OMB Watch Comments on Greenhouse Gas Reporting

OMB Watch has submitted comments [1] on the Environmental Protection Agency's (EPA) proposed mandatory greenhouse gas (GHG) registry. Our comments focused on ensuring that information about emissions is made available to the public in a comprehensive, timely, and useful manner. Without sufficient transparency, the GHG registry could end up sabotaging our nascent climate policies.

Congress ordered the EPA to create a registry that would track greenhouse gas emissions at the facility level and across all sectors of the economy, thereby providing data to inform policy decisions. The proposed rule [2], with only a few exceptions, would do just that.

In addition to the obvious emitters like coal-burning power plants, the proposed registry also covers "upstream" sources. Rather than require every SUV owner to calculate his or her emissions, the manufacturer of the SUV engine and the maker of the gasoline will have to report emissions instead, using various formulas. EPA estimates about 13,000 facilities will be covered overall.

In general, the proposed registry is a great first step on the path to reducing GHG in the atmosphere. We cannot have a functioning cap-and-trade system, as proposed by many in Congress [3], without accurate and comprehensive emissions data. However, EPA offered little information describing how it will disclose the data it collects. We identified several modifications EPA should adopt:

• Provide timely release of the emissions data to the public. EPA should let the public see the raw data soon after the agency receives the reports and follow up with detailed analyses of the trends. Data should be available in raw form so the public can do their own analyses and also in other formats that put the data in context and clearly explain the trends for the general public.
• Use current technologies. EPA should use the most current technologies to disseminate the information and encourage the public to further use the data, perhaps, for example, by combining emissions data with demographic trends like household income and a mapping program to get a better understanding of what forces influence emissions levels. The more data we have, the more analyses we can do, and the more solutions we can develop.
• Quarterly reporting. EPA has proposed yearly reporting, but we feel quarterly reports by emitters would be much more useful while not overly burdening the facilities. We also want to be certain that data needed by the public to evaluate emissions are not hidden by false claims of protected trade secrets.
• Act now. EPA must not delay implementing the rule. The agency must adhere to the proposed reporting schedule that sets January 1, 2010, as the start of the first reporting year and March 31 of the following year as the deadline for submission of emissions reports. So much time has been wasted in dealing with all climate change issues that we cannot afford to wait any longer to begin something as basic as data collection.

OMB Watch's full comments are available here [1]. The public comment period is now closed, but the nation's climate policy journey is just beginning.