The EPA, along with the “Climate Working Group” (CWG) of usual suspects (plus Judith Curry and Ross McKitrick) at DOE, have just put out a document for public comment their attempt to rescind the 2009 Endangerment Finding for greenhouse gas emissions.
Here are some relevant links:
- Original Endangerment Finding (2009)
- Proposed rule (2025)
- DOE Critical Review of Impacts of GHG Emissions on the US Climate (Christy, Curry, Koonin, McKitrick, Spencer, 2025)
This is a placeholder post for links and comments while folks try and digest the details. Feel free to post links to analyses as you find them and we’ll elevate the best to the OP. We’ll have a more considered response in a couple of days.
Updates (7/31):
Some relevant media reports:
- “Contrarian Climate Assessment from US Govt. draws swift pushback” Science
- “Trump’s EPA takes aim at the Endangerment Finding” Scientific American
- “Scientists Say New Government Climate Report Twists Their Work” Wired
- “DOE reframes climate consensus as a debate” E&E News
A self-justifying rationale for the CWG effort from Judith Curry. Note that she (somewhat incredibly) will not opine (publicly) on the Endangerment Finding itself. Stealth advocacy anyone?
Links for the public comments:
- On the EPA proposed rule: The Docket is here (but see above link on how to submit)
- On the DOE ‘Critical’ Review: (Instructions). Docket should be here, but is not yet live.
Note that It is not clear to us that comments on the DOE report will have any direct role in the EPA ruling.
Given the framing of the Administration’s environmental & energy policy as a quasi-religious crusade, as when EPA Administrator Zeldin spoke last week of :
” driving a dagger through the heart of climate-change religion and ushering in America’s Golden Age.”
one should note that he and the President are making verbatim quotes from the Cornwall Alliance and the Realist Catholic Climate Declaration issued a decade ago, and since revived by John Droz in the the K through 12 educational program of the CO2 Coalition
https://www.desmog.com/energy-environment-legal-institute/
That’s politics for you. Cuts both ways.
29 Jul 2025 by group
This placeholder was for links and discussion while folks “digested the details.” We were told a more considered response would follow in a few days.
Nine days later: silence.
Looks more like a ‘chicken little’ beat-up than anything of substance — and clearly of little interest to the broader public and the media.
Let’s be honest about where things stand. The EPA will do what it intends to do. It doesn’t care what’s said here, on Bluesky, or by frustrated celebrity scientists. It will process the public comments, then rescind the Endangerment Finding and revise emissions regulations accordingly. Biden’s EV and RE grants will be quietly unwound.
The EPA has never been a scientific body, and the Clean Air Act was never designed to regulate greenhouse gases. What’s coming is a political decision under partisan pressure — just like in 2009.
Another chapter in America’s long experiment with dysfunction.
Argue among yourselves, if that helps.
— Pedro P
Wonder if page seven, 2.2.2 will get an update for the following out today from the Australian Institute of Marine Science:
.
“World’s biggest coral survey confirms sharp decline in Great Barrier Reef after heatwave”
https://www.aims.gov.au/information-centre/news-and-stories/worlds-biggest-coral-survey-confirms-sharp-decline-great-barrier-reef-after-heatwave
.
That’s the tip of the problem with 2.2.2 “Coral reef changes” of DOE report, PDF pages 17-18+eferences, not its stupid page numbering by sections, but w/o section numbers.
https://www.energy.gov/sites/default/files/2025-07/DOE_Critical_Review_of_Impacts_of_GHG_Emissions_on_the_US_Climate_July_2025.pdf
EITHER
Whoever wrote this knew almost nothing about coral reefs
OR
Someone was seriously deceptive.
DOE p.17: “There are concerns that a decreasing pH of sea water will reduce the calcification rate of coral reefs”
STRAWMAN. Actual experts repeatedly write that current pH changes are far less important than temperature rise.
Ex: Terry Hughes is a world-class reef expert.
https://en.wikipedia.org/wiki/Terry_Hughes_(biologist)
In 2023 expert report, https://www.fedcourt.gov.au/__data/assets/pdf_file/0008/117836/Expert-report-of-Terry-Hughes-28-April-2023_Redacted.pdf
p.12: “The relationship between bleaching intensity and subsequent mortality of corals is well established (Figure 3): when bleaching is mild (affecting less than 20% of corals), most corals regain their colour after a few weeks and survive. In contrast, when bleaching is severe (affecting >20% of corals) most of the bleached corals subsequently die (Figure 3).”
p.16: ” Consequently, global heating is a much more pressing issue for coral reefs compared to the longer-term impacts of ocean acidification. …While a modest level of oceanic acidification will undoubtedly have discernible effects even in the tropics, mass bleaching due to global warming, as well as pollution and overfishing are likely to remain the most pressing challenges for reef biodiversity over the rest of the century.”
But maybe DOE authors didn’t read that, but they cited Browman(2016), https://academic.oup.com/icesjms/article/73/3/529/2459146, which included (p.532):
“Noonan and Fabricius (2016) investigated how elevated CO2 and temperature, in combination, affected the bleaching susceptibility of tropical reef corals. Their field and laboratory data suggest that levels of OA up to a pHT of 7.8 will have little effect on the sensitivity of tropical reef corals to thermal bleaching.”
(Noonan & Fabricius are researchers at Australian Institute of Marine Science, AIMS).
DOE p.17
“De’ath et al. (2009) reported that a portion of Australia’s Great Barrier Reef (GBR, the world’s largest coral reef ecosystem) had experienced a 14 percent decline in calcification since 1990. This was tentatively attributed to increasing water temperature and decreasing pH. But Ridd et al. (2013) showed that report to have resulted from a biased data analysis that, when corrected, showed no change in calcification rates. … Nevertheless, the alarm produced by the original paper has persisted as evidenced by the large number of published citations (541) to the original study compared to only 11 citations to the correction (as of 30 April 2025).”
Ridd was partly right, but mostly wrong. AIMS’ De’ath, Fabricius & Lough corrected error, lowering 14.2% to 11.4% in “Yes-Coral calcification rates have decreased in the last twenty-five years”
https://www.sciencedirect.com/science/article/abs/pii/S0025322713002016
Ridd is a problematic source, was fired by JCU, sued them, then lost on appeal
https://www.desmog.com/peter-ridd/
https://www.theguardian.com/australia-news/2021/oct/13/peter-ridd-loses-all-or-nothing-high-court-appeal-over-sacking-from-james-cook-university
(Note: marine dredging is related to Queensland coal companies.)
Ridd ignored replies:
Schaffelke, Fabricius, et al(2018), “…Reply to viewpoint “The need for a formalised system of Quality Control for environmental policy-science” by P. Larcombe and P. Ridd…”
https://www.sciencedirect.com/science/article/pii/S0025326X18301425
“We argue that their critiques demonstrate biases, misinterpretation, selective use of data and over-simplification, and also ignore previous responses to their already published claims. ”
“Larcombe and Ridd (2018) argue that, due to the potential financial liabilities, RESEARCH CONDUCTED BY INDUSTRY (my caps) “is likely” to use more rigorous quality control procedures. This, however, does not seem supported by the fact that two fields of science where major credibility problems have arisen are medicine and biomedical science (Larcombe and Ridd, 2018 and references therein), both with a considerable proportion of industry-funded research.”
DOE p.17
“The most recent annual summary of GBR conditions from the Australian Institute of Marine Science indicates that coral production has rebounded strongly (AIMS, 2023). ”
FALSE CITATION (2023) of (OBSOLETE) 2022 report that fit claims, ignoring later ones
DOE p.18 Australian Institute of Marine Science. (2022). Continued coral recovery leads to 36-year highs across two-thirds of the Great Barrier Reef. https://www.aims.gov.au/sites/default/files/2022/08/AIMS_LTMP_Report_on%20GBR_coral_status_2021_2022_040822F3.pdf
I.e., the citation claims 2023, but reference is actually from August 2022.
The 2024 report was published in August 2024, so easily available.
/https://www.aims.gov.au/sites/default/files/2024-08/AIMS_LTMP_Report_GBR_coral_status_2023_2024_final.pdf
It warned upfront “Coral cover remains high while impacts of mass coral bleaching yet to be determined”
To be fair, the 2025 report only just came out August 6, 2025
https://www.aims.gov.au/sites/default/files/2025-08/AIMS_LTMP_Report_GBR_coral_status_2024_2025_final_web.pdf
But its graphs have substantial downturns, very different from those shown by DOE authors.
The real experts know GBR health varies from different factors, of which (right now) pH is relatively minor.
DOE p.18:
“Similarly, a meta-analysis (Clements et al., 2021) of the negative effects of ocean acidification on reef fish behavior found what they called a “decline effect”…
RED HERRING: the topic was reefs. Ocean species differ widely in the effects of pH changes (and so far, not much, maybe later), but fish are not reefs….
although of course if reef coral dies (for whatever reasons), the fish go away:
https://www.aims.gov.au/information-centre/news-and-stories/coral-reef-fish-running-out-time-recover-great-barrier-reef-islands
Summary: another BAD DOE section.
Personal comment: I’ve visited Queensland ~10 times, snorkeled at GBR, lectured in Townsville (where JCU is), visited Whitsunday Islands, etc, etc … so all thsi is personally very sad to me.
Thank you Mr. Mashey for your observations. What is happening to the GBR is complex to understand for a concerned layman like myself. And thank you for your work in connection with DeSmog, you’re a fine example of those putting forth effort, not just words in the battle to educate people and stand against the tides of b.s.
Reply to John Mashey
RED HERRING: the topic was reefs.
No. You’re guilty of doing what the Report is accused of. Incomplete, biased, and cherry picking sources, data and points of disagreement. You have shifted the topic under discussion in the Report.
The topic was changing pH impacts. of the Oceans. Coral Reefs was but one example of that in the literature. Nothing about Marine Heat Waves. There was a rebound of GBR coral extent. It was real and documented.
Read the report again, slow down, then focus.
Executive Summary-states-
Elevated concentrations of CO2 directly enhance plant growth, globally contributing to “greening” the
planet and increasing agricultural productivity [Section 2.1, Chapter 9]. They also make the oceans less
alkaline (lower the pH). That is possibly detrimental to coral reefs, although the recent rebound of the Great
Barrier Reef suggests otherwise [Section 2.2]
Section – 2.2 The Alkaline Oceans
2.2.1 Changing pH
2.2.2 Coral reef changes
concludes with-
In summary, ocean life is complex and much of it evolved when the oceans were acidic relative to the
present. The ancestors of modern coral first appeared about 245 million years ago. CO2 levels for more than
200 million years afterward were many times higher than they are today. Much of the public discussion of
the effects of ocean “acidification” on marine biota has been one-sided and exaggerated.
That was not a scientific statement but an observation of the public domain. Looking at John Mashey’s public comment supports their conclusion. One sided and exaggerated.
Thomas, you, a volunteer commenter on RealClimate, have chosen to interfere in an interaction between two other people whose credibility is much greater than yours.
Aside from the breach of civility, you are plain wrong.
John Mashey @ 8 Aug 2025 at 4:40 PM claimed (paraphrasing) that the DOE review section on ocean acidification in respect of coral reefs was “deceptive” because it focused on the acidification threat to coral reefs rather than the currently more concerning warming threat.
Thomas @ 9 Aug 2025 at 7:44 PM responded: “No. You’re guilty of doing what the Report is accused of. Incomplete, biased, and cherry picking sources, data and points of disagreement. You have shifted the topic under discussion in the Report.The topic was changing pH impacts. of the Oceans. Coral Reefs was but one example of that in the literature.”
Nigel: This is a weak response and its pedantry. I can’t see any reference in the DOE report “as a whole ” to the damaging effects of warming on coral reefs. Therefore the report as a whole is actually deceptive in its treatment of coral reefs. It creates the impression the only threat or main threat to corals is acidification when it isn’t. I would add that the report is very selective and unbalanced. The danger of warming to corals is well proven. So John Mashey was raising a good point.
Thanks.
In this case, the author(s) found curves they liked, which however had little to do with their report section’s topic (pH, AIMS experts were pretty clear), screengrabbed curves from 3 separate pages of 2022 report, put them together, falsely cited result as 2023, claimed it as most recent, when 2023 & 2024 had already been published.
