Understanding the Value of the Greenhouse Gas Reporting Program, and the Impacts of EPA’s Proposal to Roll Back the GHGRP

The EPA has proposed a significant rollback of the Greenhouse Gas Reporting Program (GHGRP), which would remove reporting requirements for 46 of 47 source categories and suspend subpart W reporting until 2034. This proposal threatens the viability of over 270 carbon capture projects and $77.5 billion in capital investment because the 45Q tax credit relies on GHGRP for monitoring, reporting, and verification (MRV). Specifically, the loss of subparts PP, RR, and VV would prevent carbon capture and storage (CCS) and enhanced oil recovery (EOR) projects from claiming 45Q credits. For hydrogen projects, the delay of subpart W would reduce the reliability of upstream methane leak rate measurements used in the 45VH2-GREET tool for 45V tax credits, potentially forcing taxpayers to rely on an inaccurate 0.9% national average and increasing legal risks for high performers. Internationally, the rollback could disadvantage U.S. exporters in markets requiring verified data, such as those under the EU Carbon Border Adjustment Mechanism (CBAM). Domestically, at least ten states, including California and Colorado, have embedded GHGRP into their legal frameworks; removing it would force these states to create costly patchwork substitutes to maintain emissions inventories.

• The EPA's proposal would permanently remove GHGRP reporting requirements for 46 of the 47 source categories and suspend reporting for the remaining nine subpart W segments until 2034.
• The 45Q tax credit for carbon capture projects depends on the GHGRP for the monitoring, reporting, and verification (MRV) necessary to quantify captured CO2; without subparts PP, RR, and VV, CCS and EOR projects cannot claim these credits.
• There are more than 270 announced carbon capture projects in the U.S. representing $77.5 billion in capital investment that are at risk due to the proposed rollback.
• The delay of subpart W reporting would impair the 45V tax credit for carbon-based hydrogen by reducing the reliability of upstream methane leak rate data used in the 45VH2-GREET tool, potentially forcing a reliance on a 0.9% national average that undercounts emissions.
• U.S. companies may face disadvantages in global markets, such as those governed by the EU Carbon Border Adjustment Mechanism (CBAM), which require the verified emissions data provided by the GHGRP.
• At least ten U.S. states have integrated the federal GHGRP into their own legal frameworks, and its repeal would force these states to expend resources creating substitute systems to fill data gaps.

APA

Clean Air Task Force (2025). Understanding the Value of the Greenhouse Gas Reporting Program, and the Impacts of EPA’s Proposal to Roll Back the GHGRP. https://www.catf.us/resource/understanding-value-greenhouse-gas-reporting-program-impacts-epas-proposal-roll-back-ghgrp/

Chicago

Clean Air Task Force. Understanding the Value of the Greenhouse Gas Reporting Program, and the Impacts of EPA’s Proposal to Roll Back the GHGRP. 2025. https://www.catf.us/resource/understanding-value-greenhouse-gas-reporting-program-impacts-epas-proposal-roll-back-ghgrp/.

Wikipedia

{{cite report |author=Clean Air Task Force |title=Understanding the Value of the Greenhouse Gas Reporting Program, and the Impacts of EPA’s Proposal to Roll Back the GHGRP |date=18 December 2025 |url=https://www.catf.us/resource/understanding-value-greenhouse-gas-reporting-program-impacts-epas-proposal-roll-back-ghgrp/ |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{cleanairtaskforce2025understanding, author = {{Clean Air Task Force}}, title = {{Understanding the Value of the Greenhouse Gas Reporting Program, and the Impacts of EPA’s Proposal to Roll Back the GHGRP}}, institution = {Clean Air Task Force}, year = {2025}, month = dec, url = {https://www.catf.us/resource/understanding-value-greenhouse-gas-reporting-program-impacts-epas-proposal-roll-back-ghgrp/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }