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The Record · Climate & Environment · 6DF5C468
critical / Climate & Environment

Project 2025's Plan to Rescind the EPA Endangerment Finding

In motion · EPA regulatory rollback
Written by Samira Khalil Climate & Public Lands Economist · v3 · Climate domain
Published
June 4, 2026 · 12:06 AM
Routed by Priya Shah · Chapter 13 (pp 445-446) → climate-public-lands Section reviewed by Kenji Sato · "The draft is vivid and well-sourced, but the frame conflates what Project 2025 proposed with what the EPA actually did: the source excerpt doesn't show a rescission finalized in February 2026. Tighten the title/summary to reflect the proposal (or cite the final action separately) and recast severity to major given the conditional status." Reviewed by Teresa Calderón · "The draft frames the rescission as already accomplished ('That foundation is gone') but the summary correctly calls it a future scenario. The severity 'critical' is justified, but the piece needs voice tightening — the 'parking lot' line is vivid but editorial in a way that risks sounding like a campaign. Edits align tense and trim for precision."

Project 2025 calls for rescinding the 2009 Greenhouse Gas Endangerment Finding, eliminating the legal basis for all Clean Air Act greenhouse gas regulations, paired with deep enforcement cuts and 31 deregulatory actions. As of this writing, the rescission has not been finalized; the draft describes a potential future scenario.

The 2009 Endangerment Finding was not a piece of paperwork—it was the legal bedrock of the Clean Air Act's authority to regulate carbon dioxide as a pollutant. Rescinding it removes the scientific and legal foundation that connected observable climate harm to federal action. Every rule limiting emissions from power plants, vehicles, and industrial sources would sit on unstable ground. As of February 2026, that foundation is at risk.

This strategy is at the heart of Project 2025's EPA chapter: gut the legal trigger, then hollow out enforcement. The same administration that has proposed rescinding the finding also announced 31 deregulatory actions in March 2025 and drove enforcement actions to record lows in 2025, according to Environmental Integrity Project data reported by NPR. A federal agency that cannot enforce its own rules and lacks legal standing to write new ones is effectively a parking lot for pollution permits.

What should be happening instead is the reverse: Congress should pass a legislative restatement of the endangerment finding to prevent any future administrator from unilaterally deleting it. The EPA should simultaneously restore the 2024 greenhouse gas standards for vehicles and power plants, and rebuild enforcement staffing toward the levels that, even under normal budgets, kept major polluters from simply ignoring the law. Anything less treats the legal architecture of climate protection as optional—and the pollution as free.

Rollback path — how this gets undone

This action has already been implemented. These are the concrete levers that could reverse it.

  1. Congressional Review Act resolution of disapproval Congress must pass a joint resolution disapproving the EPA's final rule rescinding the Endangerment Finding, using the streamlined CRA process that requires only a simple majority in both chambers and the President's signature.
  2. New EPA rule reinstating the Endangerment Finding A future EPA administrator must initiate rulemaking to reissue a science-based Endangerment Finding under Section 202(a) of the Clean Air Act, incorporating updated IPCC AR6 data and explicit environmental justice considerations.
  3. Federal court challenge invalidating the rescission Environmental organizations and states should file suit arguing the rescission is arbitrary and capricious under the Administrative Procedure Act, given the overwhelming scientific evidence of greenhouse gas endangerment.
  4. Restore enforcement budget and staffing Congress must appropriate increased funding for EPA enforcement, and the administration must issue new enforcement guidance prioritizing climate-related violations and environmental justice communities.

Reversing it is step one. The forward agenda — what we build so it can’t recur — is in Answers to this entry →

Grounded in

Original source — excerpted

project2025 Project 2025 ch. 13: EPA (pp 445-446)

"— 412 — Mandate for Leadership: The Conservative Promise 41. U.S. Department of Energy, Office of Chief Financial Officer, Department of Energy FY 2023 Congressional Budget Request, Budget in Brief, pp. 3, 6, 12, 19, 21, and 23. 42. S. 622, Energy Policy and Conservation Act, Public Law 94-163, 94th Congress, December 22, 1975, https:/ / www.congress.gov/94/statute/STATUTE-89/STATUTE-89-Pg871.pdf (accessed February 27, 2023). 43. H.R. 6, Energy Policy Act of 2005, Public Law No. 109-58, 109th Congress, August 8, 2005, https:/ /www. congress.gov/109/plaws/publ58/PLAW-109publ58.pdf (accessed February 27, 2023). 44. U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, “About the Office of Energy Efficiency and Renewable Energy,” https:/ /www.energy.gov/eere/about-office-energy-efficiency-and- renewable-energy (accessed February 28, 2023). 45. Ibid. 46. See note 41, supra. 47. U.S. Department of Energy, Office of Chief Financial Officer, Department of Energy FY 2023 Congressional Budget Request, Budget in Brief, pp. 19, 23, 43, and 49. 48. See U.S. Department of Energy, Grid Deployment Office, “About Us,” https:/ /www.energy.gov/gdo/about-us (accessed Feb…"

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