We of course don’t know who wrote which sections, but I was certainly reminded of McKitrick & McIntyre’s misuse of charts in the early 2000s.
For example, see short thread on McKitrick paper:
https://bsky.app/profile/johnmashey.bsky.social/post/3lvuokrnj5s2a
Or see (a PDF of May 11, 2005 talk that M&M gave for Competitive
Enterprise Institute & George C. Marshall Institute.
https://web.archive.org/web/20060222093812/https://www.marshall.org/pdf/materials/316.pdf
Every one of slides 9-12 includes falsification/misrepresentation of one sort or another. (There are other problems, but these are simpler, exercise for the reader).
The image in slide 10 is *not* from IPCC(1991), although curve is the same, but there is nothing like it in IPCC(1995).
That image showed up shortly thereafter in the Wall St Journal, and Senator Inhofe used it in his 2012 book and in 2015:
http://www.desmogblog.com/2015/01/26/medievaldeception-2015-inhofe-drags-senate-dark-ages
That whole talk was in essence the “blueprint” for the Wegman Report, which is why Wegman had a copy of the Powerpoint (not just the PDF) given in 2010 to USA Today journalist Dan Vergano in response to FOIA:
https://embed.documentcloud.org/documents/422182-m-m-may11/
Simple diagrams are powerful, often get promulgated,, and even ones from otherwise credible sources can be deceptive if taken out of context, losign the caveats and disclaimers.
Addressing the CWG Report Critiques by nigelj, John Mashey , Susan Anderson misframing
A few observations:
On Scope
The report explicitly focuses on pH impacts—yet several critiques (e.g., John Mashey’s) conflate this with unrelated warming effects. This would be like dismissing a study on ocean acidification because it doesn’t address overfishing. Different phenomena require separate analysis.
JM: The real experts know GBR health varies from different factors, of which (right now) pH is relatively minor.
Which the CWG correctly point out in their report.
JM: RED HERRING: the topic was reefs. ?
No. The topic was Ocean pH.
On Coral Resilience
The discussion of the GBR’s recovery (post-cyclone impacts, pH adaptation) is supported by peer-reviewed literature—including Woods Hole’s 2023 findings. If the data is flawed, counter it with better data. Shifting the debate to warming is a non sequitur.
On Tone
There’s valid concern about civility—but it’s hard to reconcile when critiques themselves include remarks like “deceptive” “biased” “pedantry” or worse. Good-faith discussion requires consistency.
A: you are plain wrong.
Is not a civil mature argument.
The Bigger Picture
The report’s core argument—that public discourse has been unbalanced—is ironically reinforced here. Rather than engaging its key claims (e.g., coral adaptation, CO2 thresholds), responses instead:
– Change the subject (“but warming!”)
– Question motives (“who funded this?”)
– Focus on perceived tone over substance
If the science is as settled as claimed, it should withstand scrutiny—even from unorthodox angles. That some react so defensively suggests a deeper insecurity far beyond the science about Climate physics.
The intensity of the responses by all seem disproportionate to a critical review report – even one with potential biases or even distortions. When a scientific discussion provokes this level of institutional and activist reaction with even greater bias, it suggests we’re no longer debating data but challenging orthodoxy. That in itself warrants reflection about how consensus functions in climate science, in potentially very unhealthy self-defeating ways.
page 7-8 2.2.2 is about the reported impacts of declining ocean pH
Not marine heatwaves that have caused die offs.
I was referring to their use of last year’s AIMS report in 2.2.2 now that this year’s report is out.
Reply to David
I was referring to their use of last year’s AIMS report in 2.2.2 now that this year’s report is out.
Yes, obviously so. They could not include something that had not been published. The question is what’s the point of updating their work with that new link? It changes nothing and adds nothing. Obviously coral growth area cover changes from year to year for multiple reasons external to ocean pH. The 2023 AIMS report already provided the data scenario they chose to address. It’s a dead letter.
The CWG acknowledges openly it is far from a comprehensive assessment of all the science. Expecting they should or wishing they would update their report with the latest 2025 AIMS just because it exists is extreme overkill and further evidence their assertion: Much of the public discussion … has been one-sided and exaggerated. — is correct.
The Australian Institute of Marine Science’s latest Long-Term Monitoring Program (LTMP) 2024–2025 report (covering the Great Barrier Reef) focuses overwhelmingly on coral cover losses, bleaching events, and stressors like cyclones and starfish outbreaks. There is no mention of ocean acidification as a contributing factor in the summary materials
I read it. I word searched it. Nothing. The executive summary and key findings do not reference pH changes nor acidity as an issue of concern.
However, other science-based sources over time do highlight ocean acidification as a significant threat to the Great Barrier Reef’s health long term as well as global reefs. This is well known science theory. In the Summary they already acknowledge this : That (pH) is possibly detrimental to coral reefs .
Whereas Section 2.2.2 of the CWG “critical review” Report focuses on their stated purpose::
It is being increasingly recognized that publication bias (alarming ocean acidification results preferred by high-impact research publications) exaggerates the reported impacts of declining ocean pH
and
the Australian Institute of Marine Science indicates that coral production has rebounded strongly (AIMS, 2023). Figure 2.4 shows the results of the AIMS surveys of hard coral cover, expressed as a percentage of the reef area.
and
Ridd et al. (2013) showed that report to have resulted from a biased data analysis that, when corrected, showed no change in calcification rates. Nevertheless, the alarm produced by the original paper has persisted as evidenced by the large number of published citations (541) to the original study compared to only 11 citations to the correction (as of 30 April 2025).
Pedro Prieto points out their purpose with a direct quote:
Authors were invited specifically to “write a report on issues in climate science relevant for energy policymaking, including evidence and perspectives that challenge the mainstream consensus.” What else would you expect from such a brief?
The writing team worked with full independence — it is not a government report.
The short timeline and technical nature meant not all topics could be covered.
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/comment-page-2/#comment-837215
The GOP has been predominantly in the denier camp for decades. Nothing new here. Climate scientists push back against each other all the time for at least 35 years, there always someone being labelled by the mainstream traditionalist true believers as an outlier and a crank to be ignored.
The pushback reporting shown by PHILIP CLARKE, the John Mashey type reaction quoting a congaline of science papers, with RealClimate’s handwaving over their favourite denier targets, and the Bluesky and X cringing hype is only serving to more widely promote the PR spin by the DOE and the Republican base. The CWG exaggerates their bias as does all the ‘sciency’ responses show their exaggerated bias and political ideology too.
In the USA climate science is no different than the Abortion issue. Neither have anything to do with the Science or the Facts…but both are split right down the middle across the population and in Congress. This CWG Critical Review is a political beat up. So is the response.
Neither is worth knowing or talking about. The EPA is going to do what it is directed to do. No less than Obama ordered it to do. The CWG Report makes no difference to that. The flood of biased reactions won’t either. The Caravan will move on. Nothing changes. It’s America.
(Sigh) I was simply trying to…
Never mind. Another lesson learned. Will work on my precision writing,
And
Precision snarking, going forward :-)
As I noted, their citation claimed 2023, but reference was to 2022 report, and both 2024 report was out a year ago and warned of bleaching not yet evaluated.
Of course they couldn’t cite the 2025 report… but we’ll see what the update says..
One last point for today — I was curious about the stakes involved with potential regulation that might follow from the EPA endangerment finding. These stakes must be huge, given the massive freak out associated with the proposal to rescind the finding? Guess again.
Let’s look at some numbers. According to the Center for Climate and Energy Solutions, the projected carbon dioxide emissions reductions of the EPA 2021 light vehicle greenhouse gas emissions standards were estimated to be 3.1 billion tons, cumulatively to 2050.
From 2025 to 2050, the world would emit >900 gigatons of carbon dioxide, assuming constant 2025 emissions, and ~700 gigatons assuming emissions are cut in half by 2050.3 That means that the 2021 EPA regulations would reduce global emissions by ~0.3% (assuming constant emissions) or ~0.4% (assuming emissions are halved). I posted these numbers on X, expecting some pushback, I received none. I welcome alternative views in the comments.
I was surprised at how miniscule these numbers are, given the importance that some have placed on EPA’s ability to regulate greenhouse emissions.4 My view is that it is practically and politically impossible to accelerate decarbonization through these types of regulations. If the aim of such regulations is to create a shadow price on carbon, there are much more efficient and effective ways to price carbon.
The DOE CWG report and the response to it might tell us more about the state of climate science than it does about what might comprise effective climate policy.
https://rogerpielkejr.substack.com/p/emissions-scenarios-cwg-fact-check
“ If the aim of such regulations is to create a shadow price on carbon, there are much more efficient and effective ways to price carbon.” Probably, sure, but we do what we can.
“That means that the 2021 EPA regulations would reduce global emissions by ~0.3% (assuming constant emissions) or ~0.4% (assuming emissions are halved).” – Do I detect a hint of ‘it doesn’t matter what we do because everyone else is going to do what they do’ (tragedy of the commons) – well, ever heard of “The Golden Rule” (the non-cynical one) – “do(n’t do) unto others as you would(n’t) have done unto you”, “be the change you want to see”, etc., ie, do as you would have others do (in the same position, with the same skills/abilities/desires/fears/etc., and/or with reasonable generalization – ie I’m not a cardiothoracic surgeon in an operating room with a patient, so I’m not about to cut open the chest of the person in front of me; I’m also not going to force others to eat chocolate cake if they don’t want to)… there’s such a thing as leadership (by example); there’s also such a thing as treaties, corrective tariffs (eg. on embodied foreign emissions), …
It’s not just about justifying the policies that are (or were) already in place. It’s about potential futures. It’s also about truth.
…“ such a thing as leadership (by example)”… clarification: the argument that it shouldn’t depend on individuals acting voluntarily, which I agree with, doesn’t apply as strongly for larger, more powerful entities, and particularly when that entity has so much of the responsibility for what has been emitted so far.
Thessalonia, are you Roger Pielke Jr.? Copy and paste as a comment is not a comment, and if using other people’s words, the polite thing is to quote them. Mr. Pielke is aware of this blog and could put his words here himself if he wanted to.
Of course, your copy/paste made it seem that the only impact of ditching the Endangerment Finding is the impact on a single regulation, which is untrue. The EPA with the Endangerment Finding, is to regulate greenhouse emissions the same as it is required by law to regulate other pollutants. Even Mr. Pielke says (in the part you didn’t paste in) that he thinks that keeping it in place is the right thing to do.
Anyway, the convenience of arguing against this or that increment of a large problem is that it enables someone to placidly not do their part in solving a problem too big for any single entity to address. Is that the point you’re trying to make, entirely with someone else’s words?
And to Patrick’s point, I don’t know where you, Thessalonia, are from, but the United States, as (still) the largest emitter of CO2 in the industrial age, has a real obligation to lead by example. As the third largest population in the world, with our per-capita emissions higher than those in India and China, the obligation is even stronger.
Energy Secretary Chris Wright on Resetting the Climate Debate
Wall Street Journal Opinion
https://www.youtube.com/watch?v=r–BO8VXgnU
The Department of Energy’s new climate report is making waves, offering a fresh look at the alarmist claims pushed by special-interest groups and prior administrations. The report’s five scientists lay out data showing that while climate change is real, it isn’t the threat suggested by media or the climate lobby. On this episode of All Things, Energy Secretary Chris Wright takes Kim Strassel through the findings, including the upsides of warming, the minimal economic effects of climate change, the limits of U.S. policy actions and the lack of evidence that climate is related to the frequency or intensity of extreme weather.
Q.But your department of
energy also put out this report instead
looking at the climate science and and
what we know and what we don’t know.
Tell us why you commissioned that
report.
A. The climate change is a real physical
phenomenon. It’s scientifically
fascinating. It is a truly global issue.
But you know there’s certain facts and
data about it. There’s certain
implications about it. And most
everything I hear in the media, in the
news from politicians, from protesters
when I speak at universities, they’re
just so unaware of the basics of what
climate change is. And and to give one
example there, you hear these kids, I’m
choking, I’m coughing on so much carbon
pollution, you know, and look, the Clean
Air Act was about real pollutants that
do make you cough, that are toxic, that
do have, you know, acute human impacts
in local concentrations where where
carbon dioxide I I say it’s like oxygen
and water, H2O, it’s the three most
critical molecules for life on Earth. It
is the essential lifegiving plant food
that makes our life possible. So it does
absorb infrared radiation. So we can
have a real dialogue about too much of
it or too little of it is actually I
think maybe a bigger risk. But but you
know calling it a pollutant is is just
nuts.
