Office of the
Illinois Attorney General
Kwame Raoul

Coalition of States, Cities and Counties Stands Up for Climate Science and Opposes Proposal to Roll Back Federal Motor Vehicle Emission Standards

Chicago – Attorney General Kwame Raoul joined a coalition of attorneys general, counties and cities in filing two comment letters opposing the U.S. Environmental Protection Agency’s (EPA) proposed recission of its landmark 2009 Endangerment Finding that greenhouse gas emissions cause climate change, as well as the agency’s proposed repeal of all existing federal greenhouse gas emissions standards for all motor vehicle classes and years.

“The Trump administration’s proposals would undo decades of progress we have made to address climate change by eliminating all existing EPA vehicle greenhouse gas emission standards and denying the EPA’s authority to regulate harmful air pollution that causes climate change,” Raoul said. “I proudly join this coalition of public officials to push back against these disastrous proposals, and I will continue to defend science-backed emission standards that protect the environment and our health.”

The 2009 Endangerment Finding was the direct result of the landmark 2007 Supreme Court opinion in Massachusetts v. EPA, which confirmed the EPA’s authority under the Clean Air Act to regulate greenhouse gas emissions that threaten public health and welfare. After more than two years of scientific review, the EPA determined that greenhouse gas emissions from motor vehicles contribute to air pollution that harms the public’s health and welfare.

As the National Academies of Sciences, Engineering, and Medicine (NAS) confirmed just last week, “EPA’s 2009 finding that the human-caused emissions of greenhouse gases threaten human health and welfare was accurate, has stood the test of time, and is now reinforced by even stronger evidence.”

The coalition’s letter notes that every region of the country is experiencing ongoing and significant harms of climate change, including changes in temperature, precipitation and sea level rise. Extreme summer heat, driven by climate change, is leading to increased rates of heat-related illness and death, particularly among vulnerable populations like children, older Americans, low-income individuals and workers. Increased rates of natural disasters – like wildfires, hurricanes, flooding and droughts – have a devastating effect on public safety and state and local economies. In Illinois, 12 weather and climate disasters in 2024, including the July 15, 2024 “derecho” that produced 48 separate tornadoes, each caused over $1 billion of damage.

The EPA’s proposed recission of the 2009 Endangerment Finding ignores those facts, which are backed by robust climate science. Instead, the agency relies on a flawed, unlawful and unfinished report issued by the Department of Energy’s Climate Working Group. Raoul and the coalition argue that the EPA’s new legal interpretations are fundamentally inconsistent with the Clean Air Act and binding Supreme Court precedent and that the proposal would mark a drastic reversal of longstanding findings without any explanation grounded in science. The coalition urges the EPA to abandon its unlawful and unsupported proposal to rescind the 2009 Endangerment Finding. 

Joining Raoul in filing this comment letter, were the Arizona, Colorado, Delaware, the District of Columbia, Hawaii, Maine, Maryland, Michigan, Minnesota, Nevada, New Jersey, New Mexico,  North Carolina, Oregon, Rhode Island, Vermont, Washington and Wisconsin; the cities of Chicago, New York and Oakland; the city and county of Denver; and the counties of Martin Luther King Jr., Washington and Santa Clara, California. 

In withdrawing the 2009 Endangerment Finding, the EPA also proposes the repeal of existing federal greenhouse gas emissions standards for all motor vehicle classes and years. In a second letter submitted to the EPA, Raoul and the coalition explain that this unprecedented disruption to the regulatory landscape will be catastrophic for the states and their residents, industries, natural resources and public investments.

A robust regulatory program for greenhouse gas emissions is also crucial to vehicle affordability, consumer choice, and the success of the American automotive industry. The greenhouse gas program for vehicles spurs automakers to innovate and create better cars, saving drivers hundreds of billions of dollars in fuel and maintenance costs, and helps support domestic manufacturing and jobs. Repealing that program, as the EPA now proposes, will shutter factories, kill jobs and wipe out billions of dollars in investments that Congress, states and local governments have made to keep the American auto industry thriving and globally competitive.

Joining Raoul in filing this comment letter, were the attorneys general Arizona, Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Washington and Wisconsin; as well as the chief legal officers of Chicago; New York City; Oakland, California; Martin Luther King Jr. County, Washington; the city and county of Denver, Colorado; the city and county of San Francisco; and the County of Santa Clara, California. 

The letters are the most recent actions Raoul has taken to fight back against the EPA’s dangerous proposals. On Sept. 2, Raoul joined a coalition of 22 attorneys general, three cities and two counties to file a comment letter calling on the Department of Energy (DOE) to withdraw the Climate Working Group report that the EPA relied on for its proposed recission of the 2009 Endangerment Finding. 

In that comment letter, Raoul and the coalition identified numerous procedural and substantive flaws in the Climate Working Group report. The DOE selected five widely known climate change skeptics, ignored well-established scientific integrity standards, and failed to comply with Federal Advisory Committee Act (FACA) procedures. FACA procedures require the disclosure of all committee-related records and that committee meetings be open to the public. The letter notes that the report was written in less than two months and is riddled with inaccuracies, factual omissions and mischaracterizations of irrefutable climate science research.

On Aug. 29, Raoul joined a coalition of attorneys general and New York City in filing an amicus brief in the U.S. District Court for the District of Massachusetts in Environmental Defense Fund v. Wright. The coalition’s amicus supported the plaintiffs in their effort to declare the Climate Working Group’s report unlawful. On Sept. 17, the court held that the federal government is not exempt from FACA.