ACTION ALERT: Oppose EPA Rollbacks of Carbon Pollution Safeguards
Submit a public comment opposing the proposed rule by the U.S. Environmental Protection Agency (EPA) to repeal limits on carbon emissions produced by power plants and weaken critical environmental protections.
Public comment due 8/7/25
T37A2 Inky in front of the Cherry Point Refinery. Taken by Tamara Kelley
What is happening and why it matters?
Earlier this month, the U.S. Environmental Protection Agency (EPA) announced a proposal to repeal federal rules that limit carbon emissions from fossil fuel-burning power plants. These standards—developed under the Clean Air Act—were designed to reduce greenhouse gas emissions and support a transition to cleaner, more sustainable energy sources.
Under the new proposal, the EPA would:
Repeal existing carbon dioxide (CO₂) limits for both new and existing fossil fuel power plants
Remove the legal finding that the power sector’s greenhouse gas emissions “significantly contribute” to climate pollution
Dismiss carbon capture and storage (CCS) technology as a viable pollution control method
Eliminate requirements for states to submit emissions reduction plans
The agency argues that repealing these rules will reduce costs for the power sector. However, energy and climate experts have pointed out that many renewable options—like wind and solar—are already less expensive than fossil fuels for both providers and consumers. Rolling back emission protections could increase long-term health and climate costs, while undermining progress already underway.
How will this impact orcas and salmon?
For the critically endangered Southern Resident killer whales (SRKWs), the implications of climate policy rollbacks are not abstract—they are direct and immediate.
Southern Resident orcas depend almost exclusively on Chinook salmon, whose populations are already under significant pressure from habitat loss, warming waters, and reduced streamflow. Events like the 2021 heat dome in the Pacific Northwest caused severe river warming and low flows, leading to mass salmon die-offs before they could spawn. Without strong action to limit greenhouse gas emissions, these types of extreme weather events are projected to increase in both frequency and severity.
T99 Barakat with fire smoke in the background. Taken by Tamara Kelley
A recent SR3 study found that nearly one-third of the Southern Resident population is now in poor body condition, signaling chronic food stress—especially among reproductive-age females and juveniles.
If finalized, this EPA proposal would be yet another devastating blow to the recovery efforts of orcas and salmon. By removing key federal protections that help limit carbon emissions from one of the largest polluting sectors in the U.S., we risk exacerbating stress on already struggling populations.
How to submit a public comment:
You can submit a comment directly on the Federal Register website:
https://www.federalregister.gov/documents/2025/06/17/2025-10991/repeal-of-greenhouse-gas-emissions-standards-for-fossil-fuel-fired-electric-generating-units
Tips for public comment:
Be respectful and polite in your comments, emails, or phone calls.
Get personal, share your experiences, and explain why you care. Personal messages carry more sentiment and weight, which are more meaningful and can have a bigger impact on policymakers.
Avoid pre-written copy-and-paste templates. New practices make it so that pre-written templates only get counted once. Meaning if multiple people submit the same comment, letter, or email, it will only be recorded once. Make it personal and unique to make sure it is counted.
Cite resources and relevant data that support your comment. Scientific publications referenced in public comments MUST be addressed by policymakers and make for a strong public comment.
Suggested talking points:
The Southern Resident killer whales depend on Chinook salmon, which are particularly vulnerable to climate change. Droughts combined with loss of snowpack to feed and cool rivers during warmer months make rivers shallow, causing salmon to be more susceptible to predators.
Chinook are cold-water fish with optimal temperatures for migration and spawning between 50°F–60°F (10°C–15.5°C). Rising air temperatures will result in warming water temperatures, which pose a major threat to salmon and other cold-water species. Temperatures above 64°F (18°C), cause moderate thermal stress, which can affect salmon’s ability to migrate, feed, and spawn. Temperatures above 68°F (20°C) are considered acutely stressful, reducing oxygen availability and increasing metabolic demands, which may halt migration, cause salmon to become more vulnerable to disease, or even die before spawning. Temperatures around 72°F (22°C) or higher are lethal to salmon.
Salmon are a keystone species, which means their presence has a disproportionately large impact on the health and stability of the entire ecosystem. As anadromous fish, salmon transport marine nutrients inland when they return to freshwater streams to spawn. After spawning, their carcasses decompose and provide essential nutrients—like nitrogen and phosphorus—that support the growth of aquatic plants, insects, and even surrounding forest vegetation. This nutrient input benefits countless species, including bears, eagles, otters, wolves, and scavenging birds. In turn, these species redistribute those nutrients even farther into the landscape, creating a ripple effect that supports biodiversity and ecosystem productivity from mountain headwaters to the ocean.
