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ARTICLE · 12 AUGUST 2025

Up In The Air: EPA Opens Comment On Repealing Endangerment Finding, Motor Vehicle GHG Rules

Holland & Knight
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The U.S. Environmental Protection Agency (EPA) on Aug. 1, 2025, published a proposal to repeal all greenhouse gas (GHG) emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines from model year...

United StatesEnvironment
Michal I. Freedhoff
Michal I. Freedhoff
Zachary Pilchen
Zachary Pilchen
Brian Bunger
Brian Bunger
Susan G. Lafferty
Susan G. Lafferty
Marne S. Sussman
Marne S. Sussman
Daniela De la Rosa
Daniela De la Rosa
Maggie P. Pahl
Maggie P. Pahl
Andy Kriha
Andy Kriha
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Update (Aug. 27, 2025): EPA recently extended the public comment period to end on Sept. 22, 2025, and virtual public hearings were held Aug. 19-22, 2025.

Highlights

  • The U.S. Environmental Protection Agency (EPA) proposes to rescind the 2009 Endangerment Finding and repeal all greenhouse gas (GHG) emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines established under Clean Air Act (CAA) Section 202(a) since 2010.
  • EPA's primary rationale is that CAA Section 202(a) does not authorize the agency to regulate GHG emissions based on global climate change concerns, asserting that the CAA was designed to address air pollutants that contribute to dangerous air pollution "through local or regional exposures" rather than global atmospheric effects.

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