Endangerment Finding Comment Letter on Behalf of USCM, NLC, Climate Mayors, C40 and Sabin Center

The National League of Cities, the U.S. Conference of Mayors, Climate Mayors, C40 Cities and the Sabin Center for Climate Change Law at Columbia Law School (“Sabin Center”) respectfully submit the following comments on the U.S. Environmental Protection Agency’s (“EPA”) proposed “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.”

With respect to EPA’s proposed repeal of the 2009 Endangerment Finding and proposed repeal of greenhouse gas (“GHG”) emissions standards for vehicles, we write to make the following comments:

• In proposing to repeal the Endangerment Finding and all regulations for the emission of GHGs from motor vehicles, EPA fails to seriously consider the impacts of these regulatory actions in cities. Since 2009, when the Endangerment Finding was made, the

  scientific evidence that cities are experiencing devastating impacts from GHG-induced climate change, as established in the 2023 Fifth National Climate Assessment (“NCA5”) and as experienced in cities across the country, has only solidified. Moreover, EPA’s

  proposed and we believe erroneous reading of the definition of the term “air pollutant” ignores these local harms.

• EPA’s GHG standards for motor vehicles have significant benefits in cities, augmenting cities’ own efforts to reduce GHG emissions from the transportation sector at the local level. In particular, local governments are preempted by Section 209 of the Clean Air Act

  from regulating air pollution from new motor vehicles, meaning that without federal regulation, this heavily emitting GHG source is left unregulated.

Read the full letter HERE.