ICCT: EPA’s proposal to rescind endangerment finding and GHG standards is scientifically flawed and economically harmful

(Washington, DC) September 22, 2025 — The International Council on Clean Transportation (ICCT) submitted comprehensive public comments today in strong disagreement with EPA’s proposal to rescind the Endangerment and Cause or Contribute findings for greenhouse gas emissions from motor vehicles, and to repeal motor vehicle greenhouse gas standards. The organization has stated that the proposed recission of these findings is inconsistent with fundamental and overwhelming scientific evidence that human-caused greenhouse gas (GHG) emissions endanger human health and welfare and that motor vehicles are significant contributors to these harms.

Since the Endangerment Finding was finalized in 2009, evidence for human-caused climate change has only grown stronger. Motor vehicles are the single largest source of GHG emissions in the U.S., and if the U.S. transport sector were its own country, it would rank as the 5th highest GHG-emitting nation in the world.

“There is indisputable evidence that human-caused greenhouse gas emissions from burning fossil fuels in the transportation sector has profound environmental, health, and economic impacts,” says Drew Kodjak, President and CEO of ICCT. “Rescinding these findings and gutting regulations that mitigate emissions will put American lives, infrastructure, and the economy at risk.”

The market has consistently outpaced EPA’s conservative projections

ICCT’s analysis reveals that EPA consistently underestimates electric vehicle technology development and overestimates its costs. Battery costs and electric vehicle prices have fallen dramatically below, and EV market share has grown higher than, EPA projections, resulting in lower costs and higher benefits than previously expected. Market data and ICCT analysis directly contradict EPA’s proposal, which includes unsubstantiated predictions of prohibitively expensive cleaner cars.

Rolling back standards would devastate American consumers and industry

EPA’s own analysis of the 2027-2032 motor vehicle GHG standards it adopted would deliver $62 billion annually in fuel and maintenance savings through 2055. These standards are feasible, achievable, and cost-effective—rolling them back would cost Americans over $2 trillion when accounting for increased fuel costs and climate damages.

“The EPA’s new ‘revealed preference approach’ is fundamentally flawed, lacking peer review and scientific validation,” says Kodjak. “Their analysis erroneously inflates compliance costs while ignoring massive fuel savings and climate benefits.”

The rollback would also devastate American competitiveness, threatening to strand billions in announced electrification investments and ship jobs overseas to markets with stronger climate policies.

Multiple compliance pathways exist

Contrary to recent EPA assertions, the ICCT finds that the technologies to reduce and eventually eliminate vehicle emissions already exist, are highly cost-effective, and save consumers money. Compliance with current standards through multiple technology pathways is feasible, minimally impacting vehicle prices while greatly benefiting American consumers.

The ICCT recommends to EPA not to adopt the proposed changes to the Endangerment and Cause and Contribute findings and to maintain the existing light- and heavy-duty vehicle greenhouse gas regulations to protect American consumers, jobs, and global competitiveness.

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Media Contact:
Kelli Pennington, Global Communications Manager
communications@theicct.org 

About the International Council on Clean Transportation
The International Council on Clean Transportation (ICCT) is an independent research organization providing first-rate, unbiased research and technical and scientific analysis to environmental regulators. Our mission is to improve the environmental performance and energy efficiency of road, marine, and air transportation, in order to benefit public health and mitigate climate change. Founded in 2001, we are a nonprofit organization working under grants and contracts from private foundations and public institutions.

Find us at:
www.theicct.org
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