C2ES Urges Against EPA Rescission of GHG Endangerment Finding and Vehicle Pollution Standards  

Highlights indisputable and growing body of science on severity and costs of climate impacts, US transportation sector emissions, and economic harm of regulatory uncertainty 

WASHINGTON—Today, C2ES submitted comments on EPA’s proposed rescission of the Greenhouse Gas Endangerment Finding and the agency’s Greenhouse Gas Vehicle Standards, urging the agency against the rollback. C2ES concludes that repealing standards would cost Americans billions of dollars in climate damage, lost health benefits, and lost vehicle ownership-related savings per EPA’s own previous analysis. The comments also outline severe economic and public health risks associated with EPA’s proposed action.

Additionally, the comments emphasize the significance of U.S. emissions from the transportation sector under the Clean Air Act, which require smart, well-designed regulation, contrary to EPA’s justification of the proposed rescission.

To speak with a C2ES expert about the comments, contact Tim Carroll at press@c2es.org.

C2ES experts developed these comments with input from the private sector and additional external partners. In the comments, C2ES experts highlight the indisputable science and evidence of human-induced climate change and its negative impacts, a body of data that has only grown in size and credibility since the endangerment finding was issued in 2009. The experts also note that the agency’s proposal ignores historical precedent and the Clean Air Act’s own directive to regulate sources that contribute to air pollution, such as vehicle tailpipe emissions.

C2ES concludes by warning EPA of the risks to U.S. economic and national security and the health and wellbeing of Americans:

“Our nation’s economic well-being and security depend on a safe and stable climate. By ignoring that reality, EPA has abdicated its responsibility to protect the public health and welfare—and taken steps that, if finalized, will lead to a less prosperous America. C2ES calls on EPA to continue its mandated role in safeguarding the public’s wellbeing by upholding the Endangerment Finding and maintaining greenhouse gas vehicle standards under CAA section 202(a). Repeal would be scientifically unfounded, legally unjustified, economically harmful, and ethically indefensible.”

The comments also state:

“Worsening air quality from uncontrolled wildfires impacts respiratory and cardiovascular conditions, hundreds of thousands of acres of farmland have had to be fallowed in the Southwest due to drought, historic flooding—from Texas to Kentucky to Vermont—and hurricanes and tropical storms along the Gulf Coast and Eastern seaboard have led to lives cut short, millions of dollars of lost wages, and trillions of dollars of damage to property and the environment.

“Nationwide, home insurance rates are increasing 8.7 percent faster than the rate of inflation, with homeowners in high climate-risk regions like southern California and Florida seeing much steeper rate hikes, or being unable to acquire home insurance at all. These costs demonstrate that a finding of endangerment for GHGs is warranted, and is even more relevant today than it was when the Finding was made in 2009.” 

The comments go on to argue rescission would harm U.S. competitiveness and manufacturing leadership.

U.S. greenhouse gas vehicle standards are not just a regulatory backstop for greenhouse gas emissions; they are also a strategic enabler of U.S. automaker competitiveness:

“Retreating now would signal regulatory back-pedaling just as peers and competitors worldwide are consolidating advantages in advanced batteries, electric drivetrains, and high-efficiency internal combustion engine (ICE) components, raising the risk that domestic suppliers miss scale economies, export opportunities, and workforce development gains captured by jurisdictions with clearer standards.”

Read the full comments from C2ES here. ​​​​​​​

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These comments were submitted on September 19, 2025. 

