What Is the Proposed GHGRP Subpart W Freeze? Compliance Implications

EPA has proposed suspending all GHGRP Subpart W reporting obligations through 2034 and permanently removing reporting requirements for the Natural Gas Distribution segment . If finalized as proposed, there would be no Subpart W reporting obligations for any reporting year before 2034 . The proposed rule has not been finalized; on February 27, 2026, EPA separately finalized an extension of the CY2025 reporting deadline from March 31 to October 30, 2026 . Three compliance actions remain defensible regardless of how the broader rulemaking resolves .

Quick Answer: EPA has proposed suspending all GHGRP Subpart W reporting obligations through 2034 and permanently eliminating Subpart W reporting for the Natural Gas Distribution segment . If finalized, there would be no Subpart W reporting obligations for any reporting year before 2034. The proposed rule is not yet final; on February 27, 2026, EPA separately finalized an extension of the CY2025 reporting deadline to October 30, 2026 .

The Proposed Subpart W Freeze Would Suspend All Reporting Obligations Through 2034

The proposed rule would suspend all Subpart W reporting obligations through 2034 and permanently remove the Natural Gas Distribution segment from the program, pending finalization . This is not limited to measurement-based requirements: if finalized as proposed, there would be no reporting obligations under Subpart W for any reporting year prior to 2034 .

GHGRP Subpart W Requires Facilities Above 25,000 MT CO2e to Report Annually

GHGRP Subpart W, codified at 40 CFR Part 98, Subpart W, requires petroleum and natural gas systems facilities that emit 25,000 metric tons CO2e or more per year to report annual greenhouse gas emissions to EPA [1]. Covered source categories span the full upstream and midstream value chain: production wells, gathering and boosting, natural gas processing, transmission and storage, and distribution systems [1]. The annual submission deadline is March 31 for the prior calendar year’s emissions [2].

The 2024 Rule Added Measurement-Based Quantification Mandates for Multiple Source Categories

The Biden administration finalized updates to Subpart W in 2024, expanding measurement-based quantification requirements for certain emission source categories . The 2024 rule moved operators away from exclusively factor-based approaches for source categories including well venting, pneumatic controllers, and storage tanks .

Those updates required operators to use source-specific data or direct measurements for the affected source categories . The transition introduced two practical consequences for covered facilities: higher inventory accuracy for those who completed it, and a larger data collection burden for those in progress .

A Finalized Freeze Would Eliminate All Subpart W Reporting Obligations Until 2034

Under the proposed rule, EPA would suspend all Subpart W reporting obligations for reporting years prior to 2034 . Beginning January 1, 2034, all Subpart W segments except Natural Gas Distribution would again be subject to program requirements . Operators who had begun transitioning to measurement-based quantification methods in preparation for the 2024 rule would have no federal GHGRP reporting obligation to complete that transition prior to 2034, if the proposed rule is finalized in its current form . EPA anticipates finalizing the rule by July 2026 .

Covered Facilities Remain Legally Obligated Under Whichever Subpart W Version Is Currently in Effect

The proposed suspension is not a final rule [7]. Until EPA issues a final rule, 40 CFR Part 98 legally obligates covered facilities to comply with whichever version of Subpart W is currently in effect, including any 2024 provisions not formally stayed or enjoined . Compliance teams treating the proposed suspension as already in effect are creating enforcement exposure under the current program .

One aspect of the proposal has been separately finalized: on February 27, 2026, EPA issued a final rule extending the CY2025 annual reporting deadline from March 31, 2026 to October 30, 2026 . This extension applies only to the reporting deadline; all other Subpart W obligations remain governed by the currently effective regulations until a final rule on the broader reconsideration is published .

Facilities below the 25,000 metric ton CO2e annual emissions threshold are not covered by GHGRP Subpart W and are unaffected by this proposed rule [1].

The more immediate practical risk is inventory planning uncertainty . Measurement protocols and data collection workflows may not have a clear federal compliance pathway until the final rule is published . Three actions remain defensible regardless of how the rulemaking resolves .

This post is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel or a compliance professional for guidance specific to your operations and jurisdiction.

Three Actions That Are Defensible Under Any Rulemaking Outcome

Regardless of how the Subpart W rulemaking resolves, three compliance actions reduce enforcement exposure and preserve audit readiness: filing on time under current requirements, documenting calculation methodology, and monitoring the EPA docket for final rule publication .

Covered facilities should continue filing under currently applicable Subpart W requirements . EPA extended the CY2025 annual reporting deadline to October 30, 2026 via a final rule published February 27, 2026 . Failure to submit by the applicable deadline, or submitting with material errors, creates enforcement exposure that a proposed rule cannot cure .

Covered facilities should document current calculation methodology . Whether reporting under pre-2024 or 2024 methods, EPA expects methodological consistency and documentation across reporting years . A facility that shifts calculation approaches year-over-year without a documented rationale generates audit risk regardless of what the final rule ultimately requires .

Covered facilities should monitor the EPA docket for this proposed rule (Docket No. EPA-HQ-OAR-2025-0186) . Comment periods close on a fixed schedule unrelated to final rule publication timelines . Final rules follow on EPA-determined schedules after comment periods close .

Pending litigation can alter or delay both . The comment period for Docket No. EPA-HQ-OAR-2025-0186 closed November 3, 2025; EPA anticipates finalizing the rule by July 2026 . Confirm finalization status at https://www.epa.gov/ghgreporting before acting on any timeline assumption .

Frequently Asked Questions

Does the proposed freeze eliminate GHGRP Subpart W reporting?

If finalized as proposed, yes — through 2034. The proposal would suspend all Subpart W reporting obligations for reporting years prior to 2034 and permanently remove the Natural Gas Distribution segment from the program . This is not limited to the measurement-based quantification requirements introduced in the 2024 rule; the proposal would eliminate all reporting obligations under Subpart W until 2034 . The proposed rule has not been finalized; covered facilities remain obligated under currently effective regulations until EPA publishes a final rule .

Does the proposed freeze affect state-level O&G emissions reporting obligations?

No. Colorado’s ONGAEIR program and comparable state reporting obligations are administered by state agencies under separate statutory and regulatory authority [3]. A federal GHGRP freeze has no direct legal effect on state program requirements . Colorado operators must continue to meet ONGAEIR annual reporting requirements on the state’s schedule, independently of any changes to federal GHGRP Subpart W [4].

What should we do with measurement data already collected for 2024 rule compliance?

Retain source-specific measurement data collected in preparation for 2024 Subpart W compliance . That data improves the defensibility of any Subpart W inventory . Source-specific measurements remain directly applicable to voluntary frameworks, particularly OGMP 2.0 (the UN Environment Programme’s Oil and Gas Methane Partnership voluntary reporting framework), which requires measurement-based reporting at Levels 4 and 5 regardless of what federal GHGRP regulations require [5]]. Operators who invested in source-specific data collection have a higher-quality inventory baseline that supports both audit readiness and voluntary program participation .

Will the proposed freeze affect EPA enforcement of current GHGRP reporting requirements?

No. A proposed rule does not modify EPA’s enforcement authority over currently applicable requirements . The CY2025 reporting deadline has been extended to October 30, 2026 by a final rule published February 27, 2026 . Facilities that fail to submit by the applicable deadline, or submit with material errors, remain subject to enforcement under the existing GHGRP program . Consult qualified legal counsel for guidance on your specific facility’s obligations during the rulemaking period.

What happens to 2024 Subpart W requirements if the proposed freeze is not finalized?

If EPA does not finalize the proposed suspension, the 2024 Subpart W final rule requirements remain in effect and applicable on their original implementation timeline . Compliance teams should not defer data collection or methodology transitions on the assumption that the suspension will be finalized . The CY2025 deadline is October 30, 2026 under either rulemaking outcome .

This post is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel or a compliance professional for guidance specific to your operations and jurisdiction.

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[1] 40 CFR Part 98, Subpart W — Petroleum and Natural Gas Systems. U.S. Environmental Protection Agency. Electronic Code of Federal Regulations. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-W

[2] 40 CFR Part 98.3 — General Reporting Requirements; GHGRP Annual Submission Deadline. U.S. Environmental Protection Agency. Electronic Code of Federal Regulations.

[3] U.S. Environmental Protection Agency. Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. Final Rule. 89 Fed. Reg. 42062 (May 14, 2024). https://www.federalregister.gov/documents/2024/05/14/2024-08988/greenhouse-gas-reporting-rule-revisions-and-confidentiality-determinations-for-petroleum-and-natural. Body claims referencing specific source-category-level rule provisions are labeled , reflecting that the scope of specific requirements requires confirmation against the published rule text before reliance.

[4] U.S. Environmental Protection Agency. Reconsideration of the Greenhouse Gas Reporting Program. Proposed Rule. Docket No. EPA-HQ-OAR-2025-0186. 90 Fed. Reg. 44591 (September 16, 2025). Comment period closed November 3, 2025. Proposed rule pending finalization as of February 2026. https://www.federalregister.gov/documents/2025/09/16/2025-17923/reconsideration-of-the-greenhouse-gas-reporting-program.

[5] Colorado AQCC Regulation 7 — Oil and Natural Gas Sector Emission Inventory and Reporting (ONGAEIR). Colorado Department of Public Health and Environment (CDPHE). https://cdphe.colorado.gov/ong-air-emissions-reporting

[6] Oil and Gas Methane Partnership 2.0 (OGMP 2.0) Reporting Framework. UN Environment Programme. https://ogmpartnership.com

[7] Administrative Procedure Act, 5 U.S.C. § 553 — Rulemaking. U.S. Code. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title5-section553

References

  1. 40 CFR Part 98, Subpart W.
  2. 40 CFR Part 98.3.
  3. ONGAEIR is administered under Colorado AQCC Regulation 7; CDPHE is the administering agency.
  4. Colorado AQCC Regulation 7.
  5. OGMP 2.0 Framework; UN Environment Programme, Citation [6.