November 3, 2025

NGIN submitted comments to the Environmental Protection Agency(EPA) on its proposed rule “Reconsideration of the Greenhouse Gas Reporting Program (GHGRP)” — highlighting the need for credible, consistent, and transparent emissions data across the U.S. natural gas value chain.

NGIN recommends that EPA maintain Subpart W, which has become the central federal framework through which operators quantify and report emissions across the U.S. natural gas value chain.

The suspension of Subpart W reporting, without a consistent and credible alternative emissions data and reporting framework in place, could disrupt numerous U.S. global reaching commercial and regulatory processes that rely on the GHGRP reporting platform and its datasets.

If EPA should decide to reduce or eliminate mandatory reporting, NGIN recommends that it be predicated on the prior establishment of a market-driven, government recognized emissions data and reporting program – one which can credibly validate the emissions advantage of American energy resources, the progress of U.S. producers in reducing emissions, and strengthen American energy leadership abroad.