Green House Gas (GHG) Inventory

Understanding the GHG Inventory & Annual Report

The Greenhouse Gas (GHG) Reporting Program, established by the Environmental Protection Agency (EPA), mandates that certain facilities track and report their emissions through the Greenhouse Gas Reporting Program (GHGRP). A key component of this program is the GHG inventory and annual report, which ensures regulated entities provide accurate and timely emissions data. Approximately 8,000 facilities are required to report their emissions annually, the EPA required certain industries to begin reporting in 2010 and others in 2011.

Under the GHGRP there are three types of facilities that need to report annually:

1. Direct Emitters – Entities that emit GHGs directly from their facilities as a result of combustion or processing onsite

2. Suppliers – Entities that supply products such as fossil fuels, etc. into their supply chain that when used (via combustion, release, or oxidation), result in GHG emissions. The emissions do not take place at the suppliers’ reporting location.

3. Facilities that inject CO₂ underground.

Who Must Submit a GHG Inventory & Annual Report?

Depending on the type of industry, type of facility, facility emissions, and many other factors, a facility would need to report annually. Generally, facilities who produce:

• 25,000 metric tons or more of CO₂e per year.
• Product that if released, combusted or oxidized would result in over 25,000 metric tons CO₂e of GHG emissions.
• The facility receives 25,000 metric tons or more of CO₂ for underground injection.

Typically those required to submit are industries such as power plants, refineries, and manufacturing operations. Certain smaller emitters may also be required to report based on industry-specific thresholds. For a complete breakdown of who needs to report, click the link to the EPA website (EPA GHG Inventory Who Reports)

Key Deadlines & Compliance Requirements

Each year, regulated facilities must submit their GHG inventory and annual report by March 31st using the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT). Reports must include comprehensive data on emissions sources, methodologies, and any applicable regulatory subparts. Facilities should ensure compliance by verifying calculations, maintaining records, and preparing for potential audits.

Regulatory Implications of Non-Compliance

Failure to submit a GHG inventory and annual report on time can result in enforcement actions, including fines and penalties. Facilities should maintain thorough documentation to support reported data and adhere to EPA protocols to avoid compliance risks.

Staying Ahead of GHG Reporting Requirements

To maintain compliance, facilities should regularly review EPA updates, conduct internal audits of emissions data, and seek expert guidance on evolving GHG reporting obligations.