Northeastern Law Students Contribute Comments Through Federal Rulemaking Process
10.01.2025 — Students at Northeastern University School of Law recently participated in the federal decision-making process by filing a comment with the Environmental Protection Agency (EPA) regarding its proposed rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, which seeks to deregulate greenhouse gas emissions from motor vehicles that contribute to climate change.
Supported by the law school’s Center for Public Interest Advocacy and Collaboration (CPIAC), students were provided a first-hand opportunity to engage in the federal rulemaking process. Professor Sharmila Murthy, CPIAC’s faculty co-director and former director for environmental justice at the White House Council on Environmental Quality, invited interested students to draft comments from any political or policy perspective. Emily Ganem ’26 and Annabel Shu ’26, who are currently enrolled in Murthy's Environmental Law class, addressed complex issues at the intersection of science and law in their response and worked closely with Murthy to expand and refine it. They studied the Clean Air Act and examined how the EPA has used its authority to regulate greenhouse gas emissions under this statute. They also examined recent efforts by the current administration to change EPA’s longstanding determination that greenhouse gases endanger the public health and welfare, and thus, are subject to regulation under the Clean Air Act.”
“As law students interested in working for the public good and the environment, it's easy to feel powerless as the federal government tries to push through a partisan agenda marked by massive environmental deregulation,” said Shu. “Professor Murthy provided us the legal framework to explore the legal and scientific bases of climate change regulation in the US and empowered us to make our voices heard in the administrative record.”
On Friday, September 19, 2025, Ganem and Shu organized a “comment party” under CPIAC’s auspices, inviting fellow students to join their comment submission or draft their own responses to the EPA’s proposed rule. Three days later, Ganem, Shu and Murthy, joined by over 30 students, faculty members and Northeastern Law alumni/ae submitted their comment opposing several aspects of the proposed reconsideration of the 2009 endangerment finding.
“Organizing the comment party was crucial in helping us connect our advocacy for the climate with the struggle for immigrant rights and other marginalized populations, in an era of increasing division and fragmentation,” said Ganem.
The comment concludes, “As members of an academic and legal community interested in law, policy, and science, we have a unique interest in maintaining administrative and judicial processes. We depend on a legal field founded on just, consistent application of the law. The Proposed Reconsideration questions settled law when convenient to political priorities, and it conflates scientific findings with political power grabs. Should the Proposed Reconsideration become a final rule, it will represent just how fragmented our institutions have become, and it will contribute to the dwindling hope for important efforts to manage the cataclysmic impacts of climate change.”
The Northeastern community’s submission was one of 351,337 comments received by the EPA during the comment period. These comments now form part of the administrative record that the EPA must review as part of its decision-making process. The comment was also shared with Lawyers for Good Government, which will track its progress along with other submissions.
During the comment party, Samira Khadar ’27 shared information about how students could submit comments to the U.S. Department of Homeland Security regarding an immigration rule affecting international students on student visas, further broadening the scope of student participation in federal rulemaking.
“Having worked at the White House Council on Environmental Quality during the Biden Administration, I thought it was important for students to understand first-hand how federal rulemaking occurs,” said Murthy. “Commenting on government rules and regulations directly aligns with CPIAC’s mission to support student engagement in public interest advocacy and provide opportunities for meaningful participation in policy-making processes that affect our communities and environment.”
About Northeastern University School of Law
The nation’s leader in experiential legal education since 1968, Northeastern University School of Law offers the longest-running, most extensive experience-based legal education program in the country. Northeastern guarantees its students unparalleled practical legal work experiences through its signature Cooperative Legal Education Program. More than 1,100 employers worldwide in a wide range of legal, government, nonprofit and business organizations participate in the program. With a focus on social justice and innovation, Northeastern University School of Law blends theory and practice, providing students with a unique set of skills and experiences to successfully practice law.
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