Key Points

• Scientific analysis and direct observation demonstrate that U.S. Environmental Protection Agency’s (EPA) Endangerment Finding is even more valid today than it was in 2009.
• The recently released Department of Energy Climate Working Group report was not prepared in accordance with scientific standards for the federal government and cannot be used to justify a rescission of the Endangerment Finding.
• Growing concentrations of greenhouse gases are directly impacting American’s health and welfare by increasing the severity and cost of climate impacts experienced by communities around the United States.
• Reducing emissions from the U.S. transportation sector—the largest domestic emitter of greenhouse gases—is within the EPA’s authority to regulate under the Clean Air Act and will deliver hundreds of billions of dollars in net economic benefits by measurably reducing the impacts of climate change.
• Rescission of the Endangerment Finding would be costly for stakeholders—including automakers, technology developers, and state and local governments—who have developed reliance interests around the current greenhouse gas regulatory framework that has been law for over 15 years.
• Based on its historical emissions and its dominant role in the global economy, the United States has both an obligation and a strategic imperative to act conscientiously today by minimizing future greenhouse gas pollution. A safe and stable climate underpins U.S. economic wellbeing and national security.

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Existing tax credits modified in the recently passed One Big Beautiful Bill Act of 2025 (OBBBA) are about to negatively impact the domestic automotive industry – a major economic driver and job creator. Just as traditional automotive manufacturers were accelerating work to build out electric vehicle (EV) supply chains, the OBBBA phases out existing tax incentives, including the clean vehicle tax credit (30D) and the advanced manufacturing credit (45X).  

These tax credits helped catalyze significant job creation across the industry. As of June 2025, an estimated 62,700 jobs were created, and a total of $48.3 billion was invested in the manufacturing of batteries, in part due to 45X. Announced investments of $41.7 billion and more than 72,000 jobs are linked to facilities producing EVs and batteries eligible under the 30D tax credit.  

This analysis breaks down the 30D and 45X tax credits, how recent changes to these credits might influence the U.S. automotive industry, and a potential path forward. 

What are the 30D and 45X tax credits?  

The 30D and 45X tax credits are key federal incentives that were signed into law in 2022 to support a robust clean energy manufacturing ecosystem in the United States.  

The 30D credit offers eligible buyers of new clean vehicles up to $7,500 in savings. Although most EVs are cheaper to own over the course of their lifetime than their gas-powered counterparts, they tend to be more expensive up front. This tax credit was designed to help offset the higher cost of new electric vehicles, making them more affordable for Americans at the time of purchase. Starting in 2024, there are new eligibility requirements for clean vehicles; they cannot contain battery components that are assembled by a specified foreign entity, meaning that to receive the 30D tax credit, components from foreign countries that threaten U.S. national security cannot be used in eligible EV production.  

The 45X tax credit supports the production of America’s supply of battery cells and critical minerals crucial for EV batteries, such as lithium, cobalt, and nickel. It also supports the domestic production of the components of clean energy technologies, such as solar and wind. It offers producers of eligible battery cells a credit of $35 per kilowatt-hour (kWh) of maximum capacity. The 45X credit also provides producers with a 10percent credit on costs incurred while producing critical minerals to the required purity levels.  

Why 30D and 45X Matter  

The 30D and 45X tax credits are crucial to supporting the global competitiveness of the American automotive industry. Without the incentives, the American EV market will continue to lag far behind foreign competitors like China.  

The 30D tax credit is a central driver of EV affordability, domestic job growth, and reduced reliance on specified foreign entities. Through its domestic content requirement, it incentivizes the domestic production of EV components, encourages investment in the domestic EV supply chain, and helps ensure that consumers who want to go electric can buy American-made vehicles.  

The 45X tax credit is crucial in supporting American manufacturing of battery materials, strengthening domestic energy security, creating U.S. jobs, and accelerating investment in American communities. It lowers the costs of production to help domestic producers compete with mature markets that have lower production costs, such as China. It also provides a tax incentive to drive growth in domestic manufacturing of battery components and the refining or recycling of critical minerals.   

The credits are intended to operate in tandem: 30D makes American-made EVs more affordable for consumers while 45X makes it cheaper to build batteries domestically, which also makes EVs more affordable. Together, 30D and 45X are crucial to supporting the domestic EV market. 

