Indian Legal Clinic submits comment to the EPA

On Sept. 22, the Indian Legal Clinic (ILC) submitted a public comment to the U.S. Environmental Protection Agency (EPA) on the “Proposed Rule: Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.” The Endangerment Finding serves as the foundation for regulating emissions from new motor vehicles and engines.

The ILC emphasized that for Tribal Nations, the EPA’s duty to regulate greenhouse gases carries heightened significance. Climate change continues to impose disproportionate burdens on Tribal communities, threatening public health, cultural practices and treaty-reserved resources. The EPA itself has recognized that American Indian and Alaska Native populations face elevated risks from flooding, extreme heat and displacement — impacts that compound existing inequities and health disparities. The clinic previously hosted a conference addressing climate threats and challenges facing Tribal communities and published a report summarizing the proceedings.  

Student attorney Sam Phillips (3L) drafted the comment to support the EPA reaffirming and maintaining the 2009 Endangerment Finding in full and strong greenhouse gas and vehicle standards to fulfill statutory mandates, uphold judicial precedent, honor trust and treaty obligations and protect the public health and cultural heritage of Tribal Nations.

“This experience gave me a better understanding of how federal Indian law, environmental law and administrative law must work together for justice,” Phillips said. “It reinforced that a careful process that includes both Indigenous and Western science is the backbone of durable climate protections. It also deepened my commitment to tribal advocacy by showing how sovereignty, consultation and Tribal expertise belong at the heart of federal rulemaking.”

The ILC offers students the opportunity to apply classroom learning to real-world advocacy that makes a difference for Tribal communities. Through hands-on work in areas such as environmental protection, sovereignty and federal policy, students gain the experience and confidence to become strong advocates for justice and self-determination across Indian Country.

Written by Danielle Williams