As of August 17, 2026
Facilities across New York and New Jersey are facing a more complicated greenhouse gas reporting landscape. The obligation may come from federal reporting rules, state-specific methane and refrigerant requirements, RGGI, or more than one program at the same time.
The mistake is treating GHG reporting as a single annual form. It isn’t. Applicability depends on your facility type, source categories, emissions profile, equipment, fuel use, and reporting jurisdiction.
For owners, operators, developers, and industrial users, the practical question is simple:
Which GHG reporting requirements apply to your facility, what data must you collect, and when is each report due?
The federal baseline: EPA’s GHGRP under 40 CFR Part 98
The federal Greenhouse Gas Reporting Program (GHGRP) applies to certain direct emitters, upstream suppliers, and facilities involved in carbon dioxide injection or sequestration.
For many covered source categories, the principal threshold is 25,000 metric tons of carbon dioxide equivalent (MT CO₂e) per year. That threshold is not a universal exemption. Some source categories have different applicability tests, and some require reporting regardless of whether a facility exceeds 25,000 MT CO₂e.
Covered facilities can include:
- Fossil-fuel-fired boilers, turbines, engines, and process heaters
- Electric generating units
- Petroleum and natural gas systems
- Municipal and industrial landfills
- Industrial wastewater treatment facilities
- Chemical, cement, steel, glass, and other manufacturing operations
- Suppliers of fossil fuels, industrial gases, and certain fluorinated gases
- Facilities involved in underground CO₂ injection or geologic sequestration
EPA requires reporters to use the calculation and monitoring methods specified in the applicable Part 98 subpart. Depending on the source, that can require fuel quantity and heating value data, production records, process measurements, landfill gas information, equipment data, or direct monitoring.
EPA’s 2026 final action extends the deadline for Reporting Year 2025 emissions from March 31, 2026, to October 30, 2026. The extension applies specifically to RY2025. The standard federal deadline remains March 31 for annual reports covering the prior calendar year unless EPA changes it. See the EPA final rule extending the RY2025 deadline and the eCFR text for 40 CFR Part 98.
“The Greenhouse Gas Reporting Program … applies to certain industrial facilities that emit GHGs, upstream suppliers of fossil fuels and industrial GHGs, and industries that capture and sequester CO₂.” : EPA
The federal program also includes electronic reporting through EPA’s e-GGRT system, recordkeeping requirements, and EPA data verification. A report that technically gets submitted can still create problems if the underlying calculations, source records, or QA/QC documentation do not hold up.
New York: Part 253 begins collecting 2026 emissions data
New York’s mandatory GHG reporting program under 6 NYCRR Part 253 creates a separate state reporting obligation.
The first emissions year is 2026, covering January 1 through December 31, 2026. The first reports are due to NYSDEC by June 1, 2027.
Under the NYSDEC Mandatory Greenhouse Gas Reporting Program, a New York facility generally becomes a Reporting Entity if it:
- Emits 10,000 MT CO₂e or more during an emissions year; or
- Operates as a CO₂ Budget Source under New York’s RGGI rules in Part 242
That 10,000 MT CO₂e threshold is substantially lower than the common federal 25,000 MT CO₂e threshold. A facility that does not report under EPA’s GHGRP may still have a New York reporting obligation.
Part 253 is designed as a data collection program. It does not, by itself, function as an emissions cap or an authorization to emit. That distinction matters, but it does not make the reporting exercise minor. Facilities still need a defensible emissions inventory and records that support the numbers submitted to NYSDEC.
New York’s program may affect:
- Power plants and other RGGI-covered sources
- Large stationary combustion facilities
- Landfills and waste-to-energy operations
- Natural gas and infrastructure facilities
- Wastewater and anaerobic digestion operations
- Other facilities meeting the state’s reporting criteria
New York facilities should also evaluate separate obligations under 6 NYCRR Part 494, which addresses hydrofluorocarbon standards and reporting. Part 494 can create reporting and recordkeeping requirements for suppliers, reclaimers, and owners or operators of covered commercial refrigeration equipment.
Part 253 and Part 494 are not interchangeable. One focuses on facility-wide GHG emissions data. The other focuses on regulated HFC substances, equipment, supply, leak management, and related records.
New Jersey: methane, refrigerants, utilities, and RGGI
New Jersey’s requirements operate through several programs, including the Greenhouse Gas Monitoring and Reporting Rule, emission statement requirements, N.J.A.C. 7:27E, and the RGGI rules at N.J.A.C. 7:27F.
The NJDEP GHG Monitoring and Reporting Rule addresses reporting gaps involving methane and halogenated gases.
NJDEP states that the rule:
“require[s] sources of methane with a potential to emit 100 tons or more annually to report their emissions.”
Methane emission reporting
Facilities with the potential to emit 100 tons per year or more of methane may need to submit an annual emission statement. Examples include:
- Municipal solid waste landfills
- Wastewater treatment facilities
- Natural gas infrastructure
- Other significant stationary methane sources identified by NJDEP
The annual reporting process generally uses NJDEP’s RADIUS emissions reporting software and electronic submission through NJDEPonline. The annual emission statement deadline is generally May 15 for the preceding calendar year.
This is a potential-to-emit threshold, not simply a question of whether a facility believes its actual methane emissions are low. Applicability should be evaluated using permit information, source design, operating conditions, control equipment, and the applicable NJDEP rules.
High-GWP refrigerant reporting
New Jersey also regulates certain non-residential refrigeration systems and chillers containing 50 pounds or more of high-GWP refrigerant charge.
