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ARTICLE · 26 NOVEMBER 2025

Proposed Repeal Of GHG Reporting Program Sparks Debate

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On September 12, 2025, the U.S. Environmental Protection Agency (EPA) proposed to narrow the Greenhouse Gas Reporting Program (GHGRP) significantly, citing Executive Orders aimed at deregulation.

United StatesEnergy and Natural Resources
Shailesh Sahay
Shailesh Sahay
Brittany M. Pemberton
Brittany M. Pemberton
Lily Walton
Lily Walton

On September 12, 2025, the U.S. Environmental Protection Agency (EPA) proposed to narrow the Greenhouse Gas Reporting Program (GHGRP) significantly,1 citing Executive Orders aimed at deregulation.2 The Proposal would eliminate most GHGRP reporting requirements, leaving only those for petroleum and natural gas operations under Subpart W, which would be delayed until 2034.3 Notably, the natural gas distribution sector would be exempt in its entirety.4

This move marks a major reduction of a program established over 15 years ago. The Proposal drew over 53,000 comments from diverse stakeholders, including industry, environmental groups, state officials, tribes, and the public. Environmental organizations opposed the rollback, emphasizing the GHGRP's role in climate policy, transparency, and federal incentives.5 They argued EPA's authority under section 114(a)(1) of the Clean Air Act (CAA) supports maintaining the program, warning that its removal could hinder climate

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