EPA Endangerment Scam Study Comment Request --Everyone-- Please Comment

[Bruce Melton -- Austin, Texas]

Please, every single person on every one of these lists: Irresponsibly appointed EPA leadership is treating this study, to determine if greenhouse gases are still endangering humans, like any other EPA rule. It is a scam. Do not fall for this scam. Please -everyone- comment that this is a scam, that the science has only increased knowledge that excess greenhouse gases emitted by humans have already placed humanity in peril. If you want to submit papers as the EPA comment request suggests  - as is normal in normal non-scam EPA rule making, fine, but very, very important and above all, foremost at the top of the comment, tell EPA this is a scam that will place humanity in further jeopardy, and is a fantastic waste of time and money to advance the position of the current US Administration to dismantle pollution regulations at the peril of global citizens.

We can win, but we have to fight! We have to show our numbers. We have to leave a massive public record that this is a scam  - and important, make a record of your comment. It is entirely plausible that the scam leadership at EPA will not include negative comments in the public comment documentation of their rule making decision. All we have to do is delay this action until reality returns. Please send in your comment that this study is a scam right now. It took ten years for the initial endangerment initiation in 1999 to be made rule in 2009. If endangerment is rolled back, by law we must go through the entire process again. 

Submit comment here - https://www.nationalacademies.org/our-work/anthropogenic-greenhouse-gases-and-us-climate-evidence-and-impacts

Sincerely, 

Bruce Melton

Bruce Melton PE
Director, Climate Change Now Initiative, 501c3
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On 8/7/2025 9:29 PM, H simmens wrote:

As many of you may know the United States federal government is attempting to overturn the finding the greenhouse gases endanger public health and welfare. 

The National Academy of sciences is undertaking a study to determine whether greenhouse gases are still endangering public health and welfare. They are seeking comments and input by August 27th. 

This is a vital important report and if any of you feel that you have a contribution to make please please reach out in accordance with the information contained in the link below. 

Thank you, 

Herb

https://mailchi.mp/nationalacademies/new-study-announced-on-greenhouse-gas-impacts-47fj2f1f4s?e=2f9bb7b356

Herb Simmens
Author of A Climate Vocabulary of the Future

“A SciencePoem and an Inspiration.” Kim Stanley Robinson
@herbsimmens
HerbSimmens.com

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[Tom Goreau]

The Big Lie: there is no global warming and it’s great for bu$ine$$ anyway…………

 

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[Dana Woods]

Thanks Bruce,

Anyone want to write a sample comment for us lay people activists who don't have studies published or great skill in scientific language ? Or should we include someone else's study(ies) ?

~ Dana 

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[Bruce Melton -- Austin, Texas]

Adam, of course, I assume almost every one of us including me, has the utmost respect for NAS - On Earth One.  I would never think of addressing NAS any other way than as you describe, on Earth One. But this is no longer Earth One. NAS has dissolved their equity and inclusion program and cut staff drastically because of illegitimate funding elimination. Isn't this enough to let us know that NAS is no long the highly credible institution we all have come to know? But worse, NAS is fast tracking their review.  Why would NAS fast track this review of such a landmark decision if it were not being puppeteered by fascists at the top?

When NAS completes their review, does anyone believe EPA will consider their report if it suggest the Endangerment Finding is valid? 

This is not about the integrity of NAS, we already know that has been compromise. President McNutt will undoubtedly be fired like anyone with integrity that stands up to the fascists. 

This is not about climate science. We know for a fact that all climate science will be disregarded by EPA regardless of what NAS says, because the end game here is elimination of the Endangerment Finding. 

We cannot disrespect these upholders of the scientific method by sitting idly by. We must fight. Isn't this what each of you on all of these lists would want if your credible organization was compromised by fascists? These staff are fighting for their jobs. They have families that depend on their incomes. They are doing as they are told. Fifty have been fired from NAS so far and we all know that many, many more are in the offing.  

