The proposal targets large emissions sources and specific industries, focusing on data collection only.
By Joshua T. Bledsoe, Jean-Philippe Brisson, Betty M. Huber, Shawna Strecker, and Catherine G. Willis
On March 26, 2025, the New York State Department of Environmental Conservation (NYSDEC) announced proposed regulations that would establish a mandatory greenhouse gas (GHG) reporting program for fuel suppliers, waste haulers and transporters, electric power entities, and certain other industries as well as large emissions sources located in New York. The proposed program is for data collection only and would not impose requirements to reduce GHG emissions or obtain emission allowances.
These proposed regulations, the New York Codes, Rules, and Regulations (NYCRR) Part 253, Mandatory Greenhouse Gas Reporting (the NY Reporting Rule), would require subject industries and large facilities and emitting sources to monitor their annual GHG emissions, annually provide emissions and other data reports to NYSDEC, and follow specified record-keeping requirements for supporting data.
If the NY Reporting Rule is adopted, New York would join California in requiring large emitters to report, verify, and monitor their GHG emissions. The NY Reporting Rule would require reporting entities to submit first reports by June 1, 2027, based on 2026 data. Future reports would be submitted annually.
Our Client Alert identifies which facilities and entities are in scope, compares the NY Reporting Rule to existing regimes, and discusses next steps.