The EPA’s July 29, 2025 proposal to rescind the 2009 Endangerment Finding, which classified six greenhouse gases, including CO₂ and methane, as threats to public health, and to eliminate all federal GHG emission standards for new vehicles, represents a profound retreat from science-based regulation as well as common sense. This rollback jeopardizes all of our collective abilities to protect Texans from worsening climate impacts, respiratory ailments, and environmental degradation (Lovells, 2025).

How Eliminating the Endangerment Finding Would Harm Texas & the Environment

1. Climate-Driven Health Threats Are Already Intensifying in Texas

• Texas suffered 9 of its 10 hottest years ever recorded since 2009, with heat waves driving respiratory illness, heat-related deaths, and exacerbating chronic conditions (Daly, 2025).
• The Endangerment Rule underpins vehicle emissions standards that reduce CO₂ and fine particulates. Without it, pollution burden increases—exacerbating asthma, cardiovascular disease, and heat stress especially in our urban cities such as Houston, Dallas, San Antonio.

2. Rolling Back GHG Standards Undermines Long-Standing Climate & Energy Progress

• The Finding enabled EPA regulations for cars, power plants, and the oil & gas sector—estimated to represent over $1 trillion in positive regulatory impact over time, including projected $54 billion in annual benefits via reduced fuel costs, cleaner air, and avoided climate damage (EPA, 2025).
• Removing it will eliminate standards for vehicle emissions across all classes, light, medium, and heavy-duty, removing essential tools for reducing Texas’s GHG output (EPA, 2025).

3. Rollback Weakens EPA’s Legal Authority to Regulate Other Sectors

• The Finding supports regulations across oil & gas methane controls, power plant carbon limits, hydrofluorocarbon phasedowns, and aviation emission rules. Repealing it is taking a very important tool away from the public to control other agencies that emit GHGs (Dickinson, 2025).

4. Environmental Risks for Texas Are Acute and Localized

• Rising GHG emissions drive sea-level rise along the Gulf Coast, more frequent extreme heat, drought, and intense storm events. These conditions aggravate air pollution, trigger mental health stress, and strain health systems.
• Rural and frontline communities, already underserved in terms of health care and health care access, will continue to bear disproportionate impacts. Rolling back standards would deepen these environmental injustices.

TPSR’s Call to Action

• We urge the EPA to retain the 2009 Endangerment Finding, granting EPA authority to regulate greenhouse gas emissions under the Clean Air Act.
• We call on policymakers and the public to participate in the open comment process (comments due by mid-September 2025), urging retention of both the Finding and associated GHG vehicle standards
• We commit to mobilizing physicians and public health professionals across Texas to document local health data illustrating the tangible harm that unchecked emissions cause.

On behalf of the entire Board of Directors of Physicians for Texas Responsibility,

 

President, Adelita G. Cantu, PhD, RN, FAAN

Vice President, Anusha Govind, MD

Secretary, William B. Perkison, MD

Treasurer, Donald Williams, MD, FAAP

 

MEMBERS AT LARGE

Juan Aguilera, MD, PhD, MPH

Elizabeth Banks, Medical Student

Sanjna Bhatia, BS, BA, Medical Student

Simon Birk, Medical Student

Kimberly Carter, MD, MPP

Rose Jones, PhD

Blythe Mansfield, MD, MPH, FACOEM

Ronda B. McCarthy, MD, MPH, FACOEM, FACPM

Alan Nagarajan, Medical Student

Audrey Schulze, Medical Student

Yasir Syed, BS, Medical Student

References

EPA proposes reconsidering the 2009 GHG endangerment finding | JD Supra. (2025). JD Supra. https://www.jdsupra.com/legalnews/epa-proposes-reconsidering-the-2009-ghg-1191632/.

Trump EPA moves to repeal landmark finding that supports climate regulation. (2025, July 29). AP News. https://apnews.com/article/trump-climate-epa-endangerment-zeldin-5cba0871c880e23d044ef40a398c57b2

Pulling the Critical Block: EPA’s Repeal of the Endangerment Finding Could Topple Climate Rules | JD Supra. (2025). JD Supra. https://www.jdsupra.com/legalnews/pulling-the-critical-block-epa-s-repeal-8471273/

Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards. (2025, August). Federal Register. https://www.federalregister.gov/documents/2025/08/01/2025-14572/reconsideration-of-2009-endangerment-finding-and-greenhouse-gas-vehicle-standards

WHAT THEY ARE SAYING: Leaders Praise the EPA for Launching Largest Deregulatory Action in U.S. History with Proposal to Rescind Obama-Era Endangerment Finding | US EPA. (2025, August). US EPA. https://www.epa.gov/newsreleases/what-they-are-saying-leaders-praise-epa-launching-largest-deregulatory-action-us