On July 29, 2025, the Department of Energy (DOE) published a report from its Climate Working Group (CWG). This report features prominently in the EPA's reconsideration of its 2009 Endangerment Finding. In response, over 85 scientists have come together to write a comprehensive review, which is being submitted to the DOE, EPA, and National Academy review.
Our review reveals that the DOE report's key assertions—including claims of no trends in extreme weather and the supposed broad benefits of carbon dioxide—are either misleading or fundamentally incorrect. The authors reached these flawed conclusions through selective filtering of evidence ('cherry picking'), overemphasis of uncertainties, misquoting peer-reviewed research, and a general dismissal of the vast majority of decades of peer-reviewed research.
No one should doubt that human-caused climate change is real, is already producing potentially dangerous impacts, and that humanity is on track for a geologically enormous amount of warming. No one knows what socioeconomic impacts of this warming will be. It should also be clear that the DOE report's approach to undermining scientific evidence mirrors tactics previously employed by the tobacco industry to create artificial doubt.
Though our review doesn't explicitly address the EPA's 2009 Endangerment Finding, the process of compiling our response made one thing clear: in the 16 years since that finding, evidence of human-caused climate change and its threats to public health and welfare has only strengthened.
Instead of relying on this report, the DOE should instead use the thoroughly vetted assessments from the Intergovernmental Panel on Climate Change and National Climate Assessment, which offer more accurate representations of our scientific understanding of climate change.
This report is posted on the ESS Open Archive pre-print server and can be cited as:
Dessler, A.E. and R.E. Kopp (Ed.). (2025). Climate Experts’ Review of the DOE Climate Working Group Report. DOI: 10.22541/essoar.175745244.41950365/v2
Individual sections may be referenced as, for example:
D.S. Nolan, D. Chavas, K. Emanuel, A.J. Garner. (2025). Comment on the DOE CWG report, Section 6.2: Hurricanes and Tropical Cyclones. In A.E. Dessler and R.E. Kopp (Ed.), Climate Experts’ Review of the DOE Climate Working Group Report (pp. 162-173). DOI: 10.22541/essoar.175745244.41950365/v2
Comment submitted to the EPA. This is largely identical to the comment submitted to the DOE although it has had some typos corrected and minor clarifications added. This document includes both the cover letter for the EPA submission as well as the cover letter for the DOE submission. [the ESSOAR website has been having trouble, so if that link doesn't work, here is a mirror site]
Comment submitted to the DOE. This file is the latest version; it has had several errors corrected since we submitted to the DOE comment portal. This document lists those changes.
Review of the science of the Endangerment Finding by the National Academies. They conclude that the "EPA's 2009 finding was accurate, has stood the test of time, and is now reinforced by even stronger evidence."
Expert review by health professionals. They conclude that CO2 emissions "pose a clear and indisputable danger to human health and well-being."
Comments from the Environmental Protection Network. They conclude "The [DOE] Report provides a biased, incomplete, misleading and inaccurate characterization of climate science."
Comments from the Attorneys General of Massachusetts et al. on the EPA's rollback of the endangerment finding
The Climate Brink:
Kerry Emanuel at realclimate.org
News report: DOE Climate Working Group disbanded