Chum Salmon carcass breaking down. Taken by Tamara Kelley
Southern Resident killer whales along with many salmon stocks are listed as endangered under the Endangered Species Act. The federal government has both a legal and moral obligation to protect these species and the ecosystems they depend on. Weakening national climate policy—especially rules aimed at reducing carbon pollution—undermines those protections and increases the risk of extinction.
This proposal doesn’t just jeopardize orcas and salmon—it threatens the stability of entire food webs, from inland forests to coastal waters. Warmer rivers, ocean acidification, and shifting food availability will impact countless other species, including those not yet listed but already in decline. Human communities—especially tribal nations, fishing families, and rural towns—will also feel the consequences through cultural loss, economic disruption, and increased vulnerability to climate-driven disasters.
Climate change is increasing the frequency and severity of natural disasters—putting homes, infrastructure, and lives at risk. From devastating wildfires in the West to floods and hurricanes across the country, communities are already feeling the effects of a warming planet. Rolling back climate protections now will only deepen the damage and make recovery more difficult.
Rising temperatures and shifting rainfall patterns are threatening water access across the U.S. As snowpacks decline and droughts become more intense, many regions—especially in the West—face growing uncertainty around freshwater availability for drinking, farming, and fish habitat.
Agriculture is already feeling the strain. Heat stress, water shortages, and extreme weather events are reducing crop yields and increasing food insecurity, especially for low-income and rural communities. Delaying climate action today will raise food prices and strain food systems tomorrow.
The impacts of climate inaction will fall hardest on younger generations. The choices we make now will determine whether today’s children inherit a future of worsening disasters and economic instability—or one shaped by resilience and sustainability.
Many frontline communities are already overburdened. Low-income neighborhoods, Indigenous communities, and communities of color often live closer to polluting infrastructure and face higher rates of asthma, heat exposure, and economic vulnerability. Weakening pollution standards further removes tools meant to protect those most at risk.
Scientific Resources:
Impacts of climate change on cetacean distribution, habitat, and migration.
Albouy, C., Delattre, V., Donati, G. et al. (2021).
Ecology and Evolution, 11(13), 7597–7610.
Key Point: Climate-driven shifts in ocean temperature and prey distribution are forcing changes in whale migration, range, and feeding behavior—adding stress for species like Southern Residents.
https://www.researchgate.net/publication/352541980Global climate change and potential effects on Pacific salmonids in freshwater ecosystems of southeast Alaska.
Bryant, M.D. (2009).
Climatic Change, 95(1), 169–182.
Key Point: Warming stream temperatures and altered flow regimes threaten salmon survival, reproduction, and long-term viability across the Pacific Northwest.
https://link.springer.com/article/10.1007/s10584-009-9680-5Recent declines in salmon body size impact ecosystems and fisheries.
Oke, K.B., Rolshausen, G., LeBlond, C. et al. (2020).
Proceedings of the Royal Society B, 287(1930), 20202101.
Key Point: Smaller salmon provide fewer calories per fish, reducing foraging success for predators like orcas and affecting ecosystem dynamics and fisheries.
https://royalsocietypublishing.org/doi/10.1098/rspb.2020.2101Population growth is limited by nutritional impacts on pregnancy success in endangered Southern Resident killer whales.
Wasser, S.K., Lundin, J.I., Ayres, K.L. et al. (2017).
PLOS ONE, 12(6), e0179824.
Key Point: Reproductive success in Southern Residents is directly linked to Chinook abundance; food shortages lead to high pregnancy failure rates.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0179824Preliminary climate change assessment for the Puget Sound region.
University of Washington Climate Impacts Group (2017).
UW CIG Special Report.
Key Point: Projected changes include hotter, drier summers, increased river temperatures, and habitat loss for salmon and other cold-water species.
https://cig.uw.edu/resources/special-reports/ps-ca/Climate change impacts on tribal resources.
Institute for Tribal Environmental Professionals (ITEP), Northern Arizona University (2020).
ITEP Tribal Climate Report.
Key Point: Climate change threatens tribal treaty rights, traditional food sources like salmon, and long-held cultural practices tied to land and water.
https://www7.nau.edu/itep/main/tcc/Tribes/ImpactSocial vulnerability to climate change in California’s San Joaquin Valley.
Buechler, E., Mansfield, C., & Glicksman, R. (2015).
Ecosphere, 6(7), 1–19.
Key Point: Rural and agricultural communities face elevated climate risk, including drought, water insecurity, and economic disruption, underscoring the need for equitable climate policy.
https://esajournals.onlinelibrary.wiley.com/doi/10.1890/ES14-00466.1
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