The EPA’s 2009 Endangerment Finding has underpinned almost all U.S. efforts to reduce greenhouse gas emissions, making it a prime target for the Trump administration’s rollback of climate policies. A day-one executive order included a directive to review the “legality and continuing applicability” of the finding. On March 12, the EPA announced that it would potentially rescind the Finding, and the announcement was formalized with a proposed rule on July 29. 

Repealing the Finding would undo more than a decade of work that has made American communities healthier, skies clearer of smog and other pollution, and contributed to the country’s decreasing carbon emissions.

What is the Endangerment Finding?

The Endangerment Finding is a pivotal determination by the EPA, issued in response to the 2007 U.S. Supreme Court Case Massachusetts vs. EPA. In that case, the court held that the EPA has the authority to regulate greenhouse gases under the Clean Air Act, and that after it has made a finding of endangerment, the agency cannot refuse to regulate these gases.

Additionally, the EPA found that greenhouse gases in the atmosphere are both a hazard to public health and that motor vehicle emissions contribute to this pollution. In the years since, the EPA has built on the original ruling and issued subsequent endangerment findings relating to aircraft and utility emissions under other provisions of the Clean Air Act .

Why is the Endangerment Finding important?

As a result, the Endangerment Finding has become the legal foundation for essentially all federal regulation of greenhouse gas emissions in the U.S. – including motor vehicle tailpipe emissions and power plant rules.

The EPA’s proposed rule would repeal all greenhouse gas emissions standards for light-duty, medium-duty, and heavy-duty vehicles and engines, and would preempt any state fuel efficiency or vehicle emissions laws or regulations. Furthermore, this repeal could be a foundation for undoing greenhouse gas emissions regulations on stationary sources like power plants or oil and gas facilities.

The Endangerment Finding is based on sound science

The attempt to repeal the Endangerment Finding is emblematic of the current administration’s disregard for scientific consensus around the causes and impacts of climate change. 

The original finding draws from expertise at the U.S. Global Change Research Program, the Intergovernmental Panel on Climate Change (IPCC), and the National Academies of Sciences. It examined public health and public welfare in the U.S., with a focus on air quality, food production and agriculture, forestry, water resources, sea level rise and coastal areas, energy, infrastructure, and settlements, and ecosystems and wildlife. The EPA received over 380,000 public comments, the majority of which provided support for the Finding.

In 2018, Dr. Philip Duffy, then-president of Woodwell Climate Research Center, led a review of the scientific foundation of the Endangerment Finding. That work, published in the journal Science, found that “for each of the areas addressed in the EF, the amount, diversity, and sophistication of the evidence has increased markedly, clearly strengthening the case for endangerment. New evidence about the extent, severity, and interconnectedness of impacts detected to date and projected for the future reinforces the case that climate change endangers the health and welfare of current and future generations.”

What’s next for climate policy?

The legal validity of the administration’s proposed rule was contested almost immediately and challenges will likely continue to roll in even if the rule is made official. 

The EPA has extended a public comment period on this topic through September 22, 2025. The recently released Department of Energy (DOE) report, A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate, which challenges scientific consensus by claiming that carbon dioxide-induced warming appears to be less damaging economically than commonly believed, serves as a foundation for the EPA’s proposed rule. That report is also open for public comment through September 2, 2025.  

The National Academy of Sciences has fast-tracked its scientific review of the impacts of greenhouse gases on human health in order to inform the decision within the comment period, and has requested contributions from scientists and experts in the fields of public health, extreme weather, climate modeling, agriculture, and infrastructure. Woodwell Climate is contributing to the opportunities for public comment and scientific engagement to aid future consideration of this, and similar, proposals in courts and encourages members of the public to do the same.

Last month in Dakar, Senegal, Woodwell Climate Associate Scientist Glenn Bush and Forests & Climate Change Coordinator Joseph Zambo facilitated a high-level workshop with the Democratic Republic of Congo’s Director of Climate Change, Aimé Mbuyi, lead scientist on the country’s Nationally Determined Contributions (NDC) reporting process, Prof. Onesphore Mutshaili, and project consultant Melaine Kermarc. The goal of the workshop was to begin generating a clear set of priorities for the next 5 years for stepping up the ambition of the country’s NDCs, and to discuss strategies for monitoring and reporting on emissions.

