New York greenhouse gas reporting under 6 NYCRR Part 253 applies to facilities that emit 10,000 metric tons of carbon dioxide equivalent (tCO2e) or more a year. The New York State Department of Environmental Conservation (DEC) finalized the rule in December 2025, and 2026 is the first emissions year.
On 31 July 2026, DEC issued an enforcement discretion letter that moves the first report from 1 June 2027 to 31 December 2027. It does not pause data collection. Plants still need complete, defensible fuel and emissions records for January to December 2026.
The delay moves paperwork, not the 2026 emissions year
The DEC letter extends six compliance dates. Large emission source monitoring plans move from 31 December 2026 to 30 June 2027. Source and unit registration moves from 1 February 2027 to 31 August 2027. Verification statements for 2026 emissions move from 1 December 2027 to 1 April 2028.
DEC tied the extension to changes to the Climate Leadership and Community Protection Act (CLCPA) enacted on 26 May 2026. The obligation to report 2026 emissions stands.
A plant crosses 10,000 tCO2e at about 55 GWh of natural gas a year
Most energy managers know gas use in therms or kWh, not tCO2e. Our calculation converts both thresholds into gas use, using the federal default factor of 53.06 kg of carbon dioxide (CO2) per million British thermal units (MMBtu) for natural gas (40 CFR Part 98, Table C-1) and 293.07 kWh per MMBtu:
- 10,000 tCO2e reporting threshold: 10,000,000 kg ÷ 53.06 = 188,466 MMBtu, about 55.2 GWh or 1.88 million therms a year
- 25,000 tCO2e verification threshold: 25,000,000 kg ÷ 53.06 = 471,165 MMBtu, about 138.1 GWh or 4.71 million therms a year
These figures count CO2 from gas combustion only. Methane and nitrous oxide from combustion, other fuels and any process emissions add to the total, so a site can cross either line with less gas than shown.
New York greenhouse gas reporting weights methane over 20 years
Part 253 calculates tCO2e with 20-year global warming potentials (GWP20) from the Intergovernmental Panel on Climate Change (IPCC). Most corporate inventories use 100-year values, and methane weighs far more over 20 years. A plant’s New York figure can therefore differ from the Scope 1 number in its sustainability report, and the two need to be reconciled, not copied.
Plants above 25,000 tCO2e need a verifier and a monitoring plan
Facilities at or above 25,000 tCO2e a year are large emission sources. They must file a monitoring plan with DEC, now due 30 June 2027, and obtain third-party verification from a DEC-accredited body, now due 1 April 2028. The monitoring plan names responsible staff, data collection methods and quality assurance procedures. First-year verification includes a site visit.
Close 2026 with metered, auditable data
For a US manufacturer or life sciences company with plants in New York State, the last quarter of 2026 sets the quality of the first report. Reconcile utility gas meters with submeters on boilers, ovens and process heat. Log fuel for backup generators and other combustion equipment. Identify any process emissions. Then rank the largest combustion loads, because heat recovery and heat pumps on low-temperature process heat can cut them before verification starts.
Climeaction builds Scope 1 inventories and measurement plans for manufacturing and life sciences sites through its advisory team. Contact us to test your 2026 data.
2026 emissions still have to be reported, and annual gas use is the quickest test of whether a plant is in scope. Sites near 55 GWh of gas a year should treat this quarter as part of their first reporting year.
