From CFACT

By Donna Jackson

Reconsideration of the 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards

Docket No. EPA-HQ-OAR-2025-0194

Statement of Donna Jackson, Senior Policy Analyst

Committee for a Constructive Tomorrow

Thank you for the opportunity to participate in this public hearing and I applaud the EPA for this important undertaking. My name is Donna Jackson, and I am a senior policy analyst with the Committee for a Constructive Tomorrow.

We have already submitted a written comment that explains both the scientific and legal flaws with the agency’s 2009 endangerment finding.

We also note that subsequent scientific research and case law have only weakened the assertion that the Clean Air Act authorizes an unprecedented climate change program that, among other things, was being used to effectively phase out gasoline-powered cars in favor of electric vehicles.

This includes scientific research casting further doubt on the claimed harm from carbon dioxide emissions, and especially the minor percentage of such emissions attributable to the various categories of motor vehicles at issue here. At the same time, several recent Supreme Court decisions place additional limits on EPA freelancing beyond its clear statutory authority, as clearly was done in 2009.

Overall, the case for the endangerment finding for motor vehicles was weak and is getting weaker, but I would like to spend the rest of my time explaining why its repeal would be good news for low income and minority households for which affordable cars are so crucial.

Economic research shows how vital owning a car is for those struggling to climb the economic ladder.

One study by the Federal Reserve Bank of Philadelphia found that the wage gap between black and white Americans declines when black Americans have access to a car. Many low-income communities are located far from the best job opportunities in metropolitan areas.

And, despite all the wishful thinking about public transportation, the reality is that it can only take you to a fraction of the potential jobs available if you have a car. A vehicle of your own also opens up opportunities for jobs in the gig economy.

The list goes on of the ways vehicle ownership helps individuals and families trying to better themselves economically and achieve self-sufficiency.

To put it bluntly, anyone who genuinely cares about the poor would prioritize making car ownership as affordable as possible, and that means a gasoline-powered vehicle, not an EV or other alternative. In fact, Kelley Blue Book says that the average sticker price of an EV is $55,689, which exceeds the annual income of 63 percent of African American households.

But that, of course, is the opposite of what we get with the endangerment finding and its use by the agency to impose a costly crackdown on tailpipe emissions of carbon dioxide. And that is why the elimination of the endangerment finding and the preservation of gasoline-powered vehicles would be good for all Americans, and low-income ones most of all.

Thank you.