GHG Reporting for General Industry in CT and NY

What Are Greenhouse Gases and GHG Emissions?

Greenhouse gases (GHGs) are atmospheric gases, such as carbon dioxide (CO₂), methane (CH₄), and nitrous oxide (N₂O), that trap heat in the atmosphere and contribute to climate change. While GHG reporting has historically focused on large power plants and refineries, general industry facilities also contribute to GHG emissions and are increasingly included in climate regulatory programs.

For most manufacturing, food processing, and other industrial facilities, GHG emissions are primarily associated with fuel combustion and energy use, rather than chemical production. Common emission sources include:

• Natural gas or fuel oil-fired boilers/heaters
• Emergency generators
• Refrigerants (HFCs) used in HVAC or cooling systems

GHG emissions are usually calculated using annual fuel consumption records for combustion equipment. As climate initiatives continue to expand, certain facilities may be required to track, calculate, and report these emissions as part of regulatory compliance.

Federal GHG Reporting

At the federal level, GHG reporting is administered by the U.S. Environmental Protection Agency (EPA) under the Greenhouse Gas Reporting Program (40 CFR Part 98).

Facilities in any state are required to report to EPA if they:

• Emit > 25,000 metric tons of carbon dioxide equivalent (CO₂e) per year, or
• Operate equipment or source categories specifically covered under EPA’s GHG Reporting Program

Note: EPA reporting requirements are independent of state programs. If EPA thresholds are met, reports must be submitted through EPA’s e-GGRT system and are due by March 31 each year.

Connecticut GHG Reporting Requirements (General Industry)

In CT, GHG reporting is overseen by the Connecticut Department of Energy and Environmental Protection (CT DEEP).

For general industry, CT does not have a standalone GHG reporting threshold separate from EPA’s program. Instead, CT DEEP relies primarily on EPA GHG submissions to support state emissions tracking and climate planning.

However, CT facilities may be required to submit GHG information to CT DEEP when GHG data is tied to an air permit or emissions inventory requirement, such as:

• Facilities operating under a Title V air permit, or
• Facilities required to submit an air emissions inventory as part of a permit condition or renewal

When required, this data must be submitted through CT DEEP’s ezFile website. Due dates can vary depending on permit reporting deadlines.

New York GHG Reporting Requirements

Unlike CT, New York takes a more state-driven approach to GHG tracking. GHG reporting in NY is administered by the New York State Department of Environmental Conservation (NYSDEC) and is closely tied to the state’s air permitting and climate programs under the Climate Leadership and Community Protection Act (CLCPA).

In NY, facilities may be required to report GHG-related data even if they do not meet EPA’s threshold, particularly if they:

• Hold a Title V or State Facility air permit,
• Are required to submit annual air emissions statements, or
• Are subject to NYSDEC emissions tracking or climate-related reporting initiatives

GHG emissions data in NY is typically submitted through NYSDEC’s Air Compliance and Emissions (ACE) e-reporting system and is due by March 15 or May 1, depending on permit type.

Note: Facilities may be required to submit multiple reports on the state and federal level. Please review your site’s permit requirements.

How Walden Can Help

Walden supports general industry facilities in Connecticut and New York by helping them understand whether GHG reporting applies, what needs to be reported, and where reports must be submitted.

Walden can also assist with:

• Evaluating fuel usage and emissions potential
• Identifying whether reporting is triggered under EPA, CT DEEP, or NYSDEC programs (for example, NYSDEC’s final Part 253, Mandatory Greenhouse Gas Reporting, was issued in December 2025. Many facility types will need to submit annual emissions reports under this regulation)
• Calculating GHG emissions
• Preparing and reviewing GHG data for submittal
• Integrating GHG reporting into existing air permit and compliance programs

If you have questions about GHG reporting applicability or need assistance evaluating emissions, Walden can help clarify requirements and support compliance. Contact our air team today at 516-559-6976 to discuss your facility’s needs.