SSN Public Comment

Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards

Policy field

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Below is an excerpt from a public comment submitted to the Environmental Protection Agency in regard to the proposed rule "Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards" on September 2, 2025.

I am Dr. Claudia Persico, Associate Professor of environmental policy in the Department of Public Administration and Policy at the School of Public Affairs at American University. I can be reached at [email protected]. I am an expert on how pollution affects human health and children’s academic outcomes and life chances.

Air pollution emitted by cars, buses and trucks has numerous impacts on human health, as well as greenhouse gas emissions. These indirect costs and benefits are very real and it would be foolish to not consider them. For example, growing literatures in economics, public health and epidemiology have documented the contemporaneous health (Anderson and Thundilyil, 2011; Ransom and Pope, 1995; Pope and Dockery, 1999; Friedman et al., 2001; Moretti and Neidell, 2011; Schlenker and Walker, 2015) and mortality-related impacts among infants and the elderly (Anderson, 2016; Deryugina et al, 2016) of air pollution. In other words, exposure to air pollution kills babies and the elderly. Air pollution from traffic is linked to bronchitis (Beatty and Shimshack, 2011), diabetes (Bowe et al, 2018) and missing school (Currie et al, 2008). A growing literature also documents how in utero exposure to pollution affects health outcomes at birth such as infant mortality (Currie and Neidell, 2005; Chay and Greenstone, 2003), birth weight (Currie, Davis, Greenstone, and Walker, 2015) and the development of congenital anomalies (Currie, Greenstone, and Moretti, 2011). See also Jayachandran (2009), Currie and Walker (2011), Knittel, Miller, and Sanders (2015), Arceo-Gomez, Hanna, and Oliva (2015), and Almond and Currie (2011). Some recent research also investigates how pollution exposure during gestation affects later human capital outcomes (Almond, Edlund, and Palme, 2009; Bharadwaj, Gibson, Graff Zivin, and Neilson, 2017; Black, Bütikofer, Devereux, and Salvanes, 2013; Ferrie, Rolphe and Troeskin, Persico, Figlio and Roth, 2016; Rau et al., 2015; Sanders, 2012).