Under the Paris Agreement, each country is required to submit to the UN Framework Convention on Climate Change a detailed description of their emissions reduction commitments and then regular reports on progress. Currently, DRC has pledged to reduce emissions by 21% by 2030, focusing on reform in their energy, agriculture, forestry, and other land use sectors. While NDCs are intended to represent a country’s highest possible ambition, DRC is looking to step up further. Officials are at work developing a plan to reach net-zero emissions, which would place the country among the leaders of climate policy in Africa.

In order to do this, DRC needs a reliable framework for measuring and monitoring emissions, so that progress can be accurately reported on. At the workshop, Bush, Mbuyi, Zambo, Kermarc  and Mutshaili discussed ways to strengthen the NDC reporting process. Among the top needs identified was stronger institutional scientific capacity, increased coordination and data sharing, and more funding and awareness of the process at local and provincial levels.

“High quality data is essential to building a high integrity NDC,” says Bush. “Improving the scope and quality of data available to monitor carbon will not only help the country meet the highest tier of reporting standards, but also access performance-based payment mechanisms to help finance the transition to a low emissions economy.” 

Through their conversations about challenges and opportunities, the group identified three areas for intervention that will help the country navigate towards a stronger emissions reduction plan. These recommendations were outlined in a report on the workshop proceedings.

  1. Improved governance and policy management: Establishing a National Climate Change Council to better integrate climate policy into national development plans.
  2. Science-backed carbon accounting and budgeting: Developing credible data standards for measuring emissions and ecosystem services to support transparent and effective reporting on climate performance. 
  3. Cross-sectoral integration: Promoting emissions reductions across all sectors through collaborative partnerships, particularly in the field of climate-smart agriculture and carbon payment mechanisms. 

Mr Aimé Mbuyi, Head of the Climate Change Division (CCD) at the DRC’s Ministry of the Environment and Sustainable Development, declared that “these recommendations reflect an important set of practical steps to move from aspiration to operational reality in order to increase the financing and impact to conserve our forests and stimulate sustainable development in the DRC”.

Woodwell Climate Research Center has been a long time partner of the Ministry of Environment and Sustainable Development. The Center is assisting the ministry in laying the technical foundations to support the NDC improvement process and helping build in-country scientific capacity to make a net-zero emissions plan a reality. This and other partnerships will be essential in transitioning the DRC to a low-carbon economy.

“We appreciated the long-standing trust that has developed over years of formal and informal collaboration on climate policy,” said Mbuyi. “The scientific partnership with Woodwell is invaluable to us at CCD, providing actionable information that has proven essential to advancing the climate mitigation and adaptation agenda.”

While the annual climate Conference of Parties (COP) each fall is the largest and most visible event of the global climate effort, international climate action happens all year long. Each June, United Nations Framework Convention on Climate Change (UNFCCC) holds a preparatory conference in Bonn, Germany. These summer climate meetings, often referred to in shorthand as “Bonn,” bring together up to 7000 delegates for the nitty gritty work of international cooperation.

At Bonn, government delegations negotiate the full range of issues surrounding global climate collaboration, scientific organizations present their latest findings, civil society groups advocate for climate action, and diverse coalitions showcase their efforts. The June meetings lay the groundwork for decisionmaking and collaboration at the upcoming COP, and often give a clear indication of the challenges to come in the fall negotiations. This year, from June 16 to 26, conversations at Bonn spanned topics including the development of indicators for global resilience, clarifying how the world should pursue the global energy and forestry related targets agreed on at COP 28, mobilizing climate finance, increasing countries’ ambition for emissions reduction, and ensuring a just global transition away from fossil fuels. 

This year’s summer meetings proved a tough one for governments attempting to move forward on nearly every issue, though delegates did manage to achieve clarity on the decisionmaking agenda for the upcoming COP30, to be held in Belém, Brazil in November. In the science realm, the UNFCCC launched a systematic mapping of what research needs are currently being met by the scientific community and where there are still gaps in actionable information. 

Beyond the intergovernmental negotiations the conference included a wide range of events and activities by observer organizations. A Woodwell Climate delegation was in attendance again this year, taking part in some of the key activities of the conference. Here are 3 highlights from The Center’s engagement at this year’s June climate meetings.

On top of substantive agenda items, participants tried to grapple with the logistical issues arising around the conference in Belém, with affordability and accessibility being particularly acute concerns for non-governmental organizations and Global South participants. Despite the questions remaining on this front, the outcomes from this June’s climate meetings have built the foundations for a pivotal COP30 agenda— at a time when ambitious climate action couldn’t be more important.

