
The Comment Letter opposes the Trump Administration’s proposal to rescind a key 2009 environmental finding, arguing that it would endanger public health and violate settled law and scientific consensus.
The letter followed the Trump administration’s recent proposal to rescind the 2009 Endangerment Finding on grounds that the EPA lacks authority to regulate greenhouse gas emissions that contribute to climate change, and the proposal would also rescind existing EPA greenhouse gas emission standards for vehicles. The 2009 Endangerment Finding flowed from a 2007 US Supreme Court opinion that the Clean Air Act grants authority to the EPA to regulate greenhouse gas emissions that threaten public health and welfare.
“EPA’s brazen proposed rescissions fly in the face of settled law, Supreme Court precedent, and the scientific consensus and will endanger the lives of millions of Americans,” said the 22 September Comment Letter. “Indeed, just 5 days ago, the National Academies of Sciences, Engineering, and Medicine issued a consensus study report concluding that: 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.”
Comment Letter cites research finding on damage to US economy from climate change
The Comment Letter cites a 2023 paper co-authored by Kamiar, Associate Professor in Economics and Policy at Cambridge Judge, to rebut claims by the Climate Working Group of the US Department of Energy. The Comment Letter notes that the 2023 study found that its results “provide evidence for the damage that climate change causes in the US using various economic indicators”.
The cited paper authored by Kamiar and colleagues from the University of Cambridge climaTRACES Lab, University of Southern California and National Taiwan University was entitled Climate change and economic activity: evidence from US states. The paper investigated the long-term effects of climate change across 48 states, over the last half century, using a new model that links temperature and precipitation deviation from their long-term norms to specific economic indicators that are state and sector-specific.
Paper examines the economic losses from climate change for all 10 economic sectors including retail and agriculture
“We show that climate change has a long-lasting adverse impact on real output in various states and economic sectors, and on labour productivity and employment in the United States,” the paper said. “Using data on 48 US states from 1963 to 2016, and a novel econometric strategy … we provided evidence for the damage that climate change causes in the US using GSP (Gross State Product), GSP per capita, labour productivity and employment as well as output growth in 10 economic sectors (such as agriculture, construction, manufacturing, services, retail and wholesale trade). While certain sectors in the US economy might have adapted to higher temperatures, economic activity in the US overall and at the sectoral level continues to be sensitive to deviations of temperature and precipitation from their historical norms.”
The Comment Letter was signed by the Attorneys General of Massachusetts, New York, California, Connecticut, Arizona, Colorado, Delaware, Hawaii, Illinois, Maine, Maryland, Michigan, Minnesota, Nevada, New Jersey, New Mexico, North Carolina, Oregon, Rhode Island, Vermont, Washington, Wisconsin and the District of Columbia. It was also signed by the Chief Legal Officers of the cities of Chicago, New York, Oakland, the city and county of Denver, the city and county of San Francisco, Santa Clara County, California, and Martin Luther King Jr County, Washington.
Featured faculty
Kamiar Mohaddes
Associate Professor in Economics and Policy
Director of the Global Executive MBA Programme
Kamiar is Director of the climaTRACES lab.
Featured research
Mohaddes, K., Ng, R.N.C., Pesaran, M.H., Raissi, M. and Yang, J.-C. (2023) “Climate change and economic activity: evidence from US states.” Oxford Open Economics, 2: odac010 (DOI: 10.1093/ooec/odac010)
Related content
“Press release: Combatting the EPA’s ongoing assault on climate science: Attorney General Bonta slams EPA’s proposed rescission of endangerment finding.” Office of the Attorney General, State of California Department of Justice, 22 September 2025
“Letter: The proposed reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, 90 Fed. Reg. 36,288 (Aug. 1, 2025).” Office of the Attorney General, State of California Department of Justice, 22 September 2025




