On September 16, 2025, the U.S. Environmental Protection Agency (EPA) proposed sweeping changes to the Greenhouse Gas Reporting Program (GHGRP), including the suspension of reporting obligations for most petroleum and natural gas segments under Subpart W until 2034. While this rollback may appear to offer regulatory relief, oil and gas companies should think twice before scaling back their GHG emissions monitoring and accounting practices.
Here are five reasons why continuing “business as usual” is not only prudent—but strategic:
- State and Global Regulations Still Require Verified Emissions Data
Even if federal reporting is suspended as proposed, many states have existing emissions inventory programs that may rely on Subpart W methodologies and data formats. In addition, several states are ramping up climate disclosure laws that include reporting of GHG emissions. California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs will require third-party verified GHG data, and other states like New York, Washington, Colorado, and New Jersey have proposed similar requirements. Companies that discontinue monitoring risk falling out of compliance with state-level mandates or having to rebuild systems from scratch later.
Global demand for reliable, affordable, and sustainable energy is rising, and U.S. LNG is playing a pivotal role by offering a cleaner alternative to coal and oil. Thanks to over a decade of GHGRP reporting, U.S. LNG suppliers are uniquely positioned to offer traceable, lower carbon “premium” products. Because this infrastructure doesn’t exist in many other producing countries, companies in the LNG value chain should continue leveraging Subpart W to maintain their edge in global markets.
- Voluntary Commitments and Market Expectations Haven’t Changed
Many companies have pledged voluntary methane reductions through public corporate commitments or participation in industry initiatives with ONE Future, INGAA, and other trade organizations. These commitments require consistent emissions tracking. Investors, lenders, insurers, and customers still expect transparent, verifiable data—and without a structured framework, companies risk losing access to capital and market opportunities. In the oil and gas sector, where mergers and acquisitions are common, GHG data is often a key component of due diligence. Discontinuing GHG measurement or calculation practices could negatively impact perceived valuation during transactions.
- Emissions Data Helps Drive Operational Efficiency and Manage Risk
GHG data isn’t just for compliance, it’s a tool for operational insight. Methane leak detection, flare efficiency tracking, and equipment performance metrics derived from emissions data can help reduce product losses, improve safety, and optimize production. Much of what’s required under GHGRP aligns with the best operational practices. Companies that maintain monitoring programs can retain valuable operational insights that drive performance.
- Protecting Prior Investments is Smart Business
Over the past decade, oil and gas companies have invested heavily in building the systems, processes, and personnel needed to comply with Subpart W—ranging from emissions monitoring technologies to recordkeeping protocols and reporting platforms. Abandoning these efforts now would not only waste sunk costs but also create future expenses to reestablish compliance readiness. Maintaining current practices preserves institutional knowledge, avoids retraining costs, and ensures continuity in data quality and system integrity.
- Maintaining Practices Builds Resilience for Future Policy Shifts
Political and regulatory landscapes are fluid. A future administration could reinstate Subpart W or the Methane Emission Reduction Program (MERP), or introduce new mechanisms like methane taxes or emissions trading schemes. Companies that keep collecting data now will future-proof their business against such regulatory shifts and will be better positioned to comply quickly, advocate effectively, and avoid costly ramp-ups later.
Conclusion
The EPA’s proposed pause is not a license to disengage—it’s an opportunity to lead. While the rollback may reduce short-term compliance burdens, the long-term risks of abandoning GHG monitoring far outweigh the benefits. Oil and gas companies that stay the course will be better equipped to navigate regulatory shifts, meet stakeholder expectations, and drive operational excellence into the future. Trinity can help you navigate this pause strategically, ensuring your reporting infrastructure is robust, audit-ready, and aligned with emerging state, federal, and global requirements. Reach out to your local Trinity office or visit the O&G industry page to learn more.
