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On December 1, 2025, the New York State Department of Environmental Conservation (DEC) adopted regulations establishing a mandatory greenhouse gas (GHG) reporting program.1 DEC enacted Part 253 pursuant to the State's Climate Leadership and Community Protection Act (CLCPA), which instituted a state-wide goal to reduce GHG emissions by 40% by 2030.2 With adoption of this rule, New York becomes the third state—alongside California3 and Washington4—to implement widely applicable GHG reporting requirements.
Part 253 establishes annual reporting requirements for a wide range of emissions sources operating in New York that meet or exceed specified thresholds. Entities exceeding the emissions thresholds must also verify their emissions data using a DEC-accredited third-party verification service. Part 253 is a data-collection program only; it does not impose emission reduction requirements or require regulated entities to obtain emission allowances. Initial reports under the program are due June 1, 2027.5
Who is Required to Report?
Part 253 applies to "Reporting Entities"—emission sources that operate in New York at any time on or after January 1, 2026, and that fall into one of the defined categories described below.6 Reporting continues annually until the entity remains below the applicable reporting threshold for three consecutive years. There are several categories of Reporting Entities, and additional requirements apply to "large" emission sources.
- Owners and Operators of Facilities in New York
Entities that own or operate any "facilities" in New York must report GHG emissions if an individual facility emits 10,000 metric tons (MT) or more of carbon dioxide equivalent (CO2e) per year, or if the facility holds budget units under the CO2 Budget Trading Program.7 A "facility" is defined as "[a]ny physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right- of-way and under common ownership or common control, that emits, may emit, or may cause to emit any GHG," with limited exceptions.8 If an entity operates multiple facilities, it must submit separate reports for each facility that independently meets the emissions threshold.9 Facilities must report on-site GHG emissions from stationary combustion, process emissions,10 and vented and fugitive emissions.11 Facilities must also report "upstream out-of-state emissions for each MMBtu of fossil fuel or petroleum products...sold or bought into New York for sale to an end user, or consumed or used at a facility, or used to produce electricity imported into New York," in accordance with the methodology prescribed in section 2.18(b) of Part 253.12
- Fuel Suppliers
Entities that supply fuel for consumption in New York—including any "solid, liquid, or gaseous combustible material" 13—or that otherwise qualify as a "Fuel Supplier" under section 1.2(i) of Part 253, must report annual GHG emissions for all covered fuels supplied.14 Covered fuels include natural gas; liquid fuels and petroleum products; liquefied and compressed natural gas; and coal.15
Fuel Suppliers must report GHG emissions associated with the combustion of fuels delivered to end users in New York, with fuel-specific methodological variations. Emissions must be reported in a single annual report, with emissions broken out by fuel type.16 Reports must also include the quantity and type of fuel delivered and associated "upstream out-of-state emissions for each MMBtu of fossil fuel or petroleum products...sold or bought into New York for sale to an end user, or consumed or used at a facility, or used to produce electricity imported into New York," calculated in accordance with methodology prescribed in section 2.18(b) of Part 253.17
- Waste Haulers and Transporters
Waste haulers exporting solid waste collected in New York for disposal outside the state must submit a report if the estimated combined emissions from landfilling or combustion of exported waste exceed 10,000 MT CO2e, as calculated under section 2.19(a)(1) of Part 253.18 Required reporting includes estimated GHG emissions from waste combustion, estimated methane emissions from landfilling, and the total mass of waste transported outside the state.19
- Electric Power Entities
Electric power entities—including electricity importers, exporters, and New York retail providers20—must report GHG emissions associated with electricity generated in New York or imported megawatt-hours consumed in New York.21 Reporting may be completed on a facility-by-facility basis or separately for each importer, exporter, or retail provider, consistent with section 2.4(b) of Part 253.22
- Suppliers of Agricultural Lime and Fertilizer
Suppliers of agricultural lime or fertilizer for use in New York that generate GHG emissions must report quantities supplied and associated CO2 or N2O emissions calculated pursuant to the methodology prescribed in section 2.14 of Part 253.23
