The New York State Department of Environmental Conservation (NYSDEC) has finalized its Mandatory Greenhouse Gas Reporting Program (6 NYCRR Part 253), creating a new statewide framework for tracking greenhouse gas (GHG) emissions. The program requires certain GHG emissions sources, or Reporting Entities, to annually report emissions and related data to NYSDEC through the New York State Greenhouse Gas Reporting Tool (NYS e-GGRT). Reporting begins with the 2026 emissions year, with annual reports due beginning in June 2027.
What Is the Purpose of the Rule?
The reporting program is intended to improve New York’s understanding of GHG emissions across the state, support implementation of the Climate Leadership and Community Protection Act, and assist with NYSDEC’s Annual Statewide GHG Emissions Report. At this time, the regulation is a reporting program only and does not impose requirements for facilities to reduce GHG pollution or obtain emission allowances.
Who May Be Affected?
The rule applies to a broad range of entities:
- Facilities emitting 10,000 metric tons or more of carbon dioxide equivalent (CO2e) annually
- Natural gas, petroleum, liquefied natural gas, compressed natural gas, and coal suppliers
- Electric power entities
- Certain waste haulers and transporters
- Anaerobic digestion and liquid storage of waste at facilities, such as wastewater treatment plants and concentrated animal feeding operations, where wastes imported to or generated at the facility would generate 10,000 metric tons or more of CO2e per year
Because the rule includes anaerobic digestion and liquid storage of waste, owners and operators of agricultural digesters, wastewater digesters, food waste digesters, and renewable natural gas (RNG) projects should carefully evaluate whether the reporting requirements apply to their operations.
Why RNG and Digester Owners Should Pay Attention
Many RNG projects focus on capturing methane that would otherwise be released into the atmosphere and converting it into a saleable renewable fuel. While these projects often provide significant GHG benefits, New York’s reporting framework may still require facilities to quantify methane generation, recovery, flaring, fugitive emissions, and other GHG sources associated with the operation.
Facilities with large biogas production volumes may exceed reporting thresholds even if the majority of methane is captured and sold as RNG. As a result, project owners should begin evaluating available monitoring data, methane mass balances, flare records, and gas production records to understand potential reporting obligations.
What Should Facilities Do Now?
Although the first reports are not due until 2027, facilities should consider:
- Reviewing applicability under Part 253
- Evaluating annual GHG emissions and CO2e thresholds
- Identifying required monitoring and recordkeeping data
- Reviewing any existing United States Environmental Protection Agency (USEPA) GHG Reporting Program obligations
- Determining whether third-party verification may apply, particularly for larger emission sources, and whether an NYSDEC-accredited verifier will be needed
- Developing a strategy for future compliance and reporting
Key Takeaway
Now in effect, Part 253 creates important climate-related reporting obligations in New York. Facilities with significant GHG emissions, including anaerobic digestion and RNG operations, should evaluate applicability, data quality, and potential verification requirements early to avoid surprises as the first reporting deadline approaches.
For support with applicability, compliance, or reporting, or to discuss any questions or concerns you may have, please contact Kyle Willard.
References
NYSDEC. (n.d.). Mandatory Greenhouse Gas Reporting.
NYSDEC. (2025, December 1). DEC Finalizes Program to Track
