Two Filings, One Year
Two sets of documents describe the same year from opposite directions. One set is public: comment letters filed with the Environmental Protection Agency, carrying the letterhead of trade associations, arguing that the agency’s Greenhouse Gas Reporting Program should not be repealed. The other set surfaced through a Freedom of Information Act (FOIA) request, the legal process that compels a federal agency to release records unless an exemption applies. Filed by many of the same organizations, the two sets do not tell the same story.
The Paper Trail
The documents were obtained by the National Security Archive, a research group based at George Washington University, and shared with the outlet DeSmog. Titled “Inside the Struggle to Dismantle America’s Greenhouse Gas Data” and catalogued as Briefing Book 927, the account was written by Rachel Santarsiero with Ashley Braun and published on August 18, 2026.
The trail includes a letter from Timothy R. Parr, deputy general counsel of the American Gas Association (AGA), sent to the incoming EPA transition team four days before Donald Trump’s second inauguration in January 2025; a follow-up AGA email requesting a staff-level meeting, sent as Administrator Lee Zeldin prepared to announce a deregulatory move on the reporting program; a petition for reconsideration and a comment letter from the American Petroleum Institute (API); a separate comment letter from the Independent Petroleum Association of America (IPAA); and meeting logs compiled independently by Fieldnotes, a group that tracks oil and gas lobbying activity. All of it was obtained under FOIA and folded into a single account.
What the Meetings Were About
Through 2025, representatives of AGA, API, the American Exploration & Production Council (AXPC), and IPAA met repeatedly with EPA staff, including Aaron Szabo, an assistant administrator and former oil-and-gas lobbyist. API met with the agency in early March 2025, shortly before Zeldin’s March 12 announcement that EPA would reconsider Biden-era methane rules, returned at least three more times over the year, and asked for a fifth meeting. AXPC convened with the agency at least once. IPAA met with EPA on the same subject.
The documented request, across letters and meetings, stayed narrow and consistent: loosen the calculation methods in Subpart W, the section of the reporting program covering methane from oil and gas facilities, and shrink or eliminate the Super Emitter Program, a mechanism added in a 2024 revision to flag the largest individual leaks. Parr’s letter, for instance, asked for “increased use of facility- and company-derived emission factors and advanced methane measurement technologies” in place of the government’s own methods.
At the same time, in separate comments, AGA, API, AXPC, ExxonMobil, Shell, and the U.S. Chamber of Commerce all opposed repealing the Greenhouse Gas Reporting Program outright. Congress funded the program in the Fiscal Year 2008 appropriations act, and EPA began collecting data from roughly 8,000 industrial facilities in 2010. The public position of the same organizations lobbying to narrow Subpart W was to keep the broader program intact and “improve” it instead.
One Group’s Position, Before and After
AXPC’s own filings show a reversal that does not require reading between the lines. In a comment letter submitted in May 2024, the group called the Super Emitter Program useful while asking for fewer mandatory actions attached to it. In a presentation to EPA in May 2025, the same organization recommended eliminating the program, citing litigation risk and a lack of transparency in how leaks are verified. Both documents are dated, both came from AXPC, and the position moved from qualified support to elimination inside twelve months.
A Different Document, an Earlier Year
One further document belongs in this file, though it comes from a different inquiry and a different year. In 2024, a congressional investigation surfaced an internal email from David J. van Hoogstraten, a senior BP executive, describing the founding meeting of API’s Environmental Partnership, a voluntary emissions program launched in 2017. Van Hoogstraten wrote that the program was meant to “stave off future regulation” and to give industry “ammunition” for shaping later rules.
Nothing in the 2025 meeting logs or letters connects this email to the Subpart W lobbying described above. It is included here because it is the one place in this record where an industry executive states a defensive purpose in his own words, about a related but separate program, not about the rule at issue in 2025.
What the Record Doesn’t Say
Four things are missing from this file, and each is a fact about the paperwork rather than a hint about its contents. As of the August 2026 publication, EPA had not issued a final rule on the Greenhouse Gas Reporting Program, though it had signed a rule in February 2026 extending 2025 reporting deadlines and had proposed, on September 16, 2025, delaying Subpart W reporting for oil and gas facilities until 2034. The full text of that broader overhaul was not public. Industry’s 2025 lawsuit over the methane rule, filed after the rule took effect on January 1, 2025, had been paused, and none of the documents reviewed states how or whether it was resolved. Nothing in the letters, emails, or meeting logs describes how EPA staff weighed the trade groups’ requests internally. The record shows that meetings took place; it does not show what was said in them or what the agency decided as a result.
A Reading Offered After the Fact
Edward Maibach, a climate communication researcher at George Mason University, offered an interpretation of this pattern once the documents became public. Oil and gas executives, he told the National Security Archive and DeSmog, “will always support weak rules they already comply with rather than no rules at all,” adding that backing no rules at all “would prove to everyone how untrustworthy they are.”
That is Maibach’s reading, made after the record was released, not a conclusion the documents state on their own. What the documents establish is narrower: two sets of positions, filed by the same organizations, running side by side through 2025, and a final rule that, as of publication, EPA had still not issued.