March 03, 2026
Letter to Dr. Zeldin, Administrator U.S. Environmental Protection Agency
Re/ proposed decision to not include health in cost/benefit analysis
Dear Administrator Zeldin:
The mission of the Environmental Protection Agency (EPA) is to protect human health and the environment. In February 2025, EPA announced the agency’s new “Powering the Great American Comeback” Initiative – a 5-pillared roadmap of how the agency would achieve its mission in this administration. The top of that list as Pillar 1 is to provide clean air, land and water for every American. Given this, the undersigned health and medical organizations are perplexed and disappointed by the agency’s ongoing dismantling of clean air protections, and particularly its recent announcement that it will no longer count the monetized health costs of air pollution.
For decades, EPA has conducted cost-benefit analyses as part of rulemaking, same as many other federal agencies. These analyses conducted for implementation purposes are integral to regulatory impact analyses that accompany rulemaking. They were mandated through Executive Orders to provide a way to compare expected health benefits against the cost of compliance on the same monetized scale. EPA’s approach for quantifying and monetizing health benefits is sound and has long been accepted by environmental scientists and economists on many regulatory review bodies. Abandoning this approach on grounds of uncertainty in estimating benefits while assuming certainty on compliance cost estimates is unjustifiable and ignores the life-saving health benefits of clean air protections.
The evidence is abundantly clear that air pollution kills people, makes chronic disease worse and sends more people to the hospital and emergency room. A literature review endorsed by national health and medical organization details the many documented physical and psychological health harms of air pollution. Particulate matter and ozone –which the agency is apparently no longer estimating health harms from – are two of the most widespread and deadly pollutants. EPA’s 2019 Integrated Science Assessment (ISA) concluded that breathing particulate matter (PM2.5) causes premature death, cardiovascular harm, likely causes respiratory harm, likely causes cancer, likely causes nervous system harm and may cause reproductive and developmental harm. Additional U.S. studies have found premature deaths at levels even lower than the current standard. There is no safe threshold for PM2.5 exposure.
EPA’s ISA for ozone found that even low levels of ozone pollution can trigger immediate, dangerous health impacts. Exposure contributes to shortness of breath, wheezing and coughing; onset of asthma and asthma attacks; increased risk of respiratory infections; and increased need for people with lung disease to require hospital treatment. Researchers have also found a higher risk of death from respiratory diseases associated with increases in ozone, as well as links between ozone and lower birth weight and decreased lung function in newborns.
EPA is arguing that there are uncertainties that cloud the quantification of health benefits and claims that alone is a reason to scrap the approach altogether. However, it is most likely that EPA undercounts the health benefits of a rulemaking while overcounting compliance costs. For example, within the 2022 proposal to update the Mercury and Air Toxics Standards, EPA stated that it had overestimated the annual compliance costs of the 2012 standards by as much as $7 billion. Meanwhile, the benefits of reduced particulate matter exposure under the MATs proposal were monetized and the benefits of reduced mercury exposure were not, meaning that the total monetized benefits undercounted the full impacts.
EPA has argued that not monetizing the health impacts of pollutants does not mean the agency is no longer considering those health impacts. It is clear, however, that the agency’s decision to completely devalue the costs to human health aligns with the overall agenda of rolling back, delaying and eliminating proven health protections. Without this element of rule analysis, EPA is failing to illustrate the true costs and benefits of their own rules.
Too many people are living in areas with poor air quality. The American Lung Association’s 2025 “State of the Air” report found that over 156 million Americans live in areas with unhealthy levels of ozone or particulate matter pollution.9 Families and communities rely on strong EPA safeguards to raise their families, go to work and school, socialize and worship without worrying if exposure to air pollution will land them in the hospital or worse.
By not counting the health costs, EPA is hiding vital information that could save a life. This drastic departure in process tells the public that their kids’ asthma attack doesn’t matter, their neighbor’s hospitalization for a heart attack doesn’t count, or that a premature death is just the cost of the business of saving polluters money. We strongly urge the agency to reconsider this approach and return to fully counting the health benefits that come from lifesaving pollution regulations. Return to the core mission of the EPA instead of hiding information for polluters’ sake.
