Home/BlogThe comment portal at the Federal Register is now open for comments relating to our DOE report. If you think we weren’t alarmist enough, post your comment and explain why. If you think we were too alarmist, post your comment and explain why. I believe the comment period is open for 30 days.
Well, I get this message:
We’re sorry, an error has occurred
The feature you are attempting to access is currently unavailable.
Same here.
Well I get the link.
Thanks for the link. Comment submitted to Federal Register.
I just went to the portal and posted my two comments from the previous thread.
I tried to read the Federal Register cooments. The link is “unavailable”.
Not for me. I get the link.
When it comes to government sites, I have had issues access outside of the Country and/or not using a particular browser. I tried the link and it works for me using Firefox from Georgia USA.
My bad, I can’t see comments early. Says… The feature you are attempting to access is currently unavailable.
For your consideration:
https://www.theclimatebrink.com/p/how-the-doe-and-epa-used-and-misused
And
https://www.eenews.net/articles/doe-reframes-climate-consensus-as-a-debate/
https://bsky.app/profile/richardtol.bsky.social/post/3lvbowurbe222
https://www.wired.com/story/scientists-say-new-government-climate-report-twists-their-work/
https://richardtol.substack.com/p/is-climate-change-dangerous
https://www.science.org/content/article/contrarian-climate-assessment-u-s-government-draws-swift-pushback
From a RB post by a friend.
List of scientists who so far say the report cites but misrepresents their work. No doubt there will be more, I’ll update this as required. Please add any you find as a comment.
. “The DoE published a scientific report in support of the EPA’s legal argument. I am cited 3 times, incorrectly all three times. I am not the only one, as reported by Science and Wired.”
(I also liked this quote ‘If President Obama had asked me to write his Endangerment Finding I would have given him two words: “well duh”.)
. The report cites his paper on climate model performance, which fundamentally found they perform well, but cherry-picks a single, fairly irrelevant figure from the SI.
“They appear to have discarded the whole paper as not fitting their narrative, and instead picked a single figure that was in the supplementary materials to cast doubt on models, when the whole paper actually confirmed how well they have performed in the years after they were published,”
Hausfather says this is representative of the authors approach : “cherry-pick data points that suit their narrative”. He has previously said the EPA’s interpretation of his work got it “completely backwards” which seems relevant.
. Internationally recognized evolutionary plant biologist. The report cites her work in the section promoting CO2-induced ‘greening’. However she claims the authors neglected that the work was conducted under “highly controlled growth conditions” and the report omits other confounding factors,
“With rising CO2 in natural ecosystems, plants may experience higher heat loads, extreme weather events such as droughts and floods, and reduced pollinators—which can have severe net negative effects on plant growth and crop yields,” she says. “Furthermore, our studies indicate that major disruptions in plant development such as flowering time can occur in direct response to rising CO2, which were not mentioned in the report.”
“” ‑ Assistant Professor, Department of Earth and Space Sciences & Astrobiology Program at UW (Seattle). The report cites his work to support its claim that ‘“the recent decline in [ocean] pH is within the range of natural variability on millennial time scales’. But Josh points out ‘“The much more gradual changes in ocean pH we observe on geologic timescales were typically not accompanied by the rapid changes in carbonate saturation that human CO2 emissions are causing, and so the former are not useful analogs for assessing the impact of ocean acidification on the modern marine biosphere”
, a climate scientist at Rutgers University, claims the report misrepresents his sea level research by cherry-picking a single tide gauge.
Kristie Ebi and Micahael Allen have both posted on BlueSky to say they have also been misrepresented, without so far giving details. Professor Richard Tol amusingly also claims ‘They even got Ross McKitrick’s research wrong.’
I’d love that to be true.
Quote : “The much more gradual changes in ocean pH we observe on geologic timescales were typically not accompanied by the rapid changes in carbonate saturation that human CO2 emissions are causing.”
The proxies used in those researches simply don’t have the required bandwidth to say that.
First Step – Pure Denial
I get the page to post comments.
https://www.federalregister.gov/documents/2025/08/01/2025-14519/notice-of-availability-a-critical-review-of-impacts-of-greenhouse-gas-emissions-on-the-us-climate
But not the page to view comments. Given the very short address, I think it may be a bad link. I tried with 2 different browsers:
https://www.regulations.gov/service-down
We’re sorry, an error has occurred
The feature you are attempting to access is currently unavailabl
Link in the post woks for me.
The link to view comments is now updated to this:
https://www.regulations.gov/document/DOE-HQ-2025-0207-0001/comment
But in then crashes and goes here. I think “service-down” is the explanation:
https://www.regulations.gov/service-down
Goes to here for me. https://www.regulations.gov/document/DOE-HQ-2025-0207-0001/comment
No crash.
I wonder if the radical environmental NGO’s have launched a DNS attack on the government websites? When the Endangerment Finding is rescinded, their charitable fund donations will rapidly decline and they all will go bust.
” I wonder if the radical environmental NGO’s have launched a DNS attack on the government websites? ”
And I wouldn’t be surprised if you were paranoid.
My comment will be on sea level rise. Melting glaciers, ok. but back radiation? I don’t see it.
I have yet to see a calculation on evaporation vs radiative forcing using first principles, so I made one on X since that is right in my wheelhouse of what I do at work. This isn’t new science. If you doubled CO2, radiative forcing would increase 3 W/m², back radiation imparted on the sea surface would increase to 5 W/m². SST would only need to increase 0.2°C so that the combined emission from the SS and evaporative increase would balance the increase in downwelling. To arrive at this, I assumed a characteristic length and average wind velocity and fixed relative humidity. Most of this heat gets rejected during ENSO cycles as the ocean turns over. There would be little change in the bulk temperature.
