Comment on the DOE Climate Change Report

The U.S. Department of Energy recently issued a ‘Notice of Availability’ of a major report titled A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate. (Federal Register, Department of Energy, Docket No. DOE-HQ-2025-0207)

This is not a proposed rule—it’s a public announcement requesting comments on this new report, which could be used to justify reversing the EPA’s fundamental endangerment finding, the legal foundation for all U.S. climate regulation. Submitting comments now is crucial to ensure the public record reflects opposition to any attempt to undermine this cornerstone of environmental protection.

The below three sections include information on the Notice, the Report and a Sample Comment you can use to tailor as your own comment.

1. Notice of Availability
Read the Notice and Comment on the Report here: Federal Register Notice of Availability (click on the Green Submit a Public Comment in the top right).

2. Report
Background
The draft report titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate” was developed by DOE's 2025 Climate Working Group, a group of five independent scientists assembled by Energy Secretary Chris Wright with diverse expertise in physical science, academic research and climate science. The landing page for the CWG Report, including a press release, can be found here: www.energy.gov/​topics/​climate.

Executive Summary of the CWG Report
The report reviews scientific certainties and uncertainties in how anthropogenic carbon dioxide (CO2) and other greenhouse gas emissions have affected, or will affect, the Nation's climate, extreme weather events, and selected metrics of societal well-being. Those emissions are increasing the concentration of CO2 in the atmosphere through a complex and variable carbon cycle, where some portion of the additional CO2 persists in the atmosphere for centuries.

Elevated concentrations of CO2 directly enhance plant growth, globally contributing to “greening” the planet and increasing agricultural productivity. They also make the oceans less alkaline (lower the pH). That is possibly detrimental to coral reefs, although the recent rebound of the Great Barrier Reef suggests otherwise.

Carbon dioxide also acts as a greenhouse gas, exerting a warming influence on climate and weather. Climate change projections require scenarios of future emissions. There is evidence that scenarios widely-used in the impacts literature have overstated observed and likely future emission trends.

The world's several dozen global climate models offer little guidance on how much the climate responds to elevated CO2, with the average surface warming under a doubling of the CO2 concentration ranging from 1.8° C to 5.7° C. Data-driven methods yield a lower and narrower range. Global climate models generally run “hot” in their description of the climate of the past few decades. The combination of overly sensitive models and implausible extreme scenarios for future emissions yields exaggerated projections of future warming.

Most extreme weather events in the U.S. do not show long-term trends. Claims of increased frequency or intensity of hurricanes, tornadoes, floods, and droughts are not supported by U.S. historical data. Additionally, forest management practices are often overlooked in assessing changes in wildfire activity. Global sea level has risen approximately 8 inches since 1900, but there are significant regional variations driven primarily by local land subsidence; U.S. tide gauge measurements in aggregate show no obvious acceleration in sea level rise beyond the historical average rate.

Attribution of climate change or extreme weather events to human CO2 emissions is challenged by natural climate variability, data limitations, and inherent model deficiencies. Moreover, solar activity's contribution to the late 20th century warming might be underestimated.

Both models and experience suggest that CO2 -induced warming might be less damaging economically than commonly believed, and excessively aggressive mitigation policies could prove more detrimental than beneficial. Social Cost of Carbon estimates, which attempt to quantify the economic damage of CO2 emissions, are highly sensitive to their underlying assumptions and so provide limited independent information.

U.S. policy actions are expected to have undetectably small direct impacts on the global climate and any effects will emerge only with long delays.

Read the Full Report here:  A Critical Review of Impacts of Greenhouse Gas Emissions on the US Climate.  

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3. Comment Template:
Below is a comment for the GHG report - you are welcome to copy and paste it as is, but I recommend adding your own words, in terms of why this matters to you or other arguments you might have that aren't included below, as this adds depth in addition to volume.

