William Happer
Professor of Physics, Emeritus, Princeton University

November 3, 2025

U.S. Environmental Protection Agency
Docket ID No. EPA-HQ-OAR-2025-0186
1200 Pennsylvania Avenue NE
Washington, D.C.

Re: Reconsideration of the Greenhouse Gas Reporting Program (GHGRP) (“Proposed Rule”)

Dear Administrator Zeldin,

Thank you for the opportunity to comment on the Environmental Protection Agency’s (“EPA”) Proposed Rule.[1]

The Greenhouse Gas Reporting Program (“GHGRP”) mandates approximately 8,200 industrial facilities, at great expense, to submit data on their carbon dioxide and other greenhouse gas (GHG) emissions annually, which is then made available to the public each year.  Id. 44596.

The GHGRP is premised on the theory manifested in the EPA 2009 Endangerment Finding that carbon dioxide and other GHG emissions and the use of fossil fuels cause dangerous climate warming, more extreme weather and significant harm, and both must be reduced to net zero by 2050 (“Net Zero Theory”).

In the EPA’s words in the Endangerment Finding, “Most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic GHG concentrations,” citing the Intergovernmental Panel on Climate Change (IPCC).[2]

The EPA elaborated, “Since the Industrial Revolution, human activities have released large amounts of carbon dioxide and other GHGs into the atmosphere …. Increasing concentrations of greenhouse gases in the atmosphere have increased the greenhouse effect and caused the earth’s surface temperature to rise.  Burning fossil fuels like coal, oil, and natural gas changes the climate more than any other human activity. *** The warmer it gets, the greater the risk for more severe changes to the climate.”[3]

The highly influential IPCC asserts the “evidence is clear that carbon dioxide (CO₂) is the main driver of climate change,” where “main driver means responsible for more than 50% of the change.”[4]

Similarly, the National Academy of Sciences recently opined: “Consistent with the attribution of increasing GHG concentrations to human activities, … the best estimate of the anthropogenic contribution to the observed surface warming of 2.23°F … for 2015-2024, relative to 1850-1900, is 100%.[5]

All of these assertions are incorrect, badly flawed science. The main reasons are:

1. GHGs from the Beginning of the Industrial Age in 1750 to Now Have Not, Cannot and Will Not Cause Catastrophic Warming, Extreme Weather and Harm. Much of the public is unaware that GHGs lose their ability to warm the climate  as the level of GHGs in the atmosphere increases, what is called SATURATION in radiation transfer physics.  At today’s concentrations, CO₂ and other GHGs can only cause slight, beneficial warming, not extreme weather and any harm.
2. Most of the observed warming since the year 1750 has been a natural recovery from the Little Ice Age. GHG’s have contributed only a small fraction of the warming.
3. More Carbon Dioxide and Using Fossil Fuels are Hugely Beneficial to People Worldwide. Increasing CO₂ emissions and increasing the use of fossil fuels benefit people worldwide with more food and cheap energy.  Doubling CO₂ from today’s 420 ppm would increase the world’s food supply 40%, with a trivial increase in temperature.

In summary, very basic science demonstrates that GHG emissions from the beginning of the Industrial Age in the year 1750 until today have not caused any harm and have been a net benefit to life on Earth. Because of SATURATION the warming from CO₂ and other GHG emissions in the future will have an even smaller impact.

Accordingly, the EPA should:

(1) issue its proposed rule ASAP to stop requiring industrial entities to report misleading GHG information about climate change and

(2) take corrective action to inform the public of the real science that increasing carbon dioxide and other GHG emissions, and increasing the use of fossil fuels will benefit people worldwide with more food and cheap energy, with only a trivial effect on temperature and extreme weather.

Scientific details follow.[6]

_______________________

[1] 90 FR 44591 (Sept. 16, 2025).

[2]  EPA Technical Support Document (Dec. 7, 2009), p. 48 https://www.epa.gov/sites/default/files/2016-08/documents/endangerment_tsd.pdf

[3]  Future of Climate Change | US EPA

[5] IPCC, Climate Change 2021: The Physical Science Basis, p. 424, IPCC, Press_release_wgi_ar6_website-final (Aug. 9, 2021), p. 3.

[5]  NAS, Effects of Human-Caused Greenhouse Gas Emissions on U.S. Climate, Health, and Welfare (2025), p.19  (citations omitted).

[6] See the complete statement from William Happer here: Happer Comment – Reconsideration of the Greenhouse Gas Reporting Program (GHGRP) 2025-11-3