Coalition and Partners Oppose EPA’s Proposed Rollback of Power Plant Greenhouse Gas Protections

 

U.S. Environmental Protection Agency

EPA Docket Center

Docket ID No. EPA–HQ–OAR–2025–0124-2920

1200 Pennsylvania Avenue NW

Washington, DC 20460

Electronic Filing via Regulations.gov

Re: Comments on EPA’s Proposal for the Rescission of the Greenhouse Gas Findings for Fossil Fuel-Fired Power Plants and Repeal of Regulations for Power Plant Greenhouse Gas Emissions Under Clean Air Act Section 111 (Docket ID No. EPA–HQ–OAR–2025–0124-2920)

Dear Administrator Zeldin:

On behalf of Appalachian Mountain Club, the Coalition to Protect America’s National Parks and National Parks Conservation Association, we submit the following comments strongly opposing the Environmental Protection Agency’s (EPA) proposed rescission of greenhouse gas (GHG) findings for fossil fuel-fired electric generating units (EGUs) (referred to hereafter as Proposal).

I. Introduction

Collectively, our organizations represent the interests of America’s most beloved public lands and treasured natural and cultural resources. These public lands and cultural sites offer wondrous beauty, recreational opportunities, ecosystem services, and historic preservation, while providing experiences that improve visitors’ health and support local economies.¹ In doing so, they contribute to the social, cultural, financial, and ecological well-being of our nation.

We are particularly concerned about the impacts of climate change and air pollution on our national parks, national forests and other federal public lands, and how the Proposal could permanently end all federal efforts to mitigate GHG pollution from EGUs. America’s public lands, especially its national parks and forests, are among the places most endangered by climatic change, which is driven by greenhouse gas pollution. Because these lands are often located at ecosystem extremes, even subtle shifts in climate conditions can have major implications for their wildlife, biodiversity and unique natural features.

Appalachian Mountain Club (AMC) Founded in 1876, AMC promotes the protection, enjoyment, and understanding of the mountains, forests, waters, and trails of America’s Northeast. As a community of more than 90,000 adventurers and nature advocates our passion for the outdoors is boundless. We connect people with nature and therefore work to protect the outdoors from detrimental impacts of air and water pollution which impact the enjoyment and safety of hikers and the vitality of natural resources. AMC works to reduce greenhouse gas and air pollution emissions and their impacts to these resources, especially to visibility and hiker and ecosystem health.

The Coalition to Protect America’s National Parks represents over 5,000 members and supporters, including current, former, and retired employees and volunteers of the National Park Service, with over 50,000 collective years of stewardship of America’s most precious natural and cultural resources. The Coalition consists of protection rangers and interpreters, scientists and maintenance workers, managers and administrators, and specialists in the full spectrum of the parks’ resources. The Coalition’s membership also includes former National Park Service directors, deputy directors, regional directors, and park superintendents. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service.

National Parks Conservation Association (NPCA) is a national organization whose mission is to protect and enhance America’s national parks for present and future generations. NPCA performs its work through advocacy and education. NPCA has over 1.9 million members and supporters nationwide with its main office in Washington, D.C. and 24 regional and field offices. NPCA is active nationwide in advocating for strong air quality requirements to protect our parks, including submission of petitions and comments relating to visibility issues, Regional Haze State Implementation Plans, climate change, mercury impacts on parks, and emissions from individual power plants and other sources of pollution affecting national parks and communities. NPCA’s members live near, work at, and recreate in all the national parks.

Climate change is rapidly and irreversibly transforming landscapes within national parks and public lands. Indeed, national parks are particularly vulnerable to changes in climate because of their sensitive natural environments. Plant life in our parks, some of which is found nowhere else on the planet, faces challenges adapting to climatic shifts that are altering entire ecosystems. Buildings, visitor infrastructure and historic structures within national parks and other public lands are being degraded or destroyed by climate-driven unnatural disasters. Extreme climate disasters present serious economic, social, and environmental consequences that directly affect our national parks and public lands; these special places face consequences from rising temperatures that drive fiercer storms, prolong droughts, melt glaciers, cause rising sea levels, encourage invasive plants and animals and fuel extreme wildfires. The effects vary across the public lands system, but cover all geographic locations, including coastal areas, desert landscapes, mountain ranges and forests, as well as urban and rural park cultural and historic resources. From microorganisms to large mammals, wildlife in our parks and public lands are struggling to adapt—indeed some are facing extinction. In addition, the harms these lands are suffering serve as a sort of a “canary-in-the-coalmine,” portending harms soon to come to human health and welfare that will result, and already are resulting, from climate change. The long term health and welfare of our national parks and public lands depend on reducing climate pollution from major sources of U.S. GHG emissions like fossil fuel-fired EGUs.

EPA’s Proposal to rescind any existing federal authority to enact GHG emission standards for fossil fuel-fired EGUs is based on a narrow new interpretation of the agency’s authority under section 111 of the Clean Air Act (CAA) and suffers from numerous legal flaws and scientific inaccuracies. Moreover, in conjunction with other EPA rules rolling back GHG controls for EGUs, this Proposal will ultimately allow sources to emit significant levels of additional and avoidable GHG pollution into earth’s atmosphere unabated, which will be utterly devastating for the future of our national parks, national forests, and other public lands. We therefore urge EPA to retain GHG emission standards for EGUs and abandon this irrational and shortsighted Proposal, which drastically threatens the health and well-being of our national parks and public lands.

II. EPA’s Proposed Finding that it Lacks Authority to Regulate GHG Emissions from Fossil Fuel-Fired EGUs is Inconsistent with the Clean Air Act and is Arbitrary and Capricious.

EPA’s Proposal to rescind its prior findings that GHGs emitted by new or existing EGUs can be regulated under CAA § 111 as air pollutants that endanger public health and welfare suffers from various legal flaws. Our summary includes the following:

• EPA’s Proposal to extend its legally flawed reconsideration of the Endangerment Finding for on-road vehicles to GHG emissions from EGUs directly contradicts existing law and the plain language of the CAA.
  • Numerous courts, including the Supreme Court in Massachusetts v. EPA, 549 U.S. 497 (2007), have confirmed what the overwhelming scientific consensus shows—that GHGs are air pollutants that endanger public health and welfare and the Court subsequently held that CAA clearly grants EPA authority to regulate power plant GHG emissions as air pollutants under §§ 111(b)(1)(A).²
  • Despite this direct legal precedent, which remains binding, EPA exceeds its authority in this Proposal by reinterpreting CAA § 111 in a manner that blatantly disregards stare decisis, the plain language of the statute, clear congressional intent, decades of EPA policy, and the overwhelming scientific consensus on climate change.
• EPA’s determination that CAA § 111 applies only to local or regional air pollution and not global air pollution has no basis in the law and is arbitrary and capricious.
  • EPA’s new interpretation that § 111 does not apply to GHG pollution because it is not a local or regional air pollutant is legally defective. This interpretation creates a new standard that does not exist in the statute and is inconsistent with how EPA has interpreted § 111 and similar CAA provisions for decades. GHGs are not different from other pollutants under the CAA and the Act has never been read to limit EPA’s authority to regulate only arbitrarily defined local or regional pollutants.
• EPA erroneously concludes that the major questions doctrine precludes regulating GHGs under the CAA.
  • EPA’s authority to regulate GHGs was already affirmed by the Supreme Court in Massachusetts v. EPA, where the court held that it was not a major question, therefore there is no new question of congressional intent to resolve. Moreover, existing legal interpretations and longstanding EPA policy upholding determinations that the CAA allows for the regulation of GHG emissions under § 111 is adequately supported by congressional intent at the time of § 111’s adoption and has been subsequently confirmed by congressional action supporting this interpretation.
  • EPA’s invocation of the major question doctrine in line with West Virginia v. EPA, 597 U.S. 697 (2022) is erroneous because the Supreme Court in West Virginia left in place EPA’s authority to regulate GHGs emitted by power plants as air pollutants in line with its finding in Massachusetts v. EPA.
• EPA’s Proposal is arbitrary and capricious because it focuses only on economic costs to polluting industries while wholly ignoring the immense public costs of this Proposal and the numerous benefits that reducing GHG emissions will have on human health and the environment – including costs and benefits to national parks and public lands.
• EPA’s claim that this Proposal does not alter the CAA’s displacement of federal law or preemptive force of the CAA with respect to state law is legally faulty and counter to well established legal doctrines governing the displacement of federal or state law and federal preemption. Claiming to have no authority to regulate GHGs as pollutants under the CAA while simultaneously asserting sole jurisdictional control over any actions related to restricting GHGs is illogical on its face and unsupported by the law.

III. EPA’s Proposed Repeal of Greenhouse Gas Standards for Fossil Fuel-Fired EGUs Will Cause and Contribute to Non-De Minimus Harm to U.S. National Parks and Public Lands.

