XBRL US submitted a comment letter in response to the Environmental Protection Agency (EPA) request for feedback on Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule, Docket Id. No. EPA–HQ–OAR–2019–0424. The XBRL US letter made the argument that data collected by the EPA on greenhouse gas emissions made by facilities should be in structured, machine-readable (XBRL) format, and also that the EPA should require the use of the Legal Entity Identifier (LEI) by facilities submitting this data so that parent companies can be appropriately associated with their subsidiary facilities. The absence of standardized identifiers associated with the parent company makes it difficult and time consuming to easily and unambiguously identify the parent company.