Comments of the Center for Climate and Energy Solutions on Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards (40 CFR Parts 85, 86, 600, 1036, 1037, and 1039 (July 29, 2025)) Docket ID No. EPA-HQ-OAR-2025-0194; FRL- 12715-01-OAR

These comments were submitted on September 19, 2025. 

Key Points

• Scientific analysis and direct observation demonstrate that U.S. Environmental Protection Agency’s (EPA) Endangerment Finding is even more valid today than it was in 2009.
• The recently released Department of Energy Climate Working Group report was not prepared in accordance with scientific standards for the federal government and cannot be used to justify a rescission of the Endangerment Finding.
• Growing concentrations of greenhouse gases are directly impacting American’s health and welfare by increasing the severity and cost of climate impacts experienced by communities around the United States.
• Reducing emissions from the U.S. transportation sector—the largest domestic emitter of greenhouse gases—is within the EPA’s authority to regulate under the Clean Air Act and will deliver hundreds of billions of dollars in net economic benefits by measurably reducing the impacts of climate change.
• Rescission of the Endangerment Finding would be costly for stakeholders—including automakers, technology developers, and state and local governments—who have developed reliance interests around the current greenhouse gas regulatory framework that has been law for over 15 years.
• Based on its historical emissions and its dominant role in the global economy, the United States has both an obligation and a strategic imperative to act conscientiously today by minimizing future greenhouse gas pollution. A safe and stable climate underpins U.S. economic wellbeing and national security.