EPA claims that its modeling demonstrates that any plausible reduction in GHG emissions from domestic EGUs would have de minimis impacts on climate change indicators despite significant research and findings from around the world to the contrary.³ Then, in this Proposal, EPA comes to the absurd conclusion that GHG emissions from U.S. fossil fuel-fired EGUs do not contribute significantly to climate change despite the roughly 1.5 billion metric tons of GHGs emitted from U.S. EGUs every year.⁴

Additionally, the agency erroneously focuses only on two climate metrics, surface temperature and sea level rise, while ignoring a number of other key climate change indicators that have clear and undeniable consequences for public lands.These additional indicators that EPA failed to consider include increasing rates of precipitation and subsequent flooding, drought, extreme heat, wildfire risks, loss of glaciers and snowpack, ecosystem impacts, wildlife impacts and the spread of invasive species, among others. As discussed in the sections below, we are already seeing the effects of these various climate change indicators in our national parks and federal public lands, and the impacts are only expected to get worse as more GHGs are emitted into the atmosphere by sources including domestic EGUs.

Nowhere in its Proposal does EPA explain what level of emissions would meet its newly applied cause-or-contribution standard. Instead, the Proposal simply and arbitrarily dismisses emissions from the largest single source category of GHG pollution in the U.S. as unsubstantial when compared to other global contributions. EPA’s arbitrary decision to ignore EGU GHG emissions is based on a flawed rationale that evades decades of CAA rules that recognize the contributions of numerous sources.

By any measure, GHG emissions from U.S. EGUs are unquestionably significant. The U.S. is currently the second largest global contributor of GHG emissions worldwide after China. Historically, the U.S. is by far the largest contributor of GHG emissions, accounting, at one time, for 25% of cumulative CO₂ emissions–much of which is still in the atmosphere driving global climate change to this day. In fact, the Proposal itself confirms that U.S. EGUs are a significant source of GHG emissions. According to the Proposal, U.S. EGUs are projected to emit over 1.5 billion tons of CO₂ in 2026, accounting for over a quarter of all CO₂ emissions emitted from all sources within the U.S.⁵ Notably, the analysis in the Proposal fails to analyze other climate altering GHG pollutants beyond CO₂ . This includes methane, the primary GHG emitted by the growing gas-fired EGU sector and which has a global warming potential that is 80 times that of CO₂ over a 20-year period.⁶ EPA’s analysis also leaves out the massive amount of methane and other GHG emissions stemming from the production and transportation of fossil fuels like gas prior to being emitted by a specific EGU. Lastly, EPA’s modeling fails to account for the fact that U.S. EGU emissions are now growing as the result of this administration’s deregulatory energy dominance agenda and the recent exponential growth in electricity demand associated with data centers.⁷ Should the U.S. continue on this new track of increasing emissions, we will likely see more GHG emissions in future years, not less, as EPA’s flawed modeling assumes.

The question of whether U.S. power sector emissions are substantial in the global context and if regulating their emissions would solve climate change is not a binary question. Climate change is undeniably happening in the U.S. and across the world, and the key issue going forward is how badly – not whether – its impacts will harm the health and welfare of people and our planet, with the repercussions compounding with every additional ton of GHG pollution and every additional degree of average global temperature increase. Reducing emissions from one of the biggest sources of GHGs in the second highest emitting nation is unquestionably a necessary step toward addressing the degree to which climate change will warm our planet in the long term. The benefits of regulating power plants are further compounded when EGU focused strategies are combined with other actions to reduce GHG emissions from large domestic sources like the transportation sector. EPA’s approach in this repeal of the CPP rule arbitrarily decouples broad federal efforts to regulate major sources of GHGs into discrete parts and then minimizes the role each of those parts plays in the nation’s overall contributions to global climate change as being de minimis – this approach is illogical and contrary to law.

Ultimately there is no logical way that a source category as large as the U.S. power sector can be categorized as contributing a de minimis amount of emissions when every incremental increase in GHGs can have devastating effects on the burgeoning climate crisis and in turn our nation and its parks and public lands. As concluded by the International Panel on Climate Change (IPCC) in its 6th Climate Assessment Report, human-caused GHG emissions have unequivocally caused global warming and each incremental increase in GHG concentrations causes climate impacts to become more severe.⁸ One particularly worrying example of human impact on climate change can be found in the fact that even small increases in GHG emissions could trigger an exceedance of one or more identified climate tipping points, such as “substantial sea level rise from collapsing ice sheets, dieback of biodiverse biomes such as the Amazon rainforest or warm-water corals, and carbon release from thawing permafrost.”⁹

As it relates to national parks, between 1895 and 2010, mean annual temperatures in park areas increased at twice the rate of the country as a whole, and national parks saw annual precipitation decreases that were four times greater than the national average.¹⁰ As illustrated in the sections below, given national parks’ particular vulnerability to climate impacts and the higher than national rates of warming our parks face, even incremental increases in GHGs are having devastating effects on some of our nation’s most beloved landscapes and cultural sites – a reality that EPA wholly ignores in its Proposal.

IV. Regulating GHG emissions from Fossil Fuel-Fired EGUs is Necessary Because Those Emissions Harm the Health and Wellbeing of National Parks and Other Public Lands

America’s national parks and public lands protect landscapes and cultural and historical resources that provide extensive health, educational and welfare benefits to millions of people,¹¹ offering access to places with various physical, mental, aesthetic, cultural, environmental, and historic assets.¹² National parks are a source of pride for many Americans and offer significant economic benefits to local and state tourist economies. The CAA in § 302(h) specifically defines public welfare to include the kinds of benefits that parks and other public lands provide, including their roles in protecting the long term viability of “soils, water, . . . animals, wildlife . . . visibility, and climate,” as well as the benefits they provide to the economy and to the “personal comfort” of individuals visiting parks and public lands.¹³

With regard to economic benefits, for instance, more than 323 million visitors explored the National Park System in 2025, while in 2023, the last year in which economic contributions were released, the National Park System brought in over $26.4 billion in visitor spending to the parks and surrounding communities.¹⁴ National forests and grasslands also see significant visitation. In 2022, spending by visitors contributed about $13.7 billion to the U.S. economy and supported 161,000 full-and part-time jobs.¹⁵

Should this Proposal be finalized, the numerous health and welfare benefits that national parks and other public lands provide will undoubtedly be diminished, which is a reality EPA’s Proposal fails to address.

A. Greenhouse Gas Emissions Endanger the Public Health and Welfare Benefits That National Parks and Other Public Lands Provide.

Scientists from around the world, for decades, have agreed that the evidence from published scientific research consistently shows that human-caused climate change endangers the health of people, the integrity of ecosystems that sustain people, and the public lands that protect those ecosystems.¹⁶ According to the Intergovernmental Panel on Climate Change (IPCC) in their 6th Assessment Report (AR6):

Human activities, principally through emissions of greenhouse gases, have unequivocally caused global warming, with global surface temperature reaching 1.1°C above 1850-1900 in 2011-2020. Global greenhouse gas emissions have continued to increase over 2010-2019, with unequal historical and ongoing contributions arising from unsustainable energy use, land use and land-use change, lifestyles and patterns of consumption and production across regions, between and within countries, and between individuals . . . Human-caused climate change is already affecting many weather and climate extremes in every region across the globe. This has led to widespread adverse impacts on food and water security, human health and on economies and society and related losses and damage to nature and people . . . Vulnerable communities who have historically contributed the least to current climate change are disproportionately affected.¹⁷

Our public lands host some of America’s most beloved natural and cultural resources, yet many are particularly vulnerable to a rapidly changing climate because of their sensitive and fragile ecosystems, irreplaceable artifacts and unique geographic locations. The burning of fossil fuels driving global warming has resulted in national park mean annual temperatures increasing “at double the rate of the U.S. as a whole” between 1895 and 2010.¹⁸

The turmoil caused by this warming and the resulting extreme weather conditions is disastrous for most national park units and is projected to only get worse. All public lands are affected. As temperatures increase, risks from projected climate change are felt across all geographic regions and locations, from coastal to mountainous areas. These climate effects include: (1) rising sea levels; (2) increasingly intense wildfires; (3) wildlife habitat loss, particularly at high elevations; (4) rapid growth of disruptive, invasive species (both plants and animals); (5) ecosystem damage and danger to visitors from extreme coastal and inland flooding, heat and intense storms; (6) drier conditions leading to prolonged droughts; (7) loss of glaciers, snowpack and ice; (8) changing landscapes and disrupted ecosystems; (9) destruction of irreplaceable historic and cultural park structures and artifacts; and (10) altered visitation patterns and significant losses to valuable tourism revenue.