February 25, 2026
Press Release
Cancer Experts: Climate engagement — an increasingly relevant part of cancer care
Climate Change Requires Urgent Action by the Oncology Community to Minimize Harm to our Patients
Madison, WI – The implications of EPA’s rescission of its Endangerment Finding, which eliminates the requirement for EPA to protect people from the pollution that causes climate change, carry implications for cancer care well beyond the US. Large bodies of evidence have shown that air pollution, a warming planet, and climate change all contribute to increasing cancer incidence and have major impacts on cancer treatments, outcomes, and access to care. The international members of OUCH-Int’l (Oncology Advocates United for Climate and Health - International), a global organization of oncology health care professionals committed to mitigating the effects of climate change on cancer and its treatment, express deep concern that this action endangers the health of the entire planet.
A pollution extends past national borders. Unchecked fossil fuel pollution in the United States creates a self-reinforcing loop that will increase cancer incidence while, at the same time, the consequences of global warming threaten the medical community’s ability to care for cancer patients. Unchecked emissions will lead to devastating consequences, including more frequent natural disasters, worsening food insecurity, significant economic losses, rising rates of cancers and other heat-related illnesses, and serious harm to ecosystems and all living beings.
Without climate action grounded in environmental justice, the hard-won gains we have achieved in human health over the past many decades —especially in the most vulnerable countries and populations—are at risk. Rising rates of cancers and other heat-related illnesses, increasing frequency and severity of extreme weather events, and significant economic losses will worsen food insecurity, patient outcomes, strain already fragile health systems, and deepen global health inequities.
As physicians and health care providers, we have a moral obligation to protect our patients from preventable diseases. As cancer doctors, we understand that this action bequeaths increased cancer related suffering in all communities around the world. It is inconceivable to us that anyone with the ability to reduce this suffering would not do everything possible to prevent it. This is no longer an issue affecting polar bears in the Arctic or forest biodiversity, but a clear and imminent threat to the lives and care of our patients requiring urgent action.
We urge all oncology health care professionals to advocate for measures to improve the sustainability of their practices, clinics, and health systems, and for broader measures to increase climate resilience in their communities.
About OUCH International
OUCH-Int’l is the only international non-profit, nonpartisan organization focused on mitigating the effects of climate change on cancer care. Every day, we see living proof that cancer touches everyone. We aspire to use our unique voice as oncology health professionals and cancer experts dedicated to the care of our patients to raise awareness about the effects of climate change on cancer outcomes and galvanizing decision makers at all levels to act on climate change.
ABOUT THE ENDANGERMENT FINDING
The Clean Air Act requires the U.S. Environmental Protection Agency to protect people from “any air pollutant from any class or classes of new motor vehicles or new motor vehicle engines” that the agency deems “causes or contributes to air pollution that may reasonably be anticipated to endanger public health or welfare.”
In the 2007 landmark U.S. Supreme Court decision Massachusetts vs. EPA, the court found that carbon pollution and other climate-warming pollutants (greenhouse gases) are “air pollutants” as defined by the Clean Air Act. The court directed the EPA to make a final scientific determination whether emissions of these pollutants from new motor vehicles endanger health or welfare.
In 2009, the EPA determined that carbon dioxide, methane, and four other climate pollutants do endanger public health, and that emissions from cars and trucks contribute to that danger. Over the years, EPA has repeatedly reaffirmed that greenhouse gas emissions endanger the public and that pollution from power plants, oil, and gas
operations, and other sources contribute to that danger. The EPA's Endangerment Finding was challenged in court by big oil and gas companies, fossil fuel producers, radical right-wing front groups like the Competitive Enterprise Institute, and red-state political figures. The D.C. Circuit of Appeals upheld the finding based on the overwhelming scientific evidence supporting it. The Supreme Court denied an additional review.
Later Supreme Court decisions have limited the scope of some of EPA’s climate protections. But none of those decisions undermined the original basis for the Endangerment Finding and the EPA’s duty to act under the law.
February 22, 2026
Press Release
LETTER TO THE EDITOR: Wisconsin State Journal
EPA's negligent climate policies will threaten cancer care | Joan Schiller
OUCH-Int’l (Oncology Advocates United For Climate and Health — International) is an international nonprofit, nonpartisan organization focused on mitigating the effects of climate change on cancer care.
We are deeply disturbed that the Environmental Protection Agency has chosen to rescind the endangerment finding without any input from oncologists.
