未来能源研究所-对2009年危险源认定和温室气体汽车标准的再思考（英）

Comment on the Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards Joshua Linn, Benjamin Leard, Carlos Martín, and Zachary Whitlock Public Comment September 2025 1616 P ST. NW, SUITE 600, WASHINGTON, DC 20036 • 202.328.5000 • WWW.RFF.ORG September 22, 2025 Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 Attn: Docket ID No. EPA-HQ-OAR-2025-0194 Submitted via: www.regulations.gov Dear Administrator Zeldin, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to the Environmental Protection Agency (EPA) on the proposed Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards. RFF is a nonpartisan, independent, nonprofit research institution in Washington, DC. Its mission is to improve environmental, energy, and natural resource decisions through impartial economic research and policy engagement. While RFF researchers are encouraged to offer their expertise to inform policy decisions, the views expressed here are those of the individual authors and may differ from those of other RFF experts, its officers, 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 research expertise. 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 emissions significantly affect public health and welfare, and that the costs of emissions and their associated economic 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 past research, causing the proposal to overstate the net benefits of revoking vehicle emission standards. Several assumptions about manufacturer behavior and market outcomes, such as the relationship between 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 technology costs without explanation. Further, the proposal’s analysis relies on obsolete data that are inconsistent with recent market information. RFF researchers’ estimates are in line with previous EPA rule estimates. Our comments focus on our areas of economic and policy expertise, and not the legal questions proposed; we acknowledge 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 at lburke@rff.org. 2 Sincerely, Carlos E. Martín Vice President for Research and Policy Engagement, Resources for the Future 3 Comm