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EPA Is Trying to End Greenhouse Gas Pollution Monitoring. What It Means and What States Can Do.

State-level greenhouse gas reporting rules and public input can help fill the gap

Trent Williams (right) and his grandson, Nathan, look across the Ohio River at a coal power plant. Jeff Swensen/Getty Images News via Getty Images

In a new phase of the Trump administration’s assault on the federal government, the Environmental Protection Agency (EPA) announced last week that it plans to largely dissolve the Greenhouse Gas Reporting Program (GHGRP). The GHGRP is an important, high-quality data resource for federal agencies, industry stakeholders, community advocates, and many others working to advance the clean energy transition, cut pollution, and protect public health. 

You can’t manage what you can’t measure, and this move is an extension of the Trump administration’s broader assault on sources of truth. The public has a right to know how much dangerous, planet-warming pollution is being emitted by large industries, and policymakers need these numbers to make informed decisions. Eliminating the GHGRP would limit access to unbiased information on pollution in communities across the country—an intentional move to slow climate progress and let major polluters off the hook. 

But states can step up to fill the gap, and advocates can still push back. The comment period on EPA’s decision to eliminate the GHGRP is open until November 3, 2025. This is a moment for vocal resistance, before the White House’s decision is finalized.

 

What Is the GHGRP, and Why Does It Matter?

The Obama administration established the GHGRP in 2010 as an initiative to track climate-warming pollution from the nation’s biggest emitters. For the last 15 years, the program has collected emissions data on more than half a dozen greenhouse gases from roughly 8,000 of the highest-polluting industrial facilities across the U.S. GHGRP’s datasets. These publicly available emissions records are a treasure trove for lawmakers, businesses, and climate advocates. They can use them to track and compare facilities’ emissions, identify opportunities to cut pollution, and develop informed climate policies. Economists have even found that the GHGRP, by forcing transparency and accountability for major polluters, has helped deter greenwashing and encouraged meaningful corporate environmental initiatives.

If we want to tackle the climate crisis, we need to know where climate pollution is coming from. Pollution monitoring is often a priority for environmental justice advocates and frontline communities because cutting pollution requires understanding its sources. The GHGRP provides that foundational knowledge to empower emissions mitigation initiatives, and closing it down will broadly obscure our visibility into where climate pollution is coming from in the U.S. This move advances the Trump administration’s imperative, backed by the oil and gas industry, to undermine any attempts to combat the climate crisis. But we have the tools to respond.

 

States Can Fill the Gap Left by the GHGRP

States can establish their own greenhouse gas reporting programs—and several already have. California, Washington, Oregon, Colorado, Massachusetts, and New Jersey all require some set of major polluters to report their GHG emissions to state agencies. Each state lays out its own methodology for tracking emissions and sets its own thresholds for which entities are required to report, but the ultimate outcome is the same: an entirely state-based program collecting the kind of data that EPA will no longer track.

Those reporting programs are a valuable tool to help states measure their progress toward decarbonization targets, and California and Washington’s enable them to implement nation-leading cap-and-trade initiatives. California’s reporting rule has been on the books since 2007—three years before EPA established the GHGRP. There is a strong precedent for states acting on their own to track major pollution sources.

Other states are lining up for similar initiatives, with greenhouse gas reporting programs currently in development. Earlier this year, for example, New York’s Department of Environmental Conservation released its own draft rule to establish a mandatory GHG reporting program. The rule incorporates lessons learned from the EPA GHGRP and other state reporting programs. Building on those precedents, New York will soon have its own program in place to require annual emissions reporting from the state’s largest polluters—a model that can be replicated by any number of other states looking to maintain high-quality GHG emissions data after the GHGRP is shuttered.

Individual state programs aren’t the only pathway to collecting emissions data without federal buy-in. The Regional Greenhouse Gas Initiative (RGGI) has set up a similar system (PDF) across nearly a dozen states. RGGI sets a regional cap on carbon dioxide (CO2) pollution from the power sector and creates an interstate market in emissions allowances, which are distributed to polluters through quarterly auctions. In order to set up and run that allowance market, every RGGI member state sets rules for the covered energy facilities to monitor and report their CO2 pollution.

While these state and regional programs are more limited in scope than the federal GHGRP, they demonstrate clearly that state lawmakers have all the tools at hand to effectively replace the GHGRP for facilities within their jurisdiction. A rollback of the GHGRP would be a major blow to our ability to measure the problem we’re facing, but states can step up to gather and report their own high-quality pollution data without relying on the Trump administration.

 

What Comes Next?

Broadly speaking, state lawmakers should strongly consider deploying mandatory GHG emissions reporting programs where they don’t already exist. In doing so, they can draw on the reporting rules already written in more than a dozen states; there’s no need to reinvent the wheel. 

In the immediate term, states with reporting programs already in development—New York foremost among them—should also accelerate their rulemakings to fill data gaps before GHGRP winds down. As the Trump administration eliminates climate protections across the board, states can take up the mantle of leadership.

Climate advocates also have the opportunity to push back during the open comment period on the decision to shutter GHGRP, which closes on November 3, 2025. Public comments provide a crucial opportunity to build a record of opposition that can slow down the Trump administration’s rollbacks. Adverse comments on Trump’s rollbacks can support legal challenges down the road and serve as extra hoops for agency officials to jump through, because they are legally required to respond to substantive objections. Losing the GHGRP is a setback, but we aren’t left helpless. State leaders and concerned citizens can and must act.

Submit a Comment to EPA 

The public has a right to know how much dangerous, planet-warming pollution is being emitted by large industries. Submit a comment before the November 3 deadline to have your voice heard.

About the Contributors to This Blog

Author - Trevor Dolan

Trevor is the senior industry and workforce policy lead at Evergreen. Since joining the organization in 2020, he has led Evergreen's campaign for the American Climate Corps, developed innovative policy to strengthen domestic clean energy supply chains, and produced a wide range of written materials calling for bold climate action across every sector of the economy.

Editor - Medhini Kumar

Medhini is the writing/editing digital lead for Evergreen. Through powerful storytelling, she hopes to help move the needle on climate policy and contribute to our collective fight for a livable planet.