… “ they’re just so unaware of the basics of what climate change is.” …
Some people who haven’t looked into it much are mixed up about some (very basic) things, therefore experts and people who’ve read/studied it a lot must also be wrong? (& Why wouldn’t that also apply to the speaker?)
Heat pollution. Light pollution. Sound pollution. All real things. It doesn’t have to be a novel/unnatural/foreign entity to be a pollutant.
I can see why Lawyer and Linguist was not your first career choice. It is critical to be aware the Law at hand is about Air. And therefore it relates to things that might pollute that Air. Obviously, heat, light and sound do not apply here. Never did.
Clean Air Act Definition of “Pollutant”
Under CAA Section 302(g) (42 U.S.C. §7602(g)), the term “air pollutant” is <b<defined as:
“any air pollution agent or combination of such agents, including any physical, chemical, biological, radioactive (including source material, special nuclear material, and byproduct material) substance or matter which is emitted into or otherwise enters the ambient air.”
What this means legally:
It’s a very broad definition.
Includes any substance or matter that enters ambient air and can cause air pollution.
Covers chemical compounds, particles, biological materials, and even radioactive materials.
Importantly, it’s not limited to just harmful or toxic substances — if something is emitted into ambient air and causes pollution, it can be regulated as a pollutant under the CAA.
As legally promulgated by Congress, determined by SCOTUS and subsequently decided by the EPA with due diligence.
As mentioned elsewhere no other nation requires a legally binding Endangerment Finding by a Government Department / Regulator to pass Laws and Regulate GHG emissions. Only the US has taken this route. iow ‘Only in America’, which explains everything.
“Obviously, heat, light and sound do not apply here.” Yet the point still stands: CO2, and for that matter, CH4 and N2O and other substances naturally in the air can still be, when added to it, pollutants. Do you agree with that? (and if so, why are you arguing about it?)
AFAIK, *legislation* does not require a government study for justification, but such things can provide political cover.
Reply to patrick o twentyseven
The point does not stand. It was correctly rebutted.
as for CO2 etc quote above : and causes pollution, it can be regulated as a pollutant under the CAA
CO2 is Air. Not a pollutant. Smog is a pollutant. Each needs to be determined how it becomes a pollutant under the CAA-nothing else counts ‘legally’. The EPA has already changed it’s mind. The rest is politics not science. The rest of the world do not have this problem of determining what drives global warming and why.
H2S is also “naturally” in the air (as well as “un-naturally) in fractional ppb concentrations. That said, I wouldn’t suggest breathing stronger and stronger concentrations said “air”, however. . People of course would die from that “air”.
T: CO2 is Air. Not a pollutant.
BPL: Anything in the wrong place or in too great an amount is a pollutant. Toxicologists say, “the dose makes the poison.” If you’re trying to prepare anhydrous ammonia, water is a pollutant. If you’re trying to prepare pure bottled nitrogen, oxygen is a pollutant. CO2 is a pollutant because it’s 50% higher than during preindustrial times.
Sigh. If you don’t drink water, you die. If you drink too much, you die. Water is not a pollutant, but you can have too much of a good thing. The meaning of ‘pollutant’ has undergone an evolution–now sound pollution and light pollution are common terms.
Yes, CO2 is necessary for life. We all know that. But yes, there can be too much of a good thing. By the way, in the abstract at least the authors of the report under discussion agree, as can easily be seen in the report they wrote.
So, calling an excess of CO2 a ‘pollutant’ might not be a felicitous choice of words. Calling our current use of the fuels causing an excess of CO2 could better be described as an overdose.
But semantics aside, I continue to maintain after reading this post and the comments to it that the report was written in good faith and makes some–almost many–good points. That the vile Trump administration would co-opt it for use in their relentless destruction of the country I love could only surprise those who have been in a coma for the past decade.
General note: “Fact checker” has chosen a moniker which does not describe his or her activities. The bias is strongly against progress on cleaner energy, which ensures biased results.
In my email this afternoon from NASEM Climate – The press release includes links and contact information:
https://www.nationalacademies.org/news/2025/08/national-academies-launch-fast-track-review-of-latest-evidence-for-whether-greenhouse-gas-emissions-endanger-public-health-and-welfare
National Academies Launch Fast-Track Review of Latest Evidence for Whether Greenhouse Gas Emissions Endanger Public Health and Welfare
News Release | August 7, 2025
“WASHINGTON — A new National Academies of Sciences, Engineering, and Medicine 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 conducting the study will focus on evidence gathered by the scientific community since 2009 — when the U.S. Environmental Protection Agency first declared greenhouse gas emissions a danger to public health. Any conclusions in the committee’s report will describe supporting evidence, the level of confidence in a conclusion, and areas of disagreement or unknowns.
The EPA recently announced that it intends to rescind its “endangerment finding,” a statement issued by the agency in 2009 that found that greenhouse gas emissions do pose risks to public health and welfare. The National Academies study will be completed and publicly released in September, in time to inform EPA’s decision process.
“It is critical that federal policymaking is informed by the best available scientific evidence,” said Marcia McNutt, president of the National Academy of Sciences. “Decades of climate research and data have yielded expanded understanding of how greenhouse gases affect the climate. We are undertaking this fresh examination of the latest climate science in order to provide the most up-to-date assessment to policymakers and the public.”
The committee will be led by Shirley Tilghman, professor of molecular biology and public affairs, emeritus, and former president, Princeton University. The committee will also include experts in public health, extreme weather, climate modeling, agriculture, infrastructure, and other areas.
The committee has issued a request for information to the public and scientific community. The study is being self-funded by the National Academy of Sciences.”
They should be able to dust off hundreds of documents already laying out the scientific reason that are substantial enough to use right now and at any time since 1990 at least.
This special pleading “Decades of climate research and data have yielded expanded understanding of how greenhouse gases affect the climate. ” is really not necessary nor credible. Unless there is some degree of incompetence or error in prior scientific work.
The action of GHGs in the Air has never changed-that is basic Physics.
Quoting the EPA in 2009>
The Administrator has determined
that the body of scientific evidence
compellingly supports this finding. The
major assessments by the U.S. Global
Climate Research Program (USGCRP),
the Intergovernmental Panel on Climate
Change (IPCC), and the National
Research Council (NRC) serve as the
primary scientific basis supporting the
Administrator’s endangerment finding.1
If it was compelling in 2009, that same science would be compelling today. There is no need to reinvent the wheel, surely.
This article / issue and commentary is a storm in a tea cup – a beat up over nothing substantial.
Headline numbers (EPA Inventory, 2022 data — CO₂-equivalent basis)
Total U.S. net GHG emissions (2022, EPA Inventory): ≈ 5,489 million metric tons CO₂-eq..
Vehicles covered by EPA/NHTSA regulations (passenger LDVs + medium/heavy trucks) account for roughly one-quarter of U.S. reported GHGs (CO₂-eq).
The majority (~3/4) of reported U.S. GHGs come from other sectors — especially electricity generation, industry (including process CO₂ from cement/steel), buildings, and agriculture/non-CO₂ sources.
Combined (vehicles covered by federal vehicle regs):
Light-duty + medium/heavy trucks ≈ 1,289–1,321 MMT CO₂-eq. (that is ~23–24% of U.S. net GHGs in 2022).
US EPA
Everything else (all other reported U.S. sources combined):
≈ 5,489 − 1,305 (midpoint) ≈ 4,184 MMT CO₂-eq., i.e. ~76–77% of U.S. net GHGs — includes electric power, industry (cement/steel/etc.), buildings, agriculture (non-CO₂ gases), waste, land-use sinks, and smaller transport categories (aviation, rail, marine).
Sources: EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2022 (Data Highlights & Transportation chapter) and EIA environment / CO₂ data
Big-picture takeaway?
Since the 2009 Endangerment Finding, the only enduring, nationwide, binding GHG limits under EPA authority are for mobile sources — passenger cars/light trucks and medium-/heavy-duty trucks.
All major stationary source categories — including cement, steel, refineries, and existing power plants — have never had a sustained, implemented federal CO₂ limit.
Would anyone like to see a Table or detailed breakdown of all EPA GHG Regulations Since the 2009 Endangerment Finding (excluding Reporting-Only) ? My operating theory is this article is personal – because the “usual suspects” are involved. This does not appear motivated by concern about rescinding the EPA GHG Regulations or overall US Govt Climate Policy.
Bottom line the Impact of the EPA Endangerment Finding is minimal and has been ineffective in driving systemic change.
Outside of passenger vehicle GHG standards, EPA has never implemented broad, nationwide, binding GHG emission limits for most large industrial sources under the Endangerment Finding. From 2009 to 2025, the Endangerment Finding’s only fully implemented, nationwide, binding GHG emission standards were for passenger motor vehicles and light-duty trucks. Everything else was either reporting-only, stayed by SCOTUS before taking effect, too narrow to have broad sectoral impact, or finalized too late to bite before policy reversals.
The EPA “endangerment finding” triggered by the 2007 SCOTUS judgement is touching on a profound and painful truth about how legal systems and societies can codify injustice and fallacies under the guise of law and interpretation.
Throughout history, many deeply unjust practices — slavery, segregation, systemic racism — were upheld by courts and laws that reflected the power structures and social norms of their times, rather than true justice or morality and enlightened reason. The law can be a tool for both oppression and liberation, depending on who wields it and how. And the United States’ history is full of examples where legal decisions entrenched inequality and suffering.
This context helps explain the skepticism and anger many feel today about institutional failures to address urgent issues like climate change, racial justice, and inequality. The system’s imperfections — and sometimes its outright cruelty — are woven into the fabric of its institutions, and it takes constant struggle and pressure from movements, citizens, and leaders to push for real change.
It’s heavy, but understanding that history is crucial for grasping why calls for systemic reform and accountability remain so urgent. Meanwhile Congressional districting gerrymanders prevail – a bipartisan ordained system of convenience.
Law is not neutral; it always reflects the power dynamics and social biases of its time. Trump won the election- and you will not forget it. They remind us that legal victories and reforms require sustained activism, political will, and societal change-founded on morality not self-interest, bigotry or cultural biases. They underscore the need to critically evaluate current laws and policies — to ask who they serve and who they harm.
A huge segment of American society is saying this is precisely what the EPA re-evaluation of GHG regulations is all about. Is it really about climate science, or something else when SCOTUS voted 5-4 in 2007?
Finally a post I can agree with. Benjamin Franklin famously said, “Revolutions come into this world like bastard children–half improvised and half compromised.”
It is probably true everywhere, but it is especially true in the US, that those compromises have always involved throwing a substantial proportion of the population under the bus–or in 1776, the cart. The patriarchy that retains power demands sacrifice of the minority (or the majority when it comes to women) before extending the privilege it controls to a wider population. And so with the birth of democracy, Americans accepted anti-democratic institutions and structures.
Every economy is structured to produce a commodity or set of commodities more efficiently than the rest. For America, the structure is optimized to produce billionaires at the expense of everyone–and everything–else. The entire US population represent little more than domesticated animals to be fleeced by the billionaire class at will. But billionaires are not a sustainable industry. Eventually, the stress on the economy, the population and the environment reaches a point where the damage is irrecoverable.
So, the billionaires are not pulling up stakes and on their way out, they are stealing everything that isn’t nailed down, prying up much of what is, and destroying the rest. This is the regime that now holds power. They don’t care about the future because America has no future.
A roundup of responses in the press. I swear I tried to find some positive ones, but they don’t seem to exist.
Science
“Climate researchers say the authors cherry-picked evidence and highlighted uncertainties to achieve the net effect of downplaying the impacts of climate change.”
