Comments Against EPA's Reconsideration of the 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.
Below are my comments that I submitted against EPA’s proposal to rescind EPA’s 2009 endangerment finding and greenhouse gas vehicle standards. As someone who helped lead oversight of the Clean Air Act in the U.S. Senate when EPA finalized the 2009 Endangerment Finding on greenhouse gas emissions, helped lead the charge against the endangerment finding Congressional Review Act (which did not pass), and seen firsthand the climate costs to American people, these comments come from a deeply personal perspective. If EPA moves forward with this proposal, it will ignore decades of science and public health data and cause harm to our public health and fiscal stability. It’s also really bad for U.S. businesses.
The Honorable Lee Zeldin
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
RE: Docket ID No. EPA-HQ-OAR-2025-0194-009
Thank you for the opportunity to comment on EPA’s proposal entitled: “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.” I urge the EPA to reject this dangerous proposal and instead keep EPA’s greenhouse gas endangerment finding intact. The science, congressional direction, and costs to the American people all lead to one answer: greenhouse gases are a threat to public health and welfare, and EPA must continue to regulate greenhouse gas emissions from our nation’s largest sources, including the transportation sector.
Science: First, EPA’s 2025 assessment of the latest in climate science within the proposed reconsideration is deeply flawed. For context, I have been focused on the nexus between air pollution and public health for most of my 20-plus year career and have a Masters in Science in Public Health from the University of North Carolina at Chapel Hill. In my career, I’ve seen few issues studied as thoroughly, and as widely across the global community than the impacts of greenhouse gas air pollution on public health and welfare. The latest scientific research shows that, if anything, EPA underestimated, not overestimated, the negative impacts on public health and welfare when it determined the 2009 endangerment finding. I submit for the record in an attachment the latest National Academies of Science report, Effects of Human-Caused Greenhouse Gas Emissions on U.S. Climate, Health, and Welfare, which found that: “many of EPA’s conclusions are further supported by longer observational records and multiple new lines of evidence. Moreover, research has uncovered additional risks that were not apparent in 2009” (National Academies of Sciences, Engineering, and Medicine. 2025. Effects of Human-Caused Greenhouse Gas Emissions on U.S. Climate, Health, and Welfare. Washington, DC: The National Academies).
The welfare impacts are also far-reaching, including in your home state of New York. I submit for the record as an attachment the Adirondack Lake Assessment Program 2023 Report Technical Report by Paul Smith’s College Adirondack Watershed Institute. The report states that the “New York State climate assessment identified the Adirondacks as one of the state’s most climate sensitive regions” and points to several studies conducted after 2009 that find elevated temperatures are “driving measurable changes in Adirondack lakes”, including increased water temperatures, shifts in ice coverage, increased runoff to the lakes and increased risks for higher 1 nitrogen and phosphorous levels (L’Hote M., Glennon M., Hall J., Kelly S., Smith C., Treibergs L., Vara C., Yerger E.C., Wiltse B. 2024. Adirondack Lake Assessment Program 2023 Report: a Community Science Lake Monitoring Program in its 26th Year. Paul Smith’s College Adirondack Watershed Institute).
The science data on the negative health and welfare impacts of climate pollution are clear, as is the data on who are the largest emitters of climate pollution. The European Commission’s Emission Database for Global Atmospheric Research, working with the International Energy Agency, recently updated its estimate of global greenhouse gas emissions. The document, which I submit for the record as an attachment, finds that the United States is the second largest global emitter of carbon dioxide and greenhouse emissions, producing over 11% of the world’s greenhouse gas and carbon dioxide pollution in 2024 (M., Guizzardi, D., Pagani, F., Banja, M., Muntean, M. et al., GHG emissions of all world countries – 2025, Publications Office of the European Union, 2025, https://data.europa.eu/doi/10.2760/9816914).
Congressional Intent: Second, I contend that EPA’s 2025 assessment of congressional intent within the reconsideration proposal is misinformed. This comes from a deep-personal history of knowing congressional intent, whereas I previously served from 2008-2023 as former U.S. Senator Tom Carper’s lead for climate and air pollution oversight while he was Chairman/Ranking Member of the Clean Air and Nuclear Safety Subcommittee on the U.S. Senate Environment Public Works (EPW) Committee and Chairman/Ranking Member of the EPW full committee. During this time, I saw Congress reject resolutions and other legislative efforts that would have undermined EPA’s 2009 Endangerment Finding. At the same time, I witnessed Congress reinforce EPA’s authority and expand the federal government’s actions regarding the growing threat of climate change.
