The GHGRP, established by the EPA in 2009, requires large emitters of greenhouse gases (GHGs) to report their emissions. The program primarily covers facilities that emit 25,000 metric tons or more of CO2 equivalent per year. The purpose of the program is to collect accurate data on GHG emissions, which is essential for understanding emission trends, informing policy decisions, and guiding regulatory measures to reduce emissions.

Getting rid of collecting statistics is another example of the Bruno Strategy. “If we stop collecting data about greenhouse emissions, they don’t exist any more!” All this does is deprive policy makers of the ability to make informed decisions, in the absence of any data to review.

In terms of the program representing a significant burden for small businesses, this is an outright lie. THE GHGRP DOES NOT APPLY TO MOST SMALL BUSINESSES. It targets large emitters of GHGs, such as power plants, industrial facilities, and large manufacturing operations. The threshold of 25,000 metric tons of CO2 equivalent per year is set high enough that small businesses typically fall below this limit and are not required to report.

The “sword of Damocles” argument is creative, but misleading at best. The existence of a reporting program does not guarantee future regulation, but it does provide policymakers with the necessary information to make informed decisions. In any regulatory system, monitoring data is essential for understanding the scope of the issue and evaluating the effectiveness of any future measures.

Full contextual analysis of Section 3.4: Environmental Protection Agency here.