On March 30, a group of Harvard alumni and experts convened over Zoom to discuss a regulatory decision with sweeping implications for U.S. climate policy: the rescission of the Environmental Protection Agency’s “Endangerment Finding.”
Issued in 2009, the finding concluded that greenhouse gases endanger public health and welfare. Though not itself a statute, it became the legal foundation for federal regulation of carbon emissions under the Clean Air Act, originally enacted in 1970 and amended in 1977 and 1990. The finding’s repeal on February 12 removes that foundation, raising questions about how, or whether, the federal government will regulate greenhouse gases moving forward.
The panel, moderated by W. John Kress, curator emeritus at the Smithsonian’s National Museum of Natural History, brought together experts in history, law, environmental science, and business to assess the implications. The gathering was sponsored by ClassACT HR73, an initiative of members of the Harvard-Radcliffe Class of 1973 “who are working together for positive social change.”
To frame the discussion, John R. McNeill, a professor and historian at Georgetown University, introduced the concept of the “Great Acceleration” an era beginning around 1950 marked by rapid growth in population, global economic properity, and industrial production.
From there, panelists turned to what some describe as the “Great Unraveling”: the destabilization of environmental and social systems brought on by biodiversity loss and climate change.
“The great unraveling could be a blip,” McNeill said, “but it also could be an enduring trend that hyper-accelerates the Great Acceleration.” Its trajectory, he suggested, will depend heavily on political outcomes worldwide.
“We don’t yet know how great it is, how long it will endure, or how consequential it will be,” he cautioned.
Turning to the role of politics in climate policy, Jason Clay of the World Wildlife Fund introduced the idea of the “great disenfranchisement”: structural imbalances in political representation, particularly through the Electoral College, that amplify rural influence and make broad national consensus more difficult to achieve.
For decades, Clay argued, the United States farm bill helped bridge this divide by pairing rural subsidies with urban food security programs, enabling bipartisan coalitions. That kind of coalition-building, he suggested, has historically made large-scale federal policymaking possible, including in areas like environmental regulation. But the balance has eroded, he said.
One striking indicator, Clay explained, is that “some of the largest food deserts in the United States are now in rural areas.” Together, these shifts point to a broader breakdown in the political mechanisms that once helped manage the tensions that accompany rapid economic growth, and that are necessary to sustain complex policies like climate regulation.
The discussion then turned to the repeal of the Endangerment Finding, which the EPA justified, in part, by questioning the severity of climate risks due to greenhouse gases. Sharon Tisher, who has taught environmental law and energy policy at the University of Maine, outlined the EPA’s rationale. The agency argued that Congress never intended the Clean Air Act’s “welfare” provisions to authorize regulation of greenhouse gases.
But the agency’s scientific argument quickly unraveled, said panelist Sharon Tisher, who has taught environmental law and energy policy at the University of Maine. The EPA had relied on a report authored by a small group of long-standing climate change skeptics—with views that, Tisher noted, diverged sharply from those held by the wider scientific community.The National Academies of Sciences, Engineering, and Medicine issued a rapid report reaffirming the broad scientific consensus on climate change.
A federal court later found that the advisory process behind the EPA’s report violated statutory requirements. By the time the final rule was issued on February 26, the EPA had abandoned the scientific justification entirely—a “huge concession,” Tisher said—leaving the repeal to rest on legal arguments about congressional intent. That shift places the future of U.S. climate policy squarely in the courts. As of March 19, 24 U.S. states have sued the EPA for repealing the endangerment finding.
The Endangerment Finding, Fisher said, has served as the foundation for federal greenhouse gas regulation for more than a decade. Without it, existing rules may be vulnerable to challenge, and future administrations could be forced to rebuild the scientific and legal case from scratch. The broader scientific community has responded forcefully, reaffirming that the original 2009 finding remains robust and is strengthened by nearly two decades of additional evidence.
The panelists did not directly address the EPA’s own description of the repeal. In its published explanation, the agency states that rescinding the Endangerment Finding means that emissions standards for light-, medium-, and heavy-duty on-highway vehicles and engines no longer need to meet predefined greenhouse gas standards. The agency has described this as “the single largest deregulatory action in U.S. history,” estimating savings of more than $1.3 trillion to consumers.
Public health experts anticipate that the repeal will have cascading effects, including worsening air quality, rising healthcare and insurance costs, and higher food prices driven by more frequent extreme weather. The United States—already the only country to have withdrawn from the United Nations Framework Convention on Climate Change—also risks falling behind in the global clean energy transition.
From a business perspective, Clay emphasized that private-sector initiatives can influence environmental outcomes, particularly when large corporations adopt sustainability standards across their supply chains. Yet he cautioned that such efforts are most effective when they complement, rather than replace, government regulation—a prospect that now appears increasingly unlikely, and rests in the hand of court.
