AIA Submits Comments to EPA's Greenhouse Gas Endangerment Review

WASHINGTON – September 25, 2025 – The American Institute of Architects (AIA) has submitted formal comments to the Environmental Protection Agency (EPA) in opposition to its proposed rule to rescind the 2009 Endangerment Finding and repeal all associated GHG vehicle standards.

AIA believes this proposed rule is a direct assault on the economic progress and stability of the built environment. The proposed rule is dangerously shortsighted, jeopardizing the substantial investments in sustainable design that have resulted in billions in operational savings, higher property values, and a more productive workforce. AIA's comments highlight that high-performance, carbon-neutral design is both a viable and profitable business model, emphasizing the importance of predictable, science-based regulations for long-term economic planning.

"The EPA's claim that the 2009 finding was based on "uncertainties in science" is factually incorrect," said Arathi Gowda, FAIA, Principal at ZGF Architects and testifying on behalf of AIA. "The consensus from authoritative bodies is that climate change is already causing widespread adverse impacts. By acting on this consensus, the federal government provides market predictability that encourages investment in sustainable infrastructure, advanced technologies, and resilient building practices—all of which are essential for the future of our industry."

View comments submitted to EPA by AIA.

AIA will continue to advocate for a sustainable, equitable, and resilient built environment that includes healthy physical environments for all.

Learn more about AIA's advocacy for a sustainable, equitable, and resilient built environment.