Quote: “This shows how far we have sunk,” says Naomi Oreskes, a historian of science at Harvard University. “Climate denial is now the official policy of the U.S. government.”
https://www.science.org/content/article/contrarian-climate-assessment-u-s-government-draws-swift-pushback
Nature
Outrage over Trump team’s climate report spurs researchers to fight back
Quote: “This little report is basically designed to suppress science, not to enhance it or encourage it,” says Joellen Russell, an oceanographer at the University of Arizona. “It’s awful.”
https://www.nature.com/articles/d41586-025-02505-x
Wired
“The DOE report presents a distorted picture of climate science, experts say, relying on cherry-picked data and misrepresented studies to downplay the impacts of greenhouse gas emissions.”
Scientist Quote:
“They completely misrepresented what we said. It’s the exact opposite of our conclusions.” — Zeke Hausfather
https://www.wired.com/story/scientists-say-new-government-climate-report-twists-their-work
The Guardian
“In a move that experts say amounts to gaslighting the public, the DOE has released a report riddled with errors, omissions, and misleading interpretations of peer-reviewed research.”
Scientist Quote:
“This report is a farce. It cherry-picks data, ignores established science, and reads like a political document, not a scientific one.” — Michael Mann
https://www.theguardian.com/us-news/2025/aug/01/trump-epa-climate-change-report
The Washington Post
“The Energy Department’s analysis contradicts mainstream climate science, ignores key research, and appears designed to support a regulatory rollback rather than present a balanced scientific review.”
Scientist Quote:
“The report is scientifically flawed and politically motivated… It grossly mischaracterizes our work and the state of climate science.” — Joy Ward
https://www.washingtonpost.com/climate-environment/2025/07/31/endangerment-repeal-climate-science-report
AFP / Phys.org
“Leading climate scientists have accused the DOE of misusing their work in a controversial report that questions the dangers of greenhouse gases — a move experts say undermines scientific integrity.”
Scientist Quote:
“They used our names to lend credibility to claims we do not support. It’s a fundamental misrepresentation.” — Ben Santer
https://factcheck.afp.com/doc.afp.com.68KV7WE
Inside Climate News
“The report revives long-discredited arguments favored by climate denialists, drawing sharp rebukes from researchers who say it misrepresents their findings and misleads the public.”
Scientist Quote:
“It’s antiscientific garbage dressed up as government policy. A direct assault on climate science from within the DOE.” — Andrew Dessler
https://factcheck.afp.com/doc.afp.com.68KV7WE
Politico Pro
“In framing climate science as a debate, the Energy Department’s report departs sharply from decades of research and opens the door for regulatory rollbacks grounded in political ideology rather than empirical evidence.”
https://subscriber.politicopro.com/article/eenews/2025/07/31/doe-reframes-climate-consensus-as-a-debate-00485867
Science Feedback
Misleading U.S. Department of Energy climate report chooses bias over science, climate scientists say
Quote: Scientists with expertise on climate explain that the recent DOE climate report cherry-picks information, misrepresents research findings, and overall is not a proper, nor scientific, assessment of climate change impacts.
https://science.feedback.org/review/misleading-u-s-department-energy-climate-report-chooses-bias-over-science-climate-scientists-say
People in glass houses shouldn’t throw stones. Especially not about “cherry picking” or “gross mischaracterization” when doing exactly the same thing. For fairness alone — knowing most here and in the media won’t heed it — a few glaring errors from the Science.org article:
Claim: The Department of Energy released its own climate assessment.
False. It’s not an “assessment.”
Claim: DOE had fewer authors than the IPCC’s 721 — just five.
Irrelevant. The two are not comparable in scope or mandate.
Claim: Authors “hold contrarian views” out of step with the mainstream.
Irrelevant mischaracterization. Mainstream ≠ correct. James Hansen and hundreds of others also deviate from “mainstream” views.
Claim: The report is far from comprehensive.
Explained in the Executive Summary and Preface — the scope was intentionally focused.
Claim: Richard Tol’s work was mischaracterized to suggest climate change benefits poor countries.
False. That is not what the report said.
Claim: IPCC assessments are “much more comprehensive.”
Not necessarily more accurate.
This Science.org piece is itself neither comprehensive nor unbiased. It cherry-picks, misframes, and did not contact even one of the five authors for a right of reply.
The “report” clearly states:
It is a Critical Review of Impacts in the USA, not a PR exercise.
It examines scientific certainties and uncertainties in how CO₂ and other GHGs affect the nation’s climate, weather extremes, and selected well-being metrics.
Authors were invited specifically to “write a report on issues in climate science relevant for energy policymaking, including evidence and perspectives that challenge the mainstream consensus.” What else would you expect from such a brief?
The writing team worked with full independence — it is not a government report.
The short timeline and technical nature meant not all topics could be covered.
Focus was on topics:
treated by serious, established literature,
relevant to the brief,
downplayed or absent from recent assessments, and
within the authors’ competence.
It is exactly what they said it was.
More realism, less reflex bias — from both journalists and scientists — would help. Right now, too many are playing the same game they accuse others of.
PPr: Claim: Authors “hold contrarian views” out of step with the mainstream.
Irrelevant mischaracterization. Mainstream ≠ correct. James Hansen and hundreds of others also deviate from “mainstream” views.
BPL: These particular people are long-term global warming deniers. Hiring them to do a report on the nation’s energy sources is guaranteed to favor the arguments they have made for decades now. It’s very like a report on archaeology from Erich von Daniken and Zechariah Sitchin.
Reply to Barton Paul Levenson
(repeating from above)
Authors were invited specifically to Quote CWG:“write a report on issues in climate science relevant for energy policymaking, including evidence and perspectives that challenge the mainstream consensus.”
What else would you expect from such a brief?
Right now, too many are playing the same game they accuse others of.
Tom: I expect the EPA director will rescind the Endangerment Finding soon after September. The DOE CWG report is irrelevant and not even required to take that action. It was likely instigated to keep you and all the climate scientists busy distracted off balance and spinning your wheels over nothing.
EPA Head Zeldin Asked If He Believes Greenhouse Gases Are The Biggest Drivers Of Climate Change
Forbes Breaking News 3 minutes 7 days ago now
https://www.youtube.com/watch?v=4Ne4-4eiNTw
Pay attention to the words in his answer to the question: nothing has changed since. Nothing will change no matter what the climate scientists or their institutions and the Democrat media say.
SCOTUS is now a wholly owned subsidiary of the GOP where once it was owned by the Democrats. Obama, Pelosi and Hillary changed all that.
“SCOTUS is now a wholly owned subsidiary of the GOP where once it was owned by the Democrats. Obama, Pelosi and Hillary changed all that.”
The latter half of that is pure rubbish. The SCOTUS has never in recent times been “owned” by the Democrats the way they are owned by the facists/GOP now. Not even remotely.
And yes, CO2 is a pollutant, sport. That science is unequivocal. It is emitted by internal combustion engines all the time. Go right ahead and fill a bag full of car exhaust and breath it in if you do not believe me. And stop flaunting your scientific ignorance as if you are another KIA or Victor. You guys should get a room somewhere. lol.
T: SCOTUS is now a wholly owned subsidiary of the GOP where once it was owned by the Democrats. Obama, Pelosi and Hillary changed all that.
BPL: The hell they did. The Republicans blocked supreme court nominations by Democrats, then let Trump appoint three new MAGA justices. If Hillary had won, that wouldn’t have happened.
And one of the sockpuppet accounts is misinforming again, with not a shred of evidence cited. For example:
That leaves out the fact that the Science piece links to Dr. Tol’s blogpost. And in that blogpost Dr. Tol quotes the pertinent section of the report:
Folks should really not trust these sockpuppet accounts.
https://www.realclimate.org/index.php/archives/2025/06/unforced-variations-jun-2025/#comment-834293
“It’s like somebody took all the bullshit from 10 years ago, didn’t refrigerate it and has now regurgitated it.”
.
“Scientists launch coordinated response to Trump’s attempt to wipe credible climate research off the record”
https://www.cnn.com/2025/08/08/climate/scientists-respond-trump-report
I led with a comment from the story made by a unnamed senior government scientist because its funny (and a really gross image) and because it’s telling, illuminating the insane approach being wielded by Wright and Zeldin to yield a predetermined result. All in service of a profoundly ignorant and stupid manchild.
“We want to get all the science into the public record, so that any debate over this will have access to solid science,” Dessler told CNN.
It is already in the public record. All of it is accessible. All of it has been part of “the debate”.
“People are really mad,” Dessler said. “We’ve devoted our lives to doing good science, and bad science is offensive. They’re not raising interesting questions and they’re not identifying things that scientists have overlooked; much of it is already debunked.”
And that debunking made no difference. Trump won the last Election anyway. His Administration is doing what they were elected to do. Rescinding the EPA Endangerment Finding is part of that mandate.
That change will make no difference to climate change, extreme weather events in the USA nor have any significant impact on America’s extremely excessive GHG emissions going forward–nor from their past extremely high contributions to global warming.
The whole thing is a beat up. From both sides. Does not amount to a hill of beans. At any moment it will all be forgotten. Like Dressler’s past “debunking” has been all forgotten.
I have read this “critical review” document. To be generous, I’ll start by trying to be positive about their document.
Positive thoughts:
1. I like how they emphasize the importance of Mauna Loa CO2 data… it’s too bad that the Trump administration wants to defund it…
2. I think Nic Lewis has a point regarding the use of Bayesian priors when estimating climate sensitivity and the preference for more objective analysis. Although, I think the paper doesn’t well communicate this issue on a more intuitive level. A better way to communicate this idea might be to emphasize the importance of certain invariances as this is the underlying justification for Jeffrey’s prior. Our metric for climate sensitivity is somewhat arbitrary and I think it is plausible that an alien civilization with a different planet might use a different metric such as a square root or linear relationship. Even if the aliens had the same planet as Earth, the preference to use climate sensitivity rather than a monotonic transformation such as the logarithm of climate sensitivity is somewhat arbitrary. If we recognize that the definition of climate sensitivity is somewhat arbitrary, such as up to monotonic transformation, then this justifies an inference approach that is invariant to this arbitrariness.
3. They bring up a valid concern of the use of total least squares for fingerprinting in climate science. It would be preferable if better statistical methods were used.
4. They have a point regarding the overuse and implausibility of RCP 8.5. Although, this has been discussed a fair amount in the literature.
5. Figure 6.8.2 admits that climate change causes fire risk. They have a bit of a point that improvements to wildfire reconstructions and better assessments of wildfire attribution would be desirable.
Neutral Thoughts:
1. They claim that CO2 fertilization was omitted from AR6 summary documents. While this appears to be the case, agricultural impacts are discussed. The synthesis document says that “climate change has slowed [agricultural] growth… with related negative impacts mainly in mid-and low latitude regions but positive impacts in some high latitude regions” and mentions negative agricultural impacts on page 7. The summary for policymakers document only mentions “agricultural and ecological droughts”. So they might have a bit of a point here regarding a lack of information on agricultural impacts in summary documents.
2. Their discussion of the urban heat island is misleading as it omits much of the relevant literature. At the same time, it would be desirable if temperature datasets improved their treatment of the urbanization biases. The CRUTEM5 model is decades old and assumes a spatially uniform and linear urbanization bias across the planet; it would be nice if they could develop a physics-based model similar to recent GloSAT efforts to improve exposure bias corrections. Similarly, it would be nice if Berkeley Earth, GHCN and DCENT could include explicit adjustments for the blending of urban biases in rural areas due to homogenization algorithms.
3. McKitrick did find some data issues with the Moore et al. agricultural damage estimates, which were used by the EPA to estimate the social cost of carbon. It would be preferable to adopt newer estimates… unfortunately the recent literature on this was not discussed in their document.
Negative thoughts:
1. Much of the document is cherry picking, such as warming in the corn belt, Nile river precipitation, or various selected tide gauges.
2. Figure 5.2 annoys me greatly. Purposely not updating it to include data for 2023-2024 is misleading. Two sigma rather than one sigma uncertainty ranges would be more appropriate.
3. I genuinely don’t understand the tropospheric warming argument. If the temperature gradient between the surface and tropopause has not decreased by as much as climate models predict, then this suggests a weaker lapse rate feedback and thus a higher climate sensitivity.
Other:
For employment reasons, I should withhold opinions on the economic component of their document.
Re: “I genuinely don’t understand the tropospheric warming argument. If the temperature gradient between the surface and tropopause has not decreased by as much as climate models predict, then this suggests a weaker lapse rate feedback and thus a higher climate sensitivity.”
