In the Fall 2026 issue of Regulation, Ben Zycher argues that my critique of the Environmental Protection Agency's decision to rescind the "endangerment finding" which triggered the regulation of greenhouse gas emissions from new motor vehicles under the Clean Air Act is "deeply problematic." I appreciate that Zycher took the time to respond to my essay, but I think his analysis misses the mark.
I hope to have a full response to Zycher in due course. For the moment, I wanted to point out a serious error in Zycher's attempt at legal analysis.
Zycher writes:
