By Bob Sussman
Bob Sussman was Deputy Administrator of EPA during 1993-1994 and Senior Policy Counsel to the Administrator during 2009-2013.
Attacking the Climate Change “Hoax”
As described in my May 8 and May 15 posts, Donald Trump and his top appointees have made no secret of their belief that climate change is a fabricated concern grounded in deception, “far-left” propaganda and bogus science. Trump has denounced climate action as the “Green New Scam.” His administration is shuttering climate research programs across the federal government, firing scores of climate scientists, and forbidding federal employees from even mentioning climate change.
Vowing to “drive[] a dagger straight into the heart of the climate change religion,” EPA Administrator Lee Zeldin has staked his tenure on repealing the Agency’s 2009 endangerment finding that underpins US regulation of greenhouse gas emissions. On July 29, Zeldin followed through with a sweeping proposal to accomplish this goal.
The heart of the endangerment finding was a comprehensive review of climate science, which first received global attention at the 1992 Earth Summit in Rio de Janeiro, Brazil. The finding drew on an enormous body of data and modeling and reflected a global scientific consensus that climate change was real, well-documented and dangerous. Its conclusions have been reinforced by numerous scientific assessments, including six reports of the UN-backed Intergovernmental Panel on Climate Change (IPCC), five Congressionally-mandated National Climate Assessments by the US Global Change Research Program (USGCRP), and the European Climate Risk Assessment (EUCRA).
As EPA’s proposal took shape, observers wondered how Trump and Zeldin could justify walking away from the long-standing findings of the global scientific community. Would the Agency ignore climate science and repeal the endangerment finding on narrow legal grounds? Or would it denounce the science as flawed and biased and challenge its central conclusions as implausible and alarmist? And if the latter, who in the scientific community would defend EPA’s position, and how would the thousands of scientists whose work has been central to the mainstream consensus on climate respond to EPA’s slanted interpretation of their research?
Why Not a Blue-Ribbon Review of Climate Science?
We now have answers to these questions. As expected, Zeldin’s primary rationale for reversing the endangerment finding is a tortured reinterpretation of EPA’s authority under the Clean Air Act that has already drawn fire from legal scholars and advocates. However, the EPA proposal also frontally attacks the scientific foundation of the endangerment finding, asserting that it “papered over substantial uncertainties in the scientific record,” and was plagued by “analytical gaps, uncertainties, and speculative predictions.” On this basis, EPA maintains “there is insufficient reliable information to retain the conclusion that GHG emissions . . . cause or contribute to endangerment to public health and welfare in the form of global climate change.”
It is hard to imagine a more consequential scientific determination than EPA’s repudiation of its own endangerment finding, the anchor of US climate policy over three administrations and a pillar of the global response to climate change. An open-minded administration would not have rendered this extreme verdict without seeking the independent advice of a broadly representative panel of experts selected through a transparent public process.
For example, the National Academies of Sciences, Engineering and Medicine (NASEM) – the respected voice of America’s best scientists -- could have convened a blue-ribbon committee to reexamine the scientific basis of the endangerment finding and other influential climate assessments. Congress asked NASEM to perform a similar task in 2001, when policymakers were faced with conflicting views on the strength of newly-emerging climate science and wanted impartial guidance from the nation’s most authoritative scientific body.
But President Trump began his second term with a closed mind. The die was cast as soon as Zeldin declared on March 12 that reversing the endangerment finding was necessary for the “death of the Green New Scam.” Given this preconceived outcome, an independent process to reexamine the scientific evidence for global warming could well backfire by contradicting the President’s insistence that climate change was a “hoax.” Zeldin and other Trump appointees plainly did not want to take this risk, so they chose the safer path of commissioning a report from five hand-picked climate skeptics whose well-known opposition to mainstream climate science could provide a seeming veneer of academic legitimacy.
DOE’s Hand-Picked Climate Skeptics
The five report authors were selected by Department of Energy (DOE) Secretary and former fossil fuel CEO Chris Wright without any consultation with NASEM, other scientific organizations or stakeholders. Thus, no proponents of mainstream climate science received a seat at the table. In the first Trump term, the White House briefly entertained but then rejected a proposal for convening a debate between scientists on different sides of the climate issue (a “Blue Team/Red Team” exercise). This time around, however, the Administration took no chances.
