Dr. D. Weston Allen, MBBS, FRACGP

Fellowship of the Royal Australian College of General Practitioners (FRACGP), full-time family physician at Kingscliff on the southern Gold Coast.

Dr. Jan Breslow, M.D.

Fredrick Henry Leonhardt Professor Rockefeller University; Head Laboratory of Biochemical Genetics and Metabolism; Senior Physician Rockefeller Hospital. Former President of the American Heart Association and a member of the National Academy of Sciences, the National Academy of Medicine, and the German National Academy of Sciences Leopoldina.

Dr. Daniel Nebert, M.D.

Professor emeritus, Human Genetics Division, Department of Pediatrics and Molecular & Developmental Biology at Cincinnati Children’s Hospital Medical Center and adjunct professor title in the Human Genetics Division, Department of Pediatrics and Molecular & Developmental Biology at Cincinnati Children’s Hospital Medical Center.

All are members of the CO₂ Coalition, a non-profit scientific organization based in Fairfax, Virginia and the document was created and is submitted under the auspices of the CO₂ Coalition.

U.S. Environmental Protection Agency
Docket ID No. EPA-HQ-OAR-2025-0194
1200 Pennsylvania Avenue NE
Washington, D.C.

Re:  Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards (“Proposed Rule”)

Dear Administrator Zeldin,

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

Our comment focuses on responding to your request for comments on:

2. The scientific underpinnings of the Endangerment Finding are weaker than previously believed and contradicted by empirical data, peer-reviewed studies, and scientific developments since 2009 (C-2).

Climate Change and Health

Dr. D. Weston Allen, FRACGP, Dr. Jan Breslow, M.D., Dr. Daniel Nebert, M.D

Introduction

Human health, morbidity, mortality and longevity are significantly impacted by climate. This review examines the evidence for past, present and possible future human health impacts of climate change and its ramifications. It will also examine the health impacts of different energy sources and climate actions. It will not examine every link in the literature to a range of conditions where attribution is implausible or tenuous, or where association assumes causation.

[1] 90 FR 36288 (Aug. 1, 2025).

See the complete statement from Drs. Allen, Breslow, and Nebert here:

Climate Change and Health CO2 Coalition 2025-09

Download Climate Change and Health Publication here:

Climate Change and Health – 2025-10-17-digital-compressed