While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs.  Several states, such as California, already have some form of mandatory GHG reporting in place.  Others are introducing similar programs to take effect over the next several years.

In particular, New York is expected to finalize a rule establishing a Mandatory Greenhouse Gas Reporting Program.  The state announced its proposal in spring 2025 and public comments closed on July 1.  New York’s program appears to be similar to both the federal GHGRP (which EPA will likely roll back) and California’s Mandatory Reporting Regulation (“MRR”) and applies to companies with significant direct emissions from facilities located in New York state and fuels and electricity consumed within the state.  This blog post provides an overview of New York’s proposed program and compares it with California’s MRR.  Continue Reading State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program