What we are doing by commenting - by calling out this scam for the sham it is, is supporting the very thing these staff would also support if they were in our shoes and able to protest without getting fired. 

This is not Earth One any longer. We have to fight. Please comment and please note: your comments about climate science are not what this is about. Any comments made about climate science's robustness will be disrespected by the fascists as a matter of course with made up facts and anti-facts. This is about massive public upheaval telling public comment that this administration's efforts to eliminate regulation are illegitimate.

MeltOn

Bruce Melton PE
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On 8/8/2025 3:56 PM, Adam Wolf wrote:

I personally have great respect for the National Academies and the many members of the NAS that I have worked with. I have seen its work (from the sidelines) as it identified issues, did the work to investigate the issues, and wrote a report. Relevant to this list, the Negative Emissions Technologies report was and is an extraordinary resource. So, I will go on the record to say I so not believe that anything the National Academies does will now or in my lifetime ever be a scam, least of all a survey with Ralph Cicerone's name at the bottom. His congressional testimony demolishing climate denial is 🤌.

The EPA is of course a different organization, and absolutely some of its recent action raises alarm along the lines you identify. But this link is not a request for comment by the EPA.

Long story short I think it is okay to treat this survey sincerely if you are moved to respond. 

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[Michael MacCracken]

Hi--In this regard, the comment period for the EPA considering repealing their Carbon Pollution Standards that were based on the Endangerment Finding just closed. Just before it closed, I got a set of comments in on the submission to EPA by Dr. Richard Lindzen and Dr. Will Happer of the CO2 Coalition. A pdf file of my comments about their mischaracterizations and misrepresentations is attached (see their paper at  https://co2coalition.org/wp-content/uploads/2025/04/Lindzen-Happer-GREENHOUSE-GASES-AND-FOSSIL-FUELS-CLIMATE-SCIENCE-2025-04-28.pdf 

In preparing my submission I tried to explain the science they had wrong (starting with an incorrect discussion of how the greenhouse effect works, that their explanation of how the temperature would respond left out consideration of all climate feedbacks, and so on), hoping that this would challenge the EPA staff that have to develop a response to every comment (at least that is the tradition) would be faced with a clear as I could make it explanation of the shortcomings of that analysis.

To the extent that you can, I'd urge in responding to the solicitation of input by EPA on the Endangerment Finding as well as other solicitations, try and explain how the science is being misstated, etc., especially as their responses can be subject to litigation more so than can just an objection in general. It can take time to do, but I think does also confront them with a stronger case than just saying we object.

Best, Mike

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[Adam Wolf]

I personally have great respect for the National Academies and the many members of the NAS that I have worked with. I have seen its work (from the sidelines) as it identified issues, did the work to investigate the issues, and wrote a report. Relevant to this list, the Negative Emissions Technologies report was and is an extraordinary resource. So, I will go on the record to say I so not believe that anything the National Academies does will now or in my lifetime ever be a scam, least of all a survey with Ralph Cicerone's name at the bottom. His congressional testimony demolishing climate denial is 🤌.

The EPA is of course a different organization, and absolutely some of its recent action raises alarm along the lines you identify. But this link is not a request for comment by the EPA.

Long story short I think it is okay to treat this survey sincerely if you are moved to respond. 

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[Greg Rau]

Bruce, 

What if NASEM is truly trying to provide counter-evidence to the EPA's new efforts to abandon the endangerment findings? -thus the reason for the committee and the fast tracking?  If "fascists" are in control, why would they want to risk a NASEM report that would likely counter the gov agenda of abandoning endangerment?  Otherwise, what's the evidence that this committee is rigged?  

Greg

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[Mary Miller]

Agree about National Academies study and making your voice heard about a sham study. The real authority to regulate (or not regulate) greenhouse gases lies with the EPA and folks should also submit public comment to the agency's requested repeal of the endangerment finding below. 

https://www.regulations.gov/docket/EPA-HQ-OAR-2025-0194

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[Robin Collins]

I sent mine in. 