The health risks of increasing greenhouse gas emissions on cancer care are devastating. Climate change will increase cancer and have major impacts on cancer treatments, outcomes, and access to care. If this policy stands, we will see more preventable cancer deaths as air pollution and global warming intensify.
As physicians and health care providers, we have a moral obligation to protect our patients from preventable diseases. This is particularly true when it comes to cancer — a disease responsible for about a quarter of all deaths each year in the United States. As cancer doctors, we have seen the pain and suffering that so many patients go through. Those empowered to reduce suffering must act decisively.
February 18, 2026
Press Release
OUCH-Int’l Supports Lawsuit Filings Against EPA
Rescinding the Endangerment Finding puts lives, livelihoods, our communities, and our health at risk
Madison, WI – Broadly-based coalitions of health and environmental groups have filed separate lawsuits against the EPA contesting the current administration’s repeal of the 2009 Endangerment Finding. The decision by EPA will leave every American at risk of more climate chaos, more disease, illness, and premature death connected to climate pollution. These health risks include the devasting impact climate change has on cancer care. Air pollution, a warming planet, and climate change all contribute to increasing cancer incidence, and have major impacts on cancer outcomes. We are bitterly disappointed that the EPA has chosen to rescind the Endangerment Finding without any input from oncologists and other cancer care providers.
Scientific and medical evidence shows that air pollution is a proven cause of cancer, and that climate change is increasingly worsening cancer risk, survival, and access to care. Allowing additional greenhouse gas emissions will lock in more dangerous warming and air pollution, driving higher cancer burdens and deeper disruptions to cancer care for our children and grandchildren for generations. Dr. Joan H. Schiller, MD, OUCH Int’l Steering Committee Chair and co-founder.
In 2009, the EPA found that carbon pollution, methane, and four other climate pollutants endanger public health, a finding endorsed by both the Supreme Court and by Congress in the Clean Air Act. By claiming climate change – and the pollution that causes it – pose no threat to public health or the environment, the administration is defying mountains of scientific evidence produced in thousands of studies demonstrating how climate change, fueled by climate pollution, is causing devastating impacts on people’s lives. “We are at a crossroads. The effect of climate on cancer care is undeniable. Any stance or policy that undermines this reality will nullify any notion that makes “America great” or even a respected participant.” Dr. Edward P. Balaban, DO, FACP, FASCO, OUCH-Intl Steering Committee Member.
As physicians and health care providers, we have a moral obligation to protect our patients from preventable diseases. This is particularly true when it comes to cancer—a disease responsible for about a quarter of all death each year in the United States. As cancer doctors, we have seen the pain and suffering that so many patients go through, and it is inconceivable to us that anyone with the ability to reduce this suffering would not do everything possible to prevent it. This will require multiple modalities of action. Lawsuits are one means. State legislative actions, such as those being taken by Colorado, California, and Virginia, are another. OUCH-Int’l applauds the initiative and sense of public responsibility shown by these initiatives.
OUCH-Int’l believes that the best course of action is for EPA to reconsider its rescinding of the Endangerment Finding. Absent that unlikely event, we support these and other efforts to mitigate the impact of this tragic ruling.
About OUCH International
OUCH-Int’l is the only international non-profit, nonpartisan organization focused on mitigating the effects of climate change on cancer care. Every day, we see living proof that cancer touches everyone. We aspire to use our unique voice as oncology health professionals and cancer experts dedicated to the care of our patients to raise awareness about the effects of climate change on cancer outcomes and galvanizing decision makers at all levels to act on climate change.
ABOUT THE ENDANGERMENT FINDING
The Clean Air Act requires the U.S. Environmental Protection Agency to protect people from “any air pollutant from any class or classes of new motor vehicles or new motor vehicle engines” that the agency deems “causes or contributes to air pollution that may reasonably be anticipated to endanger public health or welfare.”
In the 2007 landmark U.S. Supreme Court decision Massachusetts vs. EPA, the court found that carbon pollution and other climate-warming pollutants (greenhouse gases) are “air pollutants” as defined by the Clean Air Act. The court directed the EPA to make a final scientific determination whether emissions of these pollutants from new motor vehicles endanger health or welfare.