These broad climate risks translate into concrete, measurable changes across the national park system. Park-specific analyses have demonstrated that historical changes, detected and attributed to human-caused climate change, in multiple U.S. national parks include glacial melt, snow cover reduction, wildfire increase, tree mortality, drought, biome shifts, sea level rise, ocean warming, coral bleaching, ocean acidification, bird species losses, and wildlife shifts.¹⁹ Moreover, projected future risks across all U.S. national parks under continued CO₂ emissions suggest that climate change could damage many natural resources including the following projected risks: glacier loss, permafrost thaw, wildfire increase, tree mortality, biome shifts, inundation from sea level rise, coral bleaching, ocean acidification, plant species changes, mammal species declines, bird species changes, reptile species decline, amphibian species declines, fish species decline, butterfly species local loss, invasive species increase, earlier cherry blooming, archeological artifact loss, and archeological site erosion.²⁰

In its 2024 report on pollution in national parks, entitled Polluted Parks,²¹ NPCA analyzed data for 397 national park sites investigated by the National Park Service (NPS) for their relative threats from certain climate change high-impact vulnerability factors—climate threats—namely, wildfire, drought, sea level rise and invasive species. These four threats were prioritized by NPS as primary concerns for parks because they have the potential to rapidly and permanently disrupt and transform park ecosystems and resources. The NPS study utilized multiple climate indicators to evaluate parks’ exposure and sensitivity to climate change as well as their adaptive capacity. The data revealed that 57% of all national parks face a high risk from at least one climate threat which has the potential to alter park ecosystems and resources fundamentally and permanently.

The data showed that invasive species are among the most dominant threats, harming 113 separate parks predominantly across the Southeast, Northeast and Midwest regions of the U.S. Wildfire stands out as the second most prominent threat—95 parks are at high risk—primarily in California but also in the Four Corners and Southeast regions. Drought is threatening 75 parks primarily in the Midwest and Western states, while sea level rise affects 48 parks predominantly along the eastern and Gulf coasts.²² Moreover, numerous national parks face simultaneous risks from multiple climate threats. For instance, a single climate threat was identified in 142 parks, while 72 parks are dealing with two threats and 14 parks are struggling to manage three different climate threats all at the same time. If climate change continues, park wildlife and plant species populations could plummet and biodiversity loss and extinctions may occur, rendering our national parks that currently protect and preserve some of our nation’s most unique and special biodiversity devoid of the robust flora and fauna that currently inhabit them. These changes can alter parks in ways that may be irreversible, underscoring the urgency needed to cut greenhouse gas emissions dramatically and swiftly to prevent the worst effects of climate change.

B. Rising Temperatures Endanger the Public Health and Welfare Benefits Provided by National Parks and Other Public Lands.

In the decade from 2011-2020, global average temperatures were about 1.1 degrees Celsius higher than they were from 1850-1900, resulting in profound climatic changes that threaten the future and integrity of our national parks.²³ National parks and other public lands are uniquely vulnerable to the impacts of rising temperatures , because they are often found in nature’s most extreme places—like the Arctic or exceptionally high elevations—where warming occurs more quickly.²⁴ These rising temperatures could lead to economic harm by reducing park visitation and degrading infrastructure, social harm by increasing the risk of heat-related illness for park visitors and employees, and environmental harm by degrading park landscapes and ecosystems. These same impacts are also happening in national forests and other public lands throughout the country, adding high levels of stress to our cherished natural landscapes. Without significant reductions in greenhouse gas emissions from sources like EGUs, temperatures will rise even more precipitously in future years than is already expected, resulting in further and more extreme harm to our public lands, and the people working in and visiting them.

Warmer temperatures negatively affect the health of park visitors and employees.²⁵ For example, when monthly temperatures exceed 80 degrees Fahrenheit, visitation in almost all national parks declines markedly.²⁶ Warming temperatures increase evaporation and transpiration, affecting humidity levels and the intensity and frequency of precipitation.²⁷Exposure to excessive heat results in heat-related illnesses, including heat stroke, heat exhaustion, and heat cramps, and can lead to long-term poor health outcomes.²⁸ Over the next 75 years, rising temperatures are projected to increase the risk of these illnesses by 29-137% for millions of Grand Canyon National Park visitors.²⁹ Tragically, deaths from heat-related illnesses in all national parks are increasing year after year.³⁰

Heavy precipitation damages infrastructure like roads, trails, and essential services buildings, often requiring parks to limit or prohibit visitation entirely.³¹ For example, in June 2022, unprecedented rainfall on snow drifts caused substantial flooding, rockslides, and mudslides within Yellowstone National Park.³² Roads and infrastructure suffered damage, entrances to the park were closed for months, and thousands of people were evacuated.³³ The park is still recovering from the devastating impacts of the floods, and the total rebuilding costs are projected to exceed one billion dollars.³⁴

In 2024, Hurricane Helene brought record amounts of rain and unprecedented hurricane-force winds to North Carolina, causing significant damage to the Blue Ridge Parkway, which connects Shenandoah and Great Smoky Mountains National Parks.³⁵ The parkway was fully closed for two weeks in October of 2024, a month that typically brings in $6 million in revenue for surrounding communities from the many visitors coming to admire the fall leaves, and portions of the parkway remained closed for nearly 2 full years after the storm, limiting access.³⁶ According to a summer 2025 article, “as of July, 157 miles [of roads] remain closed in North Carolina due to extensive damage from at least 57 landslides, widespread downed trees and other causes, according to the park service. Beyond the Blue Ridge Parkway, significant recovery work continues in Western North Carolina, where the storm damaged more than 190,000 acres of national forest land, according to the U.S. Forest Service.”³⁷ The damage to the tourism economy from this unprecedented hurricane event in the Blue Ridge Mountains cannot be understated, where businesses on average lost $322,000; places like Asheville and Lake Lure, North Carolina have struggled to bring in the kinds of tourism dollars they saw before the storm.³⁸

Rising temperatures threaten our public lands and waters in numerous other ways. For example, hotter temperatures jeopardize the integrity of coral reefs³⁹, endangering thousands of marine species and disrupting the trillions of dollars in ecosystem services that reefs provide by protecting the coast and supporting the fishing industry, tourism, and other occupational sectors.⁴⁰ Warmer temperatures put great stress on corals and can cause them to lose the algae that provide corals with food.⁴¹ This process is called “bleaching” because after the algae is gone, all that is left is the coral’s stark-white skeleton; unfortunately, it is often fatal to corals.⁴² Coral bleaching poses a large threat to reefs like those in Biscayne National Park. Live coral cover in the South Atlantic Region, which includes Biscayne National Park, has “declined by as much as 90% in the last 30 years.”⁴³

Warmer temperatures allow invasive animals and plants to thrive⁴⁴, spreading disease and crowding out vulnerable park species.⁴⁵ Moreover, warming temperatures change plant species’ flowering and fruiting times, disrupting natural feeding cycles, migration patterns, and pollination.⁴⁶ These phenological “mismatches” in timing of nature’s natural rhythms, made worse by earth’s rising temperatures, have serious implications for the health of wildlife.⁴⁷

Climate change-induced temperature rise also threatens the very features and species that some national parks were designated to preserve and protect, and often, what they were named for. For example, warming temperatures have caused every glacier in Glacier National Park to decrease in size since 1966—some by more than 80%.⁴⁸ Unless greenhouse gases are significantly reduced, by 2100, all of the park’s namesake glaciers are projected to disappear completely.⁴⁹

Namesake species are likewise at risk. The Joshua trees in Joshua Tree National Park are at risk of extensive death across the park due to hotter and drier conditions.⁵⁰ Similarly, changes in the frequency and intensity of rainfall threaten both new and mature saguaro cacti, the namesake species of Saguaro National Park.⁵¹

Warming temperatures are especially apparent in alpine areas across the U.S., which are largely found in protected public lands in the Rockies, Sierra Nevada, Cascade Mountains in the west and the Northern Appalachian and Adirondack Mountains in the east.⁵² They are destination hot spots for recreationists coveted for beautiful alpine meadows, backcountry skiing, and unobstructed views, but decreasing snowfall amounts and duration of winter in high alpine regions is already affecting winter tourism in these areas.⁵³ The importance of snow cover to cold-adapted ecosystems and winter recreation is paramount. The winter ski industry and communities that rely on this seasonal pulse of economic stimulus is essential to many regions of the U.S. including areas with public land access. A warmer winter atmosphere can hold more moisture and result in more snowfall in such conditions, lending to winters overall not necessarily showing strong declines in snowfall with a warming climate.⁵⁴ Many other factors including El Nino, the Arctic and North Atlantic teleconnections can influence winter weather variability, however, evidence is clear in the Northeastern U.S. that winter conditions are weakening. Over the last century there has been a significant trend of less snow and shorter snow seasons.⁵⁵ The importance of reducing GHG emissions now has demonstrated how winter could be saved in the Northeast. Estimates of future winter snow cover by Burakowski et al (2022) show major reductions in snow cover over the next 80+ years under both high-emissions (RCP 8.5) and lower emissions (RCP 4.5) pathways. Across the Northeastern U.S. the number of days with snow cover declined 39 and 23 days respectively. If we reduce emissions, choosing the lower emissions pathway, we could retain on the order of 16 more snow days, a significant amount in this region of the country.

