The League of Women Voters of the United States submitted comments to the Environmental Protection Agency (EPA) opposing their proposal to rescind the Endangerment Finding, which enables them to regulate greenhouse gas (GHG) emissions.
September 22, 2025
Administrator Lee Zeldin
Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20004
Submitted electronically via regulations.gov
Re: Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards Docket Number: EPA-HQ-OAR-2025-0194
Dear Administrator Zeldin,
These comments are provided by the League of Women Voters of the United States (The League), in response to the Environmental Protection Agency’s (EPA’s) proposal to rescind the 2009 Endangerment Finding on greenhouse gases (GHGs) and to rescind the Greenhouse Gas Vehicle Standards — emission standards for light-, medium-, and heavy-duty vehicles and engines. We strongly oppose the proposed rule as it will leave Americans less safe, less healthy, less prosperous, and less certain about their future.
The League and Climate Change
The League is a 105-year-old nonpartisan, nonprofit organization committed to ensuring that everyone is represented in our democracy. We are a grassroots group comprised of more than one million members and supporters across more than 750 local and state Leagues nationwide. The League focuses on advocacy, education, litigation, and organizing to achieve our mission to empower voters and defend democracy. The League believes that climate change is a serious threat facing our nation and planet and that an interrelated approach to combating climate change is necessary to protect public health. The League also believes that the federal government should have a major role in setting standards for environmental protection and pollution control.
The League strongly opposes the rescission of both the Endangerment Finding and the Greenhouse Gas Vehicle Standards, with our primary concerns to follow:
I. Rescission of the Endangerment Finding is not supported by robust scientific evidence and threatens the integrity of science.
II. The primary source cited to support EPA’s proposed rescission likely violated the Federal Advisory Committee Act and should not be used to support EPA’s proposal.
III. Combining rescission of the Endangerment Finding and the Greenhouse Gas Vehicle Standards conflates these two related but distinct rules, downplaying the scale of impact of EPA’s proposed rule.
IV. The economic argument put forth in the proposed rule is specious as it ignores key factors including:
1. the energy transition away from fossil fuels will not stop because of the rule;
2. the reach of the markets and economy are global, not national;
3. the costs to repair or mitigate the damage caused by rescinding either the Endangerment Finding or the Vehicle Regulations far exceed any short-term potential cost savings the proposed rule may effectuate; and
4. adoption of this proposal may further enhance China’s existing advantage in leading the renewable energy market.
Opposing the Recission of the Endangerment Finding and the Greenhouse Gas Vehicle Standards
I. EPA’s proposed rule is not supported by robust scientific evidence
The League supports climate policies consistent with the best available climate science. A scientific consensus is reached when independent studies by scientific experts come to a similar conclusion, as is the case with the very real adverse human health and environmental impacts of GHG emissions from anthropogenic sources. As detailed in the 2023 congressionally mandated report, “Fifth National Climate Assessment,” there is overwhelming scientific evidence to support EPA’s 2009 Endangerment Finding that the six greenhouse gases identified endanger both the public health and the public welfare of current and future generations.
Yet, in its Proposed Rule, EPA ignores its own findings and those of many other federal agencies, including the National Oceanic and Atmospheric Administration (NOAA), as well as scientists around the world. Instead, EPA relies on the findings of the 2025 CWG Draft Report, “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate” submitted by the Department of Energy’s (DOE) Climate Working Group (CWG). The draft report was not peer reviewed, was developed in less than three months by five people, shares conclusions based on misinterpretations of study results or the singling out of data and results that support the authors’ argument, and omits whole areas of recent and relevant research. This report was also published for comment just one week before EPA’s proposed rule was published for comment, undermining government transparency and accountability. EPA’s proposed rule puts forth very brief arguments that lack both breadth and depth across the many scientific fields and specific topics needed to assess climate change. Rescission of the Endangerment Finding is a threat to both public health and welfare as well as the integrity of science itself.
II. DOE’s CWG likely violated the Federal Advisory Committee Act
The Federal Advisory Committee Act (FACA) requires federal advisory committees created by federal agencies, including working groups, to provide expertise and policy advice to be "fairly balanced in terms of the points of view represented and the functions to be performed." The five scientists selected by the Secretary of the Department of Energy for the CWG do not represent a fair and balanced view of the causes and impacts of climate change. The CWG’s findings also were published without peer review. This approach was not balanced and did not provide the depth needed for an adequate scientific analysis.