In 2009, the EPA determined that carbon dioxide, methane, and four other climate pollutants do endanger public health, and that emissions from cars and trucks contribute to that danger. Over the years, EPA has repeatedly reaffirmed that greenhouse gas emissions endanger the public and that pollution from power plants, oil and gas operations, and other sources contribute to that danger. The EPA's Endangerment Finding was challenged in court by big oil and gas companies, fossil fuel producers, radical right-wing front groups like the Competitive Enterprise Institute, and red-state political figures. The D.C. Circuit of Appeals upheld the finding based on the overwhelming scientific evidence supporting it. The Supreme Court denied an additional review.
Later Supreme Court decisions have limited the scope of some of EPA’s climate protections. But none of those decisions undermined the original basis for the Endangerment Finding and the EPA’s duty to act under the law.
February 12, 2026
Press Release
Cancer Experts: Climate Denial Endangers Us All
Rescinding the Endangerment Finding puts lives, livelihoods, our communities, and our health at risk
Madison, WI – The administration has finalized its decision to make climate denial official U.S. policy, moving forward with a scheme that will leave every American at risk of more climate chaos, more disease, illness, and premature death connected to climate pollution.
“Climate change and its impact on human health is beyond any doubt. Any policy that refuses to acknowledge this reality is a policy that will doom us all for generations to come.” Dr. Joan H. Schiller, MD, OUCH Int’l Steering Committee Chair and co-founder.
By rescinding EPA’s Endangerment Finding, which eliminates EPA’s requirement to protect people from the pollution that causes climate change the administration is abandoning it’s obligation to protect people's health and the environment.
In 2009, the EPA found that carbon pollution, methane, and four other climate pollutants endanger public health, a finding endorsed by both the Supreme Court and by Congress in the Clean Air Act. By reversing this finding, the administration ignores thousands of scientific studies demonstrating how climate change, fueled by climate pollution, is causing devastating impacts on people’s lives, is increasing cancer rates, and is impairing the success of cancer treatment.
These health risks include the devastating impact climate change has on cancer care. Air pollution, a warming planet, and climate change all contribute to increasing cancer incidence and have major impacts on cancer treatments, outcomes, and access to care. We are bitterly disappointed that the EPA has chosen to rescind the Endangerment Finding without any input from medical oncologists.
As physicians and health care providers, we have a moral obligation to protect our patients from preventable diseases. This is particularly true when it comes to cancer—a disease responsible for about a quarter of all deaths each year in the United States. As cancer doctors, we have seen the pain and suffering that so many patients go through. It is unacceptable for those in power to neglect opportunities to reduce suffering.
About OUCH International
OUCH-Int’l is the only international non-profit, nonpartisan organization focused on mitigating the effects of climate change on cancer care. Every day, we see living proof that cancer touches everyone. We aspire to use our unique voice as oncology health professionals and cancer experts dedicated to the care of our patients to raise awareness about the effects of climate change on cancer outcomes and galvanizing decision makers at all levels to act on climate change.
ABOUT THE ENDANGERMENT FINDING
The Clean Air Act requires the U.S. Environmental Protection Agency to protect people from “any air pollutant from any class or classes of new motor vehicles or new motor vehicle engines” that the agency deems “causes or contributes to air pollution that may reasonably be anticipated to endanger public health or welfare.”
In the 2007 landmark U.S. Supreme Court decision Massachusetts vs. EPA, the court found that carbon pollution and other climate-warming pollutants (greenhouse gases) are “air pollutants” as defined by the Clean Air Act. The court directed the EPA to make a final scientific determination whether emissions of these pollutants from new motor vehicles endanger health or welfare.
In 2009, the EPA determined that carbon dioxide, methane, and four other climate pollutants endanger public health, and that emissions from cars and trucks contribute to that danger. Over the years, EPA has repeatedly reaffirmed that greenhouse gas emissions endanger the public and that pollution from power plants, oil and gas operations, and other sources contribute to that danger. The EPA's Endangerment Finding was challenged in court by big oil and gas companies, fossil fuel producers, radical right-wing front groups like the Competitive Enterprise Institute, and red-state political figures. The D.C. Circuit of Appeals upheld the finding based on the overwhelming scientific evidence supporting it. The Supreme Court denied an additional review.
Later Supreme Court decisions have limited the scope of some of EPA’s climate protections. But none of those decisions undermined the original basis for the Endangerment Finding and the EPA’s duty to act under the law.