The Repeal of the CPP and Replacement with the ACE Rule Are Arbitrary and Capricious and Contrary to Law. [...] Cities Are Already Grappling with the Effects of Climate Change Over 80 percent of Americans live in urban areas—and even more work in cities—meaning that the Local Government Coalition’s members are responsible for understanding the risks to, and planning for the wellbeing of the great majority of, Americans. [...] 11 See National Academies of Sciences, ATTRIBUTION OF EXTREME WEATHER EVENTS IN THE CONTEXT OF CLIMATE CHANGE (2016), bit.ly/1S2JHgf (concluding that attribution of particular heat waves to climate change is scientifically well- supported). [...] Educated by their experiences and anticipating the still more dramatic climatic changes looming in the foreseeable future, amici write in support of the petitioners challenging the CPP repeal and the ACE Rule. [...] The following summaries of Local Government Coalition members’ adaptation and mitigation efforts demonstrate cities’ grasp of the need to act, as well as the scale of efforts currently underway that would be undermined by the CPP repeal and the ACE Rule.
Authors
- Pages
- 43
- Published in
- United States of America
Table of Contents
- CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES 3
- CORPORATE DISCLOSURES 5
- TABLE OF CONTENTS 6
- TABLE OF AUTHORITIES 7
- IDENTITIES AND INTERESTS OF AMICI CURIAE 14
- 1. Cities Are Already Grappling with the Effects of Climate Change 15
- 2. EPA’s Action Frustrates Cities’ Efforts to Address and Adapt to Climate Change 20
- ARGUMENT 29
- 1. The Repeal of the CPP and Replacement with the ACE Rule Are Arbitrary and Capricious and Contrary to Law. 29
- CONCLUSION 40