I don’t get it either. For years people pointed this out to report co-author Dr. John Christy:
Report co-authors Dr. Christy and Dr. Ross McKitrick all but admitted it in their 2018 paper:
So the claim of lower climate sensitivity in chapter 4 of their report does not fit well sections 5.3 and 5.4 claims on tropical tropospheric warming:
https://web.archive.org/web/20250729225230/https://www.energy.gov/sites/default/files/2025-07/DOE_Critical_Review_of_Impacts_of_GHG_Emissions_on_the_US_Climate_July_2025.pdf
Here’s the 4.5 billion year history of CO2 in earth’s atmosphere: https://earth.org/data_visualization/a-brief-history-of-co2/. Burning fossil fuels Increases the concentration of greenhouse gases in the atmosphere which threatens the future habitability of our planet for our children and grandchildren: https://www.nrdc.org/stories/greenhouse-effect-101.
Currently, the IPCC’s goal is to limit global warming to well below 2 ºC and to pursue efforts to limit warming to 1.5 ºC.
Experts now say that the world’s 1.5 degree climate target is deader than a doornail: https://www.theguardian.com/environment/2024/nov/18/climate-crisis-world-temperature-target.
Of course we don’t really know if earth’s climate is stable at 1.5ºC or 2ºC of warming. Positive feedbacks (e.g., permafrost melting releasing additional greenhouse gases) could result in much more warming (i.e., 1.5ºC and/or 2ºC of human-caused warming could be transient and lead to a much higher stable state temperature). We only know for certain that 0ºC of warming was stable for 10,000 years with CO2 levels at around 280 ppm (https://earth.org/data_visualization/a-brief-history-of-co2/). We’re currently at 427 ppm (https://www.co2.earth) and the Amazon rainforest is no longer a carbon sink: https://www.smithsonianmag.com/smart-news/amazon-rainforest-now-emits-more-greenhouse-gases-it-absorbs-180977347/.
Here are some other climate tipping points:
https://www.theguardian.com/environment/2022/sep/08/world-on-brink-five-climate-tipping-points-study-finds,
https://news.climate.columbia.edu/2021/11/11/how-close-are-we-to-climate-tipping-points/,
https://grist.org/climate-tipping-points-amazon-greenland-boreal-forest/ and
https://www.smh.com.au/environment/climate-change/how-lucky-do-you-feel-the-awful-risks-buried-in-the-ipcc-report-20210811-p58hut.html.
The CO2 budget clock is ticking: https://www.mcc-berlin.net/en/research/co2-budget.html.
We are currently running an extremely dangerous experiment to see how much CO2 we can dump into the atmosphere without causing an existential climate crisis: https://www.theguardian.com/environment/ng-interactive/2021/oct/14/climate-change-happening-now-stats-graphs-maps-cop26.
Ray Ladbury says
9 Aug 2025 at 11:20 AM
Thomas,
Any time you opt for 100% anything, it will be more expensive than an option where any source can contribute. Learn some basic economics.
Tom: So when they push 100% WWS my guess is you think that doesn’t count in your basic economics for energy supply.
Kevin McKinney says
9 Aug 2025 at 3:57 PM
re Thomas said:
And when baseload from hydro, nuclear, fossil, or interconnectors is cut, most RE-heavy grids fail — while electricity is only ~32% of total energy use, making the whole system more fragile into the future.
Tom: The future emphasis was already there. Why can’t people recognize that and think ahead? Today every RE grid is backed by nuclear, FF, hydro or interstate interconnectors from those kind of sources plus some RE from other Grids.
The stated goal and intention of all these regional and national ‘green RE’ grids to shut down FF and Nuclear supply asap. Both UK and California are classic examples of this already mentioned; plus also Spain and South Australia Germany France and Denmark. Further Hydro supply expansion is critically limited.
What happens to every grid as those backup supply is shut down; or there is no longer an excess which can be exported to other heavy RE grids who need it? Because that back up supply is going to be Cut eventually!
The presumed hypothetical unproven and unattainable assumption being made is that by then there will be enough overbuild of RE plus backup storage in various forms to cover all contingencies in every grid all the time. There is no evidence this possible. In fact the opposite. We only have long distant theories and hope.
But today the signs don’t look good. As for Spain example above Kevin, what you have there is official govt spin protecting itself from criticism using plausible deniability, nothing more. If there was no large RE penetration operating at ~90% of local supply provision the instability event would never have occurred, the interconnectors would not have been necessary either.
The excuses try to eat their cake and have it too. But the automatic blackouts, grid collapse, interconnector disconnects are real. Not theories.
T: If there was no large RE penetration operating at ~90% of local supply provision the instability event would never have occurred
BPL: People who actually wrote the reports on the event disagree with you.
Barton cites unnamed ‘reports’ as counterevidence – a classic appeal to vague authority. For observers tracking actual grid failures: the Spanish blackout investigation report (REE 2024) explicitly notes the system’s low inertia due to 53% solar penetration was the primary instability trigger (p. 18). This isn’t theoretical – it’s the documented failure mode of high-penetration renewables without sufficient synchronous generation.
Grid physics don’t care about consensus nor internet trolls – as Spain’s 12 million temporarily powerless consumers can attest.
Tom is correct, possibly refi’ng a 2024 report in error haste. These failures are all similarly triggered by current instability as a result of RE-Heavy uptake for electricity supply.
Barton is wrong again.
The last major Spanish grid failure occurred on April 28, 2025, when a blackout on the Iberian Peninsula affected the entire Spanish and Portuguese mainland grids, as well as parts of France. The outage, which began around 12:33 CEST, was caused by a complex sequence of events, including two simultaneous disconnections of major power plants in southwestern Spain, leading to a cascading failure and a significant drop in power supply.
Details of the 2025 Blackout
Cause:
Initial reports and the subsequent government report point to a multifactorial origin, including operational errors, technical breaches, and shortcomings in voltage management, which triggered protective systems leading to a cascading failure.
Significance:
The event was described as one of the most extensive blackouts in recent European history and highlighted challenges in grid stability, reserve adequacy, and integrating renewable energy sources.
June 18, 2025 6 wks post event
Spanish government identifies critical failures in the 28-A blackout and points to Red Eléctrica
The report published on 17 June confirms insufficient voltage control capacity, planning failures, and premature disconnections that worsened the blackout. Red Eléctrica is now under scrutiny, with regulatory measures and potential sanctions expected.
A system under strain days before
The technical document provides information not included in Aagesen’s public remarks or the government communiqué. It shows that in the days leading up to 28 April, several voltage instability episodes were recorded, such as overvoltages on 22 April and undervoltages on 24 April, along with isolated oscillations.
https://strategicenergy.eu/spanish-goverment-report-blackout/
Your summary of the core information is accurate in its conclusion that the grid was not operating to handle the complexity of the new, RE-heavy makeup. The overvoltage was indeed the fundamental issue, and it was one that was exacerbated by the grid’s specific vulnerabilities to the conditions created by extensive RE supply. The official reports suggest that the failure was not a result of “too much” renewable energy, but rather the failure of conventional grid infrastructure and management to adapt to the new energy landscape. The need for more immediate current stabilization technology, such as batteries and other fast-acting systems, is a key takeaway from the event.
video discussion, Did Renewables Cause the Blackout in Spain? with Pedro Prieto.
https://m.youtube.com/watch?v=UX815YnSt0k
If you wanted to stir up a distracting hornets nest in the media, and put all the pro-climate scientists even more off balance and out of sorts, emotional and reactionary, or felt like a bit of personal retaliation, what would you do if you were in the Trump Administration?
I’d telephone Christy, Curry, Koonin, McKitrick, and Spencer and ask if they’d like to create a short climate review. So how do you know when you’re being played?
It doesn’t matter if we’re being played or not. (good point though, that is a fine list of biased favorites of the liar and bully party who think they can put profit in front of having a future; see Trump sharpie weather and Cruz Cancun vacation, etc. etc. etc. ad nauseam).
The destructive realities of toxic stupidity and ignorance face us every day in the news. Check fires, floods, toxic waste, pandemics, invasive species, ocean acidification, etc., and the people left without resources in face of same for fun and profit. No amount of lies matter one whit to the planet.
Reply to Susan Anderson
No amount of lies matter one whit to the planet.
And it’s worth remembering with a large helping of humility.
Health and Safety Impacts of Rising CO₂ Levels
A question rarely addressed in policy discussions is: How high can atmospheric CO₂ rise before directly affecting human health and safety?
A recent paper published in the Royal Society of Chemistry (June 30, 2025) examines CO₂ not just as a climate driver but as a direct pollutant with health risks:
“Carbon dioxide as a pollutant: the risks on human health and the stability of the biosphere”
“Up to now, no human being—and none of our hominin ancestors—ever lived a whole life at CO₂ concentrations higher than 300 ppm. But we will now be forced to do exactly that, while our descendants will experience even higher concentrations.”
https://pubs.rsc.org/en/content/articlepdf/2025/VA/D5VA00017C
The study argues that CO₂’s biochemical impacts may rival its radiative forcing in terms of harm to human health and ecosystems. It notes:
“We found that the current concentration of 425 ppm is not far from levels that can negatively affect people’s health—especially indoors, where concentrations are often much higher. Meanwhile, atmospheric CO₂ keeps rising by ~3 ppm/year. What are we doing?”
Key Findings:
– Cognitive Effects: Impairments in mental performance are observed at indoor CO₂ levels already common today. As atmospheric CO₂ rises, so will baseline indoor concentrations.
– Uncharted Exposure: No human population in history has lived entire lifetimes at current (let alone future) CO₂ levels. This constitutes an uncontrolled experiment on long-term health.
– Irreversibility: While short-term exposure effects can be reversed with fresh air, the atmospheric CO₂ increase is effectively permanent on human timescales.
Policy Lag Behind Science
While the EPA and other agencies focus on CO₂’s climate impacts, its direct health risks remain understudied in regulatory frameworks. The paper calls for urgent research into chronic exposure effects, particularly as indoor environments (where people spend ~90% of time) amplify CO₂’s physiological impacts.
EPA context: “The U.S. lags behind the EU and WHO in evaluating CO₂ as a direct health risk—despite indoor air quality standards existing for other pollutants.”
Indoor CO₂ data: “Classrooms, offices, and bedrooms often exceed 1,000 ppm (2.5× outdoor levels), with studies showing cognitive declines at 1,400 ppm.”
Question for Discussion: Should health-based CO₂ thresholds (beyond climate considerations) inform policy sooner rather than later?
Thessalonia, I’d suggest you look at the diagram titled A phase diagram of habitability for residents of the Earth, displayed in a YouTube video titled Mirrors for Earth’s Energy Rebalancing (MEER:refEction) | Dr. Ye Tao | 2019NSSUS, published 14 Feb 2020, duration 55 minutes, shown from about time interval 15:25. Dr. Ye Tao said:
“We can actually consider this 2-D graph as a phase space of life. So there are regions on this 2-D graph that can support life as we know it in our current environment. And we can even plot boundary lines, outside of which we cannot live. So plants would actually starve when the CO2 concentrations fall below about 30 to maybe 50 ppm, depending on the temperature. So they need CO2 to do photosynthesis, obviously. So removing all CO2 is actually bad, and when there’s too much CO2, they, you know, our blood would be acidified and ocean will be acidified and the acid will just kill life. So that’s also obviously not good, and at different levels of overall heating, people have experimentally and empirically observed, like at even one degree Celsius, we will have a local extinctions called extirpations of different populations, so that’s already very dangerous at 1 degree C and at 2 degrees C increase, experimentally has been shown that you can actually induce, you know, collapse of whole communities, And even higher, that’s basically, basically, ah, spelling biological annihilation. That’s a term that’s published in the literature from biological sciences.”
https://youtu.be/fwvPJnPP9KI?t=925
So it’s not the direct rising atmospheric CO2 concentrations that would threaten us/humanity within this century, but it’s the increasing instances of lethal heat events that would likely kill more and more of us and increasingly destroy much of our food supplies from extreme storms, heat, fire and drought events in the coming few decades.
https://globaia.org/habitability
Quite a quintet:
.
