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To Members of the National Academy of Sciences

Dear Members of the National Academy of Sciences,

We are writing to you, and other leading US scientists, seeking your support for a critical new climate initiative.

We serve, respectively, as Board President (Donn J. Viviani, a 35-year veteran EPA scientist), and Executive Director (Dan Galpern) of the nonprofit group Climate Protection & Restoration Initiative (CPR Initiative).

On June 16, 2022, we filed a citizens petition, Petition to EPA to Phase Out GHG Pollution, on behalf of renowned climate scientist James E. Hansen, the undersigned Donn J. Viviani, John W. Birks (distinguished emeritus professor in atmospheric chemistry), Richard Heede (eminent climate accountability analyst) and Lise Van Susteren (prominent physician and writer).

We have developed an approach that relies on the crystal-clear mandate of the Toxic Substances Control Act (TSCA). Under TSCA, chemical substances must be restricted, even to the point of prohibition, where the Agency determines they “present an unreasonable risk of injury to health or the environment.” The major greenhouse gases (GHGs), including carbon dioxide and methane, clearly present such a risk. Moreover, the Agency has previously used TSCA to limit CFCs, on the basis of their ozone-depleting and powerful climate forcing effect.

Our filing triggered a 90-day legal deadline, so EPA now has until September 14 to accept or reject the petition.

If EPA determines that GHG pollutants present an unreasonable risk, then the Agency is required to “promptly commence an appropriate proceeding” – including full public participation – to develop a new federal rule imposing limits “to the extent necessary so that the chemical substance. . . no longer presents such risk.”

Gaining EPA’s determination that greenhouse gases now present an unreasonable risk, and then securing a strong federal decarbonization rule, will not be easy. We need to build, and demonstrate, additional strong scientific support.

We invite you to join our effort by way of one or all of the following actions: endorse the Petition to Phase Out GHG Pollution, share your expert opinion on this topic with EPA through a public comment, contribute to our work either with a donation or by mobilizing your networks and leveraging your platform to spread the word. Only together can we restore and protect a stable and healthy climate.

Thank you,

Donn J. Viviani, Board President
CPR Initiative (


Dan Galpern, General Counsel & Executive Director
CPR Initiative (

Copyright © 2022 Climate Protection & Restoration Initiative, All rights reserved.

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