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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Last week saw Tropical Storm Erin rapidly intensify from a tropical storm to a Category 5 hurricane in just over 24 hours. While this storm is forecast to miss the coastline by hundreds of miles, the intensity of this hurricane is expected to cause severe impacts like storm surge and flooding, strong winds, rip currents and dangerous surf across the entire east coast. 

This level of rapid intensification is becoming more common as the climate warms. Tropical cyclone intensification is in part a result of rising ocean temperatures associated with climate change, which serve as the fuel for these complex storm systems. Warmer sea surface temperatures are tied to the rapid intensification, which, in addition to posing a greater threat to communities and infrastructure, can also make forecasting and early warning systems more challenging to deploy.  

Not only is the intensity of hurricanes and tropical cyclones increasing with a warming climate, but so too is the area at risk of impact. The expanded reach of hurricanes deeper into the continental United States—reaching farther from the coast—raises the alarm for communities not traditionally impacted by these storms. Just last year, Hurricane Helene made landfall in Florida before traveling north to impact communities in western North Carolina and eastern Tennessee, leaving a path of destruction more than 500 miles from its initial landfall. 

Hurricanes and tropical cyclones have short- and long-term impacts on communities and regional economies. In the immediate, strong storms cause significant damage through high power winds, heavy rain, and flooding, impacting homes, commercial buildings, schools, and other essential spaces. Storms also disrupt the power grid, contaminate drinking water, and complicate evacuation and emergency response efforts by destroying road and bridge infrastructure. In the long term, damaged infrastructure can slow down recovery efforts and keep local economies in a depressed state. In the case of Hurricane Helene, the storm took the city of Asheville’s water treatment plant offline, contaminating the city’s water supply and depriving the residents of clean water for seven weeks.  

Some communities may take decades to recover—homes in New Orleans, Louisiana, are still boarded up from Hurricane Katrina’s landfall two decades ago. Aside from physical impacts, storms also pose a risk to the mental and emotional health of survivors, worsening existing conditions and triggering increased instances of major depressive disorders, general anxiety disorders, and post-traumatic stress disorders (PTSD). 

Storms like Hurricane Katrina, Helene, and Erin emphasize the need for integrated adaptation, resilience, and disaster planning. Decision-makers and planners must identify vulnerabilities across critical infrastructure, regional and local economies, and communities and neighborhoods to inform both pre- and post-disaster efforts. Many communities have responded to extreme storm events by investing in both physical and policy strategies that build resilience. These strategies include: 

• Improved Coordination and Decision-Making: The Louisiana State Legislature consolidated coastal restoration and hurricane protection responsibilities under a single government authority in 2005 in response to Hurricanes Katrina and Rita; the Coastal Protection and Restoration Authority now oversees nearly $2 billion in projects designed to improve coastal resilience, including by mitigating extreme storm risks.  

• Investments in Nature-Based Solutions for Resilience: In 2022, Florida established the Resilient Florida Grants Program to fund projects that enhance natural systems to help mitigate flood impacts, improve water quality and prevent coastal erosion. Nature-based climate resilience solutions like those supported by the Resilient Florida Grants provide multiple benefits and help stretch the impact of necessary, but limited, funding.  

• Physical Infrastructure and Built Environment Upgrades: At the local level, communities are investing in grid resilience efforts to decrease impacts from storms on energy infrastructure systems, such as burying power lines or exploring community owned and decentralized power models. Boston, Massachusetts, Kitty Hawk, North Carolina, and Eastport, Maine have all upgraded grid infrastructure to be able to maintain power at critical nodes in preparation for storm impacts.   

While residents in Asheville struggled with access to clean water after Hurricane Helene, the damage could have been much worse if not for smart resilience planning. In 2021, the city completed construction of an auxiliary spillway for the river’s dam. During the storm, the spillway worked as intended, ultimately preventing the dam from failing outright according to city officials.  

As more communities across the United States experience the worsening impacts of climate change, it is increasingly important to invest in solutions that produce co-benefits, like upgraded infrastructure and improved water quality, delivering high value for low cost. Multi-benefit climate resilience solutions can deliver value to businesses, communities, and municipalities by both reducing risk and improving preparedness, thereby increasing a community’s capacity to respond in the case of an extreme event.  

Robust preparation and response systems can be lifelines even when a storm doesn’t make a direct hit like Hurricane Erin. Proactive steps to build resilience to hurricanes and tropical cyclones can help ensure that when storms do make landfall, communities and businesses are equipped. 

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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 event was a full-day convening with detailed sessions and speakers that laid the context for the region, the impacts, and informed the solution-oriented afternoon. The day began with the Washington State Climatologist presenting on the current and future projected extreme heat and wildfire smoke, after which participants were invited to share personal and organizational impacts from these hazards. In between collaborative and thoughtful discussions, participants heard from a range of speakers from local governments and nonprofits, many of whom called upon participants to think deeply about the impacts of this work on the communities around them and how we can protect the most vulnerable of us all as we advance work around climate resilience.

These valuable presentations and discussions culminated in a visioning exercise that allowed participants not only to envision what a climate-resilient region looks like, but also to take all the previous conversations and think through potential strategies to reach those visions. Participants then collaboratively developed and ideated strategies that can address these climate hazards and their associated impacts. Knowing that these two hazards impact every sector of the economy and communities of the region, there was a focus on developing cross-sectoral strategies to create multiple benefits for the region.

Some examples of key action areas and strategies proposed by participants include:

• Heat mapping across the region to identify areas most impacted by these hazards
• Creating a framework for best practices in funding for resilience work
• Developing passive cooling design guidelines for homes, recreational buildings, offices, and other spaces
• Investing in resilience hubs and cooling centers with extended or potentially overnight hours during peak heat periods
• Creating a workforce development program for HVAC technicians with specific training on combined AC smoke ventilation systems

These are just a handful of over 100 strategies that were identified in the event. This sample of strategies, if implemented, would have a range of potential co-benefits for the region, maximizing the limited resources available for resilience work.

No one sector can solve the climate crisis, and no one sector can build resilience alone. It will take collaborative processes with diverse sets of stakeholders and participants to produce the best possible outcomes for the people and communities we live, work, and serve in. As the resilience field evolves, stakeholder convenings like this one are increasingly vital for developing new and innovative ways to protect communities.

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