CO2 Coalition Submits Comment on EPA’s Proposed Power Plant Regulations as Dangerous and Unscientific

Release: Immediate

July 21, 2023

Download entire comment here (pdf)

ARLINGTON, Va. – A proposed federal rule to regulate carbon dioxide emissions from power plants should not be adopted because it scientifically invalid and would endanger lives by denying people the benefits of fossil fuels and increasing levels of CO2, according to two eminent physicists.

The rule has been proposed by the U.S. Environmental Protection Agency (EPA), which is accepting comments on draft regulation intended to reduce CO2 emissions to avoid purportedly dangerous atmospheric warming. Among those who have submitted comments are Drs. William Happer and Richard Lindzen, professors emeriti at Princeton University and Massachusetts Institute of Technology, respectively.

“We demonstrate (in the 47-page commentary) that EPA failed to consider critically important aspects and data concerning CO2, fossil fuels and climate change, and EPA relied on numerous studies that violate the scientific method,” wrote the professors, each authors of more than 200 peer-reviewed papers on climate and closely related subjects.

“As a result, the proposed rule, which could eliminate fossil fuel electricity plants that provide 61% of electricity in the United States, will be disastrous for the country for no scientifically justifiable reason.”

The comments cite cases of the U.S. Supreme Court requiring that scientific knowledge “be derived by the scientific method” and that an agency consider important aspects of a problem and relevant data for a rule not to be considered “arbitrary and capricious.” The EPA has failed to meet both requirements, said the professors.

Important considerations that EPA’s rulemaking overlooked include the following, according to the professors’ comments:

  • Carbon dioxide is essential to the process of photosynthesis that makes life possible, and increased atmospheric levels have improved crop harvests and an overall greening of Earth. “(O)ver the past two centuries since the Industrial Revolution a rise of CO2 from about 280 parts per million (ppm) to about 420 ppm has caused an approximate 20% increase in the food available to people worldwide,” the professors said.
  • Fossil fuels are indispensable in creating nitrogen fertilizer and pesticides that feed nearly half the world and whose elimination would result in widespread starvation; their combustion releases carbon dioxide and thus increases plant growth, creating more food worldwide; and they provide the most reliable, efficient and low-cost energy for many uses, including the production of 61% of the nation’s electricity.
  • Eliminating fossil fuels and their CO2 emissions in the pursuit of an ill-advised “net zero” agenda would deny their benefits to the world, including 2.3 billion people who face some level of food insecurity and more than 900 million who are severely affected by insufficient nutrition.

Moreover, the professors say, EPA fails to recognize that analysis based on the principles of the 400-year-old scientific method “proves that there is no risk that fossil fuels and carbon dioxide will cause catastrophic warming and extreme weather.” In support of their assertion, the professors said:

  • All the computer models that predict catastrophic global warming fail the key test of the scientific method: they grossly overpredict the warming versus actual data.
  • 600 million years of data prove that today’s CO2 level of 420 ppm is very low, not high, and that higher levels of CO2 do not cause or even correlate with higher temperatures.
  • “Even at today’s relatively low levels, atmospheric CO2 is now ‘heavily saturated,’ in physics terms, meaning that additional increases in atmospheric CO2 can have little warming effect.”

Rather than employing the traditional scientific method, the professors said, EPA relies on so-called consensus, peer review, government opinion from the International Panel on Climate Change, computer models that do not work, data falsified by the omission of contradictory information and fabrication of supporting data.

Dr. Happer is chairman of the CO2 Coalition. Dr. Lindzen is a member of the organization and a past board member. The CO2 Coalition is made up of approximately 130 scientists and researchers committed to educating the public and policy makers about the benefits of carbon dioxide and promoting science free of a political agenda.



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