The comment period for a sham “climate science” report commissioned by the US Department of Energy closed earlier this week and the verdict is in: the scientific community has overwhelmingly and resoundingly rejected the report. In addition to its deeply flawed content, which is rife with inaccuracies and disinformation aimed at downplaying the risks of climate change, many have also called out the shoddy, secretive, and potentially unlawful process used to draft it.
My colleagues and I submitted comments on the report, on behalf of the Union of Concerned Scientists (UCS). And, together with the Environmental Defense Fund, UCS has also filed a lawsuit challenging the Trump administration’s secretive and biased process for drafting this report, which does not meet the requirements of the Federal Advisory Committee Act (FACA).
Even more problematic, the US Environmental Protection Agency (EPA) is using this fatally flawed report as a basis for undoing the 2009 Endangerment Finding, a science-based finding establishing that heat-trapping emissions driving climate change are harmful to human health and well-being. That finding also sets EPA’s authority and obligation to regulate global warming pollution from power plants, vehicles and other sources—which is why undermining it is so deeply harmful for efforts to address the climate crisis.
Key points from UCS comments on DOE report
UCS’s comments made four key points:
- The DOE report perpetuates outright falsehoods. These include complete misrepresentations of Dr. Ben Santer’s climate fingerprinting research (full disclosure, Dr. Santer is a UCS Board member); incorrect citation of data related to sea ice to imply Arctic sea ice has declined by 5% since 1980, when in fact it has decreased by ~40%; and an incorrect statement that the area burned by wildfires in the U.S. has not increased since 2007 when in fact the 10-year average burn rate was approximately 5.86 million acres in 2007 and in 2024, it increased to about 7 million acres.
- The DOE report cherry-picks text, data, and studies that paint an incomplete picture. For example, the report selectively chooses five tidal gauges and vertical land motion measurements to suggest rising sea-levels in the US are only due to land-sinking, ignoring satellite altimetry observations that clearly show the acceleration of sea-level rise due to thermal expansion of oceans and the melting of land-based ice which are linked to climate change. These findings are clear from the Intergovernmental Panel on Climate Change (IPCC’s) Sixth assessment report and from the U.S. Fifth National Climate Assessment.
- The DOE report employs deceptive framing to downplay climate change harms. As one example of this: The report focuses on absolute numbers of heat vs. cold mortalities, despite risks from heat-related mortalities rapidly rising due to climate change, and the fact that adaptation measures like air-conditioning have clear limitations.
- The DOE report was drafted via an improper process. DOE Secretary Wright hand-picked five known climate contrarians to form a Climate Working Group (CWG) that convened secretly and without any public transparency of their work to draft a report that was designed to deliver a biased outcome. Under FACA, Congress mandated transparency in the establishment and operation of any federal advisory committee, including by requiring that the group’s formation be promptly disclosed and that its meetings, emails, and other records be open to the public. Meanwhile, the very existence of the CWG was not revealed until months into its work and there were no public meetings or records of its work.
As a result of these (and additional) significant flaws in content and process, in our comments we call for the DOE to withdraw this report. We also oppose its use to inform any agency rulemakings, including the EPA’s efforts to repeal the Endangerment Finding. If the DOE and the EPA are genuinely interested in an assessment of the latest climate science, they should turn to credible and trustworthy scientific sources such as the U.S. National Climate Assessments and the reports of the IPCC. The National Academy of Sciences has also launched a fast-track report on the latest climate science that is forthcoming. Finally, we urge the Trump administration to stop its broadside assaults on science and science-based policymaking.
Scientific facts should inform policy
UCS is one of many groups, including a group of 85 scientists and a group of 20+ senior national security leaders, that have called out the significant shortcomings in this report. We are alarmed to see climate science denial and disinformation in an official US government document. In many cases, this echoes long-debunked talking points from the fossil fuel industry.
People across the United States deserve and need better from our government. The evidence of the climate crisis is acutely obvious around us—including through climate-fueled extreme weather, accelerating sea level rise, and threats to lives, livelihoods and ecosystems. To deny that is cruel, contrary to climate justice, and a shameful abdication of responsibility. We need solutions, not further lies and attempts to delay action. The overwhelming benefits of a rapid transition to clean energy and to a more climate-resilient world are staring us in the face.
The EPA is still taking comment on its proposed repeal of the Endangerment Finding through September 22. Please add your voice urging EPA Administrator Zeldin to uphold scientific facts and do what’s right and necessary to safeguard our health and the health of generations to come.