AXPC Files Comments on EPA’s Proposed Suspension of Subpart W GHG Reporting 

November 3, 2025

Washington, D.C. – Today, the American Exploration & Production Council (AXPC) filed comments on the EPA’s proposed rule to suspend Subpart W under the Greenhouse Gas Reporting Program (GHGRP) for 10 years. AXPC’s comments encourage EPA to maintain Subpart W with targeted technical fixes rather than suspending the program to better achieve reductions of unnecessary regulatory compliance burdens associated with the GHGRP.

“Whether or not Subpart W is suspended, we appreciate EPA acknowledging that the program’s flaws must be fixed to reflect the best available emissions methodologies. AXPC shares the administration’s goal to reduce unnecessary compliance burdens on America’s oil and natural gas producers and believes it can be best achieved by fixing Subpart W. We remain committed to working collaboratively with EPA to advance American energy dominance through workable and effective regulations,” said AXPC CEO Anne Bradbury.

Read the full comment letter here.

Background

• Subpart W is the section of the EPA GHGRP that applies specifically to the oil and natural gas sector for the reporting of annual greenhouse gas (GHG) emissions using a combination of scientifically derived emission factors, directly measured data, and facility-specific operational data. Over the last decade and through collaboration with industry, it has become the most comprehensive and consistent emissions dataset of any oil and gas-producing country and sets a benchmark that supports American-made energy production and drives efficiencies.
• Subpart W revisions finalized under the Biden administration created significant concerns for operators due to directives for certain biased and flawed methodologies that overestimate or misrepresent emissions.
• Requiring artificial or exaggerated emissions reporting risks putting US oil and natural gas at a competitive disadvantage – even though it is among the cleanest produced in the world.

About AXPC

The American Exploration & Production Council is a national trade association representing the leading independent oil and natural gas exploration and production companies in the United States. AXPC companies are committed to safety, stewardship, and innovation to deliver reliable, affordable energy to American consumers. More information about AXPC can be found at axpc.org.