Suppose you are driving with all your loved ones down a narrow mountain road, and a cliff’s edge, dead ahead, draws clearly into view.
Should you:
(a) take your foot off the gas and apply the brake, or
(b) throw caution to the wind, and gun it?
That, in essence, was the choice confronting Lee Zeldin when he was sworn in, just six months ago, as the 17th Administrator of the Environmental Protection Agency. His Agency, over five decades, had developed or affirmed an avalanche of scientific studies establishing that a persistently high-carbon path leads only to ruin — including for the climate system on which our progeny and nation necessarily will depend.
And yet, tasked by the White House to remove pesky regulations standing in the way of a drive towards fossil fuel “energy dominance,” Zeldin threw caution to the wind and chose option (b).
Specifically, by way of a June 17, 2025 Federal Register notice, EPA proposed “to repeal all greenhouse gas (GHG) emissions standards for fossil fuel-fired power plants.”
EPA’s primary argument is that annual emissions from US power plants account “only” for three percent of global GHG emissions, and that “3 percent contribution figure,” EPA averred, “suggests that the risks to public health and welfare attributed to anthropogenic climate change would not be meaningfully different even if the fossil fuel-fired EGU source category were to cease all GHG emissions.”
But in reality there is no such suggestion. By way of our Comment letter submitted today — see here —
CPR Initiative and ten members of its Boards of Directors and Advisors, clarified that “[i[n both direct and foreseeable ways, a repeal of all GHG standards for fossil fuel-fired power plants will harm the United States, as well as the global climate.”
Directly taking on EPA’s assumption that a 3 percent increment of GHG emissions is too small to matter, we stated: “An annual contribution of 3 percent of emissions to any baseline, whether global or national, is hardly insignificant – particularly in context where contributions from all sources already have pressed the atmospheric concentration of GHGs well into the danger zone.”
We also cited the US Supreme Court’s rather elementary, two-decade old observation concerned a proposed step-by-step approach to addressing the problem of global climate change. In its Massachusetts v. EPA decision, a narrow majority of the Court rejected the argument that environmental litigants have no standing to compel the federal government to address GHG pollution. Writing with precision, a narrow majority derided
the erroneous assumption that a small incremental step, because it is incremental, can never be attacked in a federal judicial forum. Yet accepting that premise would doom most challenges to regulatory action. Agencies, like legislatures, do not generally resolve massive problems in one fell regulatory swoop. . .They instead whittle away at them over time, refining their preferred approach as circumstances change and as they develop a more-nuanced understanding of how best to proceed.
Our comment letter, as well, argued that EPA’s suggested approach would undermine the type of determined international cooperation that the Agency suggested, just 15 months ago, is required to attack the problem of global climate.
“International cooperation and reciprocity are essential to successfully addressing climate change, as the global nature of GHGs means that a ton of GHGs emitted in any other country harms . . . the U.S. just as much as a ton emitted within the territorial U.S. Assessing the benefits of U.S. GHG mitigation activities requires consideration of how those actions may affect mitigation activities by other countries, as those international mitigation actions will provide a benefit to U.S. citizens and residents by mitigating climate impacts that affect U.S. citizens and residents. This is a classic public goods problem because each country’s reductions benefit everyone else, and no country can be excluded from enjoying the benefits of other countries’ reductions. . .”
EPA, Carbon Pollution Standards Regulatory Impact Analysis (2024).
Nuance. Understanding. Logic. Science. Public Goods. Cooperation — indeed, International Obligation.
Will these fundamental building blocks of sustainable development and global order be casually discarded wherein the clearly foreseeable result portends climate chaos?
Note: you can submit your own comment by email to EPA, if done on or before midnight eastern time, Thursday, August 7, 2025.
Send your email to a-and-r-docket@epa.gov. Include, in the subject line of your message, Docket ID No. EPA–HQ–OAR–2025–0124.