Endangerment Finding

Endangerment Finding

• More Joe Sabol
• September 22, 2025

I’m opposed to repeal of the Endangerment Finding (Docket ID No. EPA-HQ-OAR-2025-0194.)

I’m a second generation fruit and vegetable grower in Racine County, Wisconsin, have a PhD in chemistry (1982) and more than 40 years experience in the chemical industry, including organizing technical conference symposia on greenhouse gas mitigation. 

Over the past 30 years, on my farm property, I’ve personally noticed the trend of more ticks and mosquitoes, vectors for a variety of diseases that are harmful to human health. This is a state-wide public health issue; the local community radio station (https://WXPR.org) ran a story on August 15, 2025 “Climate change is giving ticks and mosquitoes more chances to spread disease.” Information on tick bite statistics (Wisconsin Tick Bite Tracker) is on University of Wisconsin Department of Entomology website, https://wisconsin-ticks.russell.wisc.edu/ and similar for mosquitoes is from Wisconsin Department of Health Services, https://www.dhs.wisconsin.gov/mosquito/index.htm. A warmer and wetter environment allows for faster development of tick and mosquito larva, more survive and spread, and public health deteriorates. Enlarged periods of tick and mosquito presence endangers me and anyone on my farm.

Burning fossil fuels (underground-sourced hydrocarbons) results in increasing flux of greenhouse gases carbon dioxide, methane, and others into the atmosphere. The imbalance between natural sources and sinks of these atmospheric greenhouse gases is directly from human activity, including motorized transportation tailpipe emission. Increasing concentrations of atmospheric greenhouse gases absorb more infrared radiation, resulting in warming of Earth’s atmosphere, about 1.5 deg C in the last 200 years. The 2021 Intergovernmental Panel on Climate Change (IPCC) Sixth Assessment Report (https://www.ipcc.ch/report/ar6/wg1/) addresses the physical understanding of the climate system and climate change; subsequent IPCC reports strengthen the connection between human activity and climate disruption. 

A warmer atmosphere contains more water vapor, which can condense and fall out of the sky and a noticeable increase in extreme weather events has been observed, see, “Trends of extreme US weather events in the changing climate” in Proc Natl Acad Sci USA, 2022 Nov 14;119(47):e2207536119, https://pmc.ncbi.nlm.nih.gov/articles/PMC9704732/. Physics Today, vol 78(8), p 14 (August 2025) (https://doi.org/10.1063/pt.usyu.seby) published an article “In the Great Lakes, heat waves and cold spells are on the rise,” which cites “Climate change-induced amplification of extreme temperatures in large lakes,” Abdelhady, H.U., et al., Commun Earth Environ 6, 375 (2025), https://doi.org/10.1038/s43247-025-02341-x. A consequence of a warmer and wetter atmosphere is that weather changes will occur in more abrupt shifts and we’ll have larger and more extreme storms and more dramatic swings in temperature. Tick and mosquito populations will have more opportunity to persist. An increasing warmer and wetter atmosphere influences weather patterns, species migration, causes societal disruption and stress, and endangers human health. 

The American Geophysical Union published “What Is Endangered Now? Climate Science at the Crossroads,” Saleska, S. R., et al., AGU Advances, 6 (2025), e2025AV001808, https://doi.org/10.1029/2025AV001808, which says, “Here, we review the role climate science played in that 2006 case, and how the scientific evidence that undergirds the endangerment finding has gotten stronger in the 16 years since.” The National Academies of Science, Engineering, and Medicine released a report “Effects of Human-Caused Greenhouse Gas Emissions on U.S. Climate, Health, and Welfare,” The National Academies Press (2025), https://doi.org/10.17226/29239, which says, “EPA’s 2009 finding that human-caused emissions of greenhouse gases adversely affect human health and welfare was accurate, has stood the test of time, and is now reinforced by even stronger evidence. Today, many of EPA’s conclusions are further supported by longer observational records and multiple new lines of evidence. Moreover, research has uncovered additional risks that were not apparent in 2009.” There can be no doubt that human activity (burning fossil fuels) is a substantial contribution to warming Earth,  disruptions in climate, and endangerment of human health.

Policymakers need guidance. Reducing motor vehicle tailpipe greenhouse gas emission is an important part of ensuring air quality, mitigating climate disruption, and minimizing adverse consequences on human health. A reasonable management and adaptation strategy includes reducing 1) fossil fuel consumption and 2) emission of waste gases from hydrocarbon combustion. We maintain our farm equipment and vehicles and understand the need for tailpipe emission standards and reducing greenhouse gas emission. Strong standards, like the Endangerment Finding, are needed to help mitigate our climate disruption. For the foregoing reasons, I’m opposed to repeal of the endangerment finding. 

Do not repeal the Endangerment Finding.

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