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Letter to Department of Energy on Fake Climate Science Report

Download the full 10 page comment here

Secretary Christopher Wright
U.S. Department of Energy
1000 Independence Ave. S.W.
Washington, D.C. 20585-0270

Members of the Climate Working Group
U.S. Department of Energy
1000 Independence Ave. S.W.
Washington, D.C. 20585-0270

Re: Technical Comment Response to the U.S. Department of Energy’s Climate Working Group Report Titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate”; Docket No. DOE-HQ-2025-0207

Dear Secretary Christopher Wright and Members of the Climate Working Group,

On behalf of Public Citizen, a consumer advocacy organization with over 500,000 members and supporters nationwide, we appreciate the opportunity to respond to the Department of Energy’s (DOE) request for comment on the report “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate” disseminated by the Climate Working Group (CWG) on July 29 2025. The report is a blatant disregard of the virtually unanimous scientific consensus of climate change. It props up the minority, contrarian view of climate science while simultaneously stating misleading and false claims and did not follow several federal administrative processes during the drafting and dissemination of the report. We ask that you withdraw it.

The Department of Energy, as a science-based agency, has a legal requirement to follow the science, yet this report contains both considerable misleading and false scientific findings and legal vulnerabilities. In addition to withdrawing the report, we recommend no further action to conduct a scientific review of the impacts of greenhouse gas emissions in the U.S. until DOE can appoint additional climate scientists to the agency’s climate working group, and until DOE agrees to conduct a scientific assessment that includes robust public engagement and participation.

While the purpose of this DOE report is to seemingly review the “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,” and is written for non-technical audiences, the report’s scientific findings and evidence have been found to be misleading and false. Overall, the report casts doubt on the scientific consensus of climate change and is designed to provide the scientific underpinning and justification for the Trump administration to repeal the 2009 EPA endangerment finding — a finding that serves as the legal prerequisite for federal climate emissions regulation. This report is a contrarian view to the 97 to 99.9% scientific consensus of climate change and highlights the Trump administration’s focus on climate denialism. This report poses a grave danger to the U.S. government’s ability to protect public health and welfare by reducing climate warming greenhouse gas emissions.

It is notable that the report is “intended to be accessible to non-experts.” Unfortunately, the authors’ lop-sided and contrarian views make it difficult for any non-technical individual to understand the miscontextualized and false scientific statements. It is an important part of scientific review of federal documents to have a scientific view and robust public engagement, but this document does neither. Ultimately, the DOE report could — and likely has — lead to the perpetuation of mis- and dis-information of climate science among the public.

Below is an overview of the main scientific and legal concerns we have with the report. The below comments include:

  1. Reiterating the 97 to 99.9% “virtually unanimous” scientific consensus among climate scientists and the need for the U.S. government to address greenhouse gas emissions to avoid warming of more than 1.5 to 2 degrees Celsius;
  2. Supporting the scientific community’s response to the DOE CWG report, and;
  3. Supporting Christopher H. Frey, Ph.D.’s request for correction and recommending DOE CWG withdraw the report.

You can read the full comment letter here.

Meghan Pazik
Senior Policy Advocate
mpazik@citizen.org