OBBBA Changes to 30D & 45X 

Under the recently passed OBBBA, the 30D tax credit will now sunset on September 30, 2025 – seven years earlier than previously planned in the IRA. This will impact the EV market and its domestically produced materials significantly. Repealing 30D could: 

• Reduce the ability of consumers to buy EVs, dropping market demand as EV prices rise,  

• Increase risks to the domestic battery supply chain as the domestic and global industry becomes more reliant on cheaper, foreign EV components, and  

• Decrease domestic investment and job creation as it becomes more expensive to establish U.S.-based EV supply chains. 

As for 45X, the OBBBA limits credit use until certain Foreign Entities of Concern (FEOC) requirements are met. FEOC rules apply at two levels: the foreign taxpayer level (prohibiting companies based in China, Russia, Iran, and North Korea from claiming the credit) and the product level (prohibiting a percentage of components sourced from these same countries). Beginning in 2027, integrated components will only qualify for the tax credit if they’re built into another element at the same facility, sold to an unrelated buyer, and made with at least 60 percent U.S.-sourced materials. 

 The new FEOC rules are expected to: 

• Ensure prohibited foreign entities (PFEs) cannot claim the credit: meaning that if a company is owned or controlled by a PFE, it is not eligible for the credit 

• Restrict material assistance from PFEs: companies are limited in purchasing specified amounts of key minerals, components, or materials from foreign entities. 

• Restrict licensing agreements with PFEs: meaning that companies can’t use technology or patents licensed from FEOCs in projects claiming the credit. 

• Restrict financial arrangements with PFEs: companies are limited in establishing specific funding or investment arrangements with specified foreign entities. 

The new FEOC rules impose higher upfront costs on EV supply chain investment, encourage investors to relocate to markets outside of the United States, and complicate credit adoption, creating an uncertain environment for the domestic battery supply chain. Shortening the runway for 30D —which may lead to ceding market share to foreign vehicle manufacturers—and tightening 45X requirements hinder both the supply and demand sides of EVs in America.  

The Path Forward  

Despite the obstacles that the revised tax credits will bring, there are still ways to navigate future challenges. For example:  

• States can enact clean energy manufacturing policies to support EV adoption 

• The U.S. Department of Treasury can work with industry to streamline FEOC compliance guidance to support continued 45X tax credit adoption   

• Key players across the industry can continue to strengthen regional coordination through dialogue.  

Ensuring holistic support for the U.S. battery supply chain helps meet the rising demand for advanced energy technologies while ensuring supply chains remain secure, domestic, and globally competitive. C2ES’s Regional Clean Economies Initiative is working to bring together businesses, policymakers, and community members in the Southeast to explore scalable solutions to support the domestic battery supply chain.  

The post The 30D & 45X Tax Credits Explained: What’s at Stake for the U.S. Clean Energy Manufacturing and EV Supply Chains appeared first on Center for Climate and Energy Solutions.

Ten Years on From Paris: Does the UN Climate Regime Need Reform?

Mon, Sept 22nd | 2 – 3:30 PM ET

Attend in Person | Join Virtually

​Join C2ES for a panel discussion that will examine how the United Nations’ broader architecture, across the UNFCCC and beyond, can be leveraged to support the evolution, particularly in the context of intensifying climate risks, shifting geopolitical dynamics, and the growing pressure of financial constraints, including ongoing UN budget cuts. As demands on the multilateral system grow, so too must its ability to deliver.

From Scopes to Systems: Reimagining Climate Action for the Built Environment

Thurs, Sept. 25th | 12 – 1:30 PM ET

Register

​Meaningful climate action is about translating ambition into tangible outcomes. Join C2ES and AECOM for an engaging session exploring cross-sector collaboration to better plan, design, construct, and account for, low-carbon buildings and transportation systems as part of broader corporate efforts to reach climate goals.

​The session will start off with a panel discussion featuring key stakeholders including building and infrastructure owners, planners and designers across building, transportation and infrastructure sectors. The panel will be followed by small group discussions on what new opportunities for carbon reduction emerge when we move beyond an organizational view—focused on Scope 1–3 emissions—to a systems-based, collaborative approach that emphasizes what we can control and influence across the built environment, and how we collectively account for it.