One of President Trump’s first actions this past week—and also in his first term—was to announce the withdrawal of the United States from the Paris Agreement. It is a step that is both misinformed and misguided. But how much difference will it make? Here’s what you need to know.

1. Significance of the Paris Agreement

The Paris Agreement was adopted by 197 countries in December 2015 and has been the underpinning of international climate action for nearly a decade. The goals and strategies it sets out are critically important to maintaining a stable climate, which is the foundation of successful societies and economies. The Parties to the Paris Agreement are legally obliged to submit national climate plans, known as Nationally Determined Contributions (NDCs) every five years. However, the content and level of ambition of those NDCs are (as the framing “nationally determined” makes clear) up to the Party itself. 

2. Immediate legal implications

The Paris Agreement stipulates that any nation’s withdrawal takes effect one year after an official notice has been submitted to the Secretary-General of the United Nations.  In the case of the United States, the earliest effective date of official withdrawal is, therefore, sometime in January 2026. After that, the country will not be bound by its obligations under the Paris Agreement. Those include the submission of NDCs every five years, accounting of progress toward commitments, the submission of biennial transparency reports, and the general obligation to provide climate finance. The United States will also lose, in particular, its right to vote on decisions within the governing body of the Paris Agreement, to nominate members to institutions serving the Paris Agreement, and to participate in emission trading under the Paris Agreement. However, as the United States submitted a new NDC and a biennial transparency report in December 2024, it is currently in compliance with the key obligations under the Paris Agreement.

3. What withdrawal from the Paris Agreement doesn’t do

The executive order of January 21, 2025 does not withdraw the US from the UN Framework Convention on Climate Change (UNFCCC), the 1992 treaty that established the international climate negotiation process. The language of the executive order indicates that this is deliberate—the US will retain its right to vote in the Conference of Parties, as well as its reporting obligations under the UNFCCC. This is possibly due to the fact that a withdrawal from the UNFCCC, a treaty ratified by the U.S. Senate in 1992,  requires a two-thirds majority in the Senate. It is also notable that no action has been taken to withdraw the NDC submitted by the Biden Administration in December 2024.

4. The policy impact

The United States’ withdrawal makes maintaining—let alone enhancing—the ambition of emission reduction efforts across the world significantly more difficult. When a major emitter “free-rides,” it de-motivates ambition by others. However, although the U.S. has the second-highest GHG emissions in the world, and has always been a key player in global climate collaboration, it is important to bear in mind that 194 other countries representing approximately 90% of global emissions have not withdrawn from the Paris Agreement. 

The executive order is targeted at stopping any U.S. climate finance contributions. This will mean that the new global climate finance goal of $1.3 trillion per year by 2030, agreed upon in Baku, has become much harder to achieve. This will impact the poorest countries directly, as well as degrading the international community’s trust in the effectiveness of the process.

5. What happened last time

President Trump also withdrew the U.S. from the Paris Agreement during his first administration. Then, as now, one of the primary impacts was to create a leadership vacuum. In that case, that vacuum was largely filled by other nations, plus state, local, and business leaders. The resulting groundswell generated momentum that carried into the Biden Administration and the U.S. re-entry into the Paris Agreement. While much of that foundation remains strong, trends in the private sector have shifted, with a growing number of major corporations and financial institutions backing away from their climate commitments. Global geopolitics has also evolved, raising questions about what role other governments, in particular China, might play in reaction to the United States’ withdrawal from the international governance structures.

Negotiations at COP29 in Baku, Azerbaijan ran well past the scheduled end of the conference Friday evening. While the final outcomes fell short of hopes, they exceeded many expectations.

And while a full analysis of the final decisions will take time, a few key takeaways are already clear. The new goal for climate finance is an important step in the right direction, but responsibilities for it are ambiguous. The same can be said for the global goal on adaptation, conclusions about the need for enhanced research and observation systems, and a work plan for greater involvement of Indigenous peoples in the UN climate negotiation process. There was some enhanced clarity around mechanisms for implementing carbon markets under Article 6 of the Paris Agreement; however, the failure to reach consensus on the Just Transition Work Programme and improvements to the Global Stocktake process used to gauge progress toward climate goals were distinct disappointments.

