Livestock GHG Reporting: A Compliance Playbook

Short answer: Who must report and why this matters

Large livestock facilities that emit 25,000 metric tons CO2e or more from their manure management systems must report under the EPA s Mandatory Greenhouse Gas Reporting rule. The main rule text is at 40 CFR Part 98. This playbook shows how to decide if you must report, what data you need, and how to start a compliant inventory.

Quick compliance checklist (use this first)

• Confirm your facility s animal counts and types for the reporting year.
• Identify all manure management systems on site (lagoon, pit, storage, composting).
• Estimate whether manure system emissions could exceed 25,000 metric tons CO2e.
• If near threshold, collect detailed inputs: animal population, volatile solids, system temperatures, nitrogen excretion rates.
• Choose a calculation method (EPA Subpart JJ equations or GHG Protocol Agricultural Guidance).
• Document methods, assumptions, and records for audits.
• File reports by EPA deadlines and retain records per regulation.

Step 1: Do I need to report? A simple decision path

1. Count all animals by group (beef, dairy, swine, poultry). Use your yearly average population. Guidance tables are in Subpart JJ.
2. Check the EPA population thresholds and run a screening calculation for manure emissions. Many guides note that only manure management emissions are required; exclusions like enteric fermentation are not part of the EPA s reporting rule.
3. If your estimated manure emissions are likely under 25,000 MT CO2e, you do not need to report under the rule. If they are above or close, continue to a full calculation.

Practical tip

If you are unsure, treat the decision like a risk check. Do a conservative estimate. Many large feedlot and dairy operations exceed the threshold; EPA estimated roughly 100-110 large facilities would report (see EPA guidance).

Step 2: What emissions are counted and what are not

Under EPA Subpart JJ you must report emissions from manure management systems only. That includes methane (CH4) and nitrous oxide (N2O) from stored or treated manure. It does not include enteric fermentation (cow "burps") or emissions from land application of manure in the final rule. For broader accounting or voluntary reports, follow the GHG Protocol Agricultural Guidance, which covers more sources and scope 3.

Step 3: Key data inputs you must collect

Collect these core inputs for each animal group and manure system:

• Average annual animal population by group (beef, dairy, swine, poultry).
• Manure management system type for each group (lagoon, pit, dry lot, compost).
• Volatile solids production and methane conversion factors (see EPA tables and industry guidance).
• Temperature and storage times for anaerobic systems.
• Nitrogen excretion and handling for N2O estimates (EPA and IPCC tables).

Where to get official factors

Use EPA Subpart JJ tables and the GHG Protocol Agricultural Guidance. For international or research comparisons, see FAO s pathways report at FAO and scientific studies like the Nature beef emissions study.

Step 4: How emissions are calculated (overview)

EPA provides emission equations. The basic flow is:

1. Estimate volatile solids (VS) produced by each animal group.
2. Apply a methane conversion factor (MCF) for each manure system.
3. Calculate methane mass and convert to CO2e using the global warming potential for CH4.
4. Estimate N2O from manure storage where required and convert to CO2e.

Use the exact equations and table values in 40 CFR Part 98 and EPA s agriculture guide at epa.gov. For product-level or scope 3 work, align with the GHG Protocol Agricultural Guidance.

Short calculation example

Example: A barn stores manure anaerobically. You estimate VS = 100,000 kg/year and MCF = 0.5. Methane emitted = VS * MCF * factor. Convert CH4 to CO2e using the GWP (e.g., 28). If this single system yields a few thousand MT CO2e, sum across systems to test the 25,000 threshold. For precise equations, use EPA s Subpart JJ formulas in Part 98.

Step 5: Documentation, QA/QC, and record keeping

Recordkeeping is critical. Keep data, calculations, assumptions, and monitoring records. EPA requires retention of records and documentation for verification. The rule lists required records in Subpart JJ. Use simple logs and spreadsheets or a small database. Label each input with source, date, and person responsible.

Step 6: Reporting and filing

If you are above the threshold, file the annual report per EPA deadlines. Reports must follow the format in 40 CFR Part 98. Late or incorrect filings can carry penalties. Work with a consultant or in-house environmental staff to prepare the submission.

Reducing emissions while you report

Reporting is also a chance to act. Common mitigation options include:

• Improve manure storage design and cover systems to reduce MCF.
• Install anaerobic digesters to capture methane for energy.
• Improve feed and herd productivity to lower emissions intensity (see WRI strategies).

These steps can cut emissions and create value from captured biogas.

Decision tools and next steps

Do this in order:

1. Run the screening calculation using animal counts and rough VS/MCF numbers. If under threshold, document the check.
2. If near or over threshold, collect detailed inputs and follow EPA Subpart JJ math.
3. Set up a record system and assign a reporting lead.
4. Consider mitigation options early; they affect future inventories and costs.

Downloadable tools and checklists speed this work. Add internal links for your team: GHG Reporting Checklist, Sustainability Strategy, Carbon Accounting.

FAQ

Is enteric fermentation included?

No. EPA s mandatory reporting focuses on manure management. For broader inventories, include enteric fermentation under voluntary or corporate frameworks; see the GHG Protocol.

What if my facility is close to the threshold?

Do a full, conservative calculation and keep records. If you are close, assume you must report and get systems in place. EPA guidance is at epa.gov.

Where can I learn more about mitigation options?

See FAO and WRI resources linked earlier, and recent research such as the Nature beef emissions study for mitigation hotspots.

Final note from the author

Trend insight: regulators and buyers are asking for more transparent GHG data across supply chains, so reporting is becoming a basic business requirement. Citizen action item: if you are a local stakeholder, ask suppliers and farms whether they track manure emissions and follow best practice. Start with one clear step: run the screening calculation today and save the results.