The Emory Environmental Law and Science Changemaker Program connects undergraduate students majoring in the sciences with Emory’s Turner Environmental Law Clinic to research and comment on environmental rulemaking.
The two undergraduate students, Taylor Black and Dayan Trejo-Martinez, bring backgrounds rooted in science, while the two law students, Katherine Lawson and Julia Koepp, bring knowledge of how to navigate legal systems. With the combination of science and legal backgrounds, along with help from the rest of our team, we responded to the EPA’s request for public comments, crafting a convincing comment opposing the agency’s proposed rule to rescind the Greenhouse Gas Reporting Program (GHGRP).Since 2009, the GHGRP has required annual emissions reporting from fossil fuel suppliers, industrial gas suppliers, direct greenhouse gas emitters, and manufacturers of heavy-duty and off-road vehicles and engines. The data collected through this reporting is posted publicly online, providing a transparent account of greenhouse gas (GHG) emissions in the United States. In the private sector, companies give this data to investors and consumers who are interested in the environmental effects of their products. States also rely on this data for their individual climate goals. The EPA justifies the proposed rescission by saying that the GHGRP exceeded their authority because the program does not further the purpose of the Clean Air Act.
Our team tackled this project by using both legal and scientific arguments. In our comment, we state that the GHGRP should continue because it furthers the clearly stated general statutory provisions of the Clean Air Act. The Clean Air Act is a comprehensive federal law that regulates air pollution. The GHGRP provides technical assistance for executing air programs, helps to accelerate the national research program, and aids in protecting the Nation’s air resources, all of which are foundational purposes of the Clean Air Act. Furthermore, we state that the GHGRP is essential for protecting public health, and we provided clear examples of failed emissions reporting that led to negative outcomes for public health.
The emissions reporting data is utilized by climate scientists and institutions for transparency, benchmarking, and tracking reduction goals. The data is also a critical resource for policymakers. By using a multitude of examples, both legal and scientific, we furthered our argument that the GHGRP is immensely important across sectors. It is imperative that this reporting process continues for the sake of the wellbeing of our planet.
We are going to continue to be optimistic that this consistent, evidence-based commenting is impactful for holding agencies, like the EPA, accountable for regulating emissions. Between climate change and air pollution, monitoring GHG emissions is imperative for protecting public health and welfare. The Environmental Law and Science Changemaker Program will continue to evaluate and comment on these proposed rules in hopes to create meaningful and lasting changes for our environment.