Robin Collins

Ottawa

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[Tom Goreau]

Another take on the energy/carbon transition for those who say it can’t possibly be done:

 

 

 

August 10, 2025 In this issue: The letter: The market is dictating the final chapter of the fossil era

 

 

The market, not policy, is now writing the final chapter of the fossil era

 

China's emerging electrostate. Source: The Economist / Alamy These days, a fossil fuel executive could be forgiven for feeling anxious. Despite all their wildly successful efforts to shape US energy policy to their favor, they face an increasingly unfriendly economy where market dynamics, not policy pronouncements, are beginning to write the final chapter of the fossil fuel era. For all their influence and wealth, they may feel more like a man staring down the barrel of a mobster’s gun and hearing his last words: “Sorry. It’s just business.”   Show me the money The numbers don’t lie. Data compiled by Bloomberg indicates that financing for oil, gas, and coal projects by Wall Street's top six banks fell by 25% compared to the same period last year. Leading the retreat, Morgan Stanley reduced its fossil fuel financing by 54%. JPMorgan Chase, historically a major supporter of the oil and gas sector, trimmed its lending by approximately 7%. Analysts are noting that the first decline in global upstream oil and gas development spending since 2020 coincides with this reduction in lending. As BloombergNEF analyst Miquel Kishimoto Guardiola puts it, “The composition of banks’ lending books is a better measure of whether they’re having a ‘meaningful energy transition impact’ than their public net-zero commitments.”   Booming energy demand  The irony is that demand for energy and power has never been stronger, supercharged by the growth of artificial intelligence and the growing economies of Asia and the Global South. All this is straining electricity systems and forcing a global rethink of financing energy markets — pushing money toward the future — and away from increasingly economically uncompetitive fossil fuel assets.  Here are a few facts the oil and gas industry would prefer you not know. Globally, four-fifths of new renewables installed in 2024 produced power at a lower cost than fossil fuels. Solar-powered electricity is currently 41% cheaper than fossil fuels, according to International Renewable Energy Agency (IRENA) data. The levelized cost of energy (LCOE) for utility-scale solar ranges from $25–$35 per MWh, compared to $45–$70 per MWh for natural gas and $70–$120 per MWh for coal in 2025, making solar and wind the lowest-cost sources of new electricity in most regions. In Europe, and even the US, new solar and wind projects are undercutting even the cheapest fossil fuel plants, and the cost gap continues to widen as fossil prices remain volatile. In contrast, the costs of solar and wind fall due to scale, efficiency, and innovation. For oil executives, this horrifying new economic reality, not the pursuit of “energy security,” or saving whales and birds from wind turbines, is what is driving the Trump administration’s war on renewable energy. Their biggest nightmare is being realized: The renewable buildout is happening faster than even the optimists forecast.   The whale oil of the 21st century For fossil fuel companies, this new era is death by a thousand cuts. Every year of declining bank lending means less available capital for new projects and tighter margins on existing assets. Oil and gas bosses increasingly find themselves in the same position as the 19th-century Nantucket whaling captains — a dominant force, until suddenly they weren’t. And the future is not pretty. At present, fossil fuels still generate about 83% of the world’s energy supply. But by the end of the century, it will account for less than 25%, if they are lucky. For the industry, it’s becoming a game of musical chairs. Every dollar invested in renewables is a dollar their industry will never see again, permanently shrinking the demand for oil, gas, and coal.  A few oilies are starting to get it. In the Middle East, petro-potentates who once scoffed at clean energy are now launching some of the world’s most ambitious renewable energy projects. You see, the oil industry understands it cannot possibly compete at scale with limitless, free solar energy. But please don’t tell anybody. They also know something that most people think is preposterous. We are entering an era where power, like data and communications, will be all but free. Crazy? History is full of technological surprises. Today, we make limitless free “long-distance” calls and have unlimited “free data.” A hundred years ago, a similar call cost $500 for three minutes, and until relatively recently, every phone text cost fifty cents or more.   Pandora’s box Ironically, Wall Street is now the climate movement’s best hope for blunting the pace of rising carbon levels. Markets, unlike the environmental movement, have one huge advantage: they are amoral. But when the economics tip, the change is swift.  But with the hope of limitless, cheap, and clean energy comes an unexpected new threat: the consequences of “too much” energy. Just as we solve the 20th-century crisis of burning carbon, we will encounter a new 21st-century challenge: How do we harness boundless solar power — and keep our stewardship of the planet in check? Unlimited electric power without equally progressive advances in circular economies, regenerative agriculture, and managed oceans will only make the global environmental crisis worse. Let’s hope the market has an answer for this as well.

