Attorney General Charity Clark joined a multistate coalition of 15 attorneys general and two citiestoday in filing a comment letter opposing the U.S. Environmental Protection Agency (EPA)'s proposal to rescind the Greenhouse Gas Reporting Program (GHGRP). The programis designed to collect accurate and comprehensive data on greenhouse gas emissions from large industrial sources across the United States. Its primary purpose is to provide policymakers, businesses, researchers, and the public with reliable information to track emissions trends and evaluate the effectiveness of climate policies. In the comment letter, the coalition highlights how the recission of the program would not only be unlawful but would also jeopardize public health and the environment and undermine the nation's competitiveness worldwide by eliminating the U.S.'s longstanding source of reliable facility-level greenhouse gas data needed to plan emissions reductions effectively.

The GHGRP was established in 2009 by the EPA under the authority of the Clean Air Act, following a congressional mandate. The program requires facilities releasing 25,000 metric tons or more of carbon dioxide equivalent, along with suppliers of fossil fuels and certain industrial gases, to report their annual emissions. The GHGRP has been recognized as "the most comprehensive national inventory of greenhouse gas data in the world"and the "gold standard of emissions reporting," covering about 85-90% of total U.S. greenhouse gas emissions - providing benefits that dramatically outweigh the minor burden reporting poses to a covered facility. This data has informed regulatory actions, corporate sustainability strategies, and research on emissions trends across key economic sectors.

Last month, the EPA issued a Proposed Rule seeking to eliminate the GHGRP, arguing that it does not have the authority under the Clean Air Act to require emissions reporting and that the data collected isn't necessary for any current or future federal rule or regulation.

In the comment letter, the multistate coalition asserts that:

• Lack of emissions reporting could lead to higher greenhouse gas concentrations, contributing to climate change, extreme weather events, and ecosystem disruption.
• Without emissions data, states and businesses would struggle to develop effective mitigation strategies, resulting in severe consequences for public health and the environment nationwide. At the same time, companies would face significant financial challenges in planning for emissions reductions, making it harder to compete with companies in countries that maintain robust emissions reporting and compliance systems.
• The Proposed Rule, if finalized, would be arbitrary and capricious and based on unexplained and unsupported changes in EPA's interpretation of its statutory authority.

Attorney General Clark joins the attorneys general of California, Colorado, Connecticut, the District of Columbia, Hawaii, Illinois, Maryland, Massachusetts, Minnesota, New York, New Jersey, Oregon, Rhode Island, Washington, and the Chief Legal Office of the City of Chicagoand New York,in filing this comment letter.

A copy of the comment letter can be found here.

CONTACT: Amelia Vath, Senior Advisor to the Attorney General, 802-828-3171