Comment from Our Children's Trust.org

Comment for DOI Regulatory Reform RFI - Request for Information (Docket No. DOI-2025-0005) Dear Secretary Burgum, On behalf of all of our youth clients, including our clients in Lighthiser v. Trump and Genesis v. EPA, and on behalf of America’s children and youth, Our Children’s Trust provides these comments on the Department of Interior’s (“DOI”) “Regulatory Reform-Request for Information” which aims to support the DOI’s implementation of the President’s Executive Orders including EO 14154, “Unleashing American Energy.” Any regulatory reform that modifies or repeals regulations, guidance, and reporting requirements to accelerate fossil fuel development worsens the adverse health effects of fossil fuel pollution our clients are currently suffering directly through their inhalation and exposure to the localized pollution and the heat-trapping greenhouse gases from fossil fuels, resulting in further dangerous disruptions of the climate system on which these youths’ health and lives depend. As the Nation’s only law firm dedicated to representing children and youth whose constitutional rights are being infringed by government conduct that causes and contributes to climate change, we write to advise you that your rulemaking must be consistent with protecting the rights to life, personal security, other liberties of young people, and children’s equal protection of the law. U.S. Const. amend. V, XIV, § 1. Here, as we have demonstrated at the September 16-17, 2025 evidentiary hearing in Lighthiser v. Trump, you are engaged in an unconstitutional agency action to implement the President’s Executive Orders 14154, 14156, and 14261, in violation of U.S. Const. amend. V, XIV, § 1. Your multiplicity of actions pursuant to those Executive Orders, including this regulatory reform effort, also violate the separation of powers, by exceeding the authority DOI has been delegated by Congress and by engaging in conduct that has a significant effect on U.S. public health, welfare and the economy, while lacking any scientific integrity as Congress has mandated. DOI has no statutory authority to deprive children and youth of their fundamental rights to life, personal security, family autonomy, bodily integrity, the practice and transmission of cultural and religious traditions, and children’s equal protection of the law. U.S. Const. amend. V, XIV, § 1. PLEASE SEE THE ATTACHED COMMENT. Sincerely, /s/ Julia Olson Co-executive Director and Chief Legal Counsel julia@ourchildrenstrust.org Our Children’s Trust P.O. Box 5181 Eugene, OR 97405