“Let’s just say the quiet part out loud: EPA’s proposal is a stunningly sloppy and amateurish effort to sow doubt where there is no doubt,” said CARB Chair Liane Randolph. “And EPA cannot simply repeal its own standards based on a political whim. The agency owes the American people straight, honest answers why it is proposing to carelessly risk their health, lives and property.” 

CARB’s comments note that the U.S. Department of Energy report on which EPA is relying was assembled by a small group of self-described climate skeptics and is almost totally devoid of scientific evidence to support or explain how they reached their conclusions. Instead, the slim document relies on flawed, disproven assertions and data taken out of context. In addition, EPA acknowledges that it is relying on the DOE report because it does not trust its own analysis. EPA is shamelessly ceding its responsibility to another agency whose current mandate is to prop up fossil fuels at any cost, including public health. 

"The Trump Administration wants you to believe that this is a battle about gas-powered cars versus electric ones. That’s a lie," said California's Secretary for Environmental Protection Yana Garcia. "California is fighting for lives. Decades upon decades of science show that climate-warming gases produced by cars, trucks, power plants and gas facilities are killing people. The proof is clear—more smog, more asthma, and more emergency room visits. Instead of standing up for everyday people and businesses, Trump’s EPA is cannibalizing itself to dodge its responsibility to protect health, safety and the economy. There’s nothing patriotic about abandoning Americans."  

EPA’s proposal is also directly at odds with its own mission statement. That includes: 

• The promise that Americans are entitled to clean air. 

• National efforts to reduce environmental risk are based on the best available science.  

• Federal laws protecting human health and the environment are administered and enforced fairly and effectively.  

By any of these measures, EPA is obligated to address greenhouse gas emissions and adopt strong standards to reduce them. 

CARB also points out that beyond the scientific and documentary evidence, EPA ignores the tragic and painful experiences of thousands of Americans who’ve been severely harmed by more intense wildfires, hurricanes and other natural disasters made worse by climate change. The proposal also discounts the billions of dollars in economic loss sustained each year by the country and the people who live here. 

CARB further points out that EPA leaves no obvious paper trail leading to the environmental impacts of its proposal and therefore provides no opportunity for informed public comment on those impacts. That is fundamental to the sound development of environmental regulations and is illegal since it turns a blind eye to EPA’s obligations under the National Environmental Policy Act. 

Standing up for science 

CARB Executive Officer, Dr. Steven Cliff, testified before EPA in August noting that the DOE arguments against the endangerment finding are attempting to refute science that even 5th grade students know is true. He also pointed out that DOE’s arguments are routinely rolled out by the oil industry. 

In September, CARB filed comments with DOE specifically calling out the lack of actual science in the study and refuting its misinformation and falsehoods line-by-line.  

CARB is calling for EPA to stand up for science, and facts, and to drop this thinly veiled attempt to rewrite established history.