WASHINGTON — Ford Motor Co. has urged the Trump administration to exercise caution in its bid to strip away the legal underpinnings of 16 years' worth of automotive regulations by the U.S. Environmental Protection Agency.

In a previously unreported federal filing submitted last week, the automaker also requested "modest" greenhouse gas emissions standards that take effect for the 2025 model year and "steadily become more stringent over time."

The filing came ahead of a public comment deadline on a move to "reconsider" a key 2009 finding that enabled the EPA to begin regulating greenhouse gas emissions. The repeal of that finding could trigger a seismic shift in U.S. environmental regulations, delivering an especially significant impact on the highly polluting transportation sector.

Others in the auto industry have similarly advocated for restraint on the matter, warning of policy whiplash that makes it difficult for car and truckmakers to plan for the future.

If the administration ultimately rescinds the finding, that would mark the end of the last remaining major environmental regulation affecting the U.S. auto industry. Trump and his GOP allies in Congress this year have already defanged fuel economy rules enforced by the National Highway Traffic Safety Administration and gutted powerful state-level rules that would have required automakers to sell more zero-emission vehicles.

There were 351,300 public comments on the EPA proposal, formally titled "Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards." The comments included letters from Ford, crosstown rival Stellantis NV, Michigan Democratic lawmakers and Michigan Attorney General Dana Nessel, among others.

Not all of the comments were available online as of Thursday, and agencies may choose to redact or withhold certain submissions. Ford provided a copy of its letter, which has not yet been posted publicly.

The letter, signed by Ford executive Cynthia Williams, both praised the regulatory relief efforts underway from President Donald Trump and called for an end to "emissions standards swinging from extreme to extreme" under different administrations.

"EPA proposes to eliminate all vehicle GHG emissions standards. To be sure, current standards are not aligned with customer choice and market realities. They need to be eased, and we therefore welcome the EPA’s important efforts in this direction," wrote Williams, Ford's global director of sustainability, homologation and compliance.

"But pragmatically, eliminating standards altogether is not likely to provide the industry with the long-term stability we need to make historic investments in America and compete globally."

More industry comments

Stellantis, in its filing, was more mum on whether the EPA should attempt to rescind the 2009 endangerment finding altogether, though the Jeep maker similarly sought more lenient regulations.

"The current rules are premised on an EV market that has not developed at the pace previously anticipated by the EPA given the substantial challenges to widespread consumer adoption of EVs," said the company, citing higher buying costs for EVs, the phaseout of federal EV incentives and inadequate public charging infrastructure.

Detroit-based General Motors Co. did not file its own separate comment. Instead, the company referred to a statement from the Alliance for Automotive Innovation. The alliance is the auto industry's top lobbying group, representing nearly all major automakers — including the Detroit Three — and some major parts and systems suppliers. The group similarly made a plea for balance in its filing.

"Automakers and suppliers in the U.S. are increasingly being forced to navigate rapid and dramatic swings in vehicle emissions policy from one administration to another administration," the filing said. "Since years-long design, development, and production cadences necessitate investments in technology and production capacity years in advance, each such change puts billions of dollars of capital investment at risk.

"The proposed rule represents yet another significant change in approach that the industry will have to navigate. The approach also has the potential to further amplify the severity of policy swings in future administrations."

The lobbying group asked the EPA to reconsider "no longer feasible" Biden-era tailpipe emissions rules set to take effect starting in model year 2027 and ensure that "reasonable, achievable rules are in place if GHG emission standards are retained or reinstated."

Many Republicans, including Trump, have referred to the Biden-era rules as an electric vehicle mandate.

Toyota Motor Corp., the second-largest new vehicle seller in the United States last year, also filed a separate public comment. The letter is not yet publicly available, but the automaker did confirm its submission.

While automakers have warned of whiplash, EPA Administrator Lee Zeldin has suggested that his agency's proposal will instead give them more stability.

“With this proposal, the Trump EPA is proposing to end sixteen years of uncertainty for automakers and American consumers,” he said in a July statement after unveiling the proposal.

He continued: "In our work so far, many stakeholders have told me that the Obama and Biden EPAs twisted the law, ignored precedent, and warped science to achieve their preferred ends and stick American families with hundreds of billions of dollars in hidden taxes every single year.

"We heard loud and clear the concern that EPA's GHG emissions standards themselves, not carbon dioxide which the Finding never assessed independently, was the real threat to Americans’ livelihoods. If finalized, rescinding the Endangerment Finding and resulting regulations would end $1 trillion or more in hidden taxes on American businesses and families.”

Attorneys general, lawmakers weigh in

Michigan Attorney General Dana Nessel joined a coalition of 22 states, plus several cities and counties, in jointly filing a 225-page comment opposing the Trump administration's endangerment finding proposal.

“Decades of scientific research have shown the devastating consequences greenhouse gas emissions have on our health, our environment, and our economy. Dismantling the very finding that requires the EPA to regulate these harmful pollutants is dangerous and irresponsible,” Nessel said in a statement.

Among politicians, opposition and support for the move have fallen mostly along party lines. A coalition of 28 Republican attorneys general — including the AGs of neighboring states Ohio and Indiana — filed their own letter praising the Trump administration proposal.

"This proposed action is an important step to freeing American industry from burdensome, unlawful regulations and restoring the (Clean Air Act)'s proper, congressionally intended structure," the letter said. West Virginia AG John B. McCuskey and Kentucky AG Russell Coleman led the effort.

All six of Michigan's Democratic U.S. House members signed onto a letter urging the EPA to leave its "landmark" 2009 finding on the books. U.S. Rep. Debbie Dingell of Ann Arbor led the effort.

"The Endangerment Finding requires EPA to protect people from the pollution that causes climate change and its devastating impacts. Denying this danger does not change the fact that pollution from fossil fuels is heating our planet, producing more extreme weather disasters, and imposing devastating costs on families, especially the most vulnerable," the letter said.

"It is well-documented that climate change drives extreme weather. Rising global temperatures due to climate change contribute to more tornadoes in our region, smoke from more intense wildfires, and more extreme heat, among other impacts. The threats are having a severe impact in communities across our state."

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