Dear Trusted Friends and Colleagues,

This is less an ordinary end-of-year appeal than it is a call for deepened partnership, at this most fraught moment.

Step-by-step, through 2025, the Trump II White House and its decidedly anti-environmental EPA moved to dismantle the nation’s laboriously constructed greenhouse gas (GHG) rules. And step-by-step, we responded – while working also to develop a far-reaching path forward.

In fairness, in proceeding via notice-and-comment rulemaking, EPA’s most notorious 2025 actions at least retained some of the trappings of formal process under our procedural laws.

At bottom, however, their substantively harmful course of conduct – seeking to “unleash” the fossil fuel industry and its full associated carbon pollution – amounts to a series of “internationally wrongful acts” in patent violation of the fundamental “Obligations of States in Respect of Climate Change.”

Setting the stage: On January 20, 2025, the White House ordered EPA Administrator Zeldin to review and “submit recommendations” on “the legality and continuing applicability” of the 2009 Endangerment Finding.

That 2009 Finding, which at long last conceded that GHG emissions endanger public health and welfare, formed the basis for the Agency’s subsequently promulgated restrictions on major-source climate pollution.

Accordingly, in pressing to take back that 2009 Finding, the Trump II team and its fossil fuel patrons sought to “call into question the very ability of EPA to regulate CO₂, methane and the rest of the Kyoto six greenhouse gases as pollutants under the Clean Air Act.”

There followed, on March 12, 2025, Administrator Lee Zeldin’s bizarrely innumerate announcement that the EPA would “undertake 31 historic actions” to advance the Day One executive orders, including to repeal federal GHG restrictions on power plants and vehicles (and also to exit the 2015 Paris Agreement to the United Nations Framework Convention on Climate Change).

That was chased by EPA’s June 17, 2025, proposal to “repeal all greenhouse gas (GHG) emissions standards for fossil fuel fired power plants,” and its August 1, 2025, proposal to “repeal all greenhouse gas (GHG) emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines.”

These breathtakingly wrong-headed climate depredations required our response, on your behalf and to secure the public interest.

Accordingly, by way of our comment letter of August 7, 2025, CPR Initiative established that EPA’s proposed repeal of restrictions on power plant emissions would harm the nation and the climate system as a whole “in both direct and foreseeable ways.”

In addition, by way of our September 22, 2025, comment letter, we established that EPA had “misread the 2009 Endangerment Finding as well as Clean Air Act §202(a),” distorted the relevant scientific record, and “misapprehended the nature of the climate crisis.” We further alleged that, by its decision “to eliminate existing emissions restrictions, rather than replace them with equally or more effective tools,” the Agency was acting “directly contrary to [its] fundamental duties under domestic and international law.”

Along the way, I have sought to apprise you, and each of our other determined supporters and colleagues, of these signal efforts, mindful that you count on us to act without fear and within our full capacity. In frankness, at critical times this year that has proved difficult, including when two of our strongest moral supporters passed away.[1] Heading into the new year, their memory will impel me, at least, to move mountains to safeguard the rule of law and our beleaguered climate.

Turning to the present: we are now hard at work to fashion our response, by way of another formal comment, to the Trump Administration’s new proposal to weaken the nation’s Corporate Average Fuel Economy (CAFE) standards for new passenger cars and light-duty trucks. I am slated to testify on January 7 on this matter at an EPA administrative hearing and, as we did this year, we will share those comments with you, in part to motivate your own direct engagement where you are so moved.

Finally, for now, I should note to you that we are hard at work to fashion a potential replacement legal structure, one fully capable of supporting a national program of deep decarbonization, as required by the incontestable science.

As we have detailed at CPRclimate.org, at every juncture the Trump-Zeldin juggernaut has postulated a set of arguments, abnormally redolent of sophistry, averring that the terms of the Clean Air Act amount to an insufficient basis for the nation’s existing limits on climate pollution. Accordingly, they claim, our GHG limits must be scrapped.

As discussed, we have worked – and will continue to work — to lay bare the erroneous basis for the misguided Trump-Zeldin anti-climate claims. But we cannot guarantee that they will be thoroughly rejected upon review by our current Supreme Court.

Accordingly, we are also hard at work on an initiative that, as necessary, will demonstrate that other bedrock law is more than fully capable of standing in and indeed, in light of its crystal-clear and equally “capacious” language (as the Supreme Court put it in 2007 in a related context) may be even more capable of supporting a program of deep decarbonization while withstanding legal challenge.

Together, in all these ways, and at every critical juncture, we are ready to press in the new year to surmount the inordinate challenges to our common airshed and our common future. Toward that end, we must take this moment, as 2025 wanes, to ask for your most generous support.

Yours, in peace and hope.

Dan Galpern
CPR Initiative Founder, Executive Director, and General Counsel

[1] I speak here of my father, whom we lost on September 24, and my mother, whom we lost on October 17, and I take this occasion to thank those of you who contributed then in their honor to CPR Initiative. That mode of support, incidentally, was suggested to me by my mother, the day after my father, her partner of 75 years, had passed.

As The Year Turns

Defending Climate Law in an Era of Escalating Rollbacks