Richard Lindzen
Professor of Earth, Atmospheric, and Planetary Sciences, Emeritus
Massachusetts Institute of Technology

William Happer
Professor of Physics, Emeritus, Princeton University

April 28, 2025

SUMMARY

At the outset it is important to understand that carbon dioxide has two relevant properties, as a creator of food and oxygen, and as a greenhouse gas (GHG).

As to food and oxygen, carbon dioxide is essential to nearly all life on earth by creating food and oxygen by photosynthesis.  Further, it creates more food as its level in the atmosphere increases.  For example, doubling carbon dioxide from today’s approximately 420 ppm to 840 ppm would increase the amount of food available to people worldwide by roughly 40%, and doing so would have a negligible effect on temperature.

As to carbon dioxide as a GHG, the United States and countries worldwide are vigorously pursuing rules and subsidies under the Net Zero Theory that carbon dioxide and other GHG emissions must be reduced to Net Zero and the use of fossil fuels must be eliminated by 2050 to avoid catastrophic global warming and more extreme weather.  A key premise stated by the Intergovernmental Panel on Climate Change (IPCC) is 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.”[1]

The Biden Administration adopted over 100 rules and Congress has provided enormous subsidies promoting alternatives to fossil fuel premised on the Net Zero Theory. The EPA Endangerment Finding, for example, asserts “elevated concentrations of greenhouse gases in the atmosphere may reasonably be anticipated to endanger the public health and to endanger the public welfare of current and future generations.”[2]

On April 9, 2025 President Trump issued a “Memorandum on Directing Repeal of Unlawful Rules” and Fact Sheet stating “agencies shall immediately take steps to effectuate the repeal of any [unlawful] regulation” under Supreme Court precedents, inter alia, where “the scientific and policy premises undergirding it had been shown to be wrong,” or “where the costs imposed are not justified by the public benefits.”[3]  We understand the Supreme Court has also ruled in the leading case State Farm[4] that an agency regulation is arbitrary, capricious and thus invalid where, inter alia:

• “the agency has … entirely failed to consider an important aspect of the problem”
• “the agency has relied on factors which Congress has not intended it to consider.”

We are career physicists with a special expertise in radiation physics, which describes how CO₂ and GHGs affect heat flow in Earth’s atmosphere.  In our scientific opinion, contrary to most media reporting and many people’s understanding, the “scientific premises undergirding” the Net Zero Theory, all the Biden Net Zero Theory rules and congressional subsidies are scientifically false and “wrong,” and violate these two State Farm mandates.

First, Scientific Evidence Ignored.  All the agency rules, publications and studies we have seen supporting the Endangerment Finding and other Biden Net Zero Theory rules ignored, as if it does not exist, the  robust and reliable scientific evidence that:

• carbon dioxide, GHGs and fossil fuels will not cause catastrophic global warming and more extreme weather, detailed in Part III.
• there will be disastrous consequences for the poor, people worldwide, future generations, Americans, America, and other countries if CO₂, other GHGs are reduced to Net Zero and fossil fuels eliminated that will endanger public health and welfare, detailed in Part IV.

Second, Unscientific Evidence at the Foundation. Unscientific evidence is all we have seen underlying the Endangerment Finding and all the other Biden Net Zero rules, detailed in Part V.

Further, Pres. Trump’s Memorandum Fact Sheet stated that agencies “must repeal any regulation where the costs imposed are not justified by the public benefits.”[5]  This is a separate and an additional reason all the Biden Net Zero Theory rules must be repealed because they have no public benefits but impose enormous costs, detailed in Parts III-V.

Therefore, these Supreme Court decisions and the science demonstrated below [6] support repealing all the Net Zero Theory rules as soon as possible.

Further, for the same reasons, Congress should repeal all Net Zero theory subsidies, all laws that require GHG emissions be reduced and all laws that restrict fossil fuel development and infrastructure.

Finally, Peter Drucker warned, as every Net Zero Theory rule and subsidy demonstrates, that science in government is often based on “value judgments” that are “incompatible with any criteria one could possibly call scientific.”[7]

Therefore, we suggest the President issue an Executive Order requiring all government agencies taking action based on scientific knowledge only rely on scientific knowledge derived by the scientific method, and never base their action on unscientific evidence and sources.

We also suggest the Executive Order clarify that the scientific method is, simply and profoundly, to validate theoretical predictions with observations, and further, that scientific knowledge is never determined by the opinions of government, consensus, 97% of scientists, peer review, or is based on models that do not work, or cherry-picked, fabricated, falsified or omitted contradictory data, elaborated in Part II of the paper.

In summary, the blunt scientific reality requires urgent action because we are confronted with policies that destroy western economies, impoverish the working middle class, condemn billions of the world’s poorest to continued poverty and increased starvation, leave our children despairing over the alleged absence of a future, and will enrich the enemies of the West who are enjoying the spectacle of our suicide march.[8]

Instead, let people and the market decide, not governments.

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

[2]  EPA, Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act, 74 Fed. Reg. 66,511, 66516 (Dec. 15, 2009)(“Endangerment Finding”).

[3]  Ohio v. EPA, 603 U.S. 279 (2024), Michigan v. EPA, 576 U.S. 743 (2015).

[4]  “Normally, an agency rule would be arbitrary and capricious if the agency has relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem ….”  Motor Vehicle Manufacturers Association of the United States, Inc. v. State Farm Mutual Automobile Insurance Company, 463 U.S. 29, 43 (1983).

[5]  Michigan v. EPA, 576 U.S. 743 (2015).

[6]  As well as arguments tailored to specific rules.  See, e.g., our comments on the EPA Fossil Fuel Power Plant rule, Regulations.gov, Department of Energy Gas Stove Rule, Regulations.gov and the SEC Climate Risk Disclosure Rule, s71022-20132171-302668.pdf (sec.gov)

[7]  Peter Drucker, Science and Industry, Challenges of Antagonistic Interdependence, Science 806 (May 25, 1979).

[8] Richard Lindzen, Manufacturing Consensus on Climate Change, The American Mind (Nov. 21, 2024).

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