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In furtherance of its sound-science advocacy mission, ALF has submitted comments to the U.S. Environmental Protection Agency (EPA) supporting the Trump administration's proposal to rescind the agency's 2009 Greenhouse Gas Endangerment Finding—a prerequisite for Clean Air Act regulation of greenhouse gas ("GHG") emissions, such as carbon dioxide (CO2), as an "air pollutant" from new motor vehicles.
ALF applauds EPA for its proposal and submits that the broad public interest would be better served by rescission of the Endangerment Finding. More specifically:
"ALF's comments address the critical tension between administrative law and scientific evidence in the regulation of carbon dioxide (CO2). The Supreme Court's redefinition of "endangerment" in Massachusetts v. EPA, 549 U.S. 497 (2007), broadened the term from a traditional focus on immediate, direct threats to include highly linked, long-term risks. This judicial reinterpretation enabled what some observers might advocate as the precautionary principle in U.S. law, but it is actually much more. It compels regulatory action on speculative future harm without requiring a robust scientific consensus on immediate, direct health effects from ambient CO2 levels.
The premise of the Endangerment Finding is challenged by scientific counterpoints, including the documented beneficial effects of increased CO2 on global vegetation. A particularly compelling counterargument is provided by U.S. Navy medical studies on submariners, who are chronically exposed to CO2 concentrations in an order of magnitude higher than projected atmospheric levels with no documented adverse health effects. This real-world evidence offers a critical empirical challenge to the scientific basis of the "endangerment" finding and highlights the profound shift in regulatory decision-making toward model-based risk assessment rather than direct, observable health impacts."
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ALF has long been a leading national advocate for sound science in judicial and regulatory proceedings. Among the prominent professionals, including lawyers, scientists and business executives, serving on ALF’s leadership team, is Dr. Dennis K. McBride, who co-authored ALF's comments with ALF Chairman & President Hayward D. Fisk.
Dr. McBride is especially well informed from his experiences and research concerning the key issues underlying GHG regulation. In addition to serving as President of the Institute for Regulatory Science, he is an Adjunct Professor at Georgetown University School of Medicine and Florida Tech College of Aeronautics, and former editor-in-chief for Review of Policy Research. Recently, Dr. McBride served as the Director of the Office of the Secretary of Defense, Acquisition Innovation Research Center, a policy game-changing consortium of two dozen universities, including colleges of policy, business, law, science, engineering, and technology.
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