Also tote that the comment below is pretty high level, focused on addressing the summary points from the Executive Summary. It is does not delve deeply into the science as other comments might.

Here's the link to the Public Comment page.

I appreciate DOE’s decision to solicit public comment on the CWG draft report. The following technical points respond to specific claims in the report, using the most recent authoritative data to ensure that U.S. policy is grounded in accurate climate science.

1. Climate Sensitivity Range (CWG Report: Overview paragraph on doubling CO₂ — 1.8°C to 5.7°C)
While estimates vary, multiple independent lines of evidence — paleoclimate records, observed historical warming, and modern Earth system models — converge on a likely range of 2.5–4°C per CO₂ doubling (IPCC AR6 WG1, 2021). Lower estimates (<2°C) are now considered extremely low likelihood, and we are blowing past 1.5°C as we speak.

2. Extreme Weather Trends (CWG Report: “Most extreme weather events… do not show long-term trends”)
This statement is incomplete. Certain events (e.g., U.S. tornado counts) lack clear trends, but heatwaves, heavy precipitation, and extreme rainfall have increased significantly since the mid-20th century (NOAA, 2017; IPCC AR6, 2021), with direct consequences for health, infrastructure, and agriculture.

3. Sea Level Rise (CWG Report: “No obvious acceleration in U.S. tide gauge measurements”)
Global mean sea level is now rising ~4.5 mm/year — more than double the 20th-century average — with clear acceleration since the 1990s (NOAA, 2022). Tide gauges in many U.S. coastal locations confirm this trend, even after accounting for vertical land motion. Ignoring acceleration risks underestimating flooding hazards for coastal communities.

4. Ocean Acidification (CWG Report: “Possibly detrimental… rebound of Great Barrier Reef suggests otherwise”)
The cited “rebound” of parts of the Great Barrier Reef is a short-term recovery of coral cover, driven by a period of reduced bleaching events and fast-growing species. This does not negate the well-documented, ongoing global trend of coral decline linked to warming and acidification (Hughes et al., Nature, 2023). Local rebounds cannot be extrapolated to a global or long-term recovery.

5. Attribution & Natural Variability (CWG Report: “Challenged by natural variability”)
While natural variability influences year-to-year and decadal fluctuations, multiple attribution studies using independent methods show that over 100% of the observed warming since 1970 is attributable to human greenhouse gas emissions, with natural factors having a net cooling or neutral effect over this period (NOAA, IPCC AR6).

6. U.S. Policy Impact & Global Cooperation (CWG Report: “Undetectably small direct impacts”)
This framing is misleading. While U.S. emissions reductions alone will not stabilize global temperature, the U.S. remains the world’s largest historical emitter and the second-largest current emitter. As in other areas of global security (nuclear non-proliferation, infectious disease control), leadership from major powers like the US is essential to catalyze collective action. 

7. Risk Framing
The report’s comparison of potential climate damages with potential costs of mitigation underplays systemic and non-linear risks (e.g., crop failures, supply chain disruptions, climate migration). These “tail risks” — though lower probability — carry catastrophic potential.

Historically, the U.S. has acted decisively against such risks: during the Cold War, even a 1% chance of nuclear exchange justified massive investments in deterrence and diplomacy. Climate change poses a similar low-probability/high-impact threat profile, except that its probability is much higher and its effects cumulative. Applying the same precautionary principle here is both rational and consistent with past U.S. policy precedent.

Conclusion:
The CWG report raises important points about uncertainties but selectively emphasizes findings that downplay risk. The full weight of evidence demonstrates significant observed impacts, accelerating trends, and credible high-end risks.

To ensure not only the survival of our country and our people, but also that of the human species, we must commit to sustained investment in both mitigation and adaptation, coordinated on an international scale.

Failing to act with the same urgency we have applied to other impending disasters would be willful self-sabotage at best — and, at worst, could qualify the United States for crimes against humanity or even contribute to the end of our species.

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