Emerging Best Practices for Net Zero Transition Plan Engagement Investor Feedback Session with Breakfast

Thurs, Sept. 25th | 9 – 11 AM ET

Register your interest

This “closed-door” session will provide a forum for investors to exchange insights and identify emerging best practices for investor engagement on climate transition planning, a timely and growing priority for investors. The event will feature investor perspectives on key successes, challenges, and opportunities within these engagements, including insights from Andrea Ranger, Director of Shareholder Advocacy at Trillium Asset Management. It will also highlight leading use cases for the newly updated Transition Plan Index tools to deepen engagements and drive impact.

More Opportunities to Connect with C2ES

Climate Leaders Ring the Opening Bell at the Building the Future Summit

Mon, Sept 22nd

Nasdaq will kick off New York Climate Week with an Opening Bell Ceremony convening forward-thinking leaders, including C2ES President Nat Keohane, tackling the future of the climate economy. The third annual Building the Future Summit examines systems innovation while spotlighting energy resilience, reindustrialization, nature-based innovation, and sustainability. It brings together a high density of visionary leaders, institutional investors, heads of state, and corporate executives.

AI for Real: Powering the Energy Shift

Tues, Sept 23rd

The advent of AI is revolutionizing the energy conversation, transforming power consumption and unleashing unprecedented potential for optimization and efficiency. On September 23, Widehall, in partnership with Siemens, will be at Climate Week in NYC, bringing together the brightest minds in AI and energy. C2ES President Nat Keohane will speak at this event intended to examine the delicate balancing act required to harness AI’s transformative benefits while managing energy usage. This event will be livestreamed.

Watch the Livestream

COP30: The Road from Baku to Belém

Thurs, Sept 25th

DLA Piper, which has represented developing countries in multilateral environmental negotiations for more than a decade, is hosting senior policy leaders from the Center for Climate and Energy Solutions, CDP, and the International Chamber of Commerce to examine the trajectory of multilateral climate action from COP 29 in Baku, Azerbaijan, to COP 30 in Belém, Brazil, and how countries and corporate actions can help keep the Paris Agreement’s temperature goals within reach.

C2ES VP for International Strategies, Kaveh Guilanpour, alongside panelists will discuss the emerging negotiating agenda, implementing the outcome of the first Global Stocktake, and the dynamics likely to shape climate diplomacy in 2025 and beyond. Participants will hear of the challenges and opportunities governments and the private sector face in driving decarbonization, strengthening resilience, and delivering a just transition.

Request to Attend

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2025 is shaping up to be a historic year for climate impacts, with large wildfires raging and blowing smoke across the United States and the world. Smoke from one of Canada’s worst wildfire seasons in history has blanketed the Midwest and the East Coast and is only expected to worsen. Against this backdrop, the case for building resilience to these fires couldn’t be stronger, and the solutions and goals below must be deployed to better protect communities.

The U.S. is facing a worsening wildfire crisis driven by rising temperatures, prolonged droughts, and outdated land and building practices. Since 2005, wildfires have destroyed over 129,000 buildings nationwide. According to the U.S. Congress Joint Economic Committee, wildfires now cost the U.S. economy an estimated $400 to $900 billion annually. That cost includes health impacts, hospital stays, lost workdays, and even premature deaths as more people are exposed to the harmful effects of fire and smoke.

As of today, the U.S. National Interagency Fire Center states on its website: “There are currently 47 large fires burning across nine geographic areas nationwide. A total of 15,453 firefighters and support personnel are assigned to incidents, including 307 crews, 736 engines, and 102 helicopters. So far in 2025, 44,130 wildfires have been reported, for a total acreage of 3,766,597.”

Wildfire: A Threat Multiplier

The true cost of wildfire to the U.S. economy is vast, easily underestimated, and growing. A 2022 report highlights that wildfire-related costs go far beyond suppression—encompassing direct damages to timber, infrastructure, and homes, as well as indirect losses such as degraded water quality, post-fire flooding, public health impacts, and economic disruption.

