For Immediate Release
September 19, 2025
C2ES Urges Against EPA Rescission of GHG Endangerment Finding and Vehicle Pollution Standards
Highlights indisputable and growing body of science on severity and costs of climate impacts, US transportation sector emissions, and economic harm of regulatory uncertainty
WASHINGTON—Today, C2ES submitted comments on EPA’s proposed rescission of the Greenhouse Gas Endangerment Finding and the agency’s Greenhouse Gas Vehicle Standards, urging the agency against the rollback. C2ES concludes that repealing standards would cost Americans billions of dollars in climate damage, lost health benefits, and lost vehicle ownership-related savings per EPA’s own previous analysis. The comments also outline severe economic and public health risks associated with EPA’s proposed action.
Additionally, the comments emphasize the significance of U.S. emissions from the transportation sector under the Clean Air Act, which require smart, well-designed regulation, contrary to EPA’s justification of the proposed rescission.
To speak with a C2ES expert about the comments, contact Tim Carroll at press@c2es.org.
C2ES experts developed these comments with input from the private sector and additional external partners. In the comments, C2ES experts highlight the indisputable science and evidence of human-induced climate change and its negative impacts, a body of data that has only grown in size and credibility since the endangerment finding was issued in 2009. The experts also note that the agency’s proposal ignores historical precedent and the Clean Air Act’s own directive to regulate sources that contribute to air pollution, such as vehicle tailpipe emissions.
C2ES concludes by warning EPA of the risks to U.S. economic and national security and the health and wellbeing of Americans:
“Our nation’s economic well-being and security depend on a safe and stable climate. By ignoring that reality, EPA has abdicated its responsibility to protect the public health and welfare—and taken steps that, if finalized, will lead to a less prosperous America. C2ES calls on EPA to continue its mandated role in safeguarding the public’s wellbeing by upholding the Endangerment Finding and maintaining greenhouse gas vehicle standards under CAA section 202(a). Repeal would be scientifically unfounded, legally unjustified, economically harmful, and ethically indefensible.”
The comments also state:
“Worsening air quality from uncontrolled wildfires impacts respiratory and cardiovascular conditions, hundreds of thousands of acres of farmland have had to be fallowed in the Southwest due to drought, historic flooding—from Texas to Kentucky to Vermont—and hurricanes and tropical storms along the Gulf Coast and Eastern seaboard have led to lives cut short, millions of dollars of lost wages, and trillions of dollars of damage to property and the environment.
“Nationwide, home insurance rates are increasing 8.7 percent faster than the rate of inflation, with homeowners in high climate-risk regions like southern California and Florida seeing much steeper rate hikes, or being unable to acquire home insurance at all. These costs demonstrate that a finding of endangerment for GHGs is warranted, and is even more relevant today than it was when the Finding was made in 2009.”
The comments go on to argue rescission would harm U.S. competitiveness and manufacturing leadership.
U.S. greenhouse gas vehicle standards are not just a regulatory backstop for greenhouse gas emissions; they are also a strategic enabler of U.S. automaker competitiveness:
“Retreating now would signal regulatory back-pedaling just as peers and competitors worldwide are consolidating advantages in advanced batteries, electric drivetrains, and high-efficiency internal combustion engine (ICE) components, raising the risk that domestic suppliers miss scale economies, export opportunities, and workforce development gains captured by jurisdictions with clearer standards.”
Read the full comments from C2ES here.
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