Does the Data Still Support EPA’s Endangerment Finding?

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CENTER FOR STATISTICAL MODELING AND SCIENTIFIC ANALYSIS Does the Data Still Support EPA’s Endangerment Finding?

Dr. Kevin Dayaratna, Vice President FEBRUARY 10, 2026

TOPLINE: The Trump Administration is moving to rescind EPA’s 2009 Endangerment Finding—the legal gateway for regulating car emissions. That is the correct decision given the flawed science and the unreliable data on which the 2009 Endangerment Finding was based.

The Trump Administration’s Proposed Policy: • Trump’s EPA’s proposal states that absent a legitimate endangerment finding, EPA

lacks statutory authority under the Clean Air Act to regulate the emissions standards for vehicles and engines. • The Trump Administration is poised to roll back the 2009 findings.

There’s No Scientific Consensus on CO₂ Harm: • Climate alarmists often claim that “97% of scientists agree” that climate change is real, dangerous, and caused by human emissions of carbon dioxide. • This widely cited figure is misleading and traces back to a 2013 study.

o The study reviewed the abstracts of nearly 12,000 papers on climate change

published between 1991 and 2011 and classified them according to whether they expressed a position on anthropogenic global warming. • The results are frequently misunderstood. Of the papers reviewed:

o 66% expressed no position. o 33% endorsed the view that humans contribute to warming. o 0.7% rejected that view. o 0.3% expressed uncertainty. • Among the pro-climate change papers, 97% endorsed the statement that humans are contributing to warming.

o However, the study did not assess whether warming is dangerous,

catastrophic, or requires urgent policy action. • The reality is the “97 % consensus” refers only to the share of papers expressing a view on human contribution to warming—not to the full body of climate research.

The Obama Administration’s Original Finding was Scientifically Flawed: • Recent reports contradict many of the Obama Administration’s findings, which

was riddled with bad science: o Climate Model Performance vs. Observations

▪ Observed warming trends over decades have been weaker than many

model projections. ▪ For example, in the lower atmosphere, climate models on average

overpredicted warming trends by between 40 and 75 percent.

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▪ Analyses highlight deficiencies in the physical assumptions of models and

note mismatches between projected and observed temperature patterns, including failures to replicate expected vertical atmospheric warming structures. o Extreme Weather Trends

▪ Long-run U.S. and global data show no significant increase in hurricane

frequency or severity. ▪ Strong tornado counts have declined since the mid-20th century, and

inflation-adjusted damage trends do not align with claims of worsening storm impacts due to rising greenhouse gases. o Health Impact Claims and Causation

▪ Many high-profile environmental health claims rely on observational

studies that face persistent statistical challenges, including confounding, model dependence, multiple testing, and limited reproducibility. ▪ For example, the literature linking fine particulate matter (PM2.5) to

outcomes such as heart attacks and premature deaths illustrates these issues, as reported associations often hinge on complex modeling choices rather than clear causal identification. ▪ Analysis on the link between climate change, ozone, and asthma is also

plagued by similar issues. o Temperature-Related Mortality Evidence

▪ A large multi-country study published in The Lancet found that

temperature-related deaths have been dominated by extreme cold rather than extreme heat 17 to 1. ▪ Claims that warming will expand vector-borne diseases or worsen

extreme-weather health impacts depend on projections and assumptions that overstate risk relative to historical evidence showing cold as the primary temperature-related mortality driver, while affordable, reliable energy has been central to gains in life expectancy and human welfare such that restricting access would likely do more harm than modest warming itself. o Other recently published research reveals additional flaws.

Existing Policies Have Failed to Deliver Results: • Even if alarmist predictions about the climate were correct, existing policies to

reduce GHG emissions would not meaningfully impact the climate. • Using the same climate simulator modeling drawn upon by the IPCC, even if the

United States were to completely stop all CO2 emissions, there would be less than 0.24 degrees C temperature impact over this same time horizon.

BOTTOMLINE: Lawmakers should support rescinding the Endangerment Finding for motor vehicles and extend that approach across the entire economy to remove unnecessary and unjustified regulatory barriers to energy abundance and human flourishing.

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