This crisis is exacerbated by continued development in the Wildland-Urban Interface (WUI). In this area, human development and infrastructure intermingle with wildland vegetation, creating higher wildfire risks and challenges in managing these risks. Warming is causing more frequent strong winds and dry air, expanding fire-prone areas beyond the WUI to grasslands, rainforests, and urban environments. The 2018 Camp Fire, 2021 Marshall Fire, 2023 Maui Fire, and 2025 Los Angeles fires demonstrate the devastating consequences of increasing wildfire risk to U.S. homes and businesses.

While recovery is difficult for any major disruption, the Government Accountability Office testified that wildfire recovery is 10 times harder than that of floods, hurricanes, and other disasters, due to the extent of damage to land and homes. Meanwhile, the return on investment (ROI) for proactive mitigation, including fuel treatments and home hardening, is substantial and well-documented. In its 2024 report, the U.S. Chamber of Commerce found that every $1 invested in resilience and disaster preparedness saves $13 in economic impact, damage, and cleanup costs after the event.

Government at all levels plays a crucial role in supporting and coordinating wildfire mitigation and preparedness for the benefit of community safety, economic security, public health, and forest health.

Why Federal Policy Matters

Federal spending on wildfire response doubled between 2011 and 2020 due to climate change, WUI development, and decades of accumulated fire deficit. Despite recent historic investments—over $20 billion through the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA)—federal policy still disproportionately focuses on suppression, with some Members of Congress even advocating to return to outdated strategies. This includes the “10AM rule,” a policy adopted by the Forest Service in 1935 requiring the extinguishing of any fire by 10 a.m. the day after it was reported. While this protected timber and communities in the short term, it led to a buildup of combustible vegetation, known as “fuel,” intensifying the severity of future fires. This created the “wildfire paradox” where successful suppression can worsen long-term wildfire risk.

The 2023 Wildland Fire Mitigation and Management Commission offered 148 federal policy recommendations to transition from reactive response to proactive resilience. Building on these through the Climate Resilient Communities Accelerator, C2ES is working to increase community resilience to wildfires through on-the-ground engagement in Colorado and beyond. After consulting with 27 local, national, and business leaders, C2ES offers five goals for federal wildfire policy that reflect opportunity for significant impact and broad support.

Five Goals for Federal Policy

Through federal leadership, we can reduce the intensity and cost of future wildfires, protect infrastructure, homes, and lives, and equip communities with the tools they need for long-term resilience. To achieve this, C2ES has identified five interconnected policy goals, each paired with an actionable recommendation to drive meaningful progress.

• Secure Power Systems
• Strong Infrastructure
• Cleaner Air
• Safe and Skilled Workforce
• Healthy Lands

Goal #1: Secure Power Systems

Electric utilities are critical to maintaining essential services during disasters, yet they are increasingly threatened by wildfires and can also be a source of ignition. However, the lack of consistent regulatory guidance has created a patchwork of state-level requirements and utility-driven wildfire mitigation plans, with no standardized best practices for permitting or implementing risk reduction work.

Recommendation: Empower utilities with clear guidance and industry standards for wildfire readiness to streamline planning, reduce costs, and improve coordination among utilities—especially smaller providers and co-ops—state energy offices, and land management agencies, helping to build a more reliable and fire-resilient grid. Invest in research and development (R&D) partnerships for utilities to pilot advanced fire prediction technologies, such as Xcel Energy’s use of AI to detect and mitigate wildfires in Texas.

Goal #2: Strong Infrastructure

Proactive mitigation measures across the built environment help protect communities from wildfire by reducing risks to homes, infrastructure, and critical services. Implementing comprehensive fire-resilient building practices, including creating buffers around buildings, hardening exteriors, and using noncombustible materials, offers promising solutions in high-risk areas. This year, for example, Colorado adopted a Wildfire Resiliency Code and passed a new law requiring premium discounts or underwriting adjustments for homeowners who implement proven mitigation strategies. The state also supports resilience hubs through an annual technical assistance and grant program.