Climate change threatens these mountain top gems with warming temperatures, longer growing seasons, and shorter winters allowing upslope encroachment of treeline and invasive species, and declines of cold-weather adapted species.⁵⁶ Species like the American pika (Ochotona princeps) living at the tops of these mountains quite literally have nowhere to go as global warming affects their high altitude homes. This iconic pika, a small mouse-like creature lives and thrives only at a very narrow habitat range at high elevation cold zones in the western mountains; climate change is threatening the Pika with extinction.⁵⁷

Large scale shifts in alpine plant compositions are occurring as phenological mismatches affect these unique locations. Shifts in seasonal timing of spring warm up disrupts the alignment of plant flowering times with pollinator emergence or arrival, potentially leading to seed/fruit production declines or failure.⁵⁸ Across 5 western alpine sites (Glacier National Park National Park, Yellowstone National Park, Rocky Mountain National Park, Great Sand Dunes National Park and Preserve, and Pecos Wilderness in the Santa Fe National Forest) over nearly 2 decades, plant species have shifted to more shrubs and grasses than forbs (broadleaf herbaceous plants other than grasses) driven by changes in precipitation and warmer temperatures.⁵⁹ In Rocky Mountain NP snowmelt timing is highly correlated with flowering times and risk of frost damage is more prevalent in warmer/early snow melt years leading to less seed production.

Warmer temperatures also threaten freshwater aquatic wildlife. The Appalachian Mountain region, which includes the Appalachian National Scenic Trail, eight national forests, and six national parks, is known for native brook trout that thrive only in cold-water streams that are now directly threatened by rising water temperatures, which will fragment their aquatic habitat and drive thermal stress concerns.⁶⁰ National parks in the Southeast like Shenandoah, Great Smoky Mountains, the Appalachian Scenic Trail as well as Acadia National Park in Maine and other public lands in the Northeast, are critical homes for brook trout, but climate warming is eroding the safe sanctuary that these parks provide.

Iconic species are also being impacted in the northern Appalachians and broader Northern Forest, which covers 26 million acres and is the largest continuous forest east of the Mississippi. This important forest habitat encompasses numerous public lands such as the Appalachian National Scenic Trail, the White and Green Mountain National Forests, and Umbagog National Wildlife Refuge and is home to many cold and snow-dependent species such as moose, pine marten, and Canada lynx. Recent dramatic declines in moose have been documented in ongoing studies in Maine, New Hampshire and Vermont and linked to winter tick, warmer fall and winter due to climate change.^61,62 A study by New Hampshire Fish and Game found that winter ticks are causing increasingly negative impacts to adult female moose productivity. When Northern New England winters start later, more ticks are able to latch on in the fall resulting in more moose calf deaths the following year.⁶³ New Hampshire state biologists are finding that the tick loads are directly related to longer falls and shorter winters. In a very mild winter, 2016, moose calf mortality was 81% and adult mortality 25%.⁶⁴ The biologists expect that as winters become consistently shorter and warmer, more ticks will survive, and calf mortality will likely remain high.⁶⁵

C. Increased Intensity and Frequency of Wildfires Endanger the Public Health and Welfare Benefits Provided by National Parks and Other Public Lands.

Human-caused climate change is intensifying the heat and low humidity that drives extreme wildfires.⁶⁶ Numerous scientific studies have found statistically significant changes in key fire drivers and attributed these changes to human-caused climate change rather than natural variability. For instance, climate change has increased the fire weather season by up to two months⁶⁷ and has doubled the average annual area burned across the western U.S. from 1984 to 2015,⁶⁸ and tripled it in northern and central California from 1996 to 2021.⁶⁹ Climate change also elevates the combustion potential by increasing the aridity of air and soil leading to the degradation of vegetation. Climate change has also reduced post-fire regeneration of montane coniferous forest species such as ponderosa pine and Douglas-fir by half from 1979 to 2015.⁷⁰

While other factors like fuel density play a role in U.S. wildfires, as drought and higher temperatures from climate change increase, the frequency and severity of wildfires are also projected to intensify.⁷¹ Since 1989, U.S. wildfires have burned more than 200 million acres.⁷² Over a 10 year period from 2014 to 2023 wildfires in the U.S. burned on average over 7.0 million acres annually and federal agencies spent an average of $2.7 billion a year on fire suppression.⁷³ In January of 2025, the Greater Los Angeles wildfires wreaked havoc in Southern California, resulting in dozens of lives lost, thousands of structures destroyed, and over 37,000 acres burned, including some areas within the Santa Monica Mountains National Recreation Area.⁷⁴ Moreover, in the summer of 2025 wildfires in the west burned through thousands of acres within Black Canyon of the Gunnison National Park, as well as over a hundred thousand acres in Grand Canyon National Park, where they destroyed historic structures, including the historic Grand Canyon Lodge and North Rim Visitor Center.⁷⁵

Wildfires are degrading national parks’ and forests’ innate beauty and recreational appeal, thereby negatively affecting visitation.⁷⁶ While many public lands are threatened by wildfires, Yellowstone, Glacier, and Rocky Mountain National Parks are projected to experience the highest increase in wildfire incidents.⁷⁷ This heightened incident rate not only jeopardizes the ecological integrity of these parks, but also puts at risk the scenic landscapes, biodiversity, and recreational opportunities that draw millions of visitors to these parks annually.⁷⁸

A decline in visitation and recreation opportunities because of wildfires results in reduced tourism spending, triggering a ripple effect of job and income losses throughout local economies.⁷⁹ For example, the regional economic losses from annual wildfires across Utah’s National Parks, which include Bryce Canyon, Arches, Canyonlands, Capital Reef, and Zion National Parks, are estimated to range from $2.7 million to $4.5 million per year, as well as result in the loss of dozens of jobs.⁸⁰

Wildfires exacerbate climate change directly because forests act as carbon sinks that absorb and store atmospheric carbon for extended periods, but when wildfires occur they can release massive levels of stored carbon back into the atmosphere in a single event.⁸¹ Wildfires in national parks also significantly threaten public health from the resulting smoke.Wildfire smoke includes large quantities of carbon dioxide, particulate matter, and ozone precursors that not only further contribute to climate change but can also cause severe health consequences for park visitors, staff, and communities.⁸² Studies show a direct association between exposure to wildfire smoke and increased rates of asthma, chronic obstructive pulmonary disease, bronchitis, and pneumonia, all of which endanger public health and welfare.⁸³ Moreover, these health risks discourage people from visiting parks, thereby preventing them from reaping the physical and mental health benefits provided by park exploration and recreation.⁸⁴

Additionally, fires can quickly turn deadly, as hotter temperatures and dry conditions can lead to fires exploding and spreading rapidly, limiting the opportunity for people to evacuate and wildlife to escape. This was exemplified by a 2016 fire that started in Great Smoky Mountains National Park, spread rapidly due to high winds and dry weather, burned over 17,000 acres, and tragically took the lives of 14 people.⁸⁵

In addition, wildfires in our public lands disrupt critical ecological processes, causing lasting effects on soil health and water systems. Extreme soil temperatures during intense fires can disturb the soil’s physical and biological properties, potentially leading to long-term ecological degradation.⁸⁶ These changes make the land more vulnerable to erosion and slower to regenerate, threatening the balance of plant and animal life in national parks.⁸⁷ Wildfires also significantly impact water systems, with sediment and ash from burned areas accumulating in streams and rivers.⁸⁸ This runoff carries pollutants that harm aquatic habitats, reduce water clarity, and disrupt ecosystems.⁸⁹

More severe fires can adversely impact species that typically are fire tolerant, such as the giant sequoia trees found in Sequoia and Kings Canyon National Parks. Despite sequoia trees having a fire-adapted life cycle, between 13 to 19 percent of the world’s giant sequoias are estimated to have died in 2020 and 2021 from high-severity fires.⁹⁰

D. Increased Drought Conditions Endanger the Public Health and Welfare Benefits Provided by National Parks and Other Public Lands.

