WESTAR Comments on AERR ICR

On August 4th, 2025, WESTAR submitted comments on EPA’s renewal information collection request (ICR) for the Air Emissions Reporting Rule (AERR). EPA is seeking approval to renew its authority to collect emissions inventory data from state, local, and Tribal air agencies, and this renewal ICR estimates the burden in time and cost of collecting emissions inventory information.

WESTAR’s comments focused on the reasonableness of EPA’s updated cost assumptions, voluntary reporting of certain data elements, and the practical challenges states face in meeting the requirements. We also acknowledged and appreciated EPA’s efforts to update labor rates and cost estimates using recent federal data, as this conservative approach better reflects the resources needed by agencies to fulfill their obligations. The comment letter can be found here.