On February 12, 2026, the Environmental Protection Agency finalized a rule overturning the agency's 2009 endangerment finding — the legal determination, sustained for more than fifteen years, that greenhouse gas pollution endangers public health and welfare and therefore requires regulation under the Clean Air Act. At the same time, the agency repealed emissions standards for light-, medium-, and heavy-duty vehicles.
The legal implications of the repeal will be litigated for years. The practical implications, in the meantime, are that the primary statutory basis for federal greenhouse gas regulation has been removed, and federal climate policy is contracting at a pace not seen in any recent administration.
The more interesting story since February has been the state-level response. We want to walk through where that response has moved, what it tells us about the structure of climate policy in 2026, and what TerraFuture's policy team is watching most closely going into the rest of the legislative year.
What the repeal actually did
A brief technical note, because the federal action has been described in multiple, slightly different ways across coverage.
The endangerment finding is the EPA's formal determination that greenhouse gases endanger public health and welfare. The Clean Air Act, by statute, requires the EPA to regulate air pollutants that endanger health. The 2009 finding triggered that obligation for greenhouse gases, and it has been the legal anchor for federal vehicle emissions standards, certain power plant rules, methane rules, and a range of other regulations issued under the Clean Air Act over the subsequent fifteen-plus years.
The February repeal does not strike down those underlying statutory authorities. It removes the predicate finding on which most of them depended. The legal questions about whether specific regulations survive the loss of the predicate, and whether courts will sustain the repeal itself, are open and will be substantially litigated. The World Resources Institute and several legal academics have published useful analyses suggesting that ending the endangerment finding does not, in itself, end the EPA's ultimate climate regulatory obligations — but it does significantly slow the practical work.
What is unambiguous is that the EPA is signaling, formally and operationally, that it intends to substantially reduce federal climate regulation. The vehicle emissions standards repeal that paired with the endangerment finding repeal is the clearest example of that intent.
How states are responding
The pace of state-level activity in the ninety days since the repeal has been faster than we would have predicted six months ago. A few specific signals.
New York. The New York State Senate passed a package of bills in late April strengthening state-level climate and environmental protections. The package included measures limiting toxic substances, addressing PFAS contamination, protecting children from lead exposure, and authorizing additional state-level greenhouse gas monitoring. Several of the bills had been in the pipeline for years; the passage timing was clearly responsive to the federal repeal.
Climate XChange tracking. The Climate XChange policy research group is now tracking 63 active state-level bills across 25 states focused specifically on utility regulation, climate-aligned ratepayer protections, and limits on the use of customer rates for political activity. This is a notable expansion of the policy frontier — utility regulation has historically been a slow, technical area where most ratepayer-facing climate work has happened indirectly. The current wave of legislation is targeting it directly.
California. California has continued to advance both its existing climate framework and new vehicle electrification, building electrification, and clean energy procurement standards. The state's autonomy on certain emissions rules — once protected by federal waivers — is itself now contested at the federal level. The legal trajectory there will matter.
The broader state landscape. The Center for American Progress and several other policy organizations have published detailed scorecards of state-level climate activity in 2026. The summary picture is that state and local governments have raised the stakes significantly this year, with leaders moving quickly to reshape climate and energy policy around affordability, reliability, and demonstrable public benefits. The reframing — away from abstract climate metrics and toward concrete consumer-facing benefits — is itself a meaningful shift.
What this means structurally
Three observations from where we sit.
State capacity is real, but it is uneven. A handful of states — California, New York, Washington, Oregon, Massachusetts, Colorado, Minnesota, and several others — have built out the regulatory, technical, and legal capacity over the past decade to operate complex climate policy programs at the state level. Other states have not. The federal contraction will be partially offset by state action in some places and largely unoffset in others. The geography of climate policy is becoming more sharply varied, not less.
Utility regulation is the new frontier. The 63 bills tracked by Climate XChange are concentrated in an area — public utility commission authority — that is technical, slow-moving, and politically underdiscussed compared to vehicle or building standards. The fact that this is where the activity is moving suggests that state climate advocates are reading the ratepayer-cost terrain accurately. The conversations about climate that move the most policy in 2026 may be conversations about utility bills.
Coalition geometry is shifting. Some of the new state-level climate work is being driven by traditional environmental coalitions. A meaningful fraction is being driven by ratepayer advocacy groups, public health organizations, environmental justice coalitions, and consumer protection groups that were not centrally part of climate coalitions a decade ago. The coalition broadening is one of the more durable changes coming out of the federal repeal, and we expect it to outlast the current federal administration.
What we are doing
A few specific notes on TerraFuture's policy work in this environment.
We are publishing a state-specific policy tracker, in partnership with two regional coalition partners, covering active legislation in our service area. The tracker will go live in the first week of June, with quarterly updates.
We are expanding our policy advocacy capacity. Our policy director is in the process of hiring two additional staff focused specifically on state legislative engagement and utility commission docket participation. The state-level technical work that climate policy now requires is hard to staff for at the scale we need.
We are continuing to publish open data that state agencies and legislators can use. The role of independent, credible environmental data is more important, not less, in an environment of contested federal regulation. Our 10-year retrospective last week documented how this work has gone. The work continues.
What advocates can do
A few practical notes for community members who care about this.
State-level climate policy is being made in real time. Your state representative and state senator are voting on this. Local utility commissions are holding hearings on it. The opportunity for engaged community input is genuinely higher at the state level than at the federal level right now.
Show up to public comment. State and local hearings consistently get fewer comments than the work they are doing warrants. A short, specific comment from a constituent carries weight. We have seen it.
Subscribe to your state climate coalition's email list. The legislative calendars are tight, and the most useful information arrives a few days before a vote, not in the abstract.
Support credible, independent environmental data sources. Federal data infrastructure is becoming less reliable as a planning resource. The state, academic, and nonprofit data infrastructure that fills the gap is what state policymakers will increasingly rely on.
The federal repeal reshapes the landscape. It does not end the work. The states, the cities, the utility commissions, and the communities are still here. So are we.
