October 02, 2025

Without Greenhouse Gas Reporting, There’s No Climate Accountability

By Max Lopez, Associate Attorney

On October 1, the U.S. Environmental Protection Agency (EPA) held a hearing on its proposed rule to end its Greenhouse Gas Reporting Program (GHGRP), which would remove reporting operations for virtually all large industrial facilities.

GHGRP data provides a critical source of information about climate pollution from industrial facilities and economic sectors that is fundamental for transparent, evidence-based decision-making. Here in the Midwest, industries like steel, cement manufacturing, and oil and gas are major emitters. We cannot protect clean air, public health, or the climate when the EPA withholds critical emissions data.

In EPA’s hearing, I testified before the EPA, urging the agency to reconsider its proposal to remove these crucial reporting requirements.

READ MY TESTIMONY

Highlights from My Testimony:

• The Greenhouse Gas Reporting Program (GHGRP) is an essential planning tool for public utility commissions and other decision-makers to ensure consumers have a reliable and affordable grid.
• Greenhouse gas emissions data is an integral factor in maintaining consistency and accountability with state law climate initiatives.
• GHGRP data is essential in quantifying emissions from utility operations, oil and gas systems, and power plants – allowing clear comparisons between fossil fuel infrastructure and electrification alternatives to rationally plan for the long term.
• Emissions reporting is needed to track methane leaks from oil and gas systems, helping improve grid reliability, conserve energy resources, and lower costs for consumers.
• In an Illinois rate case, ELPC used GHGRP data to show that Ameren emitted 92,479 metric tons of CO2, with over 90,000 metric tons coming from methane leaks – wasting resources, weakening reliability, and worsening climate change.
• EPA’s claim that it lacks authority under the Clean Air Act to collect this data is inconsistent with decades of agency practice and the statute’s explicit language.
• Greenhouse gas reporting provides the emissions data necessary to develop pollution standards, identify harmful industries, and determine the best emissions reduction strategies.
• Without this reporting, states, regulators, and communities lose a critical tool for holding polluters accountable.

I urge EPA to abandon this proposal and preserve the GHGRP to ensure accountability, transparency, protect public health, and support effective environmental protection.

Max Lopez,

Associate Attorney

Max Lopez is an Associate Attorney at ELPC. During his summers he worked in the New York and D.C. offices at NRDC focusing on clean air and clean water work.

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