EPA’s Proposed Repeal of the 2009 Endangerment Finding: Unexpected Arguments and Implications for Industrial Sources

On August 1, 2025, EPA published its long-awaited proposal to revoke the 2009 endangerment finding that underlies most of EPA’s efforts to regulate CO₂ and other greenhouse gases. Jeff Holmstead and Brittany Pemberton explore the legal foundation of this proposal and whether it might effectively prevent EPA from regulating CO₂ and other greenhouse gases under the Clean Air Act.