Covered facilities can include:
- Grocery and distribution facilities
- Industrial refrigeration operations
- Refrigerated warehouses
- Ice rinks
- Chemical industry facilities
- Commercial and industrial chiller operations
Annual facility refrigeration system reports are generally due April 1 through NJDEPonline. Required information can include the refrigerant type, global warming potential, system size, refrigerant purchases, servicing, and usage information.
Gas public utilities
New Jersey gas public utilities face additional reporting requirements under N.J.A.C. 7:27E, including pipeline modernization reporting for defined reporting periods beginning in 2026.
The reporting process can require information about gas mains and service lines owned, leased, or controlled by the utility. NJDEP implementation materials identify an annual submission deadline of June 15 and an annual fee associated with this report.
RGGI-covered electric generating units
RGGI reporting is separate from the broader GHG Monitoring and Reporting Rule. Covered electric generating units must continue to comply with RGGI requirements, applicable air permits, and NJDEP submission procedures.
Typical RGGI deadlines include:
- Quarterly reports due April 30, July 30, October 30, and January 30
- Annual reports due March 1
- Compliance certification reports according to the applicable RGGI control period
RGGI-covered facilities should not assume that a federal GHGRP submission satisfies every New Jersey obligation. The programs may use overlapping data, but they have different regulatory purposes, forms, calculations, and deadlines.
Why data management matters more than the form
The report is the final step. The real compliance burden sits in the data collection that comes before it.
A facility may need to reconcile:
- Natural gas, fuel oil, diesel, coal, or other fuel consumption
- Meter readings and utility invoices
- Fuel heating values and operating hours
- Production quantities and process inputs
- Landfill gas collection and destruction data
- Methane source calculations
- Refrigerant purchases, servicing, and leak records
- RGGI monitoring information
- Prior submissions and permit records
- Calculation methodologies and emission factors
A missing month of fuel data or inconsistent refrigerant records can trigger questions long after the report is submitted. EPA and state agencies may compare reported emissions against permit data, prior-year submissions, production levels, and other available records.
That is why a spreadsheet assembled days before a deadline is not a compliance strategy.
A practical NY/NJ GHG reporting readiness checklist
Facility owners and operators should begin with an applicability and data audit:
-
Identify every regulated source category.
List combustion units, process sources, landfill or wastewater operations, natural gas systems, refrigeration equipment, and RGGI units. -
Calculate both federal and state thresholds.
Do not stop at the federal 25,000 MT CO₂e threshold. New York’s Part 253 threshold can apply at 10,000 MT CO₂e, while New Jersey uses source-specific requirements such as 100 tons per year of methane and 50 pounds of high-GWP refrigerant charge. -
Build a source-level data matrix.
Assign each data stream to a responsible person. Track fuel, production, process, refrigerant, methane, and monitoring records throughout the year. -
Separate reporting programs by deadline.
Create a calendar for EPA GHGRP, NYSDEC Part 253, NYSDEC Part 494, NJDEP emission statements, NJDEP refrigeration reporting, utility reporting, and RGGI. -
Document calculation methods and QA/QC.
Preserve source records, assumptions, emission factors, meter data, revisions, and review signoffs. -
Confirm portal access early.
e-GGRT, NJDEPonline, RADIUS, and RGGI submission systems each require account access and facility-specific information.
How Envicon helps facilities stay ahead
GHG mandatory reporting is not just an air compliance assignment. It connects facility operations, environmental permitting, equipment management, engineering judgment, and regulatory communication.
Envicon Group helps owners and operators evaluate applicability, organize source data, prepare emissions calculations, and coordinate reporting requirements across New York and New Jersey. Our team also supports air quality permitting and reporting, environmental compliance audits, facility documentation, and real-time compliance tracking.
Our approach is field-first and regulator-facing. We do not hand you a report and leave you to interpret it. We connect the numbers to the equipment, the permit, the site conditions, and the agency expectation.
That includes:
- Direct review by experienced environmental professionals
- Facility-specific applicability screening
- Data collection and source documentation plans
- Emissions calculation and QA/QC support
- Coordination with operations, facility managers, attorneys, and regulators
- Digital dashboards for schedule, deliverable, and compliance visibility
Large firms often place this work into separate departments: one person reviews the regulation, another builds the spreadsheet, and someone else handles the submission. Envicon keeps ownership connected from the first applicability question through final reporting.
The goal is not to produce more paperwork. The goal is to give you a clear, defensible path through the requirements.
Summary: act before the next reporting deadline
The NY/NJ GHG reporting environment now includes multiple overlapping programs:
- EPA GHGRP under 40 CFR Part 98, commonly involving the 25,000 MT CO₂e threshold
- EPA RY2025 reporting due October 30, 2026
- New York Part 253 reporting for 2026 emissions, with first reports due June 1, 2027
- New York Part 494 HFC requirements
- New Jersey methane reporting for sources with potential emissions of 100 TPY or more
- New Jersey high-GWP refrigerant reporting for systems with 50 pounds or more of charge
- New Jersey gas utility and RGGI reporting obligations
If you wait until a report is due, you are already behind. Start with an applicability screen, build the data trail, and confirm which agency requirements apply to your facility.
Solve environmental and engineering challenges with precision, speed, and trust.
Need help with GHG reporting compliance?
- Visit the Envicon Group main website
- Call Envicon Group at (917) 764-2171
- Get a free consultation and quote