- Anaerobic Digestion and Liquid Waste Storage
Owners and operators that "treat waste in anaerobic digesters or reactors or store waste that contains degradable organic carbon as a liquid or slurry in storages,"—including operations at solid waste management facilities or Concentrated Animal Feeding Operations (CAFOs)—must report if "wastes imported to the facility or generated at the facility during the reporting year" exceed one of the thresholds specified in section 2.2 of Part 253.24 Thresholds are based on quantities of specific waste streams, including industrial or commercial food waste; municipal wastewater; yard trimmings or other plant biomass; paper or paper pulp; fats, oils, or grease; other organic carbon waste; or certain combinations of these waste categories.25 Reporting requirements include operational information, activity data,26 and quantified biogas methane destruction.27
- Petroleum and Natural Gas Systems
Operators of petroleum and natural gas facilities in New York must report if emissions from covered sources collectively equal or exceed 10,000 MT CO2e per year. Covered sources include "onshore petroleum and natural gas production, onshore petroleum and natural gas gathering and boosting, onshore natural gas transmission compression, onshore natural gas transmission pipeline, underground gas storage, liquefied natural gas storage and natural gas distribution segments."28 Reporting must include emissions from stationary combustion, process emissions, vented and fugitive emissions, and associated upstream out-of-state emissions calculated under section 2.18(b) of Part 253.29
Natural gas distribution facilities must also report county-specific emissions data and related operational metrics, including pipeline mileage, customer meters, metering stations, pipeline dig-ins, and leak detection rates.30
Large Emissions Sources
Part 253 imposes additional obligations on "Large Emission Sources," which exceed higher applicability thresholds.31 These entities must (1) obtain third-party verification of their annual emissions report from a DEC-accredited verifier, and (2) submit a GHG monitoring plan to DEC for review.32
| Emission Sources | Threshold for Large Emission Sources |
| Facilities | ≥ 25,000 MT CO2e per emission year |
| Suppliers of natural gas | ≥ 15 million cubic feet per emission year |
| Suppliers of liquid fuels and petroleum products | ≥ 100,000 gallons of affected liquid fuels per emission year |
| Suppliers of liquified or compressed natural gas | ≥ 15 million cubic feet of liquified or compressed natural gas per emission year |
| Suppliers of coal | ≥ 500 U.S. short tons of coal per emission year |
| Waste haulers and transporters | ≥ 25,000 MT CO2e per emission year (combined emissions from all exported waste to out-of-state landfill and combustion facilities) |
How Do I Know If I Have to Report?
DEC has developed a GHG Estimation Tool that applies emission factors and calculates estimated emissions in CO2e using a 20-year global warming potential for each activity. DEC emphasizes that the tool is for illustrative purposes only and does not constitute a legally binding determination of reporting obligations under Part 253.33 Entities may alternatively calculate emissions using standardized formulas or emissions factors based on available activity data, such as fuel volumes.
Entities subject to the U.S. Environmental Protection Agency's (EPA) Greenhouse Gas Reporting Program (GHGRP)34 must comply with both the federal GHGRP and New York's Part 253 requirements. DEC has also indicated that it will "conduct robust outreach" and provide additional guidance regarding reporting applicability.35
What Must Be Included in a Report, and When Are Reports Due?
Reporting entities must submit annual emissions reports—and verification statements where required—through DEC's forthcoming NYS e-GGRT platform, compiled in accordance with methodologies adopted from the EPA's GHGRP.36 Although Part 253 incorporates references to the GHGRP, DEC has clarified that these are "static references to a specific version" of the federal GHGRP and will remain effective regardless of future changes to the GHGRP.
Emissions data submitted to DEC is generally public information, although entities may request confidential treatment for information qualifying as a trade secret or otherwise exempt from public disclosure.37
The first annual GHG emissions reports are due June 1, 2027.38 Failure to submit required reports and verification statements authorize DEC to estimate and assign emissions values for the non-reporting entity.39 Incomplete, inaccurate, or untimely reporting constitutes a violation of Part 253 and may result in penalties or formal enforcement.40
Footnotes
1 6 NYCRR Part 253.
