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Comment Deadline on Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards
Monday, 9/15/25 is the Comment Deadline on Trump administration revoking EPAs “endangerment finding” -. The “endangerment finding” is the EPA’s scientific and legal conclusion that the Clean Air Act requires regulation of greenhouse gas emissions to protect public health and welfare. The EPA issued the endangerment finding in 2009 pursuant to the Supreme Court’s decision in Massachusetts v. EPA.
In addition to rescinding the EPA’s 2009 endangerment finding, the proposal also seeks to rescind all GHG emission standards for new motor vehicles and engines. This rescission includes GHG emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines for model years 2012 to 2027, and beyond.
EarthJustice has an alert & on-line pre-fab form letter on this rule-making
EarthJustice On-Line – pre-fab comment letter
https://earthjustice.org/action/dont-let-the-epa-gut-this-cornerstone-climate-protection?ms=web
Earth Justice Legal analysis
Environmental Defense Fund pre-fab comment letter
https://actnow.edf.org/a/endangerment
EDF’s You-Tube video on this
https://www.youtube.com/live/-HuXY6lwQog
Columbia Law pre-fab comment letter and legal discussion
The Endangerment Finding: The Local Perspective Matters Right Now (Template Comment Letter Linked)
We assume other environmental NGO’s also have alerts and pre-fab comment letters.
We copied the text of the EJ and EDF pre-fab comment letters, – so you all can copy one of them, in case they close the pre-fab letter sending down before 9:59 pm on Monday 9/15/25 – URL:
https://phas-wsd.org/wp-content/uploads/Earth-Justice-and-Environmental-Defense-Fund-pre.pdf
Proposed rule can be viewed here, as well as directions on how to comment by uploading or mailing individual comments:
https://www.regulations.gov/document/EPA-HQ-OAR-2025-0124-0001
Quotes from notice at above Federal Register link
ACTION:
Proposed rule.
SUMMARY:
“In this action, the U.S. Environmental Protection Agency (EPA) is proposing to repeal all greenhouse gas (GHG) emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines to effectuate the best reading of Clean Air Act (CAA) section 202(a). We propose that CAA section 202(a) does not authorize the EPA to prescribe emission standards to address global climate change concerns and, on that basis, propose to rescind the Administrator’s prior findings in 2009 that GHG emissions from new motor vehicles and engines contribute to air pollution which may endanger public health or welfare. We further propose, in the alternative, to rescind the Administrator’s prior findings in 2009 because the EPA unreasonably analyzed the scientific record and because developments cast significant doubt on the reliability of the findings. Lastly, we propose to repeal all GHG emission standards on the alternative bases that no requisite technology for vehicle and engine emission control can address the global climate change concerns identified in the findings without risking greater harms to public health and welfare.”
DATES:
Comments. Comments must be received on or before September 15, 2025. Comments on the information collection provisions submitted to the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA) are best assured of consideration by OMB if OMB receives a copy of your comments on or before September 2, 2025.
Public Hearing. The EPA will announce information regarding the public hearing for this proposal in a supplemental Federal Register document. Please refer to the SUPPLEMENTARY INFORMATION section for additional information on the public hearing.
ADDRESSES:
Comments. You may send comments, identified by Docket ID No. EPA-HQ-OAR-2025-0194, by any of the following methods:
• Federal eRulemaking Portal: https://www.regulations.gov/ (our preferred method). Follow the online instructions for submitting comments.
• Email: a-and-r-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2025-0194 in the subject line of the message.
• Mail: U.S. Environmental Protection Agency, EPA Docket Center, OAR Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
• Hand Delivery or Courier: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. The Docket Center’s hours of operations are 8:30 a.m.-4:30 p.m., Monday-Friday (except Federal Holidays).
Instructions. All submissions received must include the Docket ID No. for this rulemaking. Comments received may be posted without change to https://www.regulations.gov/, including any personal information provided. For detailed instructions on sending comments and additional information on the rulemaking process, see the “Public Participation” heading of the SUPPLEMENTARY INFORMATION section of this document.
FOR FURTHER INFORMATION CONTACT:
Alan Stout, Assessment and Standards Division, Office of Transportation and Air Quality, Environmental Protection Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105; telephone number: (734) 214-4805; email address: stout.alan@epa.gov.”