Every COP presents unique challenges and opportunities, the pace of diplomacy rarely matches the acceleration of climate change, and under the Paris Agreement, the responsibility for ambition lies at the national level. But the main negotiations—as important as they are—are not the only venue where progress is made. Over the course of the two week convening, Woodwell Climate’s delegation hosted and participated in dozens of meetings and events, scoring significant wins at COP29:

As is always the case, this COP was the first step on the road to the next one. COP30 will bring the UN climate change negotiation process back to Brazil, where the UN Framework Convention on Climate Change was adopted in 1992, and where sustainable food production and tropical forest conservation—core areas of research and expertise for Woodwell Climate—are expected to be at the top of the agenda.

Woodwell Climate Research Center and UN Climate Change are collaborating to develop a new training course—announced November 14 at COP29 in Azerbaijan—to prepare experts for a voluntary review of adaptation reporting by Parties under the Paris Agreement.

Countries submit Biennial Transparency Reports (BTRs) every two years to inform the world about their national climate efforts. These reports are vital enabling tools for governments, helping to build a robust evidence base critical to strengthening climate policies and climate action over time. The first BTRs are due at the end of 2024.

“Transparency is a priority for the COP29 presidency, because transparency is a cornerstone of climate action,” said a representative for the COP29 presidency at the Together for Transparency event on Thursday. 

Each BTR will be reviewed by teams of technical experts coordinated by UN Climate Change, which provides a set of training courses for experts to prepare for that task. A country can request a voluntary review of the information it has reported on adaptation efforts, which requires special expertise on climate risk and adaptation to execute. 

This collaboration draws on Woodwell expertise on climate change impacts and adaptation reporting, as well as climate risk and vulnerability assessments. Woodwell Climate’s Director of International Government Relations, Dr. Matti Goldberg, was responsible for spearheading this collaborative effort.  

The training will encompass a set of five lessons and accompanying exams that help future expert reviewers learn key aspects of vulnerability assessments, adaptation planning, monitoring and evaluation, and loss and damage, among other issues. These lessons will be launched in a PDF downloadable format by the end of 2024.

Squabbling, compromise, disappointment, hope, and incremental change— these are features of any decision making process, but especially one requiring the cooperation and agreement of nearly 200 countries with varied interests, resources, and desire for change. 

At the annual Conference of Parties (COP) to the United Nations Framework Convention on Climate Change (UNFCCC), member countries gather to hash out the gritty details of international agreements concerning climate change. These COPs have become the world’s most prominent stage for climate action, drawing not only heads of state and diplomats, but also scientists, activists, businesses, journalists, financial organizations, Indigenous knowledge holders, artists, and spiritual leaders, just to name a few. All are in attendance to influence the future of planet Earth. 

Here’s how climate’s biggest event of the year steers the international framework for combating climate change.

What is COP?

Formally, the COP is the decision-making platform for signatories of the UN Framework Convention on Climate Change (UNFCCC). The UNFCCC is a legally binding agreement between UN member countries, created specifically to tackle the crisis of climate change. Each year since its creation, delegations from participating countries (called Parties) have met at the COP to discuss the agreements and mechanisms by which to address climate change. 

After two weeks of negotiation, conference delegates produce text that becomes binding for UNFCCC Parties. These texts have legislated things from the commitment of industrialized nations to reduce emissions, to the direction of funding for climate action, to the upper limit of acceptable warming. 

The prominence and importance of these conference proceedings have grown with each year and each increment of warming. The conference itself has expanded to encompass climate action across multiple channels at once.

“There are actually three COPs happening in parallel,” says Woodwell Climate’s Director of International Government Relations, Dr. Matti Goldberg, who has learned the ins and outs of the conference over 15 years spent working for the UN’s Climate Change Secretariat.

The first layer is the core of the conference— the negotiations. This is the space where each participating country sends delegates to argue on their behalf. The agenda for each year’s negotiations is developed during preparatory meetings of the delegates, with planning sometimes starting two years in advance, and resulting in agendas of 50-60 interlinked issues. COPs are typically judged as successes or failures based on the strength of the resulting text from the formal negotiations. The complexity of the issues, and the negotiating tactics of different countries, tend to push final agreements well beyond the scheduled closing of the COP.  

Then there’s what Goldberg calls the “high-level COP.” This is the platform for heads of state to showcase their country’s progress on various issues. Think, speeches from the president, announcements of new coalitions, hand-shaking between ministers, or denunciations of other countries’ lack of action. Although the high-level COP can feel like superficial performance, deals between countries can help move the negotiations forward— or delay them, depending on a country’s interests.

