Comments on DoE’s Notice of Availability: A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate, 2025-14519 (90 FR 36150); Docket No. DOE-HQ-2025-0207
Government Accountability & Oversight
SUMMARY OF COMMENTS:
COMMENT 1: This Review is essential because it introduces into the official government record some semblance of the balance which exists in the observational and publication records but which was excluded from previous consideration by the agency. Balance is generally downplayed or excluded outright from higher-profile compendia whose content is dictated by parties whose livelihoods, revenues and business models depend on a crisis narrative. Immediately upon the Department announcing this Review, the individuals and institutions comprising the scientific establishment revealed their objective to discredit the Review. Many of those same individuals and institutions responsible for the distorted picture of observational data that dominates climate policy and legal discourse participate in litigation campaigns both attempting to impose a policy agenda and seeking hundreds of billions of dollars in disgorged revenues from the energy industry. The success of these campaigns hinges on a climate-crisis narrative, and the “disgorged” proceeds these ideological actors seek most certainly would go in part to furthering the climate industry of which these individuals and institutions are a part. The Department should consider this enormous conflict of interest when evaluating the record.
Additionally, the scientific establishment gunning for this Review has a history of targeting “dissenting” arguments, assertions, and even mere information for discredit, and even the individuals and institutions associated with such dissenting views. Coincidentally, this same establishment has a history of being wrong seemingly without parallel in any other context, profession, or discipline.
COMMENT 2: “U.S. policy actions are expected to have undetectably small direct impacts on the global climate and any effects [NB: again, while not expected to be detectable] will emerge only with long delays” (Review, at p. ix); “Thus, in contrast with conventional air pollution control, even drastic local actions will have negligible local effects, and only with a long delay. The practice of referring to unilateral U.S. reductions as “combatting climate change” or “taking action on climate” on the assumption we can stop climate change therefore reflects a profound misunderstanding of the scale of the issue.” Id., at 129; “Consequently, in contrast to the case of local air contaminants like particulates and ozone, even the most aggressive regulatory actions on GHG emissions from U.S. vehicles cannot be expected to remediate alleged climate dangers to the U.S. public on any measurable scale.” Id. at 130.
The absence to date of clarity and emphasis on this point has enabled jurisprudence arguing, in short, “the evidence shows ‘we must do “something”’; regulating (this or that sector’s GHG emissions) is ‘something’; therefore, we must do that.” See generally, Massachusetts v. EPA, 549 U.S. 497, 127 S Ct. 1438 (2007), and Id. 127 S Ct. at 1458. This in turn has led to profound regulatory and economic costs, distortions and dislocation. It is therefore difficult to overstate the importance of the Review placing that critical point in perspective: there is no projected detectable climate impact (let alone benefit) from “climate” policies (i.e., all-pain-no-gain).
You can read the entire comments here.