 

Peter McKillop Founder & CEO Climate & Capital Media

 

From: 'Hawkins, David' via Carbon Dioxide Removal <CarbonDiox...@googlegroups.com>
Date: Saturday, August 9, 2025 at 3:52 PM
To: Greg Rau <gh...@sbcglobal.net>, Greg Rau <gr...@ucsc.edu>, Bruce Melton -- Austin, Texas <bme...@earthlink.net>, Hawkins, Dave <dahaw...@gmail.com>
Cc: Adam Wolf <ad...@carbonista.co>, healthy-planet-...@googlegroups.com <healthy-planet-...@googlegroups.com>, Planetary Restoration <planetary-...@googlegroups.com>, Healthy Climate Alliance <healthy-clim...@googlegroups.com>, CDRANet <cdr...@gaggle.email>, Carbon Dioxide Removal <CarbonDiox...@googlegroups.com>, Grassroots Network Climate Emergency Issue Team <gn-cem-d...@lists.sierraclub.org>
Subject: Re: [CDR] EPA Endangerment Scam Study Comment Request --Everyone-- Please Comment

Thanks Greg,

I can’t prove you wrong; only the Committee can do that. We shall see.

I think the wording you highlight was intentionally chosen to avoid a claim by the supporters of revocation that the NAS “prejudged” the results of the assessment of science since 2009.  Of course, it is ridiculous that the NAS should have to take such steps.  But that is the U.S. today, alas.

Regarding “whether,“ here the NAS is simply reciting the words of the Clean Air Act, on which EPA’s revocation purportedly rests.  To me, this suggests the NAS intends to take aim directly at the EPA claim that GHGs do not “endanger” us.

If a committee composed of scientists with solid credentials, who have not advocated in the policy space, determines that the evidence for endangerment is stronger now than in 2009, that will be more influential, not on the Trump Adminstration, but on the public and perhaps on the courts that will review the EPA action.

David

 

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Sent: Saturday, August 9, 2025 3:36:39 PM
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Subject: Re: [CDR] EPA Endangerment Scam Study Comment Request --Everyone-- Please Comment

 

[apologies to those on the CDR list expecting CDR info, but without US science leadership fully onboard with climate action, why have a CDR list?]

 

Thanks David.  I want to believe your scenario, but then there’s this wording in the public announcement:

"Decades of climate research and data have yielded expanded understanding of how greenhouse gases affect the climate. This fast-track study will review the latest scientific evidence on whether greenhouse gas emissions are reasonably anticipated to endanger public health and welfare in the U.S. The committee’s report will be completed and publicly released in September.."

 

"Expanded" is an inappropriately neutral word that implies that evidence for the endangerment may not have increased since 2009 and may have weakened. This is obviously false, and for an esteemed science body like NASEM to imply otherwise is extremely disturbing. Secondly, the next sentence questions the evidence for endangerment by the use of "whether" greenhouse gas emissions are reasonably anticipated to endanger public health and welfare in the U.S. Given the overwhelming evidence that GHGs have increased temperatures and highly anomalous weather resulting in increased death, injury, and property and environmental damage (and increased insurance rates), how can endangerment be posed as open question? from the nation's highest science body?