Drought conditions, intensified by climate change, pose a significant threat to the economic, social, and environmental vitality of public lands and natural resources. Water scarcity reduces stream flows and lowers water levels in reservoirs, lakes, and ponds, directly impacting wildlife and visitor activities such as fishing, boating, wildlife viewing and even the availability of drinking water.⁹¹ As with rising temperatures and wildfires, these changes in freshwater availability have cascading economic effects on communities near parks, which depend on visitor spending tied to park-based recreation. Desert parks, such as Death Valley and Joshua Tree National Parks, exemplify this dynamic: during drought years, spring visitation declines due to the diminished presence of wildflowers and wildlife.⁹² Conversely, wet winters can lead to wildflower “super blooms” that attract many visitors, showing the economic and ecological significance of water availability.⁹³

Additionally, drought-driven water scarcity results in lower water levels in lakes and rivers, which limits the availability of water-based recreation activities in mountain parks such as Sequoia and Kings Canyon National Parks, causing reduced summer and fall visitation during drought years.⁹⁴ Visitation to Lake Mead National Recreation Area in Nevada dropped by 25% from 2021 to 2022, and visitor spending dropped by $94 million, the result of significantly lower-than-normal water levels in the lake.⁹⁵

Drought disrupts ecosystems within national parks by degrading soil quality, hindering plant growth, and increasing the loss of native vegetation.⁹⁶ Water scarcity also exacerbates other climate-related challenges, including heightened wildfire risks, invasive species proliferation, and insect outbreaks, all of which harm biodiversity within and around parks.⁹⁷ Even iconic American species like the bison are at risk. Bison are found in several national parks, including Wind Cave National Park in South Dakota, where scientists have observed decreases in bison body size as drought becomes more severe and temperatures increase.⁹⁸

E. Rising Sea Levels Endanger the Public Health and Welfare Benefits Provided by National Parks and Other Public Lands.

Increased temperatures from climate change raise sea level by causing ice on land to melt and water to expand as it warms.⁹⁹ As with the other climate disasters previously discussed, rising sea levels pose significant threats to the economic, social, and environmental benefits that national parks and public lands provide. Global-mean sea level (GMSL) has increased by approximately 1.5 mm yr-1¹⁰⁰,¹⁰¹ over the twentieth century. More specifically, the IPCC (2023)¹⁰² reports that the average rate of sea level rise was 1.3 [0.6 to 2.1] mm yr-1 between 1901 and 1971, increasing to 1.9 [0.8 to 2.9] mm yr-1 between 1971 and 2006, and further increasing to 3.7 [3.2 to 4.2] mm yr-1 between 2006 and 2018 (high confidence). As climate change progresses, additional sea level rise is inevitable, but its severity depends on the future rate of greenhouse gas emissions. The National Park Service manages 88 ocean and Great Lakes parks, including over 11,000 miles of coast and 2.5 million acres of ocean and Great Lakes waters.¹⁰³ The National Park Service estimates that 92% of coastal parks are affected by sea level rise or will be in the future.¹⁰⁴ U.S. Fish and Wildlife Service, which manages 180 marine, coastal, and Great Lakes wildlife refuges, reports sea level rise is already impacting fish and wildlife habitats, including shorebird and sea turtle nesting habitats.

Rising sea levels damage the infrastructure in national public lands. According to a 2015 report by the U.S. Department of the Interior, which surveyed one-third of national park units threatened by sea level rise, 1 meter of sea level rise could place 40 billion dollars of national park assets at risk.¹⁰⁵ That number is likely much higher now when accounting for both the totality of all park units threatened by sea level rise and the increased value of park assets when accounting for inflation.

Sea level rise endangers numerous historic locations protected as national park units. In 2019, the National Trust for Historic Preservation listed Washington D.C.’s Tidal Basin as one of America’s 11 most endangered historic places.¹⁰⁶ Twice a day during high tide, water from the Potomac River flows over the sea wall, in part because of sea level rise.¹⁰⁷ The flooding threatens the cherry trees that have lined the Tidal Basin inside of the National Mall and Memorial Parks for more than a century by exposing their roots to salty water.¹⁰⁸ In 2024, the National Park Service began a $113 million restoration project that required cutting down over 150 of these historic trees due to the persistent flooding.¹⁰⁹

Rising sea levels cause saltwater intrusion into freshwater resources and endanger coastal areas through increased shoreline erosion, coastal flooding, aquifer and soil contamination, and lost wildlife habitat.¹¹⁰ Because Everglades National Park is an ecosystem that requires both salt and freshwater and much of its landscape is less than 1.5 meters above sea level, it is particularly vulnerable to rising sea levels that may alter the freshwater-saltwater balance.¹¹¹ Increased saltwater levels impact freshwater wetland habitats within the namesake Everglades ecosystem by degrading roots, promoting erosion, and limiting the areas where freshwater species can grow.¹¹² Effects of saltwater intrusion on the distribution of the mangrove forests have already been observed in the park.¹¹³ Many rare species, including endangered species found only in southern Florida, are threatened by the salinization of groundwater and soil. And, increased salinization risks contaminating the Biscayne Aquifer, which serves as South Florida’s primary source of drinking water.¹¹⁴ According to a USGS 2020 report the Mississippi delta region, with 7 National Wildlife Refuges, has some of the highest rate of relative sea level rise in the world raising salinity and flooding.

V. Conclusion

Global climate change, driven by the enormous levels of GHG emissions from fossil fuel-fired EGUs, is unquestionably endangering public health, welfare and the vitality of our national parks and public lands. EGU GHG pollution causes significant harm to our national parks, national forests, and other public lands, and calls their long term viability into question. We urge EPA to discard this ill conceived and legally flawed Proposal and keep in place the existing findings on the agency’s authorities under CAA § 111 to regulate GHGs from the U.S. power generation sector in order to protect the health and wellbeing of our national parks, public lands and all the people who enjoy them.

Sincerely,

Ulla Reeves
Clean Air Program Director
National Parks Conservation Association

Emily Thompson
Executive Director
Coalition to Protect America’s National Parks

Georgia Murray
Senior Scientist
Appalachian Mountain Club

Footnotes

1. Danielle Buttke, Diana Allen, and Chuck Higgins, Benefits of Biodiversity to Human Health and Well-Being, 31 Park Science (2014), https://perma.cc/HQC2-4VTK, (“Benefits of Biodiversity”) (Attached as Ex. 1).

   ↩

2. Am. Elec. Power Co., Inc. v. Connecticut, 564 U.S. 410, 424, 428 (2011). See also, Coalition for Responsible Regulation v. EPA, 684 F.3d 102, 118-19 (D.C. Cir. 2012) and American Lung Association v. EPA, 985 F.3d 914, 935 (D.C. Cir. 2021).

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3. See generally, Intergovernmental Panel on Climate Change [IPCC], AR6 Synthesis Report: Climate Change 2023 (2023), https://www.ipcc.ch/report/ar6/syr/downloads/report/IPCC_AR6_SYR_FullVolume.pdf.

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4. EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2022 – Executive Summary, www.epa.gov/system/files/documents/2024-04/us-ghg-inventory2024-chapter-executive-summary_04-16-2024.pdf.

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5. See Proposal at 59038. See also, EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2022 – Executive Summary, www.epa.gov/system/files/documents/2024-04/us-ghg-inventory2024-chapter-executive-summary_04-16-2024.pdf.

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6. Moseman, Andrew, Why do we compare methane to carbon dioxide over a 100-year timeframe? Are we underrating the importance of methane emissions?, MIT Climate Portal (August 8, 2025), available at, https://climate.mit.edu/ask-mit/why-do-we-compare-methane-carbon-dioxide-over-100-year-timeframe-are-we-underrating.

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7. Press Release, Nat. Res. Defense Council, Coal Pollution Spiked After Trump Administration’s “Free Pass to Pollute” (Feb. 26, 2026), https://www.nrdc.org/press-releases/coal-pollution-spiked-after-trump-administrations-free-pass-pollute.

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8. IPCC, supra note 3, at 12-22.

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9. Armstrong-McKay et al., Exceeding 1.5°C global warming could trigger multiple climate tipping points, Science 377 (2022), available at, DOI:10.1126/science.abn7950 (Attached As Ex. 2).

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10. Patrick Gonzalez, et al., Disproportionate Magnitude of Climate Change in United States National Parks, 13 Envtl. Res. Letters. 6 (2018), available at https://iopscience.iop.org/article/10.1088/1748-9326/aade09 (Attached as Ex 3).

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11. Diaz et al., Pervasive human-driven decline of life on Earth points to the need for transformative change, Vol 366, Issue 6471 (2019) https://doi.org/10.1126/science.aax3100] (Attached as Ex. 4).

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12. Buttke, Benefits of Biodiversity.

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13. 42 U.S.C. § 7602(h).

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14. Nat. Park Serv. Public Interest in National Parks Remains Strong as Visits Top 323 Million in 2025 (March 13, 2026), https://www.nps.gov/orgs/1207/03-13-26-2025-visitation-statsitics.htm. See also, Flyr, Matthew et. al., 2023 National Park Visitor Spending Effects, Nat’l Park Serv. 11 (2024), https://doi.org/10.36967/2305351 (Click on “NPS_2023_Visitor_Spending_Effects.pdf”) (“2023 Park Visitor Spending”) (Attached as Ex. 5).

