On November 3, 2025, Environmental Protection Network submitted comments urging EPA to withdraw its proposal to repeal the Greenhouse Gas Reporting Program, citing threats to transparency, policymaking, industry stability, and climate accountability.
EPN’s comments focus on the points summarized below:
- The GHGRP is crucial for understanding and addressing US and global GHG emissions, which harm human health and the environment. The program informs policy on all levels: federal, state, local, and non-profit organizations. The sunsetting of this program will not only affect government programs, but also US foreign policy, Wall Street, and US businesses. While other programs and data sources can complement data from the GHGRP, none are comprehensive enough to replace the program.
- EPA has authority under the Clean Air Act Sections 101 and 114 to collect GHG emissions data from large US emitters. EPA has used this authority successfully in many instances to monitor GHGs and carbon dioxide emissions. Congress also appropriated funding for this program and passed other legislation that relies upon it.
- The GHGRP is integral to the American Innovation and Manufacturing (AIM) Act of 2020, which targets the reduction of HFCs, a potent and large contributor to US GHG emissions. Similarly, the IRS relies upon the GHGRP for several tax credits implemented by the Inflation Reduction Act.
- The estimated costs and benefits of repealing the GHGRP outlined in this proposal are flawed and not backed by economic analysis, and alternatives for this proposal were not reviewed.