 

Coming from a supposedly science-driven org like NASEM, the paragraph should read:

""Decades of climate research and data have yielded expanded increased understanding of how greenhouse gases affect the climate. This fast-track study will review the latest scientific evidence on whether how much greenhouse gas emissions are reasonably anticipated to endanger public health and welfare in the U.S. The committee’s report will be completed and publicly released in September."

 

The fact the something like the preceding wording was not used leaves me wondering who and what is driving this NASEM report.

 

Furthermore, there is no listing of the committee members. Following a discussion with a very senior climate scientist and member of the Academy, I learned that the announcement to the membership read in part like this:

 "With partial funding from the Cicerone fund—to which so many

   members regularly contribute—we will launch this study immediately.

   Our goal is to assemble a balanced committee from academia,

   industry, and other sectors who are knowledgeable on the issues,

   open-minded to both the strengths and weaknesses of climate science,

   and who have avoided taking strong advocacy positions."

 

In other words, those members most intimately aware of the evidence and thus who are most motivated to act on that evidence will be excluded. So the aim is a neutral jury as though the doubters/deniers have a valid case. As a science body, shouldn't the case against endangerment be thrown out of this "court" for lack of evidence? Why is NASEM legitimizing doubt/denial in this particular matter given the overwhemling evidence and its massive global significance?

 

So, David, I'd like to believe that NASEM is operating in the best interest of science (and engineering and medicine), but the smell test suggests to me that something else might be afoot. Please prove me wrong. 

 

Regards,

Greg 

 

 

On Saturday, August 9, 2025 at 06:37:51 AM PDT, David Hawkins <dahaw...@gmail.com> wrote:

 

 

I very much doubt this review is intended to support the endangerment revocation. Recall that in 2001 the G W Bush White House requested NAS to review the IPCC’s assessment of the science, thinking the NAS would question the IPCC’s conclusions. However, the NAS issued a report affirming the IPCC’s findings.

Note that the current review is not being funded by the government. Rather, it is self funded by the NAS, including one fund established in honor of Ralph Cicerone, who repeatedly confirmed the strength of the science underpinning the human causation of climate change.

David

 

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[Bruce Melton -- Austin, Texas]

Dr. McNutt,

Thank you for you response. I am sure the vast majority on these lists have the utmost respect for NAS. Perhaps the subject line of this thread should have been, "Endangerment Scam; Study Comment Request."

The best to you and all your staff. So many of us are doing everything we can to try and overcome the challenges posed by this current administration.

Sincerely,

Bruce Melton

Bruce Melton PE
Director, Climate Change Now Initiative, 501c3
President, Melton Engineering Services Austin
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On 8/9/2025 10:31 PM, Greg Rau wrote:

Marcia,

Thanks for your clarifications. Let’s see how this plays out. As for my last ps, I meant “… used in the original thread title and text.”

Regards,

Greg

Sent from my iPhone

On Aug 9, 2025, at 6:46 PM, McNutt, Marcia K. <MMc...@nas.edu> wrote:



PS - about the “scam” word. This is exactly the criticism we are trying to avoid. That the administration concludes that the study was not honestly undertaken to sort out the facts but rather engineered to ensure the “right” answer. Just because the DOE document cherry picked its authors and ensured that they got the answer they wanted doesn’t mean that it is the way the NAS operates.

Sent from my iPad

Dr. Marcia K McNutt

President, National Academy of Sciences

Washington, DC

On Aug 9, 2025, at 5:05 PM, Greg Rau <gh...@sbcglobal.net> wrote:



Caution: This email originated outside the organization. Please exercise caution when opening attachments or clicking links, as they may contain malicious content.

Thanks NASEM President McNutt for your response. To be clear, I had bcc'ed you (and a few other members also bcc'ed here) to give you a heads up as to the discussion and sentiment, but didn't expect a response. So, thanks for reaching out so quickly and publicly. I don't have posting privileges either to some of the addresses listed in the original post so we'll have to rely on others to repost to those groups if they chose to.  