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15. U.S. Forest Service, National Visitor Use Monitoring Survey Results National Summary Report, (September 2023) www.fs.usda.gov/sites/default/files/2022-National-Visitor-Use-Monitoring-Summary-Report.pdf (Attached as Ex. 6).

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16. IPCC, Climate change 2022: Impacts, adaptation, and vulnerability, Cambridge University Press (2022), https://www.ipcc.ch/report/ar6/wg2.

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17. Supra note 3, at 6.

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18. Gonzalez, supra note 10, at 3..

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19. Patrick Gonzalez, Human-Caused Climate Change in United States National Parks and Solutions for the Future, 36 Parks Stewardship Forum 188 (2020), https://escholarship.org/uc/psf, (Attached as Ex. 7).

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20. Id.

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21. Daniel Orozco et al., Polluted Parks, Nat’l Parks Conservation Ass’n. 13 (2024), https://www.npca.org/reports/air-climate-report (Herinafter “Polluted Parks”) (Attached as Ex. 8).

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22. Michalak JL Et. Al. A strategic analysis of climate vulnerability of national park resources and values. Natural Resource Report, Nat’l Park Serv. (2021) https://doi.org/10.36967/nrr-2287214 (Attached as Ex. 9). See also, Polluted Parks.

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23. See generally, Forster, Piers M., et al. Indicators of Global Climate Change 2024: annual update of key indicators of the state of the climate system and human influence, Earth System Science Data Discussions (2025) at 1-72 (attached as Ex. 10).

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24. Gonzalez, Supra note 10 at 7.

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25. Buttke, Danielle et. al., Predicting Climate-Change Induced Heat-Related Illness Risk in Grand Canyon National Park Visitors, 18 PLoS One 1, 2, 9 (2023), https://perma.cc/P7NN-T6CY (Attached as Ex. 11).

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26. Climate Change: Park Visitation and Climate Change, Nat’l Park Serv. (Aug. 12, 2024), https://perma.cc/T5KG-UUTV (Attached as Ex. 12).

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27. Climate Change Indicators: U.S. and Global Precipitation, Envtl. Prot. Agency (June 27, 2024), https://perma.cc/QW8W-ZD8D (Attached as Ex. 13).

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28. Id.

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29. Id. at 2.

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30. Jacobo, Julia, Deaths Due to Extreme Heat at National Parks Increasing, Data from the National Parks Service Shows, ABC News (July 26, 2023), https://perma.cc/FVJ8-2T5R (Attached as Ex. 14).

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31. NPS, Flooding and Climate Change, Nat’l Park Serv. (Dec. 8, 2021), https://perma.cc/EGJ6-842T (Attached as Ex. 15).

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32. Yellowstone National Park: Flood Recovery, and Operations, Nat’l Park Serv. (Dec. 13, 2023), https://www.nps.gov/yell/planyourvisit/flood-recovery.htm.

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33. Id.

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34. Post-Flood Yellowstone Rebuilding Could Cost More Than $1 Billion, 360 Yale Env’t. (June 22, 2022), https://perma.cc/J3SH-58YJ; see also, Laurenz Busch, Yellowstone National Park Gets $16M for Flood Repair, Resilient Infrastructure, Bozeman Daily Chronicle (Jan. 25, 2024), https://perma.cc/S2VZ-U8M2.

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35. Linda Coutant, Helene: Facing Loss and the Blue Ridge Parkway’s “Most Tremendous Challenge,” Nat’l Parks Conservation Ass’n (Oct. 29, 2024), https://perma.cc/6D34-FHGE.

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36. Id.

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37. Abby Hassler, The Long Trail Back: Public Lands Recovery After Hurricane Helene, The Appalacian Voice (july, 24 2025), appvoices.org/2025/07/24/public-lands-recovery-after-hurricane-helene/. See also, Helene Impacts and Recovery – Blue Ridge Parkway, Nat’l Park Serv., www.nps.gov/blri/planyourvisit/helene-impacts-and-recovery.htm.

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38. Phil Francis, Opinion: Trump administration cuts to National Park Service threaten NC economy, The Citizen-TImes (Sept, 14 2025) www.citizen-times.com/story/opinion/2025/09/14/opinion-trump-park-service-cuts-threaten-blue-ridge-parkway-repairs/86074466007/.

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39. Hughes et al., Spatial and temporal patterns of mass bleaching of corals in the Anthropocene, Science 359,80-83(2018).DOI:10.1126/science.aan8048 (Attached as Ex. 16).

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40. Rivera, Hanny, et al., Coral Reefs Are Critical for Our Food Supply, Tourism, and Ocean Health. We Can Protect Them from Climate Change, MIT Science Policy Review (Aug. 20, 2020), https://perma.cc/2TMF-YD5J (Attached as Ex. 17).

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41. Id.

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42. Id.

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43. NPS, Biscayne National Park to Receive Funding from the Inflation Reduction Act, Nat’l Park Serv. (Mar. 6, 2024), https://perma.cc/B8VG-4WYE.

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44. Early, et. al., Global threats from invasive alien species in the twenty-first century and national response capacities, Nat. Commun. 7, 12485 (2016), https://doi.org/10.1038/ncomms12485 (Attached as Ex. 18).

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45. Climate Impact: Invasive Species, Nat‘l Parks Conservation Ass‘n., https://perma.cc/2PRW-UJWJ (last visited Dec. 18, 2024).

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46. Maxence Gérard et al., Global Warming and Plant–Pollinator Mismatches, Emerging Top Life Sci. 77, 79 (Apr. 1, 2020), https://perma.cc/8BCM-KGD7 (Attached as Ex. 19).

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47. Yang, Yuguang et. al., Time delays modulate the stability of complex ecosystems, Ecol. Evol. 7, 1610–1619 (2023), available at, https://doi.org/10.1038/s41559-023-02158-x (Attached as Ex. 20)

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48. Glacier’s Glaciers: Are the Glaciers Shrinking? Nat’l Park Serv. (Aug. 12, 2024), https://perma.cc/F6A3-RB7C.

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49. Northern Rocky Mountain Science Center, Status of Glaciers in Glacier National Park, U.S. Geological Survey (Apr. 6, 2016), https://perma.cc/KRE6-8T2N (Attached as Ex. 21).

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50. Sweet et al. Congruence between future distribution models and empirical data for an iconic species at Joshua Tree National Park, Ecosphere Vo. 10 Iss. 6 (2019) https://doi.org/10.1002/ecs2.2763 (Attached as Ex. 22).

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51. EPA, Climate Change Connections: Arizona (Saguaro Cactus), Envtl. Prot. Agency (Nov. 8, 2024), https://perma.cc/U8CG-354X (Attached as Ex. 23).

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52. Specific regions are the Zirkel Wilderness, Rocky Mountain National Park in Colorado, the Beartooth Mountains on the Montana-Wyoming border, and the North Cascades in Washington.

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53. Yang, Xiao-Hong et. al., Impact of climate change on ski tourism and its adaptation research: Progress and prospects, Advances in Climate Change Research (2026), Available at, https://doi.org/10.1016/j.accre.2026.09.013 (Attached as Ex. 24).

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54. Burakowski, Elizabeth et. al., Future of Winter in Northeastern North America: Climate Indicators Portray Warming and Snow Loss That Will Impact Ecosystems and Communities, Northeastern Naturalist 28(sp11), 180-207, (2 February 2022). https://doi.org/10.1656/045.028.s1112 (Attached as Ex. 24).

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55. Contosta, A. R., et. al., Northern forest winters have lost cold, snowy conditions that are important for ecosystems and human communities, Ecological Applications 29(7) (2019) https://doi.org/10.1002/eap.1974 (Attached as Ex. 25), See also, Murray, G.L.D., et. al., Climate Trends on the Highest Peak of the Northeast: Mount Washington, NH, Northeastern Naturalist, 28 (sp11), 64-82, (9 July 2021). https://doi.org/10.1656/045.028.s1105 (Attached as Ex. 26).

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56. Tourville, J., Publicover, D., & Dovciak, M. (2023). Forests on the move: Tracking climate-related treeline changes in mountains of the northeastern United States, Journal of Biogeography, 50, 1993–2007. https://doi.org/10.1111/jbi.14708 (Attached as Ex. 72); see also, Murray, supra note 55 at 64-82, see also, Sperduto, D., et. al., Non-native vascular flora of alpine areas in the White Mountains, New Hampshire, USA, Arctic, Antarctic, and Alpine Research, 55(1), (2023), available at, https://doi.org/10.1080/15230430.2023.2243704 (Attached as Ex. 28).

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57. Moritz, Craig, et al., Impact of a Century of Climate Change on Small-Mammal Communities in Yosemite National Park, USA, 322 Science 261, 261–64 (2008), available at http://www.jstor.org/stable/20145010 (Attached as Ex. 29).

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58. Inouye, D. W., Climate change and phenology. WIREs Climate Change, 13(3), e764 (2022), https://doi.org/10.1002/wcc.764 (Attached as Ex. 30).