“The Trump administration’s “critical review” of climate science is authored by some of Fox News’ favorite climate deniers” – Written by Allison Fisher, Published 08/14/25 3:47 PM EDT
.
https://www.mediamatters.org/fox-news/trump-administrations-critical-review-climate-science-authored-some-fox-news-favorite
Paul Pukite Quote:
“The tipping point is reached when the gate-keepers of the conventional wisdom can no longer hold back the plethora of scientific evidence.”
This may describe the current situation in climate science. The official consensus still presents a steady, gradual path toward stabilization, but recent observations suggest the system may be moving faster and less predictably than the models assume. Whether through unexpected warming in 2023/24 or the optimistic reliance on rapid fossil fuel decline in IAM pathways, there are growing signs that our frameworks may be underestimating risks.
If so, the “tipping point” Pukite refers to may not just be about evidence, but about communication itself—when the gap between the official message and the emerging data becomes too wide to ignore.
patrick o twentyseven says
16 Aug 2025 at 10:13 PM
The challenges of storage are the amount of power and the amount of energy.
Plus the Length of Time that amount of Power/Energy needs to be stored for in order to meet the Needs of the Grid users in time and space in the real world.
None of the comments by the residents here address any of these matters holistically or accurately.
But, if one day you can solve those Grid supply challenges then you can turn your head toward solving the other 80% of Energy Demand in a constantly increasing demand curve for decades into the future. The default approach here of only looking at one Lego Brick at a time will never got you to solve either. Which ironically, is precisely where we are now and will continue to be while the realities are denied dismissed and ignored. ad nauseum.
“the other 80% of Energy Demand”? – (I’m not sure that’s the right number)
Perhaps you’ve missed the various comments addressing electrification of transportation (BEVs, but also rail…; BEVs can include public transportation) and industry (including process heating) (note (again!) opportunity for thermal storage (also in HVAC, H2O heaters eg. residential…).
Often fuel energy consumption can be replaced by a smaller amount of electrical energy: consider the losses in engines as well as power plants (less for CHP plants but there’s the efficiency of heat transfer/transport to consider**), and the heat lost in exhaust/chimneys (can be reduced with heat exchangers), and the COP of heat pumps and benefits of regenerative breaking. The main exception where electricity would increase losses, that I know of, would be where fuel is used as a chemical feedstock (possibly along with it’s energy content, or not) ie. carbon electrodes, asphalt. Well asphalt for roads isn’t burned so… There may be alternatives for the C in Al-production; alternatively… can we make renewable graphite? Anyway…
Mark Z. Jacobson, et al. (2022) “Low-cost solutions to global warming, air pollution, and energy insecurity for 145 countries” https://pubs.rsc.org/en/content/articlelanding/2022/EE/D2EE00722C , https://web.stanford.edu/group/efmh/jacobson/Articles/I/145Country/22-145Countries.pdf , related: https://web.stanford.edu/group/efmh/jacobson/Articles/I/145Country/21-WWS-145Countries.pdf , https://web.stanford.edu/group/efmh/jacobson/Articles/I/WWS-145-Countries.html
https://www.rsc.org/suppdata/d2/ee/d2ee00722c/d2ee00722c1.pdf
from bold link – Note, I haven’t read a lot of the article, but from the intro (emph. mine):
Beginning of part 2 (emph. mine):
See also fig. 1. (p. 3348) (6/118)
patrick o twentyseven says
14 Aug 2025 at 1:12 PM etc
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837555
Patrick O twentyseven mentions Yebo’s “6 months” — perhaps a misinterpretation.
How much backup capacity would be needed for occasional load shedding of tens to a hundred hours per year? Isolated regions or small grids would need more dispatchable power.
Relying on optimistic wind and solar projections ignores real-world constraints. Energy shortages already occur globally, and extreme weather only worsens them. Modern societies halt when power fails.
Fundamentally, you cannot bypass EROEI or thermodynamics: 1 barrel of oil equals roughly 4.5 years of human labor; 1 ton of coal equals about a year of work by a horse at full output.
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837711
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837725
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837728
in re to patrick o twentyseven, 18 Aug 2025 at 6:10 PM,
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/comment-page-2/#comment-837871
Hallo Patrick,
Thank you very much for your contributions tp this topic.
As regards “Prieto”‘s arguments vaguely mentioning thermodynamics, I suspect that he/she/it has, actually, no idea how or why it should matter in fossil fuel replacement with renewable energy sources. Otherwise, he/she/it would be specific, I suppose.
Greetings
Tomáš
“Also, how bad would a bit of load shedding for a few 10s to maybe 100 hrs/year be? ” – This was an incomplete thought that I shouldn’t have included, at least not in the original place;
ie. the scenarios I was discussing (perfect T&D with sufficient capacity @ continental scale, either with:
fig 7: no storage or overbuild,
fig 6: 12 hrs storage (@ average power demand) and 50% overbuild,
( https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837543 )
the power supply gaps would be the load shed if there were no additional backup/storage/etc. or demand changes etc.
What I was thinking when I wrote that was something like impromptu holidays. Now, I’m a person who likes schedules, but as a kid the occasional snow day was fun (100 hrs would be excessive, though)… Anyway…
I will admit, though, that I may have missed something: **if these graphs are for an average year, then the largest gaps would be larger than shown. But when the average peak gap is near 0, then sizable gaps (implied necessary additional infrastructure/inputs/adaptability/etc.) would have to be either small or rare or both.
(**Don’t have time to look deeper into it right now.)
I also am not sure about the impact of T&D, both ‘regular’ (in already developed regions) and additional for a more wind+solar prominent/dominant system, in EROEI/EPBT…
https://static-content.springer.com/esm/art%3A10.1038%2Fs41467-021-26355-z/MediaObjects/41467_2021_26355_MOESM1_ESM.pdf fig 6 (p 9/18) “Supplementary Figure 6 | Average power supply gap. The power supply gaps under the most reliable electricity systems for six continents with 12 hours of storage and 50% of capacity margin are shown.”:
– oops, it’s a little unclear whether they included the continental scale values for Asia* (*I believe that’s non-Russian Asia) and Africa in the graphs – I think they’re graphed but not with the thick black lines; Oceania does have a significant peak gap remaining for 5 hrs/yr (~5%,±, near peak gap, visually est. from graph); Europe also has on the order of a few % (maybe ~2%?) for ~ several hrs/yr (~5%,±, near peak gap, visually est. from graph); the other continents(al scale) peak gaps look about 0 %.
PS individual smaller-area countries in same case, Europe: it looks like peak gaps (average year?) are only significant for ~400 hr/yr or less (less than 5 % of time) (~200 hr/yr Spain). Thus whatever inefficiencies (eg. long-distance HVDC, e-fuels, etc. (resistance and conversion energy losses, not usage-independent portion of infrastructure upkeep) are involved in supplying that power would be correspondingly more tolerable.
Driving:
https://www.distancecalculator.us/search.php?from=Casablanca&to=Kyiv
“Distance from Casablanca to Kyiv” 4247.2 km
https://www.distancecalculator.us/search.php?from=Casablanca&tcity1ll=&to=Glasgow
“Distance from Casablanca to Glasgow” 2851.3 km
“There is 3046.0 km driving distance between Glasgow, Glasgow City, Scotland, G2 1AL, United Kingdom and Kyiv, Ukraine.”
“There is 3349.0 km driving distance between San Diego, San Diego County, California, United States and Chicago, Cook County, Illinois, United States.”
“There is 4504.7 km driving distance between San Diego, San Diego County, California, United States and New York, United States.”
“There is 1272.3 km driving distance between New York, United States and Chicago, Cook County, Illinois, United States.”
“There is 5238.6 km driving distance between Cape Town, City of Cape Town, Western Cape, 8001, South Africa and Nairobi, Nairobi County, Kenya.”
…
Corrected Version of last comment – please replace:
https://static-content.springer.com/esm/art%3A10.1038%2Fs41467-021-26355-z/MediaObjects/41467_2021_26355_MOESM1_ESM.pdf fig 6 (p 9/18) “Supplementary Figure 6 | Average power supply gap. The power supply gaps under the most reliable electricity systems for six continents with 12 hours of storage and 50% of capacity margin are shown.”:
– oops, it’s a little unclear whether they included the continental scale values for Asia* (*I believe that’s non-Russian Asia) and Africa in the graphs – I think they’re graphed but not with the thick black lines; Oceania does have a significant peak gap remaining for 5 hrs/yr (~5%,±, near peak gap, visually est. from graph); Europe also has on the order of a few % (maybe ~2%?) for ~ several hrs/yr (visually est. from graph); the other continents(al scale) peak gaps look about 0 %.
PS individual smaller-area countries in same case, Europe: it looks like peak gaps (average year?) are only significant for ~400 hr/yr or less (less than 5 % of time) (~200 hr/yr Spain). Thus whatever inefficiencies (eg. long-distance HVDC, e-fuels, etc. (resistance and conversion energy losses, not usage-independent portion of infrastructure upkeep) are involved in supplying that power would be correspondingly more tolerable.
Driving:
https://www.distancecalculator.us/search.php?from=Casablanca&to=Kyiv
“Distance from Casablanca to Kyiv” 4247.2 km
https://www.distancecalculator.us/search.php?from=Casablanca&tcity1ll=&to=Glasgow
“Distance from Casablanca to Glasgow” 2851.3 km
“There is 3046.0 km driving distance between Glasgow, Glasgow City, Scotland, G2 1AL, United Kingdom and Kyiv, Ukraine.”
“There is 3349.0 km driving distance between San Diego, San Diego County, California, United States and Chicago, Cook County, Illinois, United States.”
“There is 4504.7 km driving distance between San Diego, San Diego County, California, United States and New York, United States.”
“There is 1272.3 km driving distance between New York, United States and Chicago, Cook County, Illinois, United States.”
“There is 5238.6 km driving distance between Cape Town, City of Cape Town, Western Cape, 8001, South Africa and Nairobi, Nairobi County, Kenya.”
…
me: “**if these graphs are for an average year, then the largest gaps would be larger than shown. ”…
https://www.nature.com/articles/s41467-021-26355-z :
I believe what they did is sort the hours of each year by power gap % (of power demand in that hour**), and then average each hour over all the years (ie. the hour of the largest gap in each year, then the hour with the next largest gap…), averaging the gaps (averaging the % or the GW ?).
“Benefits from sharing resources of multiple nations”: …
– the numbers they give are a bit different then what I saw in the graphs.
PS What I’m thinking for HVDC long-distance grids – I’m unsure about the engineering challenges with |V| of ~1+ MW, but I was thinking about lines/grids/networks with multiple nodes, so that, eg., power may often be flowing in opposite directions directions along sequential segments, but sometimes, when the necessity arises, there will be power generally flowing from one far end to the other, with larger power values in the middle segments (which, depending on design, would then have larger losses, but this may be tolerable if this only happens for a smaller fraction of time). Some AC-DC conversion tech. only allows one way power flow; in that case, if the economics dictates, one could have on-ramp sites and off-ramp sites where they make sense. PS an obvious method would involve a motor-generator, but I had read this is inefficient – however, would a modern update be more efficient, particularly as this would double as flywheel-spinning reserve storage? Overhead lines could be coated with SW-reflecting, LW-emitting material (especially on top half) to help keep lines cooler (effective?). There’s a website about an “elpipe” idea: https://elpipes.blogspot.com/ …
cont. from
https://www.realclimate.org/index.php/archives/2025/06/unforced-variations-jun-2025/#comment-834468
m/ P₀ = ( ρ_m·ρ_e ÷ f ) · (ℓ²/ V₀²)
m/ P₀ = ( ρ_m·ρ_e ÷ f ) · (ℓ/ V₀)²
(kg/m³) · (Ω·m) · (km ÷ kV) ²
=(Ω· kg/m²) · (m ÷ V) ²
= (V/A) · kg ÷ V²
= kg ÷ (V·A)
= kg / W
Notice: If you double ℓ to account for the round-trip, then you also double V₀, assuming bipolar (I hope that’s the right term here) transmission lines (DC). The mass/power relationship still works if you just count one-way distance and the voltage magnitude, which is half the voltage difference (eg. ±765 kV).
