Today, the Environmental Protection Agency (EPA) opened a several-day public hearing over its “reconsideration” of its 2009 Endangerment Finding and its proposed “repeal all greenhouse gas
(GHG) emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines.”
If these developments fail to shock our collective conscience, that is a sign only of our hardening — perhaps borne of exposure to recurrent other outrages.
This means that our nation — the largest global GHG polluter over time — now seeks to repeal all GHG restrictions on its transportation sector. Combined with its earlier-proposed repeal of GHG restrictions on the power sector, our chief environmental agency is moving to lift restrictions on sources comprising half of all GHG emissions within the United States.
If these developments fail to shock the conscience, it may be a sign of our hardening, perhaps to recurrent outrages.
I was number 19 on the slate of hundreds today (August 19, 2025). Each witness was provided 2.5 minutes. My written testimony is immediately below. EPA apparently will not be releasing a video of the hearing.
I tried here to respond to EPA’s current claim that the Clean Act Act does not permit the Agency to continue its current restrictions on GHG emissions from the light, medium, and heavy-duty vehicle sector on the basis that their contribution is but a small fraction of total world emissions.
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[Testimony of Dan Galpern, CPR Initiative, before the Environmental Protection Agency.]
Thank you for the opportunity.
I will use my time to emphasize a short passage, whose source I will provide at its close.
We absolutely must consider:
the totality of the circumstances in order to understand the role played by §202 source categories. This is consistent with Congress’ intent to consider the cumulative impact of all sources of pollution. In that context, the global nature of the air pollution problem and the breadth of countries and sources emitting greenhouse gases means that no single country and no single source category dominate or are even close to dominating on a global scale.
“The total emissions of greenhouse gases are from numerous sources and countries, with each contributing a relatively small percentage of the total. That means that [a] country or a source may be a large contributor, in comparison to other countries or sources, even though its percentage contribution may appear relatively small. In this situation, addressing a global air pollution problem [calls] for many different sources and countries to address emissions even if none by itself comes close to dominating the global inventory.
“A somewhat analogous situation can be found in the ozone air pollution problem. Emissions of NOx and volatile organic compounds (VOCs) often come from numerous small sources, as well as certain large source categories. The global aspects of the greenhouse gas air pollution problem amplify this kind of situation many times over. In this situation it is reasonable [and necessary] to consider emissions from source categories even where their percentage contribution may appear relatively small.”
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Those words, with the exception of my sole addition “and necessary,” derive directly from your own Agency’s original Endangerment Finding (from 2009).
What was true then remains true today, and necessary, for all practical purposes.
At this late hour, we simply must not renege on our national commitment to combat dangerous climate change.
[End of Galpern testimony]
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Please note: You can submit your own comments. EPA’s new deadline for receipt of them is September, 22, 2025. Comments may be submitted is several ways:
- Via EPA’s Federal eRulemaking Portal: https://www.regulations.gov/.
Follow the online instructions for submitting comments. - Via email to: a-and-r-Docket@epa.gov.
Include Docket ID No. EPA–HQ–OAR– 2025–0194 in the subject line of the message. - By Mail: U.S. Environmental Protection Agency, EPA Docket Center, OAR Docket, Mail Code 28221T, 1200
Pennsylvania Avenue NW, Washington, DC 20460.