Costs: Third, EPA’s 2025 assessment within the reconsideration proposal regarding the costs of climate action is also deeply flawed and ignores the overall costs to the U.S. taxpayer. I previously served as Associate Director within the Office of Management and Budget (OMB) under President Biden, where I led the team in charge of tracking federal climate fiscal risks. The OMB team worked across the federal government to spearhead the release of three OMB white papers, which I submit for the record, and three AP Budget chapters within the President’s Budget on federal climate fiscal risk, which I submit for the record the AP Chapter for FY2025.
The findings throughout these climate risk budget documents are staggering. In 2022, OMB found that a 3 degree increase in Celsius would result in “7.1 percent lower Federal revenue by 2100 -- equivalent to approximately $2 trillion per year in today’s dollars” (OMB_Climate_Risk_Exposure_2022.pdf). Though OMB also found that the fiscal strain of climate change is already visible in our economy. In 2024 alone, the U.S. experienced 27 billion dollar events costing $182.7 billion in economic damages. Between 2020 and 2024, FEMA spent $104.5 billion from the Disaster Relief Fund on climate-related disasters. The Department of 2 Defense spent $1 billion to rebuild Offutt Air Force Base after flooding, $3 billion for Camp Lejeune post–Hurricane Florence, and $5 billion for Tyndall Air Force Base after Hurricane Michael. From 2019 to 2023, the USDA Forest Service and the Department of the Interior spent over $16.5 billion on wildfire suppression. (BUDGET-2025-PER-3-8.pdf). These costs are already borne on the taxpayer and are not reflected in EPA’s assessments of costs.
EPA also ignores the rising costs to taxpayers, with OMB estimating billions of dollars expected to be lost in the next decade from infrastructure and disaster relief costs alone from climate related events. More federal dollars will be needed to support our nation’s farmers from climate related damages. More federal dollars will be needed to help rebuild damaged roads, bridges, military bases, and federal buildings. And more federal dollars will be needed to cover rising Medicaid and Medicare costs as climate impacts our most vulnerable the hardest.
Two examples of increased federal program costs found in the FY2025 AP Budget Chapter, include:
U.S. Department of Agriculture’s Livestock Forage Disaster Program, which helps ranchers during periods of prolonged and intense drought, estimates annual expenses may increase up to $800 million per year (in 2022 dollars) more than current expenditures by the end of the century because of the effects of climate change; and
U.S. Department of Agriculture and Department of Interior wildland fire suppression spending on federal lands is expected to increase by $1.3 billion per year by mid-century and more than $2.5 billion per year by late-century in response to the dramatic increase in wildfires due to climate change.
These are just the federal costs; state and local governments, businesses, and households are also paying the increased costs of climate pollution.
EPA’s proposal for reconsideration also ignores the role Clean Air Act regulations have played in our nation’s economic competitiveness, especially for our nation’s transportation sector. Smart Clean Air Act pollution rules often help U.S. companies lead in the global clean tech markets, not set them back and bring benefits far beyond their costs, spurring new industries, improving our trade balance, protecting our health, and cutting energy bills for families. For example, coming out of the Great Recession, a bright spot in our nation’s trade deficits and economic growth came from companies like Cummins, which had invested in clean vehicle technology to meet EPA emission standards. The demand for cleaner engines, especially abroad in places like China, was at the time booming and American companies were able to meet the global demand and benefit financially. Because EPA vehicle emissions standards helped drive American innovation, regulations didn’t kill business, regulations helped it grow.
We’ve also seen what happens when regulations do not drive innovation. For example, nearly 15 years ago, after fighting for decades against stronger emission and efficiency vehicle standards, 3 the U.S. automakers found themselves collapsing under the weight of outdated gas-guzzling fleets during the Great Recession. Meanwhile, companies – many global competitors – who had invested in cleaner technology were thriving. It took billions in taxpayer bailouts to keep U.S. manufacturers afloat, and new greenhouse gas and efficiency standards under the Obama administration to restore their global competitiveness. The EPA proposal ignores this history and ignores the potential economic benefits and economic risks to U.S. companies if the endangerment finding is rescinded.
In conclusion, EPA’s proposal to reconsider the endangerment finding is flawed in its assessment of the science, congressional intent, and costs and should be rejected. The fallout from ignoring climate pollution will be enormously detrimental to our public health and our fiscal stability. It will also increase energy costs on families and risk U.S. global competitiveness.
Thank you for your consideration of my comments.
Sincerely,
Laura Gillam