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59. NPS, Change in Alpine Vegetation in the U.S. Rocky Mountains: Analysis of Data from Five GLORIA Sites, 2003–2021, Nat’l Park Serv., https://www.nps.gov/articles/000/nrca_gloria2025.htm, last visited 7/27/2025 (Attached as Ex. 31).

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60. Snyder, Craig, et al., Accounting for Groundwater in Stream Fish Thermal Habitat Responses to Climate Change, 25 Ecological Soc’y. of Am. 1397, 1397 (2015) (Attached as Ex. 32).

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61. Jones, Henry, et. al., Mortality assessment of moose (Alces alces) calves during successive years of winter tick (Dermacentor albipictus) epizootics in New Hampshire and Maine (USA), Canadian Journal of Zoology. 97(1): 22-30 (2019) https://doi.org/10.1139/cjz-2018-0140 (Attached as Ex. 33).

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62. Debow, J., et. al., Effects of Winter Ticks and Internal Parasites on Moose Survival in Vermont, USA, Jour. Wild. Mgmt., 85: 1423-1439 (2021) https://doi.org/10.1002/jwmg.22101(Attached as Ex. 34).

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63. Jones, supra note 61 at 22-30.

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64. Eric Orff, Here’s why we are losing our moose herd, Fosters Daily Democrat (Sept. 2, 2016),

    https://www.fosters.com/story/opinion/2016/09/02/heres-why-we-are-losing-our-moose-herd/25528251007/.

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65. N.H. Fish and Game, Moose in New Hampshire, https://www.wildlife.nh.gov/wildlife-and-habitat/moose-new-hampshire (last visited Oct. 29, 2026).

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66. Gonzalez, P., Wildfire, Climate Change, Forest Resilience, and Carbon Solutions, Parks Stewardship Forum, 39(3) (2023) http://dx.doi.org/10.5070/P539362026 (Attached as Ex. 35).

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67. Zhuang, Y., et. al. Quantifying contributions of natural variability and anthropogenic forcings on increased fire weather risk over the western United States, Proceedings of the National Academy of Sciences of the USA 118: e2111875118 (2021) https://doi.org/10.1073/pnas.2111875118 (Attached as Ex. 36).

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68. Abatzoglou, J.T., et.al., Projected increases in western US forest fire despite growing fuel constraints, Communications Earth and Environment 2: 227 (2021 ) https://doi.org/10.1038/s43247-021-00299-0 (Attached as Ex. 37).

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69. Turco, M., et. al., Anthropogenic climate change impacts exacerbate summer forest fires in California, Proceedings of the National Academy of Sciences of the USA 120: e2213815120 (2023) https://doi.org/10.1073/pnas.2213815120 (Attached as Ex. 38).

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70. Davis, K.T., et.al., Wildfires and climate change push low-elevation forests across a critical climate threshold for tree regeneration, Proceedings of the National Academy of Sciences of the USA 116, 6193–6198 (2019) https://doi.org/10.1073/pnas.1815107116 (Attached as Ex. 39).

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71. Jones, Matthew, et al., State of Wildfires 2023-2024, 16 Earth System Science Data 3601, 3603 (2024), https://perma.cc/6HA4-YSHK (“State of Wildfires”). (Attached as Ex 40).

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72. Suppression Costs, Nat’l Interagency Fire Ctr., https://perma.cc/AU6Y-5CN3 (last visited Jan. 8, 2025).

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73. Id.

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74. Los Angeles Times, California Wildfires Map, https://www.latimes.com/wildfires-map/ (last visited Jan. 13, 2025).

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75. Status of Black Canyon of the Gunnison National Park, Nat’l Park Serv., (July 18, 2025) www.nps.gov/blca/learn/news/status-of-black-canyon-of-the-gunnison-national-park.htm; see also, Status of the North Rim, Nat’l Park Serv. www.nps.gov/grca/northrimstatus.htm.

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76. Man-Keun Kim & Paul M. Jakus, Wildfire, National Park Visitation, and Changes in Regional Economic Activity, 26 J. Outdoor Recreation & Tourism, 34, 35 (2019), https://perma.cc/YUL4-QZPT (Attached as Ex. 41).

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77. Climate Impact: Fire, Nat’l Parks Conservation Ass’n, https://perma.cc/6GFF-XVDZ (last visited Oct. 29, 2025).

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78. Yellowstone saw over 4.5 million visitors in 2023, while Glacier and Rocky Mountain National Parks attracted approximately 2.9 million and 4 million, respectively. See also, Flyr supra note 5 at 27, 35, & 39.

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79. Kim, supra note 76 at 35.

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80. Id. at 34.

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81. Confronting the Wildfire Crisis at 16.

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82. Id; Cascio, Wayne, Wildland Fire Smoke and Human Health, 624 Sci Total Envtl., 3 (2018), https://perma.cc/Z9F8-G5L4 (“Wildland Fire Smoke”) (Attached as Ex. 42).

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83. Cascio, supra note 82 at 3; see also 42 U.S.C. §§ 7521(a)(1), 7602(h).

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84. Buttke, supra note 1.

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85. Kelly Ann Krueger, Remembering the Gatlinburg Wildfires Five Years Later, WVLT8 (Nov. 28, 2021), available at, https://www.wvlt.tv/2021/11/28/remembering-gatlinburg-wildfires-five-years-later/.

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86. Agbeshie, Alex, et al., A Review of the Effects of Forest Fire on Soil Properties, 33 J. For. Res. 1419, 1420 (2022), https://perma.cc/SY7H-E7HK (Attached as Ex. 43).

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87. Id.

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88. Paige, Ginger et.al,, The Science Behind Wildfire Effects on Water Quality, Erosion, Living With Wildfire in Wyoming 31, 32–33 (2013), https://perma.cc/7J9X-WD9E (Attached as Ex. 44).

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89. Id.

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90. Giant Sequoias Face New Threats, Nat’l Park Serv. (Feb. 24, 2022), www.nps.gov/articles/000/giant-sequoias-face-new-threats.htm.

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91. Jeffrey Jenkins et al., Visitation to National Parks in California Shows Annual and Seasonal Change During Extreme Drought and Wet Years, PLOS Climate, 3 (Aug. 9, 2023) https://perma.cc/3ZSA-G4ET (“Drought and Visitation”) (Attached as Ex. 45). See also, NPS, How the NPS is protecting groundwater for people and ecosystems, www.nps.gov/articles/how-the-nps-is-protecting-groundwater-for-people-and-ecosystems.htm.

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92. Id. at 12-13.

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93. Id. at 14-15.

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94. John Abtazoglou, New Research Shows Impacts of Drought on National Park Visitation, Nat’l. Integrated Drought Info. Sys. (Jan. 24, 2024), https://perma.cc/E5BF-8CAS (Attached as Ex. 46).

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95. Jarah Wright, Lake Mead Visitor Spending Drops by $94 million in One Year, According to Report, KTNV Las Vegas (Aug. 22, 2023), https://perma.cc/R5YP-FP76.

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96. Sarah R. Weiskopf et al., Climate Change Effects on Biodiversity, Ecosystems, Ecosystem Services, and Natural Resource Management in the United States, 733 Sci. of the Total Envt. 1, 6 (2020), https://perma.cc/7PQB-3PSU (“Climate Change and Biodiversity”) (Attached as Ex. 47).

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97. Id.

    ↩

98. Jeff Martin et al., Decadal Heat and Drought Drive Body Size of North American Bison (Bison bison) Along the Great Plains, Ecology and Evolution 336, 344 (2019) https://onlinelibrary.wiley.com/doi/epdf/10.1002/ece3.5898 (Attached as Ex. 48).

    ↩

99. Frederikse, T., et al., The causes of sea-level rise since 1900, Nature 584: 393-397 (2020) https://doi.org/10.1038/s41586-020-2591-3 (Attached as Ex. 49).

    ↩

100. Oppenheimer, M. et al., IPCC Special Report on the Ocean and Cryosphere in a Changing Climate, Cambridge University Press,321–445 (2019) www.ipcc.ch/site/assets/uploads/sites/3/2022/03/06_SROCC_Ch04_FINAL.pdf.

     ↩

101. Hay, C. et. al., Probabilistic reanalysis of twentieth- century sea-level rise, Nature 517, 481–484 (2015) https://doi.org/10.1038/nature14093, (Attached as Ex. 50).

     ↩

102. IPCC, IPCC AR6 Synthesis Report.

     ↩

103. Ocean and Coastal Resources, Nat’l Park Serv. Coastal Resources Div.

     ↩

104. Id.

     ↩

105. DOI, Interior Department Releases Report Detailing $40 Billion of National Park Assets at Risk from Sea Level Rise, U.S. Dep’t Of The Interior (Jun. 23, 2015), https://perma.cc/79S2-KXQT (Attached as Ex. 51).