Anyway, my concerns still stand. While we can quibble about the degree of impact, GHGs endanger humans and the planet. To imply this is unsettled is ignoring the evidence. Let's see what the climate experts and climate advocates within and outside your membership (who are apparently excluded from this committee) have to say about this new approach to informing climate policy.

Regards,

Greg Rau

ps the term "scam" was used in the original threat tile and text. I'm not using or condoning that term in my responses.

On Saturday, August 9, 2025 at 01:29:06 PM PDT, McNutt, Marcia K. <mmc...@nas.edu> wrote:

Dear Greg,

We are not doing this fast track study for you.  Read the statement of task as though you are a political appointee in this administration, and then tell me how you would accept this study as a fresh and honest assessment if the SOT has been worded as you wish: presupposing the outcome. 

Let me know if you want to discuss.  

Marcia

Sent from my iPhone

On Aug 9, 2025, at 12:39 PM, Greg Rau <gh...@sbcglobal.net> wrote:



Caution: This email originated outside the organization. Please exercise caution when opening attachments or clicking links, as they may contain malicious content.

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[Bruce Melton -- Austin, Texas]

Greg, 

Of course NAS will do their job and report the science. The game is rigged.  Our current administration will obfuscate this report like AG Barr nuked the Mueller report. This is the scam that we must fight. It's the EPA's Scientific Advisory Boards that are rigged - https://earthjustice.org/press/2025/earthjustice-condemns-the-new-epas-dismissal-of-critical-science-advisory-boards

Reading the discussion in this thread, my response to Dr. McNutt's replies that, perhaps the subject of this thread should have been, "EPA Endangerment Scam; Study Comment Request." A little punctuation creates clarity.

B

Bruce Melton PE
Director, Climate Change Now Initiative, 501c3
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[Greg Rau]

Subject: Re: [CDR] EPA Endangerment Scam Study Comment Request --Everyone-- Please Comment

 

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[Ron Baiman]

Thanks for the heads up Bruce, Herb, Mike and others!

I have submitted the third section of our cooling paper (with references) as evidence for the harm that GHG accumulation has done that will accelerate and get much worse if we don't cut and drawdown GHG (and cool - but did not directly include this in my excerpt - as the topic is GHG emissions!). 

Best,

Ron

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[Greg Rau]

Thanks NASEM President McNutt for your response. To be clear, I had bcc'ed you (and a few other members also bcc'ed here) to give you a heads up as to the discussion and sentiment, but didn't expect a response. So, thanks for reaching out so quickly and publicly. I don't have posting privileges either to some of the addresses listed in the original post so we'll have to rely on others to repost to those groups if they chose to.  

Anyway, my concerns still stand. While we can quibble about the degree of impact, GHGs endanger humans and the planet. To imply this is unsettled is ignoring the evidence. Let's see what the climate experts and climate advocates within and outside your membership (who are apparently excluded from this committee) have to say about this new approach to informing climate policy.

Regards,

Greg Rau

ps the term "scam" was used in the original threat tile and text. I'm not using or condoning that term in my responses.

On Saturday, August 9, 2025 at 01:29:06 PM PDT, McNutt, Marcia K. <mmc...@nas.edu> wrote:

Dear Greg,

We are not doing this fast track study for you.  Read the statement of task as though you are a political appointee in this administration, and then tell me how you would accept this study as a fresh and honest assessment if the SOT has been worded as you wish: presupposing the outcome. 

Let me know if you want to discuss.  

Marcia

Sent from my iPhone

On Aug 9, 2025, at 12:39 PM, Greg Rau <gh...@sbcglobal.net> wrote:



Caution: This email originated outside the organization. Please exercise caution when opening attachments or clicking links, as they may contain malicious content.

[McNutt, Marcia K.]

Dear Greg,

Thanks for the explanation. All of the NAS  reports on climate change relevant to the endangerment finding are now more than 10 years old, which I why we want to update the science with the progress and additional data from the last 10 years. Much of what is claimed in the DOE report does not refer to this new work. 

