The EPA Finally Got It Right on the Endangerment Finding — And Life:Powered Helped Make It Happen

On Feb. 12, the Environmental Protection Agency finalized a rule rescinding the 2009 Greenhouse Gas Endangerment Finding — a decision the agency called the single largest deregulatory action in U.S. history. For the team at Life:Powered, this moment represents the culmination of years of research, public comment, and persistent advocacy to bring sound science and legal rigor back to environmental policy.

The original 2009 finding, issued under the Obama administration, declared that greenhouse gas emissions from motor vehicles endanger public health and welfare. That determination became the legal foundation for a cascade of sweeping regulations touching nearly every sector of the American economy. Emissions mandates pushed manufacturers toward electrification targets that would have required the majority of new cars and nearly half of trucks sold to be electric within years. Power plant rules sought to restructure how America generates electricity. Methane regulations burdened oil and gas producers.

All of it flowed from a single regulatory finding that was rushed through without the peer review required by the Administrative Procedure Act, and that relied heavily on assessments from international organizations rather than independent EPA analysis.

The costs were enormous. The regulations built on the Endangerment Finding imposed billions in compliance burdens across mining, manufacturing, transportation, construction, agriculture, and energy production — driving up prices for consumers and constraining the affordable, reliable energy that American families and businesses depend on. Life:Powered estimated that the vehicle regulations alone were costing American automakers more than $10 billion annually and rising. The EPA now estimates that rescinding these regulations will save Americans over $1.3 trillion over the next couple decades.

But the costs were only half the problem. The benefits were virtually nonexistent.

This is where Life:Powered’s research proved decisive. In our June 2025 white paper, The Materiality of U.S. CO₂ Emissions on Global Climate, Dr. Brent Bennett laid out a rigorous methodology for assessing whether any category of U.S. emissions meaningfully contributes to global temperature change. Using the IPCC’s own middle-of-the-road emissions scenario and the MAGICC climate model, we demonstrated that eliminating all future U.S. power plant CO₂ emissions would reduce global temperatures by just 0.015°C by 2050 — and eliminating all U.S. CO₂ emissions entirely would reduce temperatures by only about 0.05°C.

Not only are these changes small, but they are also well below the approximately ±0.1°C measurement error in global surface temperature data.

In other words, even the most extreme reductions in American emissions would produce changes too small to reliably measure.

The EPA’s final rule adopted this same line of reasoning. A key element of the agency’s rationale was what it termed “futility”: that eliminating all U.S. motor vehicle greenhouse gas emissions would have only a de minimis impact on global temperatures through 2100, far below any threshold that could be considered significant. The EPA specifically credited climate impact modeling submitted during the rulemaking proceeding — modeling consistent with the analysis Life:Powered and our collaborators provided in our formal comments. We are proud that our 35-page comment filing, which detailed the legal, scientific, and economic deficiencies of the original finding, helped shape the final rule.

As Dr. Bennett put it when we submitted those comments: “The EPA’s original finding failed to demonstrate that the moderate warming caused by greenhouse gas emissions is endangering public health, ignoring evidence like the fact that climate-related deaths have plummeted by 98% over the past century. We applaud the EPA for rejecting flawed climate models and speculation and returning to sound science.”

The reversal also sets up a direct legal challenge to the U.S. Supreme Court’s disastrous Massachusetts v. EPA ruling that declared greenhouse gases, which are essential to life on Earth, to be pollutants that could be regulated under the Clean Air Act. The EPA concluded that the Clean Air Act was designed to address pollutants causing local and regional harm to human health — not to serve as a vehicle for regulating globally distributed atmospheric gases.

This is the correct reading of the statute and sets up a direct avenue for the Supreme Court to overturn its prior ruling. Legal challenges have already been filed, which will set in motion the processes to bring this case before the high court in a few years.

The good news is that the Supreme Court is primed to overturn its prior precedent, as it has done in a couple of major cases in recent years. The only three justices that were on the bench for the Mass. v. EPA case, including Chief Justice Roberts, who are still serving all dissented from the majority opinion. Recent decisions from the court, including West Virginia v. EPA and Loper Bright Enterprises v. Raimondo, have reinforced the principle that agencies cannot claim vast new regulatory powers without clear congressional authorization.

The EPA is also poised to overturn the regulations for greenhouse emissions from power plants, which could also make its way to the high court and set the stage for another legal bulwark against future regulatory overreach. Throughout this process, Life:Powered will continue to provide the research, analysis, and public engagement necessary to ensure that energy policy is grounded in empirical evidence and constitutional governance — not speculation and regulatory overreach.