Comment on EPA Proposal to Reconsider the 2009 Greenhouse Gas Endangerment Finding and Roll Back Emissions Reporting (Docket EPA-HQ-OAR-2025-0194)

Comment:

Edison Global Solutions strongly opposes EPA’s proposal to reconsider the 2009 Greenhouse Gas Endangerment Finding and to roll back emissions reporting requirements (Docket EPA-HQ-OAR-2025-0194). This proposal undermines decades of scientific consensus and will severely weaken the nation’s ability to protect public health. The Endangerment Finding is a cornerstone of public health protection and economic stability, ensuring that emissions reporting remains transparent and actionable. It is necessary to mitigate the escalating health, environmental, and financial costs associated with air pollution and climate change, and its continued enforcement is essential to safeguard both community health and the U.S. economy.

Transparent, accurate emissions reporting is the foundation of effective public health surveillance. State and local health departments, researchers, and communities rely on these data to monitor air quality, identify pollution hot spots, and design interventions that prevent disease (Centers for Disease Control and Prevention [CDC], 2023). Weakening or eliminating these reporting requirements would obscure the true scale of pollution, delay response to emerging hazards, and strip communities of the information they need to safeguard health (CDC, 2023).

The health consequences of reduced reporting will not be borne equally. Communities already overburdened by pollution are often low-income, rural, and communities of color that face disproportionate exposure to harmful emissions. Rolling back reporting requirements will only deepen existing health inequities by concealing risks from those most affected (Intergovernmental Panel on Climate Change [IPCC], 2022; CDC, 2023).

The 2009 Endangerment Finding is grounded in overwhelming scientific evidence that greenhouse gases endanger public health and welfare. These emissions are the primary driver of the climate variability and extreme conditions we are already experiencing, linking pollution at its source to the health harms that follow. This evidence has only strengthened over time: climate variability and extreme conditions (commonly referred to as climate change) are driving heat-related illness, respiratory disease from wildfire smoke, cardiovascular impacts from poor air quality, and the spread of vector-borne disease (IPCC, 2022; Romanello et al., 2021). To reconsider or weaken this finding is to deny both science and lived public health realities.

Weakening emissions reporting does more than obscure pollution levels, it severs the connection between emissions and their health consequences. By denying the well-established link between carbon emissions and public health, this proposal conceals responsibility from those who should bear the costs. Fossil fuel pollution already imposes enormous economic burdens on the U.S. population, costing more than $820 billion annually in health damages, with disproportionate burdens falling on vulnerable communities (NRDC, 2021). Peer-reviewed research further demonstrates that extreme heat and poor air quality increase hospital expenditures (Becker et al., 2024) and drive measurable losses in worker productivity and economic capacity across industries (Brewer et al., 2021; Han et al., 2024). While a broader discussion of climate change is outside the scope of this response, it must be emphasized that halting or rolling back data collection is antithetical to science, transparency, and the protection of American lives and health.

We strongly urge the EPA to withdraw this proposal to repeal the 2009 Greenhouse Gas Endangerment Finding in its entirety and to reaffirm its commitment to science-based, transparent emissions reporting as a non-negotiable tool of public health protection. Anything less is a step backwards that puts communities at greater risk.

Respectfully submitted,

Kathy Edison, MPH, DrPH(c)President, Edison Global Solutions

References:

Becker, D. A., Tefft, N. W., Sloan, F. A., & Yang, W. (2024). Environmental quality, extreme heat, and healthcare costs. International Journal of Environmental Research and Public Health, 21(10), 1322. https://doi.org/10.3390/ijerph21101322

Brewer, G. J., Casa, D. J., Morrissey, M. C., Quinn, T., & Williams, W. J. (2021). Impact of occupational heat stress on worker productivity and economic cost. American Journal of Industrial Medicine, 64(12), 981–988. https://doi.org/10.1002/ajim.23297

Centers for Disease Control and Prevention. (2023). Climate and health program. U.S. Department of Health and Human Services. https://www.cdc.gov/climateandhealth

Han, S., Dong, L., Weng, Y., Xiang, J., & Li, J. (2024). Heat exposure and productivity loss among construction workers: A meta-analysis. BMC Public Health, 24, 3252. https://doi.org/10.1186/s12889-024-20744-x

Intergovernmental Panel on Climate Change. (2022). Climate change 2022: Impacts, adaptation and vulnerability. Working Group II contribution to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change (H.-O. Pörtner, D.C. Roberts, M. Tignor, E.S. Poloczanska, K. Mintenbeck, A. Alegría, … B. Rama, Eds.). Cambridge University Press. https://doi.org/10.1017/9781009325844

Natural Resources Defense Council. (2021). The costs of inaction: The economic burden of fossil fuels and climate change on health in the United States. NRDC. https://www.nrdc.org/press-releases/report-health-costs-climate-change-and-fossil-fuel-pollution-tops-820-billion-year

Romanello, M., McGushin, A., Di Napoli, C., Drummond, P., Hughes, N., Jamart, L., Kennard, H., Lampard, P., Solano Rodriguez, B., Arnell, N., Ayeb-Karlsson, S., Belesova, K., Cai, W., Campbell-Lendrum, D., Capstick, S., Chambers, J., Chu, L., Ciampi, L., Dalin, C., Dasandi, N., Dasgupta, S., Davies, M., Dominguez-Salas, P., Dubrow, R., Ebi, K. L., … Hamilton, I. (2021). The 2021 report of the Lancet Countdown on health and climate change: Code red for a healthy future. The Lancet, 398(10311), 1619-1662. https://doi.org/10.1016/S0140-6736(21)01787-6