and reporting guidelines. The GHGRP applies to large industrial facilities that emit 25,000 tons or more of CO2 equivalent in GHG emissions per year, as well as CO2 injection sites, and most upstream suppliers of fossil fuels and industrial gases. It now covers approximately 8,000 sources. In the oil and gas industry, covered facilities include upstream production, gathering and boosting as well as transmission assets, refineries, petrochemicals facilities, and CO2reinjection wells. Onshore oil and gas producers must report emissions of carbon dioxide, methane, and nitrous oxide.
The U.S. greenhouse gas inventory has served as the model for other countries to tally greenhouse gases across their economies. In fact, it is the basis for reporting of GHGs under the UN Framework Convention on Climate Change (UNFCC), which underpins the Paris agreement. EPA uses GHGRP data to prepare the annual Inventory of Greenhouse Gas Emissions and Sinks, and the U.S. government submits the data to the UNFCCC.
The Value of GHGRP Data
Over time, the use of GHGRP data has evolved substantially. As scrutiny of GHG emissions has grown, investors, environmental organizations, consultants, journalists, and others have turned to the GHGRP. There are several factors that make it a uniquely valuable data source.
First, the GHGRP is comprehensive. The program is the only consistent framework for emissions accounting from oil and gas companies in the world. Nearly every major producer or supplier reports to the GHGRP and uses the exact same methods—so the program summarizes emissions performance among a wide range of companies. It is also detailed, requiring companies to report emissions across operating areas and segments. EPA publishes various data sets and tools as well as sector summaries and highlights.
Second, the GHGRP provides transparent, comparable data. This is arguably its most important feature. Even as more oil and gas companies have shifted toward measurement rather than emissions factor-based estimates of GHG emissions, the GHGRP remains the only dataset that is fully comparable for a large number of companies.
Third, the GHGRP shows how emissions performance has evolved. The data track industry-wide changes in emissions, and for individual companies such as producers or major pipeline companies, the program is an important way to demonstrate improved performance. Of course, as companies have moved toward measurement rather than estimates of GHGs, especially methane, they have new methods to share emissions data. But since not all companies conduct their own measurement campaigns, the GHGRP remains a comprehensive benchmark.
Fourth, the GHGRP has improved over time—but recent changes to require measurement are being rolled back. Revised reporting requirements under Subpart W, which covers the upstream and midstream segments, now require companies to adopt advanced measurement. When Congress introduced the Inflation Reduction Act (IRA) Waste Emissions Charge, it required EPA to amend Subpart W to ensure that reporting and calculation of the WEC charges “are based on empirical data” and “accurately reflect the total methane emissions and waste emissions from the applicable facilities.” Congress overturned EPA’s implementation rule for the WEC via a Congressional Review Act resolution in March 2025, and in H.R. 1 or the “Big Beautiful Bill”, it delayed collection of the WEC for ten years until 2034, effectively killing the “methane fee.” It also rescinded unobligated funding to support methane mitigation and compliance with Subpart W reporting requirements. But the bill did not rescind the Subpart W requirements—likely because EPA’s Subpart W Update Rule was rooted in other EPA authorities and has no budget implications, and therefore could not be undone in a budget reconciliation bill. (For details, see CEESA white paper Will Trump Mend or End Federal Methane Rules?, January 2025). Instead, EPA must make any changes to the Subpart W requirements through normal administrative procedures—and indeed it has begun this process.
To be sure, the GHGRP is imperfect. The greatest weakness, as noted above, is that the engineering-based estimates that constitute the inventory are based on emissions factors for individual pieces of equipment and processes. Early methane measurement campaigns suggested that emissions could be some 60% higher than inventory data would suggest. However, as companies have adopted measurement and reduced methane emissions, this gap is beginning to narrow—and as long as Subpart W compels companies to adopt advanced measurement, this trend will continue. Even a 30% variation between GHGRP data and measurement-based data would place it within the uncertainty range of most measurement studies.
Meeting Market and Regulatory Demands
As investors have demanded better data on GHG emissions in recent years, public companies have made methane reductions a key part of their sustainability reports and investor presentations. Halting or curtailing the collection of GHGRP data from the oil and gas industry would be at odds with these demands for greater transparency on emissions, and indeed it could leave U.S. companies ill equipped to meet such demands.
Attention from NGOs and media organizations is also increasing the scrutiny over industry-wide emissions, and policy and regulatory changes mean that customers and supply chain partners are beginning to request more emissions data. Eliminating the GHGRP or substantially scaling it back would not eliminate the calls for producers to account for their emissions. However, it may increase dependence on less credible systems for emissions accounting—potentially including third-party interpretations of satellite data that compare emissions with a GHGRP-derived baseline.
The Trump administration’s own proposed policies could increase the importance of the GHGRP. In August 2024, the European Union methane regulation entered into force, and upcoming deadlines will require EU gas importers and their suppliers to provide data on methane monitoring, reporting, and verification (MRV). By January 1, 2027, EU gas importers will have to prove that gas supplies placed onto the EU market are produced under MRV conditions equivalent to the rules that apply to oil and gas production within the union. Producers can satisfy this MRV equivalence requirement at a corporate level by providing producer-level data (as well as independent verification), but the methane regulation also allows the possibility of national “equivalence determinations” for supplier countries. (For details, see CEESA white paper Three Big Questions on the EU Methane Regulation, March 2025). The European Commission must still spell out the process of granting equivalence determinations in secondary legislation, and at this stage, producer-level equivalence seems more straightforward and easier to attain. Nonetheless, U.S. liquefied natural gas (LNG) exporters hope this will be a way for the EU to issue a free pass to U.S. supplies.
Already, the ending of the WEC and the reconsideration of EPA methane regulations harm the case for an equivalence determination for the United States. But if EPA regulations are weakened, GHGRP data will be all the more important. Indeed, U.S. government officials have reportedly briefed EU officials on the GHGRP program in an effort to bolster the case for an equivalence determination. Crippling the GHGRP would certainly seem to harm the cause.
Ultimately, the GHGRP is valuable to the oil and gas industry because it collects data that are essential to corporate commitments and external demands. Data transparency enhances competitiveness and market access for US oil and gas exports. Substantially weakening emissions data collection would harm rather than help U.S. companies.
About the Author
Ben Cahill is Director for Energy Markets and Policy at the Center for Energy and Environmental Systems Analysis, University of Texas at Austin.