Surrounding both the formal negotiations and closed door deals is the “third COP” — also referred to as the “Blue Zone”: a space open to scientists, NGOs, activists, and companies for hosting side events, pavilions with panel talks and presentations, forge new partnerships, hold protests, and apply pressure on negotiators. The third COP also spills out into a “Green Zone”, a space where those not badged for the official conference can organize events and contribute to the momentum of the moment.

What does an NGO do at COP?

For an organization like Woodwell Climate, the third COP is the main stage on which to contribute to the conference. 

“Our first priority is to showcase our research and its relevance to the key questions of each year’s COP,” says Goldberg.

At COP29 in Baku, Azerbaijan, Woodwell Climate will host a pavilion to showcase the organization’s work in several key areas, including climate risks and national security, accounting for growing natural emissions sources like permafrost thaw and wildfires, as well as emerging collaborations with new partner countries such as Ethiopia. The pavilion also serves as a convening place to discuss work with partners.

“The sheer scale of participation at COPs makes them critical annual opportunities to solidify existing partnerships and build new ones,” says Goldberg.

While participants of this third COP aren’t officially part of negotiations, Woodwell Climate scientists still have opportunities to participate in the more formal COP processes. Each COP hosts an “Earth Information Day” where scientists exchange data and research with country delegations to better inform decision making. At COP29, Woodwell has proposed to highlight the latest research on wildfire emissions.

Scientists also have a role to play in ensuring national emissions reductions plans are based on accurate numbers—a point that Woodwell Climate will be emphasizing both at this COP and beyond. In 2025, countries must submit their updated 5-year climate targets (called Nationally Determined Contributions or NDCs) to the UNFCCC. The adequacy of those targets depends on how much carbon can still be emitted without surpassing the agreed-upon maximum limit of warming.

“Our research on permafrost and wildfires indicates that the global carbon budget available for staying below the 1.5 degrees Celcius temperature limit might be much smaller than countries are thinking right now,” says Goldberg. “From the Woodwell perspective, it would be great to remind the international community that the numbers need to add up. We need to take into account these emissions that are not being discussed.”

Successes and failures in three decades of COP

Over his tenure with the UN Secretariat, Goldberg has witnessed both promising action and frustrating setbacks, sometimes at the same conference. 

COP15, held in Copenhagen in 2009 was one of those moments for him. Here negotiations decayed, and the weak resulting agreement failed to legally bind countries to emissions reductions.

“Turkeys don’t vote for Thanksgiving,” Goldberg jokes. “Countries will generally not agree to a regime that will force them to take on targets determined at the UN or by others.”

But Goldberg says that Copenhagen did, at least, define a new paradigm where every country would commit to doing something. Voluntarily, and perhaps not ambitiously enough, but in a year widely considered a failure, steps towards universal climate cooperation were still made.

Each successive COP built upon this new paradigm and in 2015 the conference arrived at another milestone— the Paris Agreement. This is the framework under which the world operates today, with every country creating NDCs appropriate to their size and resources, with the goal of limiting warming to 1.5 degrees C above pre-industrial levels. 

The agreement spurred more conversation around how that goal would be achieved, and in 2018 the parties adopted a rulebook for its implementation. Since then, however, Goldberg says many of the conferences have been “searching for real purpose” — some kind of action to match the ambition of the Paris Agreement. But, in Goldberg’s mind, that doesn’t necessarily indicate a failure of the process.

“You can’t have a spectacle forever,” says Goldberg. “At some point the pressure should be less on the COP itself and more on countries actually working under the Paris Agreement to get more ambitious about what they’re doing, and probably making some very painful decisions at the national level.”

Climate has the world’s attention

But of course, policy making moves slowly, both for the UN and national governments. And with each year that passes, cooperation and increased ambition becomes more urgent. In 2023, record high temperatures spurred conversations about whether the 1.5 degree limit has already been surpassed. In five years, Goldberg states, “it might be way too late even to pretend that we are under that limit.”

But Goldberg remains hopeful. Before the COPs, before 30 years of tough conversations attempting to find a way through the climate crisis, Goldberg says, the prevailing thought among political scientists was that international cooperation on this scale was a fantasy. But despite its failures, the process has persisted, inching the world towards climate action. Other international treaties have taken their lead from this process as well, hosting COPs to address issues like plastic pollution and biodiversity.

“The fact that there are so many people dedicated to solving this and to working through mutual disagreements, that people haven’t walked away, makes me hopeful,” says Goldberg. “This is possibly the hardest global policy problem there is, and it has the world’s attention. I think that’s very positive.”