对2009年危险源认定和温室气体汽车标准的再思考（英）

Joshua Linn, Benjamin Leard, Carlos Martín, and Zachary Whitlock Public CommentSeptember 2025 September 22, 2025 Environmental Protection Agency1200 Pennsylvania Avenue NWWashington, DC 20460Attn: Docket ID No. EPA-HQ-OAR-2025-0194Submitted via:www.regulations.gov Dear Administrator Zeldin, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to theEnvironmental Protection Agency (EPA) on the proposedReconsideration of 2009 Endangerment Finding andGreenhouse Gas Vehicle Standards. RFF is a nonpartisan, independent, nonprofit research institution in Washington, DC. Its mission is to improveenvironmental, energy, and natural resource decisions through impartial economic research and policyengagement. While RFF researchers are encouraged to offer their expertise to inform policy decisions, theviews expressed here are those of the individual authors and may differ from those of other RFF experts, itsofficers, or its directors. RFF does not take positions on specific policy proposals. Several RFF experts have provided comments on the proposed rule in two categories related to our researchexpertise. These are described in detail in the accompanying response and summarized here. •C-2, regarding the scientific underpinnings of the Endangerment Finding.A preponderance of evidence since the 2009 finding confirms that greenhouse gas emissionssignificantly affect public health and welfare, and that the costs of emissions and their associatedeconomic effects outweigh the benefits across a range of sectors. •C-21, regarding analysis of the proposal’s overarching costs and benefits.The draft regulatory impact analysis provided for the proposal misinterprets findings from pastresearch, causing the proposal to overstate the net benefits of revoking vehicle emission standards.Several assumptions about manufacturer behavior and market outcomes, such as the relationshipbetween compliance costs and regulatory stringency, remain unclear or unjustified in that analysis,causing the proposal’s approach to depart from historical methods for estimating vehicle technologycosts without explanation. Further, the proposal’s analysis relies on obsolete data that areinconsistent with recent market information. RFF researchers’ estimates are in line with previous EPArule estimates. Our comments focus on our areas of economic and policy expertise, and not the legal questions proposed; weacknowledge that our empirical work may be cited by others, as it has in the past. If you have any questions or would like additional information, please contact Liam Burke atlburke@rff.org. Sincerely, Carlos E. MartínVice President for Research and Policy Engagement, Resources for the Future Comment on the Reconsideration of 2009 EndangermentFinding and Greenhouse Gas Vehicle Standards Dr.Joshua Linn, Senior Fellow,jlinn@rff.orgDr. Benjamin Leard, University Fellow,leard@rff.orgDr.Carlos Martín, Vice President for Research and Policy Engagement,cmartin@rff.orgZachary Whitlock, Senior Research Analyst,zwhitlock@rff.org Resources for the Future C-2 Comment The proposal asserts that the scientific underpinnings of the Endangerment Finding are weaker thanpreviously believed and not supported by the body of scholarship since 2009. NASEM (2025) provides themost recent review of the literature regarding greenhouse gas (GHG) emissions’ effects on public health andwelfare. The public effects covered in NASEM (2025) include local and regional exposures. A repeal of thesefindings has broad implications (Elkerbout 2025). The thorough review of the scientific literature provided inNASEM (2025), as well as the conclusions provided, stand in direct contrast to the EPA’s proposal languageand references. In its proposal, the EPA cites the US Department of Energy's Climate Working Group (CWG) reportextensively, titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the US Climate” (CWG 2025),to support its scientific claims on the connections between greenhouse gas emissions and public health andwelfare. NASEM (2025) demonstrates that this report is highly inaccurate in its assessment of the relatedliterature. The proposal and CWG (2025) are also inaccurate with respect to stated assumptions andconclusions regarding economic impacts associated with the effects on human health and welfare. Asignificant body of peer-reviewed empirical work concludes that greenhouse gas emissions’ effects on healthand other societal costs outweigh the benefits from those emissions (NASEM 2017). CWG (2025) incorrectly interprets several recent economic studies (Prest 2025). For example, the reportincorrectly cites Newell, Prest, and Sexton (2025) when it claims that the net temperature effect on GDP “islikely positive but too uncertain to distinguish from zero.” Newell, Prest, and Sexton (2025) find that thelikelihood of a negative impact on GDP is 92 percent, or an 8 percent likelihood of a negative value. CWG(2025) also in