     ↩

106. Discover America’s 11 Most Endangered Historic Places for 2019, Nat’l Tr. For Historic Preservation (2019), https://perma.cc/PL8J-ZX7Q.

     ↩

107. Andrew Moore, Cherry Blossoms Reflects Troubling Future for Coastal Forests, NC State College of Natural Resources News (Apr. 8, 2024), https://perma.cc/BTJ2-PCZ3 (“Troubling Future”) (Attached as Ex. 52).

     ↩

108. Id.

     ↩

109. Id.

     ↩

110. Christina Nunez, Sea Level Rise, Explained, Nat. Geographic (Feb. 19, 2019), https://perma.cc/S6FT-GWDU.

     ↩

111. Shimelis B. Dessu et al., Effects of Sea Level Rise and Freshwater Management on Long-Term Water Levels and Water Quality in the Florida Coastal Everglades, 211 J. Envtl. Mgmt. 164, 174 (2018), https://www.sciencedirect.com/science/article/pii/S0301479718300252 (Attached as Ex. 53).

     ↩

112. Id. at 164.

     ↩

113. Ken W. Krauss et al., Sea-Level Rise and Landscape Change Influence Mangrove Encroachment into Marsh in the Ten Thousand Island Region of Florida, USA, J. Coastal Conservation 629, 632 (2011), https://perma.cc/U237-42YZ (Attached as Ex. 54).

     ↩

114. Climate Change Connections: Florida (The Everglades), Envtl. Prot. Agency (Nov. 8, 2024), https://perma.cc/SP8D-PQZ8.

     ↩

TABLE OF EXHIBITS

Exhibit No.	Description
1	Danielle Buttke, Diana Allen, and Chuck Higgins, Benefits of Biodiversity to Human Health and Well-Being
2	Armstrong-McKay et al., Exceeding 1.5°C global warming could trigger multiple climate tipping points, Science
3	Patrick Gonzalez et al., Disproportionate Magnitude of Climate Change in United States National Parks
4	Diaz et al., Pervasive human-driven decline of life on Earth points to the need for transformative change
5	Flyr, Matthew et. al., 2023 National Park Visitor Spending Effects, Nat’l Park Serv.
6	U.S. Forest Service, National Visitor Use Monitoring Survey Results National Summary Report
7	Patrick Gonzalez, Human-Caused Climate Change in United States National Parks and Solutions for the Future, Parks Stewardship Forum
8	Daniel Orozco et al., Polluted Parks, Nat’l Parks Conservation Ass’n
9	Michalak JL Et. Al. A strategic analysis of climate vulnerability of national park resources and values, Natural Resource Report
10	Forster, Piers M., et al. Indicators of Global Climate Change 2024: annual update of key indicators of the state of the climate system and human influence, Earth System Science Data Discussions
11	Danielle E. Buttke et al., Predicting Climate-Change Induced Heat-Related Illness Risk in Grand Canyon National Park Visitors
12	NPS, Climate Change: Park Visitation and Climate Change, Nat’l Park Serv.
13	EPA, Climate Change Indicators: U.S. and Global Precipitation, Envtl. Prot. Agency
14	Julia Jacobo, Deaths Due to Extreme Heat at National Parks Increasing, Data from the National Parks Service Shows, ABC News
15	NPS, Flooding and Climate Change, Nat’l Park Serv.
16	Hughes et al., Spatial and temporal patterns of mass bleaching of corals in the Anthropocene, Science
17	Rivera, Hanny, et al., Coral Reefs Are Critical for Our Food Supply, Tourism, and Ocean Health. We Can Protect Them from Climate Change, MIT Science Policy Review
18	Early, et. al., Global threats from invasive alien species in the twenty-first century and national response capacities, Nat. Commun.
19	Maxence Gérard et al., Global Warming and Plant–Pollinator Mismatches, Emerging Top Life Sci.
20	Yang, Yuguang et. al., Time delays modulate the stability of complex ecosystems, at Ecol. Evol.
21	Northern Rocky Mountain Science Center, Status of Glaciers in Glacier National Park, U.S. Geological Survey
22	Sweet et al. Congruence between future distribution models and empirical data for an iconic species at Joshua Tree National Park, Ecosphere
23	EPA, Climate Change Connections: Arizona (Saguaro Cactus), Envtl. Prot. Agency
24	Burakowski, Elizabeth et. al., Future of Winter in Northeastern North America: Climate Indicators Portray Warming and Snow Loss That Will Impact Ecosystems and Communities, Northeastern Naturalist
25	Contosta, A. R., et. al., Northern forest winters have lost cold, snowy conditions that are important for ecosystems and human communities, Ecological Applications
26	Murray,G.L.D., et.al, Climate Trends on the Highest Peak of the Northeast: Mount Washington, NH, Northeastern Naturalist
27	Tourville, J., Publicover, D., & Dovciak, M. (2023). Forests on the move: Tracking climate-related treeline changes in mountains of the northeastern United States, Journal of Biogeography
28	Sperduto, D. D., Nichols, W. F., & Jones, M. T. (2023). Non-native vascular flora of alpine areas in the White Mountains, New Hampshire, USA, Arctic, Antarctic, and Alpine Research
29	Moritz, Craig, et al., Impact of a Century of Climate Change on Small-Mammal Communities in Yosemite National Park, USA
30	Inouye, D. W., Climate change and phenology, WIREs Climate Change
31	NPS, Change in Alpine Vegetation in the U.S. Rocky Mountains: Analysis of Data from Five GLORIA Sites, 2003–2021, Nat’l Park Serv.
32	Snyder, Craig, et al., Accounting for Groundwater in Stream Fish Thermal Habitat Responses to Climate Change, Ecological Soc’y. of Am.
33	Jones, H. et. al., Mortality assessment of moose (Alces alces) calves during successive years of winter tick (Dermacentor albipictus) epizootics in New Hampshire and Maine (USA), Canadian Journal of Zoology
34	Debow, J., et. al.,, Effects of Winter Ticks and Internal Parasites on Moose Survival in Vermont, USA. Jour. Wild. Mgmt.
35	Gonzalez, P., Wildfire, Climate Change, Forest Resilience, and Carbon Solutions, Parks Stewardship Forum
36	Zhuang, Y., et. al. Quantifying contributions of natural variability and anthropogenic forcings on increased fire weather risk over the western United States, Proceedings of the National Academy of Sciences of the USA
37	Abatzoglou, J.T., et.al., Projected increases in western US forest fire despite growing fuel constraints, Communications Earth and Environment
38	Turco, M., et. al., Anthropogenic climate change impacts exacerbate summer forest fires in California, Proceedings of the National Academy of Sciences of the USA
39	Davis, K.T., et.al., Wildfires and climate change push low-elevation forests across a critical climate threshold for tree regeneration, Proceedings of the National Academy of Sciences of the USA
40	Jones, Matthew, et al., State of Wildfires 2023-2024, Earth System Science Data
41	Kim, Man-Keun, et. al.,, Wildfire, National Park Visitation, and Changes in Regional Economic Activity, J. Outdoor Recreation & Tourism
42	Cascio, Wayne, Wildland Fire Smoke and Human Health, Sci Total Envtl.
43	Agbeshie, Alex, et al., A Review of the Effects of Forest Fire on Soil Properties, J. For. Res.
44	Paig, Ginger, et. al., The Science Behind Wildfire Effects on Water Quality, Erosion, Living With Wildfire in Wyoming
45	Jeffrey Jenkins et al., Visitation to National Parks in California Shows Annual and Seasonal Change During Extreme Drought and Wet Years, PLOS Climate
46	John Abtazoglou, New Research Shows Impacts of Drought on National Park Visitation, Nat’l. Integrated Drought Info. Sys.
47	Sarah R. Weiskopf et al., Climate Change Effects on Biodiversity, Ecosystems, Ecosystem Services, and Natural Resource Management in the United States
48	Jeff Martin et al., Decadal Heat and Drought Drive Body Size of North American Bison (Bison bison) Along the Great Plains, Ecology and Evolution
49	Frederikse, T., et al., The causes of sea-level rise since 1900, Nature
50	Hay, C. et. al., Probabilistic reanalysis of twentieth- century sea-level rise, Nature
51	U.S. Dep’t Of The Interior, Interior Department Releases Report Detailing $40 Billion of National Park Assets at Risk from Sea Level Rise
52	Andrew Moore, Cherry Blossoms Reflects Troubling Future for Coastal Forests, NC State College of Natural Resources News
53	Shimelis B. Dessu et al., Effects of Sea Level Rise and Freshwater Management on Long-Term Water Levels and Water Quality in the Florida Coastal Everglades
54	Ken W. Krauss et al., Sea-Level Rise and Landscape Change Influence Mangrove Encroachment into Marsh in the Ten Thousand Island Region of Florida, USA, J. Coastal Conservation