FACA also requires that meetings be open and available to the public, and that the public can comment on the workings of the committee. As described above, the CWG convened without public notice or public participation. Therefore, the 2025 CWG Report should not be used to support EPA’s proposed rule.
III. Combining rescission of the Endangerment Finding and the Greenhouse Gas Vehicle Standards conflates the rules
In 2009 the EPA published the rule entitled “Endangerment and Cause or Contribute Finding for Greenhouse Gases Under Section 202(a) of the Clean Air Act,” also known as the Endangerment Finding. It said that six GHGs endangered public health and welfare, and that the combined emissions of these GHGs from new motor vehicles and engines contribute to the GHG air pollution that endangers public health and welfare.10 Under the Clean Air Act (CAA) section 202(a), this finding gave the EPA the statutory authority to regulate GHG emissions.
EPA’s 2009 Endangerment Finding provides the legal foundation to regulate all six greenhouse gases (GHG) under the Clean Air Act. While the immediate result of the Endangerment Finding was the promulgation of emission standards for motor vehicles, it also provided the legal basis for regulating emissions from power plants, cement manufacturing, oil and gas wells, and more. The Endangerment Finding is the underpinning for current and future regulations of GHG emissions from any source. If the Finding is rescinded, it will remove the legal underpinning to regulate GHG emissions not only for vehicles but also stationary sources. Given the enormous regulatory impact of the Endangerment Finding, any proposed rule to rescind it needs to discuss its impact on all regulated industries that rely upon it. Rescission of the Endangerment Finding would be an enormous setback to climate change policy and have lasting impacts on human health and welfare.
By combining rescission of the Endangerment Finding with a proposal to rescind GHG vehicular standards, EPA conflates these two related but very distinct rules. EPA’s decision to put them together is at best a rushed, ill-considered choice; at worst, it is a deliberate attempt to obfuscate the Agency’s intent and mislead the public about the full impact of rescinding the Endangerment Finding: removing the foundation to regulate GHGs.
IV. EPA’s economic rationale for the proposed rule is specious
EPA argues in the proposed rule that rescinding regulations that reduce GHG emissions from motor vehicles will result in cost savings for consumers. This argument ignores four key factors: (1) the energy transition away from fossil fuels is well underway; (2) the market and the economy are global; (3) costs due to accelerating climate change far exceed any cost savings; and (4) China is quickly outstripping the US in the future of renewable technology.
1. Energy Transition: The economy is already well advanced in transitioning away from fossil fuels. The primary driver of this is that renewables are not only cleaner but also cheaper, and the costs are continuing to fall because of both improved technologies and increased deployment. The growth in renewables is exponential, not linear. An attempt to limit this energy transition will be met by a contrary and inexorable economic driver.
2. Global Economy and Markets: Motor vehicle manufacturers compete at a global level, rather than national, and will need to provide features that comply with stricter international standards. The global markets are moving contrary to the proposed rule.
3. Climate Costs Exceed Any Possible Cost Savings: According to the National Oceanic and Atmospheric Administration (NOAA), recovery from climate-related disasters alone cost a cumulative $2.9 trillion for 1980 – 2024. Although that number is large, it is only one wedge of the economic pie chart. Additional costs include increasing property insurance premiums, heating and cooling costs, healthcare costs, direct and indirect economic impact on agriculture, and many others. Additionally, we need to consider costs that cannot be quantified, such as loss of biodiversity and tipping points –critical thresholds in a system that, when exceeded, can lead to a significant and often irreversible change in the state of the system– as well as other quantifiable costs like environmental externalities.
4. China Dominates Renewable Energy: China has a commanding lead in manufacturing of wind and solar, electric vehicles, and electrification. It also has control over global supply chains for lithium and rare earths through its dominance in refining and processing. The changes in the proposed rule may give China further advantage in a situation that is already threatening to national security.
Conclusion
As per EPA’s official website, the Agency has a responsibility to ensure that Americans have clean air, and that national efforts to reduce environmental risks are based on the best available scientific information. In the service of these responsibilities, the League urges EPA not to finalize the proposed rule “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.”16 The health and welfare of our country depend on it.