EPA Proposes Rule to Nix Greenhouse Gas Reporting Requirements for Most Sources

Trump’s Environmental Protection Agency (EPA) this week published a proposed rule to eliminate greenhouse gas reporting requirements for most of the sources subject to them. 

For one source category – petroleum and natural gas delivery systems – the proposed rule would suspend greenhouse gas reporting requirements until 2034. 

Little bit of background: EPA began requiring certain stationary sources to determine and report their greenhouse gas emissions in 2009.  According to the rule proposed on Sept. 16, there are currently 47 source categories (other than petroleum and natural gas delivery systems) that have greenhouse gas reporting obligations. 

However (and other than for petroleum and natural gas delivery systems), EPA has determined there is no statutory basis in the Clean Air Act (or elsewhere) to require sources to report their greenhouse gas emissions, which is the reason EPA is proposing to eliminate reporting requirement for those source categories. 

Abysmal news for sure, but: It also bears mentioning that we are not aware of any source (at least in western Pennsylvania) that is subject to limits on its emissions of greenhouse gases.

That’s not so with Sources in the petroleum and natural gas delivery systems category. Here’s why: Section 136 of the Clean Air Act does specifically require those sources to  report their greenhouse gas emissions for the purpose of calculating a waste emissions charge on methane emissions imposed by that section. We wrote about that last year, if you need a little more details on that one.

However, the One Big Beautiful Act, amended section 136 so the waste emissions charge will not be collected until 2034. Accordingly, EPA determined there is currently no statutory purpose to be served by requiring sources in that category to report their greenhouse gas emissions and suspended their greenhouse gas reporting obligation until 2034, when EPA should begin collecting the waste emission” charge pursuant to section 136.

The kicker?

EPA estimates that between now and 2034, the elimination (and suspension) of the greenhouse gas reporting requirement will save the entities that are subject to it a little less than $302.7 million per year in compliance costs. 

“The proposed rule did not attempt to calculate the value of any losses that might be suffered as a result of the elimination of greenhouse gas emissions reports, nor did it identify how those reports are used to further the purposes spelled out in the Clean Air Act,” GASP Senior Attorney John Baillie said.

Our Executive Director Patrick Campbell called this latest proposed rule “just another in a series of moves to systemically dismantle environmental regulations created to protect public for corporate convenience.”

EPA is accepting comments on the proposed rule through Nov. 3 and will hold a virtual public hearing on the proposed rule on Oct. 1.  You can submit comments at www.regulations.gov, identified by Docket ID No. EPA-HQ-OAR-2025-0186.

Editor’s Note: Stay tuned – we’ll be sharing more guidance on how