August 20, 2025

Abandoning Science, Endangering the Midwest

ELPC pushes back against EPA’s misguided attempt to repeal the “endangerment finding”

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EPA is proposing to undo the 2009 “Endangerment Finding,” the scientific basis for key greenhouse gas regulations from motor vehicles and other sources. At a recent hearing, some of the nation’s leading environmental, legal, and scientific voices testified, including three ELPC staffers who spoke on three separate topics, each challenging the unlawful and misguided attempt to overturn this long-standing, science-backed finding.

Howard Learner, ELPC Executive Director & CEO: Legal Errors

Howard highlighted the fundamental errors of law within EPA’s rationale.

• EPA’s proposal rests on the false premise that greenhouse gas pollution does not substantially contribute to climate change, despite decades of scientific evidence and EPA’s own repeated findings that it does.
• The proposal misconstrues the Clean Air Act by arguing that greenhouse gas emissions are not “pollutants” because their harmful impacts are somehow too indirect. Multiple Supreme Court decisions have already recognized greenhouse gases as pollutants under the Clean Air Act.
• EPA argues that it can withdraw the Finding and abandon any Clean Air Act regulation of greenhouse gases, but that the Act would still block other remedies for climate harm under federal common law or state climate law. This is legally indefensible.

READ HOWARD’S TESTIMONY

Ann Mesnikoff, ELPC’s Federal Legislative Director: Consumer & Health Impacts

Ann focused on the vital vehicle standards that would be nullified if the Endangerment Finding were repealed:

• The 2009 Endangerment Finding remains scientifically sound and legally required under the Clean Air Act; rescinding it ignores strong evidence of climate harms already impacting the Great Lakes and the nation.
• The Finding resulted in standards for the leading source of U.S. GHGs – motor vehicles including cars and heavy-duty trucks – that save lives and benefit consumers.
• The standards provide significant consumer and health benefits that would be lost under EPA’s proposal: $13 billion in annual health benefits, $46 billion in reduced annual fuel costs, and nearly $16 billion in reduced annual maintenance and repair costs for drivers.

READ ANN’S TESTIMONY

Callie Sharp, Associate Attorney with ELPC: Flawed Science

Callie discussed the selective and biased evidence that EPA used to justify this repeal:

• The Endangerment Finding is underpinned by sound science, including thousands of studies and comprehensive assessments from reputable organizations like the National Academy of Sciences, the Intergovernmental Panel on Climate Change, and many others.
• EPA itself stated the following about these scientific assessments. “No other source of information on climate change provides such a comprehensive and in-depth analysis across such a large body of scientific studies and adheres to such a high and exacting standard of peer review.”
• EPA discounts this robust peer-reviewed body of literature in exchange for a biased assessment which cherry-picks only the data that supports this Administration’s narrative and ignores the substantial majority of the literature that does not.

READ CALLIE’S TESTIMONY

Repealing the Endangerment Finding would go against science and EPA’s core – and only – mission to protect public health and the environment. ELPC will offer further written comments illustrating that the proposed repeal is not supported by EPA’s rationale.

EPA should rescind its dangerous and reckless proposal and protect people over polluters.