2 Climate Leadership and Community Protection Act, 2019 N.Y. Laws ch. 106 (S.6599) (2019).
3 Cal. Code Regs. Tit. 17 §§ 95100-163 (2019).
4 Wash. Admin. Code § 173-441 (2024).
5 See 6 NYCRR Part 253-1.4(b).
6 See 6 NYCRR Part 253-1.2(b).
7 See 6 NYCRR Part 253-1.2(c)(3)(i). The CO2 Budget Trading Program establishes New York's cap-and-trade program to reduce carbon dioxide emissions from power plants pursuant to the Regional Greenhouse Gas Initiative. See 6 NYCRR Part 242.
8 6 NYCRR Part 253-1.3(b)(148).
9 See 6 NYCRR Part 253-1.2(d)(1).
10 Process emissions are defined as "[t]he emissions from industrial processes involving chemical or physical transformations other than fuel combustion." 6 NYCRR Part 253-1.3(b)(328).
11 See 6 NYCRR Part 253-2.7.
12 6 NYCRR Part 253-2.18.
13 6 NYCRR Part 253-1.3(b)(173).
14 See 6 NYCRR Part 253-1.2(d)(2); 253-1.2(i). This definition includes position holders, enterers, downstream owners, and below-the-rack distributors of liquid fuels, as well as owners of liquefied petroleum gas, energy service companies provide gaseous fuels to end users, operators of interstate or intrastate pipelines delivering gaseous fuels, importers of compressed or liquefied natural gas, local gas distribution companies, natural gas liquid fractionators, and facilities that make liquefied or compressed natural gas products.
15 See 6 NYCRR Part 253-1.2(d)(2).
16 See 6 NYCRR Part 253-1.2(d)(2); 253-2.15 (outlining specific requirements for suppliers of coal); 253-2.16 (outlining specific requirements for suppliers of liquid fuels and petroleum products); 253-2.17 (outlining specific requirements for suppliers of natural gas, natural gas liquids, compressed natural gas, and liquefied natural gas).
17 6 NYCRR Part 253-2.18.
18 See 6 NYCRR Part 253-1.2(c)(3)(iii).
19 See 6 NYCRR Part 253-2.19.
20 See 6 NYCRR Part 253-1.2(j).
21 See 6 NYCRR Part 253-1.2(c)(3)(iv).
22 See 6 NYCRR Part 253-1.2(c)(3)(v); 253-2.4.
23 See 6 NYCRR Part 253-1.2(b)(5); 253-2.14.
24 6 NYCRR Part 253-2.2(a)(1).
25 See id.
26 Activity data include specific waste-related metrics such as nitrogen content in waste, animal manure data, oxygen demand in wastewater, and other degradable organic carbon sources. 6 NYCRR Part 253-2.2(d)(2).
27 CAFOs may be eligible for abbreviated reporting requirements if they have "2500 or fewer mature dairy cows at any one time" or if they have more than 2500 mature dairy cows, import less than 50% of any waste threshold, and "the facility does not heat waste in liquid or slurry storages or anaerobic digesters or reactors using fossil fuels." 6 NYCRR Part 253-2.2(d)(2).
28 6 NYCRR Part 253-2.12(a).
29 See 6 NYCRR Part 253-1.2(k).
30 See 6 NYCRR Part 253-2.12(c).
31 See 6 NYCRR Part 253-1.2(f).
32 See 6 NYCRR Part 253-1.4(c).
33 See NYSDEC, Mandatory Greenhouse Gas Reporting Program Frequently Asked Questions (Dec. 1, 2025).
34 40 C.F.R. Part 98.
35 NYSDEC, Mandatory Greenhouse Gas Reporting Program Fact Sheet (Dec. 1, 2025).
36 6 NYCRR Part 253-1.2(n); 253-1.6; 253-1.8. In addition, an operator of an anaerobic digester or liquid storage that is required to report under Part 253-2.2(a)(1) and is not eligible for abbreviated reporting under section 2.2(a)(2), and an operator of a solid waste landfill where reported annual emissions exceed 300,000 MT CO2e are required to develop and implement an operation or facility-specific Emissions Monitoring and Measurement Plan pursuant to Part 253-2.20.
37 6 NYCRR Part 253-1.8.
38 6 NYCRR Part 253-1.4(b).
39 6 NYCRR Part 253-1.4(d).
40 6 NYCRR Part 253-1.9.
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