We are casting a wide net for committee members for this new report. Several are from outside the NAS, with an attempt to get the petroleum industry’s own climate modelers on the committee. No requirement for NAS membership, but we are excluding anyone who has made a public statement criticizing the administration on its climate stance.

I hope this helps. It is essential that we not undermine the report before it is even written by allowing criticisms that we pre-engineered the outcome through the SOT or the committee members.

Marcia

Sent from my iPad

Dr. Marcia K McNutt

President, National Academy of Sciences

Washington, DC

[McNutt, Marcia K.]

PS - about the “scam” word. This is exactly the criticism we are trying to avoid. That the administration concludes that the study was not honestly undertaken to sort out the facts but rather engineered to ensure the “right” answer. Just because the DOE document cherry picked its authors and ensured that they got the answer they wanted doesn’t mean that it is the way the NAS operates.

Sent from my iPad

Dr. Marcia K McNutt

President, National Academy of Sciences

Washington, DC

[Greg Rau]

Marcia,

Thanks for your clarifications. Let’s see how this plays out. As for my last ps, I meant “… used in the original thread title and text.”

Regards,

Greg

Sent from my iPhone

On Aug 9, 2025, at 6:46 PM, McNutt, Marcia K. <MMc...@nas.edu> wrote:



PS - about the “scam” word. This is exactly the criticism we are trying to avoid. That the administration concludes that the study was not honestly undertaken to sort out the facts but rather engineered to ensure the “right” answer. Just because the DOE document cherry picked its authors and ensured that they got the answer they wanted doesn’t mean that it is the way the NAS operates.

[John Fitzgerald]

Dear All,

You may find the comments filed with EPA by the Climate Protection and Restoration Initiative to be useful as background information.

John Fitzgerald

Vice President of the Board

Climate Protection and Restoration Initiative

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[McNutt, Marcia K.]

I appreciate your support, Bruce. Thanks for writing. 

Sent from my iPhone

[Becca Neumann]

There are also two other opportunities to submit comments on federal efforts that downplay the negative effects of rising CO2. 

1) EPA's Proposed Rule: Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards. Written comments due Sept 15 / public hearing registration by Aug 12. 

https://www.epa.gov/regulations-emissions-vehicles-and-engines/proposed-rule-reconsideration-2009-endangerment-finding

2) DOE's report "Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate." Comments due Sept 2.  

https://www.regulations.gov/document/DOE-HQ-2025-0207-0001

On Fri, Aug 8, 2025 at 11:48 AM Bruce Melton via CDRANet <cdranet+bmelton_...@gaggle.email> wrote:

Please, every single person on every one of these lists: Irresponsibly appointed EPA leadership is treating this study, to determine if greenhouse gases are still endangering humans, like any other EPA rule. It is a scam. Do not fall for this

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[John Nissen]

Dear Dr. McNutt,

I go along with Bruce.  We wish to support you as much as we can in your predicament.  How can NASEM go along with the administration's requirements, while maintaining scientific integrity?  I think it is possible, but it means confronting some of the received wisdom on climate change.  In particular it means challenging the mantra "Climate change is caused by CO2 emissions, therefore cuts in emissions are essential to prevent dangerous climate change".

The administration is clearly on the side of the fossil fuel companies in a fight over cuts in CO2 emissions.  The administration assumes that the science is clear: cuts are vital to prevent dangerous climate change.  They don't like this message.  They react by dismissing the science of climate change and the scientists working on it.  They throw doubt on whether climate change is a serious issue.  And they throw doubt on whether climate change is caused by anthropogenic emissions of greenhouse gases.