Al:
ρ_e =
26.5 nΩ⋅m = 2.65 E−8 Ω⋅m @ 20 °C ( https://en.wikipedia.org/wiki/Aluminium )
( calculated, https://www.engineeringtoolbox.com/resistivity-conductivity-d_418.html : )
3.46 E−8 Ω⋅m @ 100 °C
4.46 E−8 Ω⋅m @ 200 °C
ρ_m = 2.699 g/cm³ = 2.699 t/m³
ρ_m·ρ_e =
Ω· kg/m²
7.152 E-05 @ 20 °C
9.327 E-05 @ 100 °C
1.204E-04 Ω· kg/m² @ 200 °C
At f = 0.01 (1 % loss), at 1 E-04 Ω· kg/m², if ℓ/ V₀ = 1 m/V (eg., 7 km @ 7 kV, 1000 km @ 1000 kV),
Then we would need 1 E-02 kg/W = 10 g/W (assumes constant power; divide by capacity factor, and for AC, … 3 lines? instead of 2 and sinusoidal so mult by 1.5*2 ??)… Sum over segments…
No error there. The use of hydrosols in reef cooling and bleaching mitigation is being studied by UNEP coral conservationist Tom Goreau
The Mar A Lago comment is a response to Paul Pukite’s noting my observation’s agreement with another sea level reference nearby My point is that the reference level structure to which i refer abuts bedrock, and dates to the PB B&T’s founding in 1926 .
in Re to Russell Seitz, 18 Aug 2025 at 7:53 PM
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/comment-page-2/#comment-837873
Dear Russell,
Many thanks for your reply to my questions of 16 Aug 2025 at 10:21 AM,
https://www.realclimate.org/index.php/archives/2025/07/the-endangerment-of-the-endangerment-finding/#comment-837704
and for your kind explanations!
I am really pleased that your idea is being practically tested just in this particularly appealing embodiment.
Best regards
Tomáš
Mr. Anderson’s daughter gives me too much credit.
My submission https://www.regulations.gov/commenton/EPA-HQ-OAR-2025-0194-0093
Public Comment on the Practical Utility and Climate Efficacy of Proposed EPA Rules
TL;DR:
The proposed EPA vehicle GHG rules reduce projected global warming by only ~0.004–0.006°C over 5–10 years—effectively zero. While co-benefits for air quality and public health remain, the climate rationale for these rules is negligible and cannot justify their costs. EPA should rescind the 2009 Endangerment Finding as applied to vehicles and focus on tangible, measurable benefits.
1. Introduction: The IPCC Framework as the Basis for Assessment
This comment evaluates the proposed rules using IPCC AR6 WGIII findings, reflecting the international scientific consensus. The central question: do these rules provide a practical climate benefit that justifies their costs under governing statutes?
2. IPCC Projected Energy Reality Contradicts “Net Zero” Rhetoric
IPCC AR6 WGIII mitigation scenarios show a disconnect between aspirational rhetoric and modeled reality:
– SSP1-1.9 (most ambitious): ~44% of global energy in 2050 from fossil fuels
– SSP2-4.5 (middle-of-the-road): ~45% from fossil fuels
These projections rely heavily on carbon dioxide removal (CDR) and carbon capture (CCUS)—technologies without proven feasibility at scale. Even after adjusting for assumptions that “sequestered” fossil fuels are counted as non-fossil energy, actual unmitigated fossil fuel use remains roughly 30% of total energy.
Source: IPCC AR6 WGIII Table 3.4; raw data via IIASA: https://data.ece.iiasa.ac.at/ar6
3. Quantifying the Rules’ Incremental Climate Impact
Using IPCC’s Transient Climate Response to Cumulative Carbon Emissions (TCRE: 0.45°C per 1000 GtCO₂; likely range 0.27–0.63°C):
– Projected avoided CO₂ (2027–2032): ~8 GtCO₂
– Resulting avoided warming:
— Central estimate: ΔT ≈ 0.0036°C
— Likely range: 0.0022–0.0050°C
Including broader rules since 2010 (~12 GtCO₂ avoided):
– ΔT central estimate ≈ 0.0054°C
– Likely range: 0.0032–0.0076°C
These changes are undetectable against natural variability and much smaller than uncertainties in measurement and modeling.
4. Contextualizing the Minuscule Impact
Climate impact is effectively zero in practical, policy-relevant terms.
Co-benefits for air quality and public health may be meaningful, but using climate mitigation as justification is unsupported.
Premising costly rules on a climate effect of this magnitude is, by statutory standards, arbitrary and capricious.
5. Conclusion and Recommendation
The EPA is obligated to ensure rules provide tangible benefits that justify costs. Based on IPCC data:
Climate benefits of the proposed vehicle GHG rules are negligible.
EPA should rescind the 2009 Endangerment Finding as applied to vehicles, not the Finding generally, and base regulatory action on real, measurable co-benefits.
Thomas says: “The proposed EPA vehicle GHG rules reduce projected global warming by only ~0.004–0.006°C over 5–10 years—effectively zero”
Why pick 5 – 10 years? Wouldn’t it make more sense to at least consider the impacts over something like 50 years, something related to net zero goals? Of course someone might pick 5 years to try to make the impacts sound as small as possible, a dishonest tactic..
His whole argument seems wrong to me, because you can take any mitigation measure by any country and it only reduces a small part of the global warming. But they all add up together to make a substantial difference, so we all have to be involved and committed to make changes. By dropping out you are letting the team down, and being bloody selfish and using a flawed argument.
Thomas says: “These projections rely heavily on carbon dioxide removal (CDR) and carbon capture (CCUS)—technologies without proven feasibility at scale. Even after adjusting for assumptions that “sequestered” fossil fuels are counted as non-fossil energy, actual unmitigated fossil fuel use remains roughly 30% of total energy.”
CCS doesnt relate to the endangerment finding does it? I thought the finding only applied to things like car emissions.
Thomas sounds exactly like yet another sock puppet with a big ego and anti renewables views, to add to the growing collection (PP, Fact Checker, Thessalonia etc ,etc)
Climate impact is effectively zero in practical, policy-relevant terms.
Page 36304
In the Endangerment Finding, the Administrator made two distinct findings based on two distinct sets of assumptions.
In the first, the Administrator found that the ‘‘air pollution,’’ defined as the combined elevated global concentrations in the upper atmosphere of six ‘‘well-mixed GHGs,’’ CO2, methane, NOX, HFCs, PFCs, and SF6, endangered public health or welfare by playing a causal role in global temperature increases and ocean pH changes, which, in turn, were then asserted to play a causal role in environmental phenomena with adverse impacts on public health and welfare. 74 FR 66516.
In the second, the Administrator found that the ‘‘air pollutant’’ (defined as the combination of the same six ‘‘well-mixed GHGs’’) emitted by new motor vehicles and engines contributed to the ‘‘air pollution.’’ 74 FR 66536. Nowhere in the Endangerment Finding did the Administrator consider the extent to which emissions from CAA section 202(a) sources have a more than de minimis effect on the danger identified with respect to elevated concentrations of GHGs in the upper atmosphere—let alone whether emissions from any particular class or classes of sources that EPA intended to regulate had such an effect.
https://www.govinfo.gov/content/pkg/FR-2025-08-01/pdf/2025-14572.pdf
+ Combine above with the extract/comment posted below
– In 2009, the Administrator (under Obama’s EPA) said the Endangerment Finding was based solely on science (climate evidence, not economics).
-They explicitly said that only science could be considered under the Supreme Court’s Massachusetts v. EPA ruling.
– They also excluded any economic or implementation concerns (e.g., costs, regulatory impacts) — saying the statute gave them discretion to issue the finding alone, without weighing those factors.
[ A standard EPA requirement ]
You’ve got a smoking gun here–by itself is just cause to review and/or rescind the 2009 Endangerment Finding. It clearly distinguishes 2009 = only science from 2025 reconsideration = broader welfare factors, including individual, business or society wide economic, health, legality and welfare impacts.
The EPA explicitly states the 2009 Administrator limited the Endangerment Finding to science only, excluding cost, implementation feasibility, adaptation, and mitigation or other concerns.
Federal Register / Vol. 90, No. 146 / Friday, August 1, 2025 / Proposed Rules
page. 36295
https://www.govinfo.gov/content/pkg/FR-2025-08-01/pdf/2025-14572.pdf
“In the Endangerment Finding, the Administrator found that ‘the science [was] sufficiently certain’ to compel an affirmative determination and interpreted Massachusetts as ‘allow[ing] for the consideration only of science.’ 74 FR 66501. Relatedly, the Administrator did not consider any of the implementation challenges or options discussed in the 2008 ANPRM, asserting instead that CAA section 202(a) confers ‘procedural discretion’ to issue standalone findings without considering a regulatory response because the statute ‘is silent on this issue.’”
What this means:
– In 2009, the Administrator (under Obama’s EPA) said the Endangerment Finding was based solely on science (climate evidence, not economics).
-They explicitly said that only science could be considered under the Supreme Court’s Massachusetts v. EPA ruling.
– They also excluded any economic or implementation concerns (e.g., costs, regulatory impacts) — saying the statute gave them discretion to issue the finding alone, without weighing those factors.
You’ve got a smoking gun here by itself is just cause to review and/or rescind the 2009 Endangerment Finding. It clearly distinguishes 2009 = only science from 2025 reconsideration = broader welfare factors, including individual, business or society wide economic, health, legality and welfare impacts.
Also on Page 36295, further proof:
“With respect to endangerment, the Administrator began by excluding adaptation—human responses that reduce potential adverse impacts—and mitigation—independent measures that reduce the causes of potential adverse impacts—from the analysis of global climate change concerns. 74 FR 66513. The Administrator acknowledged that ‘some level of autonomous adaptation will occur’ and that ‘this separation means this approach may not reflect the actual conditions in the real world in the future, because adaptation and/or mitigation may occur and change the risks.’ Nevertheless, the Administrator reasoned that ‘it would be extremely hard to make a reasoned projection of human and societal adaptation and mitigation responses’ because they are‘largely political’ or ‘individual personal judgments.’”
Yes — that’s exactly the crux. The 2009 Endangerment Finding boxed itself into a “science-only” corner, explicitly excluding costs, adaptation capacity, technological shifts, or welfare tradeoffs. That framing elevated the most narrow interpretation of “endangerment” — essentially, “is the science sufficiently certain?” — and deliberately set aside the wider picture of human welfare or policy feasibility.
The result was structural bias: by limiting the scope to climate science papers, EPA locked in a one-sided, myopic view. Scientists themselves may not see it as cherry-picking — they would say “we’re just following the statute and the science” — but the choice to exclude other welfare factors is itself a bias. And once entrenched, it gets defended reflexively, as you’ve seen, 24/7/365.
Neither climate science and scientists, nor the EPA, hold a royal prerogative or veto to override all other concerns of the population and the broader welfare of the common good.
I recommend reviewing the full text of the proposed rule available here:
EPA Proposed Rule – Reconsideration of 2009 Endangerment Finding
Federal Register / Vol. 90, No. 146 / Friday, August 1, 2025 / Proposed Rules
https://www.govinfo.gov/content/pkg/FR-2025-08-01/pdf/2025-14572.pdf
END PART 1
Critical Extracts
https://www.govinfo.gov/content/pkg/FR-2025-08-01/pdf/2025-14572.pdf
Page 36292
Furthermore, the Administrator reviewed available information, including the most recently available science, bearing on the assumptions and conclusions in the Endangerment Finding, the impacts of global GHG concentrations on public health and welfare in the United States, and the relative contribution of domestic emissions from new motor vehicles and engines to global GHG concentrations. As part of that review, the Administrator received and evaluated the draft report submitted by the U.S. Department of Energy (DOE) Climate Working Group (CWG) to Secretary of Energy Christopher Wright on May 27, 2025, titled “Impacts of Carbon Dioxide Emissions on the U.S. Climate” (2025 CWG Draft Report). The 2025 CWG Draft Report analyzes empirical data, peer-reviewed studies, and available scientific information bearing on direct human influence on ecosystems and climate, climate response to CO2 emissions, and impacts on ecosystems and society.10 The Administrator also considered available assessments by the U.S. Government and relevant international bodies, including the Third, Fourth, and Fifth National Climate Assessments (NCAs) reported by the U.S. Global Change Research Program (USGCRP) 11 and the Fifth Assessment Report (AR5) and Sixth Assessment Report (AR6) by the United Nations Intergovernmental Panel on Climate Change (IPCC).12 As discussed in section IV.B of this preamble, the Administrator also considered critiques of the NCAs, and the Fifth NCA in particular, and reviewed these analyses for consistency with OMB information quality guidelines13 and the transparency and reliability requirements of Executive Order 14303, “Restoring Gold Standard Science.”14
The Administrator’s review of the relevant information, including scientific literature, gave rise to serious concerns that our actions taken to regulate GHG emissions from new motor vehicles and engines exceed our statutory authority under CAA section 202(a) and are otherwise inappropriate. Continuing to impose billions of dollars in regulatory costs on American businesses and consumers without an adequate legal basis would threaten to undermine public confidence in our activities and commitment to fulfilling the Agency’s core mission: protecting human health and the environment. The EPA has expended significant resources implementing the GHG regulatory program for mobile sources and attempting to expand its GHG regulatory program to stationary sources with limited success in the courts and no apparent real-world results, often at the expense of programs that fall squarely within our statutory authority. Prompt action is needed to address these concerns with the benefit of public participation.
