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Sending you an email about an AI and climate resilience publication

This looks great. I just signed up. Want to weave in more discussion of AI into my Howard undergraduate class on climate change and am interested in AI for resilience in particular.

The proposal would focus political oversight on review of individual research proposals, consuming time that would better be used for high-level leadership. It assumes that political judgement can legitimately supersede objective assessment of merit by multidisciplinary expert peer review.

** OMB has not fully considered the economic impacts of the proposal. ** The proposal purports to “restore gold standard science” and promote scientific integrity, including transparency and independent (unbiased) peer review. However, it is difficult to see how it would achieve these objectives.

Agencies cannot simply delegate to OMB their respective authority. These agencies have their respective statutory requirements to implement congressionally-mandated programs, some of which explicitly require scientific peer review to take precedence over political reviews.

Moreover, this is the very first time that OMB is not providing direction in the form of guidance, but instead binding regulations.

OMB asserts they have the authority to promulgate this regulation by citing statutory language which states that the Deputy Director Manager is able to 'provide overall direction and leadership to the executive branch on financial management matters' but the proposal goes far beyond financial mgmt.

www.environmentalprotectionnetwork.org/epn-and-l4gg...

EPN and L4GG Comments on Regulation for Federal Financial AssistanceOn July 13, 2026, Environmental Protection Network and Lawyers for Good Government submitted formal comments opposing the Office of Management and Budget’s proposed regulation governing federal financ...www.environmentalprotectionnetwork.org

Congrats to Piers!!

Was sad to get this news. Rafe was a good guy, really respected him and enjoyed his sense of humor.

Yes, they recently finalized a decision repealing the endangerment finding. That will be litigated. You could still have a climate adaptation program even without the endangerment finding.

EPA did that very formally in 2009 with the GHG endangerment finding under the Clean Air Act. But yes, you have to acknowledge that there's a problem worth adapting to in the first place.

Ok! That sounds like a good one over beers.

EPA's previous analyses showed large net benefits. For the medium/light-duty rule alone, monetized benefits using SCC were on the order of $72B. Yes, now those benefits are assumed to be zero. Couple of us ex-feds who worked on 2009 finding have our commentary here substack.com/home/post/p-...

I love how it sounds like electronica but it's all old school humans playing instruments live

The Supreme Court, not the Obama EPA, ruled that GHGs are air pollutants under the Clean Air Act. The first draft tech support doc with all supporting science that eventually supported 2009 finding was released for public comment under the Bush Admin.

Of course EPA has now decided that it will assign the benefits of GHG or other pollution reductions, including lives saved, a value of zero.

EPN pointed out in their comments that the rules EPA is rescinding have positive net benefits. The Clean Car Rule avoids over 3,000 deaths and has annual net benefits of $96 billion. The Clean Truck Rule (phase 3) will save over 100 lives and has annual net benefits of over $10 billion.

Other arguments from last year's proposal seem to be at odds with the 2007 Mass v EPA Supreme Court decision, which held that GHGs meet the Clean Air Act's definition of an air pollutant and directed EPA to make a science-based decision whether GHGs cause endangerment

Publications should be accessible to a general audience. All proposed publications will be subject to the editorial board's decisions and peer review by recognized authorities in their respective fields. Proposals will be reviewed on an ongoing basis. Submit proposals here: lnkd.in/eM6APXUg