Facilities and suppliers that monitored greenhouse gas emissions during 2010 under U.S. EPA's Greenhouse Gas Reporting Program were required to submit the first round of annual reports under the program to EPA by September 30, 2011. EPA received most of the emissions-related data through its new web-based system, known as the Electronic Greenhouse Gas Reporting Tool, or "e-GGRT."

Industries that were not required to begin collecting data until January 1, 2011 were not subject to the deadline. Those facilities' first annual emissions reports are currently due March 31, 2012, but EPA proposed on August 4, 2011 to extend that initial reporting deadline by six months to September 28, 2012.

Before the first reports were due, U.S. EPA issued a final rule that deferred the reporting deadline for certain business-sensitive data elements used as inputs to emission equations for some direct emitters (i.e., those covered by Subparts C through JJ, RR, SS, and TT of the reporting rule). The new deadline for some of that data for calendar years 2010 and 2011 is now March 31, 2013, and for others it is now March 31, 2015. EPA says the reporting deferral is necessary to allow more time for it to consider whether the data should be made publicly available.

In addition, on September 27, 2011, EPA published two final rules modifying requirements for certain facilities. One rule allows the largest semiconductor manufacturing facilities the option of using default emission factors (instead of directly measured recipe-specific emission factors) to calculate emissions from etch processes during 2011 through 2013. The other rule amends certain provisions for oil and natural gas systems. The two rules provide additional time for the covered facilities to use "best available monitoring methods" or "BAMM" in 2011 without submitting a request to EPA, and additional time to submit a request to use BAMM to estimate emissions beyond 2011.

EPA continues to refine the program. On August 4, 2011 and September 9, 2011, EPA proposed technical corrections and clarifications to the general provisions of the mandatory greenhouse gas reporting rule, 40 C.F.R. Part 98, as well as to a number of industry-specific subparts of the rule.