Relatedly, the Administrator has serious concerns that many of the scientific underpinnings of the Endangerment Finding are materially weaker than previously believed and contradicted by empirical data, peer-reviewed studies, and scientific developments since 2009. This proposal seeks public comment on these developments for the first time. Prompt action is needed to address these concerns, and the Administrator requests stakeholder input on the continuing vitality of the assumptions, predictions, and conclusions animating the Endangerment Finding.
C. Summary of the Major Provisions in This Proposed Action
If finalized, this action would rescind the 2009 Endangerment Finding for GHGs emitted by new motor vehicles and new motor vehicle engines under CAA section 202(a) (74 FR 66496). If finalized, this action would also rescind denials of petitions for reconsideration of the Endangerment Finding in 2022 and 2010 entitled “Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act; Final Action on Petitions,” 87 FR 25412 (Apr. 29, 2022), and “EPA’s Denial of the Petitions to Reconsider the Endangerment and Cause or Contribute Finding for Greenhouse Gases Under Section 202(a) of the Clean Air Act,” 75 FR 49556 (Aug. 13, 2010).15 Although the 2022 and 2010 petition denials have no prospective legal effect, we propose to rescind them for the sake of consistency and to ameliorate potential confusion regarding the EPA’s proposed action. As explained later in this preamble, the denials reflect many of the same legal and scientific flaws we propose to correct by rescinding the Endangerment Finding. We seek comment on the impact of the denials, if any, and on whether the denials were legally flawed for additional reasons not explicitly explored in this proposal.
In addition, as a result of these proposed changes, we would no longer have a basis for issuing or retaining GHG emission standards for new motor vehicles and new motor vehicle engines, including for MYs that have completed manufacture but are subject to ongoing obligations. As discussed elsewhere in this preamble, the EPA is reconsidering additional endangerment findings and GHG emission standards issued under distinct provisions of the CAA in separate rulemakings and is not reopening or proposing to modify those additional findings and standards in this proceeding.
In connection with the proposed rescission of the Endangerment Finding, if finalized, this action would remove all existing regulations that require new motor vehicle and new motor vehicle engine manufacturers to measure, report, or comply with GHG emission standards.
——————————————————————————————-
Page 36299
Specifically, we propose that the major questions doctrine applies and precludes the EPA from asserting authority to regulate in response to global climate change concerns under CAA section 202(a). At a minimum, Congress did not clearly authorize the EPA to decide the Nation’s response to global climate change concerns by empowering the Agency to “prescribe . . . standards” for certain air pollutants emitted by new motor vehicles and engines. On these bases, and on account of the additional procedural and analytical errors set out below, we propose that the Endangerment Finding exceeded the EPA’s authority and must be rescinded.
Page 36300
CAA section 302(h) also provides that any reference to “effects on welfare includes, but is not limited to, effects on” the environment, property, transportation hazards, and “on economic values and on personal comfort and well-being.” 45 The EPA proposes that this statutory language is best read as authorizing the Agency to identify and regulate, as an integral part of a rulemaking prescribing emissions standards, air pollutants that cause or contribute to air pollution that itself endangers public health and welfare through local or regional exposures. This proposed interpretation is consistent with the text and structure of the statute, our decades-long implementation of the statute prior to 2009, and background principles of statutory interpretation, including default rules for proximate cause. This proposed interpretation is also consistent with the Supreme Court’s decision in Massachusetts, which addressed distinct issues and must, as a matter of stare decisis, be read in harmony with the Supreme Court’s subsequent decisions bearing on the EPA’s authority and statutory interpretation in UARG, West Virginia, and Loper Bright.
Dangerous Air Pollution. The EPA proposes that CAA section 202(a) is best read as authorizing the Agency to regulate air pollutant emissions that cause or contribute to air pollution that endangers public health or welfare through local or regional exposure. For the purposes of this proposed action, we use the phrase local or regional exposure to distinguish air pollution that impacts public health and welfare by its presence in the ambient air from “air pollution” consisting of six “well-mixed” GHGs that, as conceptualized in the Endangerment Finding, impacts public health and welfare only indirectly and not by its mere presence in the ambient air. As discussed below, this proposal would effectively return the EPA to its interpretation of CAA section 202(a) prior to 2009.
That pattern holds for the criteria pollutants identified in the CAA—CO, lead, ground-level ozone (O₃), nitrogen dioxide (NO₂), PM, and sulfur dioxide (SO₂)—as well as the initial list of hazardous air pollutants in CAA section 112(b)(1). 48 We find it significant that in subjecting a number of air pollutants emitted by new motor vehicles and engines to regulation under CAA section 202, Congress did not include substances that are potentially indirectly harmful to public health or welfare based on elevated global concentrations in the upper atmosphere. That conspicuous omission supports the conclusion that the air pollutants subject to regulation under CAA section 202(a) are those that cause or contribute to air pollution which itself endangers public health or welfare through local or regional exposure.49
Put another way, we propose that the air pollutants identified in CAA section 202 and throughout relevant provisions of the CAA are those that cause or contribute to air pollution for which the air pollution itself, through local or regional exposure to humans and the environment, endangers public health or welfare. 50 For certain regulated air pollutants, the air pollutants are themselves the dangerous air pollution, i.e., the air pollutants are the air pollution with adverse health and welfare impacts.
END PART 2
PART 3 CONT’
Page 36300
The “air pollution” addressed in the Endangerment Finding is different in kind. In that decision, the Administrator defined the relevant “air pollutants” as six “well-mixed GHGs” and the relevant “air pollution” as “the combined mix of” these GHGs “which together,
cont’ Page 36301
constitute the root cause of human-induced climate change and the resulting impacts on public health and welfare.” 74 FR 66516. In contrast to the air pollution addressed expressly in CAA section 202 and elsewhere in the statute, GHGs do not endanger public health or welfare through local or regional exposure. Rather, the Endangerment Finding asserted that GHG “air pollution” would lead to increases in global temperature and change to ocean pH that, in turn, would lead to environmental phenomena, in combination with an open-ended universe of additional factors, which would potentially have adverse public health and welfare impacts of varying severity in certain regions.
Regulating GHG emissions based on global climate change concerns requires reading an additional instance of “cause, or contribute” into the statute, such that CAA section 202(a) encompasses the “emission of air pollutants that cause, or contribute to, dangerous air pollution that causes, or contributes to, endangerment of public health or welfare.”
This proposed interpretation is also supported by the best reading of the terms “cause” and “contribute.” In enacting and amending CAA section 202(a), Congress legislated against background legal principles, including principles of causation and proximate cause. 57
These ‘‘default rules’’ are ‘‘presumed to have [been] incorporated, absent an indication to the contrary in the statute itself,’’ 58 and nothing in the text of CAA section 202(a) indicates that Congress intended to depart from ordinary legal meaning. As a general matter, there is a point at which harm no longer has a sufficiently close connection to the relevant conduct to reasonably draw a causal link. We propose that emissions from new motor vehicles and new motor vehicle engines in the United States do not have a sufficiently close connection to the adverse impacts identified in the Endangerment Finding to fit within the legal meaning of ‘‘cause’’ or ‘‘contribute.’’
and
As discussed further below, under this logic, the release of water vapor (H₂O) would meet the standard for regulation because water can be said to result in significant harms and because motor vehicles and engines can be said to “contribute” to that harm by emitting non-de minimis quantities of water vapor into the upper atmosphere. The EPA would have the authority, and statutory duty, to prescribe standards for water vapor emissions because water vapor is a recognized GHG emitted by motor vehicles and engines as well as the vast majority of other mobile and stationary sources. Because that reading effectively converts CAA section 202(a)(1) into a roaming license to “prescribe . . . standards,” we believe the reading proposed herein is more faithful to the governing principles of statutory interpretation.
We further emphasize that this proposed interpretation would effectively return the EPA to its longstanding practice prior to 2009 of applying CAA section 202(a) and related statutory endangerment provisions to air pollution that adversely impacts public health and welfare through local or regional exposure. As noted above, we historically utilized this authority to prescribe standards for pollutants identified in the CAA itself, including NOₓ, PM, HC, and CO. The distinction between air pollution that harms public health and welfare through local and regional exposure and global “air pollution” consisting of GHG concentrations without any such direct impacts has also played a role in our evaluation of waiver requests under CAA section 209. 60 Even in the Endangerment Finding, the Administrator recognized that we had previously applied CAA section 202(a) to “a more typical local or regional air pollution problem.” 74 FR 66538 (emphasis added). We propose that in adopting a novel analytical approach in the Endangerment Finding, the EPA failed adequately to address its prior practice and improperly relied on the Supreme Court’s decision in Massachusetts for the proposition that CAA section 202(a) authorizes emission standards in response to air pollution raising global climate change concerns.
Page 36302
In sum, we propose that CAA section 202(a) does not provide authority to regulate GHGs based on global climate change concerns because that provision authorizes regulating only air pollutants that ‘‘cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare.’’ The EPA must ‘‘ground its reasons for action or inaction in the statute,’’ Massachusetts, 549 U.S. at 535, and ‘‘possess[es] only the authority that Congress has provided,’’ NFIB v. DOL, 595 U.S. 109, 117 (2022). In proposing this interpretation, we note that our actions must be consistent with ‘‘the single, best meaning’’ of the statute and cannot expand our authority in response to pressing concerns based on statutory silence or ambiguity. Loper Bright, 603 U.S. at 400, 411. We seek comment on this proposed interpretation, including the rationales articulated above and any further rationales that commenters believe support, or detract from, this interpretation.
Page 36304
In the Endangerment Finding, the Administrator made two distinct findings based on two distinct sets of assumptions.
In the first, the Administrator found that the ‘‘air pollution,’’ defined as the combined elevated global concentrations in the upper atmosphere of six ‘‘well-mixed GHGs,’’ CO2, methane, NOX, HFCs, PFCs, and SF6, endangered public health or welfare by playing a causal role in global temperature increases and ocean pH changes, which, in turn, were then asserted to play a causal role in environmental phenomena with adverse impacts on public health and welfare. 74 FR 66516.
In the second, the Administrator found that the ‘‘air pollutant’’ (defined as the combination of the same six ‘‘well-mixed GHGs’’) emitted by new motor vehicles and engines contributed to the ‘‘air pollution.’’ 74 FR 66536. Nowhere in the Endangerment Finding did the Administrator consider the extent to which emissions from CAA section 202(a) sources have a more than de minimis effect on the danger identified with respect to elevated concentrations of GHGs in the upper atmosphere—let alone whether emissions from any particular class or classes of sources that EPA intended to regulate had such an effect.
Content
Page 36289
I. Executive Summary
Page 36293
II. Background
Page 36296
III. Legal Framework for Proposed Action
Page 36298
IV. Proposed Rescission of the Endangerment Finding
Page 36311
V. Separate Bases for Proposed Repeal of GHG Emission Standards
Page 36313
VI. Proposed Repeal of GHG Emission Standards
Page 36324
VII. Requests for Comment (Notation C-1 through C-27)
Page 36326
VIII. Statutory and Executive Order Reviews
https://www.govinfo.gov/content/pkg/FR-2025-08-01/pdf/2025-14572.pdf
END