Recommendation: Remove financial barriers and incentivize local risk-reduction efforts, including faster deployment of post-fire resources and enabling wildfire-ready building codes and construction. Federal programs can support wildfire-resilient building codes and land use policies, which are adopted at the local and state levels and include the International Wildland-Urban Interface Code. Wildfire Prepared is a system of mitigation actions that addresses both the structure and defensible space (Wildfire Prepared Home and Home Plus) and the neighborhood (Wildfire Prepared Neighborhood) from the Insurance Institute for Business and Home Safety (IBHS), which is receiving growing recognition from insurers. Investments can also support resilience hubs and microgrids at critical and community-serving facilities that can augment local emergency response capacity.

Goal #3: Cleaner Air

Communities across the U.S. are increasingly experiencing harmful smoke events, both from unplanned wildfires and the growing use of prescribed fire. While prescribed burns are a necessary tool for long-term wildfire risk reduction, they can still pose short-term health risks if not carefully managed. Wildfire smoke disproportionately harms vulnerable populations, including seniors, children, outdoor workers, people with asthma or cardiovascular disease, and communities lacking access to healthcare or safe indoor environments. Although Tribal, state, and local public health agencies often have strong community ties and local knowledge, they lack sufficient capacity, training, and resources to prepare for and respond to these growing health threats.

Recommendation: Promote smoke-ready communities and minimize the health impacts of both wildfires and prescribed fire. Federal and state agencies must coordinate to align land management and air quality goals while ensuring communities are equipped to manage smoke exposure. This includes training healthcare providers, investing in air quality improvements, supporting public outreach and education, and developing best practices for risk reduction—especially in high-risk and underserved areas.

Goal #4: Safe and Skilled Workforce

Wildfire is no longer just a land management issue—it requires a cross-sector workforce that integrates fire response, proactive fuels reduction, forest and land stewardship, emergency services, planning, and public health to meet the complexity of today’s challenges. As wildfires grow more intense and seasons extend, workforce demand is surging while existing responders face burnout, mental health strain, and insufficient support. While state and local fire services, the private sector, and non-federal responders are critical to both proactive mitigation and emergency response, they remain largely disconnected from federal wildfire operations. At the same time, the federal firefighting workforce—especially within the U.S. Forest Service—is under pressure from hiring freezes, inadequate pay, and limited training opportunities. With only one prescribed fire training center in the country and the expiration of federal firefighter pay increases, the ability to attract, train, and retain qualified personnel is rapidly eroding.

Recommendation: Strengthen and engage the non-federal workforce while stabilizing and investing in federal firefighting and mitigation teams. Increase capacity for the U.S. Fire Administration to expand community-based training, foster coordination between local and federal responders, and promote fire-adapted communities. Programs like Colorado’s Strategic Wildfire Action Program (COSWAP) demonstrate how state-federal partnerships can enhance workforce development and proactive mitigation. Simultaneously, Congress must address compensation gaps, improve benefits, and expand training infrastructure—such as additional prescribed fire centers—to meet the growing demand for skilled wildfire professionals and ensure a sustainable, high-quality workforce across sectors, including public health.

Goal #5: Healthy Lands

Existing federal performance metrics, such as acres treated or timber volume harvested, fail to capture the full range of outcomes needed to address wildfire risk in today’s context. Furthermore, because wildfire impacts cross state, Tribal, federal, and private lands, collaboration among diverse actors is essential to ensure forward-thinking stewardship of important lands. However, fragmented authorities, differing regulations, and inconsistent management capacities often hinder effective strategies. Multi-benefit land management approaches—those that integrate forest health, community safety, and resource protection—are more effective but remain difficult to implement without structural support.