The IPCC correctly affirms that climate change is a global security issue and correctly affirms that the underlying cause of climate change is the anthropogenic emissions of greenhouse gases.  But is the strategy of "emissions reduction alone" sensible?   There are some fatal flaws in this strategy.  Here is the evidence which NASEM might consider in a report:

1. Global warming has been mostly driven by the accumulation of CO2 in the atmosphere above the preindustrial level of 280 ppm, and emissions add less than 2% each year to that legacy of CO2 in the atmosphere, currently at 426 ppm.  Many of the global climate models make projections showing that CO2 emissions will make a greater difference than is warranted: they have wildly different trajectories depending on emissions scenario.  This makes it appear that emissions reduction has a greater effect than it really has.  The administration is rightly suspicious of the models.

2. Carbon Dioxide Removal (CDR) at a rate which exceeds emissions is required to bring the CO2 level back some way towards 280 ppm and thus towards the elimination of its global warming effect.  The global mean temperature will continue to be driven upward by excess CO2 until that excess is removed.  The underlying trend is an acceleration in temperature rise.  Net zero only straightens the upward curve of temperature; it doesn't turn the curve downwards which requires CDR.

3. Global warming causes climate change rather than the other way round.  

4,  The planet is too hot.  Millions of people are regularly suffering from barely tolerable heat extremes.  And most of the problems for ecosystems are to do with temperature rather than climate change or anything else.  Corals suffer more from raised temperature than from ocean acidification.

5. CERES satellite data indicates that, for the past two decades at least, the Earth's Energy Imbalance (EEI) has been increasing.   There is a shortwave and a longwave component to the EEI.  Global warming is now driven more by a reduction in the amount of shortwave insolation reflected into space than by a reduction in the longwave radiation escaping into space.  Warming from albedo loss is more critical than warming from greenhouse gases.

6. The situation of increasing heat, climate change and sea level rise does NOT have to be accepted as inevitable, with adaptation "as best you can".  Cooling intervention by albedo enhancement (also known as SRM) is possible; and research suggests that it is quite practicable.

7.  There are climate scientists who claim that the prospect of SRM deployment would encourage the consumption of fossil fuels, but there is no evidence for this.  There are also those who say that SRM is intrinsically dangerous, again without evidence.  The IPCC has been remarkably silent about SRM, almost as if it is a taboo subject.

8.. SRM can lower global temperatures and reverse climate on a timescale of years rather than decades.  Thus tipping point catastrophes can be avoided: this was the main purpose of keeping global warming below 1.5C, which has already been reached. 

9.  SRM research suggests that Stratospheric Aerosol Injection (SAI) has the necessary qualities for successful deployment  in the near future to urgently lower temperatures in the polar regions and elsewhere; SAI has credibility, availability, speed of deployment, efficiency, affordability, scalability, safety and sustainability for deployment.

10.  Refreezing the Arctic is particularly urgent: to avoid tipping point catastrophes, slow sea level rise, and reverse the trend towards ever more frequent and intense weather extremes in the Northern Hemisphere.

Thus NASEM has good reason to join in with the administration's desire to downplay the importance of emissions cuts in the scheme of things.  It has an opportunity to fill in some of the missing bits of science ignored or neglected by the IPCC.  And it has a chance to put forward SRM as a sensible approach for bringing down temperatures, reversing climate change and avoiding tipping point catastrophe.  Moreover, a combination of CDR and SRM can restore and stabilise the planet's temperature and climate for the long term, even if emissions remain at their current level: the administration might appreciate this point!

Kind regards,

John Nissen

Chair of the Planetary Restoration Action Group (PRAG)

Bath, UK

+44 7890 657 498

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[McNutt, Marcia K.]

Thanks John for these comments.

On account of the fast-track nature of this study and the looming deadline for comments on the recision of the endangerment finding, the study is not going to address everything that it ideally could. It is going to concentrate on the evidence that climate change is happening, that it is primarily anthropogenic, that the models have done a good job, and what the known impacts are. We are going to avoid getting into mitigation versus adaptation versus carbon capture versus geoengineering. Those are policy choices, but this administration is going to avoid any policies to address climate change unless there is public pushback on their plan to allow climate change to run amok.

Marcia

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Marcia K. McNutt

President, National Academy of Sciences

mmc...@nas.edu