Office of the
Illinois Attorney General
Kwame Raoul

Chicago– Attorney General Kwame Raoul, as part of a coalition of 15 attorneys general and two cities, filed a comment letter opposing the U.S. Environmental Protection Agency’s (EPA) proposal to rescind the Greenhouse Gas Reporting Program. The program is 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.

“Ending the Greenhouse Gas Reporting Program would jeopardize public health and the environment,” Raoul said. “This program is a longstanding source of reliable greenhouse gas emissions data that strengthens our nation’s competitiveness and allows policymakers to plan emissions reductions effectively. I join my fellow attorneys general in opposing this unlawful proposal.”

The Greenhouse Gas Reporting Program 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 program has been recognized as the most comprehensive national inventory of greenhouse gas data in the world, covering about 85% to 90% of total U.S. greenhouse gas emissions. 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 program 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. 

Raoul and the coalition argue in their comment letter that the lack of emissions reporting could lead to higher greenhouse gas concentrations, contributing to climate change, extreme weather events and ecosystem disruption. The coalition maintains that without emissions data, states would struggle to develop effective mitigation strategies, resulting in severe consequences for public health and the environment nationwide. Businesses would also 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 coalition asserts that the proposed rule is arbitrary and capricious and based on unexplained and unsupported changes in the EPA’s interpretation of its statutory authority. 

Attorney General Raoul is joined in filing the comment letter by the attorneys general of California, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Maryland, Massachusetts, Minnesota, New York, New Jersey, Oregon, Rhode Island, Vermont, Washington, and the chief legal officers of Chicago and New York.