Recommendation: Update land management performance metrics and support landscape-scale solutions to reflect desired outcomes that improve both forest and community health. There is widespread agreement that new outcome-based metrics are needed, such as the number of protected assets, communities protected, local partnerships, watershed conditions, and healthy forests and rangeland. At the same time, we must empower landscape-scale action between state, local, and Tribal partners for more effective wildfire risk reduction across jurisdictions, including prescribed burns and new uses of woody biomass. For example, capacity-building programs and “forests to faucets” initiatives that span multiple jurisdictions, such as Coalitions & Collaboratives, the Northern Colorado Fireshed Collaborative, and the Peaks to People Water Fund, should be supported and replicated.

A Path Forward

These five policy goals reflect a holistic and broadly supported approach to wildfire resilience, advancing community safety, economic stability, and forest health. Through federal leadership, we can empower local communities to implement solutions that fit their unique needs, while simplifying programs to reduce barriers, expand access, and expedite the processes for both planning and recovery.

Realistically, addressing these goals will require investments in funding and staff capacity. First, we must maximize the impact of existing funds, protecting programs that have proven beneficial to communities and businesses, while continuing to build a case for future investments.

Policymakers, businesses, and community leaders all have a role to play in ensuring the nation is better prepared for the wildfire risks of today and tomorrow. Community exchange can speed recovery by sharing hard-earned lessons, as Superior, CO’s recovery leaders did—drawing on their experience from the 2021 Marshall Fire to help shape Project Recovery: Rebuilding Los Angeles After The January 2025 Wildfires.

C2ES will continue to support community and cross-sector partnerships and advance public policy solutions as we expand the Climate Resilient Communities Accelerator to new vulnerable regions across the United States.

The post Building Resilience as Wildfires Worsen: Five Federal Policy Goals appeared first on Center for Climate and Energy Solutions.

The proposed repeal hinges on a critical question: do emissions from U.S. power plants contribute “significantly” to the problem of climate change? To most scientists, economists and policymakers, the answer is an unequivocal “yes.”  

In its proposed repeal, EPA suggests that the U.S. power sector’s current 3 percent contribution of total greenhouse gas emissions “may not be a significant contribution to the GHG concentrations in the atmosphere.” The main rationale EPA offers for its judgment is that U.S. power sector emissions made up 5.5 percent of total global greenhouse gas emissions in 2005 and in 2022 comprised 3 percent of total global greenhouse gas emissions. EPA provides no evidence for its argument, which seems to rest solely on the observation that 3 is smaller than 5.5 and much smaller than 100. For context, 3 percent of U.S. GDP is $870 billion, hardly an insignificant dollar amount.  

Notably, while U.S. power sector emissions have fallen 36 percent (2005 – 2022), global emissions have grown by 30 percent over the same period. Therefore, 45 percent of the “decline” in U.S. power sector emissions relative to total global greenhouse gas emissions is due to the fact that global emissions have increased by 13.2 billion metric tons per year since 2005. 

Far from insignificant, the numbers are massive 

In 2024, the U.S. power sector emitted 1,427 million metric tons of carbon dioxide, the second largest U.S. source by sector. This amount exceeds the combined economywide emissions of Germany, France, and the United Kingdom. Indeed, if the U.S. power sector were its own country, it would be the sixth largest emitter of carbon pollution in the world, after only China, the rest of the U.S., India, the European Union, and Russia.   

Moreover, other sectors with smaller global shares—like aviation (1.6 percent), international shipping (1.9 percent), and aluminum production (1.9 percent)—are widely acknowledged as significant sources of climate pollution, with international efforts underway to reduce their emissions. Suggesting that 3 percent isn’t significant enough to warrant regulation sets a dangerously low bar. If we followed this logic, nearly every country and sector in the world would be excused from climate action. Climate change is a collective problem. Every meaningful source must be addressed—especially one as large and controllable as the U.S. power sector. 

The economic case: pollution isn’t free 

There’s also a compelling economic argument for keeping strong carbon standards in place. Every ton of carbon dioxide emitted into the atmosphere contributes to the rising costs of climate change—from damaged infrastructure and lost agricultural productivity to increased healthcare costs and disaster recovery. 

