The EPA has quite a long history. So one approach could be to see if the EPA has ever covered another industry with such data collection before. 


concurring - Gorsuch:

"Third, courts may examine the agency’s past interpretations of the relevant statute. See ante, at 20–21. A “contemporaneous” and long-held Executive Branch interpretation of a statute is entitled to some weight as evidence of the statute’s original charge to an agency. United States v. Philbrick, 120 U. S. 52, 59 (1887). Conversely, in NFIB v. OSHA, the Court found it “telling that OSHA, in its half century of existence, ha\[d\] never before adopted a broad public health regulation” under the statute that the agency sought to invoke as authority for a nationwide vaccine mandate. 595 U. S., at \_\_\_ (slip op., at 8); ante, at 18;"