The five authors were dubbed by DOE the Climate Working Group (CWG). Their 150-page report, “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” was shared with EPA on May 27, 2025 but not released publicly until July 29, the same day EPA announced its proposal.
Wright cast the report as an expose of “cancel culture Orwellian squelching of science.” However, there was nothing Orwellian about the many previous climate assessments that Wright accused of “squelching science.” These assessments were all the result of an interactive and open process that engaged the global scientific community, rather than a unilateral edict from a small cabal of climate extremists.
By contrast, the CWG report was conceived and then prepared in secret. Bypassing the time-honored interagency review process for important science reports, DOE failed to consult hundreds of climate experts at NOAA, NASA and EPA. It likewise ignored the peer review guidelines of EPA and the Office of Management and Budget (OMB), both of which require robust independent review of significant scientific work products that influence major policy decisions. If anything was Orwellian, it was this closed and clandestine process, which resembled Trump’s many other autocratic efforts to shut down climate research and silence dissenting scientific voices.
EPA’s Reliance on the Flawed DOE Report
Despite DOE’s failure to observe elementary safeguards of scientific objectivity, EPA is relying almost exclusively on the CWG report for its critique of climate science. Apart from parroting its assertions, the Agency’s proposal provides virtually no analysis of the endangerment finding or subsequent IPCC reports and National Climate Assessments. Although the EPA proposal seizes on the finding’s candid acknowledgement of uncertainties in the climate data-base, a hallmark of even-handed scientific analysis, these uncertainties do not weaken the overall strength of the evidence supporting the finding’s conclusions, and in any case have been largely addressed by more recent research.
EPA’s heavy reliance on the CWG report (as opposed to its own climate experts and the peer reviewed climate literature) is hard to defend in light of its glaring deficiencies. Well-known climate scientists have been withering in their criticisms of the CWG’s incomplete and one-sided analysis. Ben Sanderson, research director at the CICERO Centre for International Climate Research in Oslo, said that: “Each chapter follows the same pattern . . . Establish a contrarian position, cherry-pick evidence to support that position, then claim that this position is under-represented in climate literature and the IPCC in particular. Include a bunch of references, most of which don’t support the central argument.”
Zeke Hausfather, a climate scientist at the science nonprofit Berkeley Earth, agreed: “This is a general theme in the report; they cherry-pick data points that suit their narrative and exclude the vast majority of the scientific literature that does not . . . This gives a terribly skewed view of the underlying climate science, and highlights a number of fringe studies that have been subsequently shown to be riddled with errors."
Many more scientists have echoed these complaints.
Will the DOE Report Be Reconsidered?
Unfortunately, DOE and EPA are not likely to take to heart the concerns of climate scientists who believe their research findings have been misrepresented or ignored. DOE has provided just a 30-day period for public comment on the CWG report. While it has made a pro forma promise to consider feedback, we should not expect extensive revisions. The five authors are locked into their positions, which they have espoused for years, and will have no interest in revisiting them. And neither Zeldin nor Wright will have any appetite for a lengthy peer review process or a detailed rewrite of the report since this would delay withdrawal of the endangerment finding, a Trump priority and necessary first step in dismantling all of EPA’s climate regulations.
A Call for Action by the Scientific Community
However, this should not deter the scientific community from making its voice heard in the court of public opinion. An organized campaign should be mounted to defend the mainstream science and translate it into terms that a lay audience can understand. This campaign could employ a wide range of strategies, including town hall meetings, briefings for public officials and members of Congress, editorial board presentations, op-eds, science workshops, teach-ins, letters from scientific luminaries to Trump agency heads and the President, petitions from working level scientists and academics, and comprehensive, well-documented comments on the EPA proposal and CWG report.
A key focus of these efforts must be a graphic explanation of the convergence between key scientific findings and the real-world, human consequences of climate change, including extreme weather events, flooding, heat waves, sea-level rise, property damage, destructive fires, and drought. These are observable and increasingly common occurrences that the public has experienced directly, and can go far to ground the science in the realities of daily life.
Scientists are often wary of engaging with the media and public policy process, but the stakes are too high in this case to remain on the sidelines. Instead, the Administration’s unprecedented war on climate science demands a vocal, sustained, and effective response from the scientific community.