Economists use a measure called the Social Cost of Carbon (SCC) to quantify these damages. The latest estimate from leading experts puts the central value of the SCC at around $190 per ton of carbon dioxide. 

Using that value, the 1.4 billion tons of carbon dioxide emitted by the U.S. power sector in 2024 would result in more than $271 billion in annual economic damage. Even using a much lower SCC value of just $1 per ton—a figure used by the first Trump administration—the damages still exceed $1.4 billion per year. That’s seven times the threshold the federal government (i.e., Office of Information and Regulatory Affairs) uses to define a regulation as “economically significant.” 

According to the EPA’s own analysis, repealing the standards would increase annual emissions by 123 million tons in 2035. That translates to $23 billion in additional damages every year if the repeal goes forward. 

Over the past five decades, the U.S. power sector has released nearly 96 billion tons of carbon dioxide into the atmosphere, much of which remains in the atmosphere today and is a significant contributor to climate and health impacts (e.g., more frequent and intense heatwaves, droughts, floods, wildfires, ecosystem disruption, sea level rise, ocean acidification, heat-related morbidity and mortality) that we are currently experiencing. 

Continued emission declines aren’t guaranteed 

Even with the welcome growth of clean electricity sources like wind and solar, today, more than 60 percent of U.S. electricity still comes from natural gas- and coal-fired power plants. And while emissions have declined in recent years due to coal plant retirements and a shift toward more natural gas and renewables, this trend is not guaranteed to continue. In fact, it may be reversing. 

For the first time in decades, electricity demand in the United States is rising. New data center growth driven by the rapid expansion of artificial intelligence, a manufacturing resurgence, and a growing number of electric vehicles are all pushing consumption higher. Experts project a 15–25 percent increase in electricity demand by 2030, and possibly 50–80 percent by mid-century.  

Solar power is being deployed at record levels, and mothballed nuclear power plants are being restarted on the positive side; however, increasing electricity demand is also putting pressure on utilities to keep older fossil fuel plants online longer and even build new ones. More than 4 gigawatts (GW) of new natural gas plants are under construction, with another 14 GW planned by 2028. A slate of coal plant retirements are being reconsidered, and in many cases are being postponed for years in light of growing demand. Without enforceable carbon standards, we risk a long-term increase in emissions just when we should be doing everything possible to reduce them. 

U.S. leadership matters—at home and abroad 

The United States has long been a global leader in energy innovation and environmental policy. Walking further away from that leadership now would send the wrong signal at a time when the rest of the world is watching—and many countries are stepping up their own climate ambitions.   

Strong domestic standards also help U.S. companies remain competitive in global markets. As more countries implement border carbon adjustments (BCAs)—tariffs on goods from countries with weaker climate policies—American industries could face trade disadvantages if our emissions rise. Since the industrial sector is the largest user of electricity, a higher carbon intensity in our power sector could make U.S. goods less attractive abroad in the long run. Conversely, a clean, reliable, and well-regulated power sector gives American businesses an edge—especially as the world pivots toward low-carbon technologies. 

Investors need predictability, not whiplash 

Energy infrastructure isn’t built overnight. Power plants cost hundreds of millions of dollars and operate for decades. Investors need clear, consistent policies to plan for the future. Repealing carbon standards creates uncertainty, raises risks, and undermines confidence in long-term investments in clean power. As C2ES notes, balanced regulations are not only essential for cutting emissions—they’re also vital for ensuring regulatory stability, market confidence, and energy sector resilience. 

A time to lead, not retreat 

EPA’s proposed repeal of the Carbon Pollution Standards is out of step with science, economics, and global trends. 

 The impacts of climate change are already costing Americans dearly. The tools to reduce emissions are available. And the responsibility—and opportunity—for the United States to lead has never been clearer. 

Reasonable, practical, and forward-looking policies are how we protect public health, preserve our economic edge, and ensure a sustainable energy future. That means strengthening our carbon standards—not dismantling them. 

Read the full comments from C2ES here. 

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