Clean Energy Counsel Comments on EPA’s GHG Reconsideration

On September 22, Clean Energy Counsel submitted a comment letter to the U.S. Environmental Protection Agency (“EPA”) strongly opposing its proposal to reconsider and potentially rescind the 2009 Greenhouse Gas Endangerment Finding and related vehicle emission standards.

On August 1, 2025, the EPA issued a proposed rule titled: “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards by the EPA (Docket ID No. EPA-HQ-OAR-2025-0194)”. The 2009 Endangerment Finding is a cornerstone of U.S. climate regulation. It established, based on extensive scientific evidence, that greenhouse gases (“GHGs”) pose a threat to public health and welfare. This determination provides the legal foundation for regulating GHG emissions under the Clean Air Act. Rescinding this finding goes against well-established case law and would strip away EPA’s ability to regulate the main sources of pollution contributing to the climate crisis.

As attorneys who have dedicated our practice to the clean energy transition, we view it as both a professional and moral obligation to speak out against this proposed action. Our clients, our communities, and the broader public rely on EPA to uphold its duty under the Clean Air Act to protect human health and welfare. The Endangerment Finding remains a lawful, evidence-based determination, and any effort to weaken or dismantle it would be a grave disservice to the nation and to the generations who will live with the consequences of today’s decisions.

As a mission driven law firm, we will continue to use our voice, knowledge, and skill sets to advocate, not only for our clients, but also for the greater good of the planet, our communities, and the rule of law.