Since 2011, the US Environmental Protection Agency (EPA) has administered an extensive Greenhouse Gas Reporting Program (GHGRP), which requires thousands of facilities and organizations to report annual emissions of greenhouse gases (GHGs) (40 CFR part 98). Although reports are usually due by March 31 of the following year, EPA has delayed the deadline for reporting year (RY) 2024 until May 30, 2025. EPA cites delays in making the new version of its Electronic Greenhouse Gas Reporting tool (e-GGRT) available.
Who has been required to report?
I’ve written about these rules many times, most recently following significant technical amendments in 2024 (see HERE). In short, EPA’s current GHGRP requires reporting from the following qualifying entities, based on GHGs emitted and/or on the emission source’s industrial sector:
- 19 sectors - facilities with a source of any size (includes cement production; electricity generation; and petroleum refineries).
- 4 sectors - facilities with a source in a specified sector with emissions above a specified threshold (includes specified types of HFC-23 destruction processes).
- 13 sectors - facilities with any source in any specified source categories, and that emit a total 25,000 metric tons CO2e or more per year in combined emissions from specified sources (includes electronics manufacturing; glass production; and iron and steel production).
- 6 sectors - suppliers of specified following GHGs or fuels that emit GHGs when burned or consumed (includes natural gas and natural gas).
- PLUS facilities without any source in the preceding categories, but with aggregate maximum rated heat input capacity of stationary fuel combustion units of 30 million Btu per hour (mmBtu/hr) or greater), and emit 25,000 metric tons CO2e or more from all stationary fuel combustion sources.
How are emissions reported?
EPA provides an Electronic Greenhouse Gas Reporting tool (e-GGRT), which must be used to report emissions under the GHGRP. EPA revises and updates this tool in most years, EPA launches the tool in February in order to provide reporters with 6 weeks to “interact” with the tool and submit their reports. The 2025 update for RY 2024 reports was delayed (no reason was provided, but readers should note that the 2024 revisions I note above were very extensive).
What now?
EPA opened the RY 2024 version of e-GGRT for use during April 2025, so reporting entities will have the agency’s preferred 6 weeks to interact before meeting the one-time deadline of May 30.
Implementation Checklist
Has the organization prepared a GHG emissions inventory, identifying operations that:
- Burn fossil fuels and/or use GHGs?
- Supply fossil fuels and/or GHGs?
For each such potential source of GHG emissions, has the organization collected appropriate information?
- Fossil fuel and GHG use?
- GHG emissions?
- List of any sources regulated for emissions of GHGs or other air pollutants, and documentation associated with applicable their permits and compliance reports (including part 98 reports from prior years)?
Has the organization identified facilities and individual sources subject to part 98 reporting?
If the organization is a supplier of fossil fuels or specified GHGs, has the entity identified materials streams subject to part 98 reporting?
If the organization is presently subject to mandatory GHG emission reporting under part 98, has it evaluated any impacts from changes adopted by EPA?
If the entity has activities in any of the additional sectors EPA will regulate beginning in 2025, has it evaluated how the requirements will apply and how it would comply?
Where Can I go For More Information?
EPA provides extensive information on its website, and has published these revisions in the Federal Register:
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com