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CO2 Coalition Co-Founder and Chair Dr. William Happer of Princeton University, together with MIT’s Dr. Richard Lindzen, have submitted a formal scientific comment to U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin that addresses the Agency’s supplemental proposed rule, published September 17.
In that proposal, the EPA moves to rescind the greenhouse-gas findings for fossil-fuel-fired power plants and to repeal the associated regulations under Clean Air Act Section 111. Specifically, the Agency proposes that the statute does not authorize regulation of power-plant emissions in response to global climate-change concerns.
On that basis, it would rescind the Administrator’s 2015 findings and determinations and repeal the remaining 2015 New Source Performance Standards and 2024 Carbon Pollution Standards for the fossil-fuel-fired electric generating unit source category.
Drs. Happer and Lindzen’s analysis demonstrates that the Human-Caused GHG Warming Theory underlying these rules is flawed science. Since 1750, CO2 has had little effect on global temperatures; as concentrations rise, each additional molecule rapidly loses its warming power. At today’s level of 420 ppm, a further 20-ppm addition produces only 0.038 °C of warming. Water vapor and clouds dominate the greenhouse effect, and human activities have little influence on the water cycle.
Geological records spanning hundreds of millions of years show little correlation between CO2 concentrations and temperature. Doubling CO2 will increase the world’s food supply by roughly 40% while adding only modest warming. Net-zero policies, by contrast, threaten food production and affordable energy with virtually no effect on temperatures. CO2 is a benefit to life on Earth, not a pollutant.
This comment to Administrator Zeldin was submitted by the CO2 Coalition and reflects the Coalition’s commitment to scientific integrity. Real science is determined by validating theoretical predictions against observations, not by consensus, peer-review panels, or models that fail to match the data. As the comment recalls from Nobel Laureate and Theoretical Physicist Richard Feynman, “If it disagrees with experiment, it is wrong.” Their analysis places these well-established facts—long overlooked by regulators—directly into the official docket.
This did not happen by accident. For years, while others dismissed or ignored the evidence, the CO2 Coalition continued publishing, speaking, and filing formal comments. The repeal of the 2009 Endangerment Finding itself was the direct result of sustained pressure and credible science that made it impossible for regulators to pretend the evidence did not exist.
The battle has only just begun, first in the courts and then in the broader public conversation. The CO2 Coalition has intervened in the D.C. Circuit Court of Appeals to defend the repeal, armed with the same observational evidence now reinforced by this latest comment.
As we enter this season of thanksgiving, let us all be reminded: There is no climate crisis. CO2 is essential to life. Historic victories must be defended.
Your support ensures this scientific record remains strong.
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