William Happer (Princeton) and Richard Lindzen (MIT) are career physicists who have specialized in radiation physics and dynamic heat transfer for decades, subjects directly relevant to the global warming debate.
In sum, the EPA has acted arbitrarily and capriciously in what it has failed to consider and
what it has considered as the basis for the Proposed Rule.
EPA has failed to consider critical aspects and data that reflect the enormous social benefits
of CO2, the enormous social benefits of fossil fuels, the scientific proof that there is no danger of
catastrophic global warming from the use of fossil fuels and resulting CO2 emissions, and the
disastrous consequences of restricting or eliminating them, including eliminating 61% of
electricity in the United States provided by fossil fuel electricity plants. Under State Farm and its
progeny, failing to consider such crucial aspects of the problem that the rule purports to address is
the hallmark of arbitrary and capricious agency action.
The EPA’s proposed Fossil Fuel Power Plant rule is fatally flawed and
should not be adopted, or at minimum must be revised from the ground up. As scientists, we urge
the EPA to change course from the fraught path it has outlined in the Proposed Rule.