” Melting glaciers, ok. but back radiation? ”
Why to speak about the minuscule back radiation?
Why not to speak about rising sea temperatures instead, which not only
– are the main cause of glacier melting (ice melts from the bottom and not at the surface)
but also
– contribute to rising sea levels because warmer oceans need more volume than colder ones?
https://oz4caster.wordpress.com/wp-content/uploads/2025/01/fig10-ncar-nh-sh-rmsat-1948-2024.gif
Thermal expansion from warmer oceans causes seal level increase. That is trivial. CO2 doubling can’t cause the oceans to warm. My calculation shows that CO2 doubling would only contribute to a 0.2°C increase in SST. The bulk temperature of the ocean would increase much less than that as most of the Sea Surface turns over every 5 to 7 years.
sam shicks
” My calculation shows… ”
YOUR calculation?
What exactly are your scientific / technical skills?
Engineer. Qualified heat transfer specialist. I think that qualifies me to calculate atmospheric heat transfer. We figured this stuff out long before climate scientists came around and tried to reinvent the wheel.
Oh oh oh, an engineer. I’m one too, Sah.
Please show us your detailed calculation.
Just because you are an engineer doesn’t mean you can do heat transfer. I’m in an exclusive club. Few have reached my level.
Sam
Your results bear no resemblance to observed and measured reality.
You have probably made the usual errors that happen when an expert in one field tries to operate outside his field.
Please make your working accessible so that we can critique it properly.
Ent, Sam specifically said “CO2 doubling would only contribute to a 0.2°C increase in SST.
You believe that is wrong. So the correct thing to do is show why you believe that. IOW, do you have ANY science to go along with your beliefs?
Not going to play head games with you. Here is a homework problem for you. If downwelling increased by 3.2 W/m² which caused SST to increase and the air temperature above the SST to increase. Assuming constant relative humidity and convection remained unchanged for simplicity, how much would the SST need to increase in order to balance the energy at the SST?
Assume 7 mph wind and turbulent boundary layer.
“I have yet to see a calculation”
Second Step – Sammich Request
Have you ever calculated the evaporation rate off a spent fuel pool under loss of cooling scenario? I use the mass transfer method. This method is grounded in the physics of mass transport and can be and adaptable to flow regime and environmental variables.
If you believe we achieved 2.5 W/m² of radiative forcing and treated the atmosphere as a single layer grey model, downwelling will have increased 4.2 W/m² after the atmosphere heated up. Absent any other feedbacks and assuming no clouds or water surface, the average earth surface would have heated up 0.76K and the atmosphere would have heated up 0.64K. The total increase in GHE would be 2.5 W/m². This comes from the basic procedure provided by Daniel Jacob.
Since there is water, we need to calculate what the increase in SST would be with the additional back radiation of 4.2 W/m². We only need to be concerned with what changed and that is back radiation. While it doesn’t penetrate the SS, it does get added in the surface energy balance. This is implicitly solved with a few assumptions.
1. The increase in air temperature equals that of the sea surface increase
2. The RH of the air remains constant. This is conservative (provides a lower bounding limit of evaporation rate) as it limits evaporation (vapor pressure deficit) to just that given by the expansion of air at higher temperatures.
3. Constant wind velocity. Again conservative. Thus, we can ignore convection.
Taking credit for increase long wave emission at higher SST and taking credit for an increase in evaporative heat loss from the SST due to evaporation.
The mass transfer method, also known as the aerodynamic or Dalton-type method, estimates evaporation as a process of vapor transfer from the water surface into the air through diffusion and convection. The fundamental equation for mass transfer can be expressed as:
E = kc × (Cs – Ca)
Where:
• E = Evaporation rate (kg/m²·s)
• kc = Mass transfer coefficient (m/s)
• Cs = Vapor concentration at the water surface (kg/m³)
• Ca = Vapor concentration in the air (kg/m³)
The mass transfer coefficient (kc) is a central parameter and can be estimated using dimensionless numbers that characterize transport phenomena in the system, such as the Schmidt number (Sc) and Sherwood number (Sh).
The result is SST increase of 0.25°C, assumed equal amount of air temperature increase of 0.25°C which produces an increase of 1.503 W/m² of long wave emission and 2.697 W/m² of evaporation.
The key here is that even though I assumed constant RH, a 0.25°C increase in air temperature at fixed RH results in a decrease in the density of the water vapor in the air by 0.000293 kg/m³. This is what drives the increase in evaporation rate.
Third Step – Saying Stuff
A “Red Team” / “Blue Team” exercise has aleady occurred. It led to APS statement on climate change .
Climate Change Statement Review Workshop transcript of proceedings https://share.google/pR3HcPHm53dyRB8f9
Hi Roy,
I think Wim Rost and I found an error in the report fyi.
Page 41:
“Since ocean is less reflective than land, the NH should have higher albedo. Clouds (which are highly reflective) are more common in the NH and so compensate the surface albedo…”
Replace “NH” with “SH”. Clouds are more common in the Southern Hemisphere.
** Looks like you are right, thanks. -Roy
Typos are getting more and more prevalent. I know….
This is clearly caused by CO2. The correlation is obvious:
ΔT = τln(C/Co)
Exact number is obtained from transient CO2 response (TCR) and the long-term equilibrium CO2 sensitivity (ECS), as additional funding is approved.
New atmospheric data shows strong easterly winds descending through the tropical stratosphere, which could bring notable changes to Winter 2025/2026 across the United States, Canada, and Europe. Known as the Quasi-Biannial Oscillation (QBO), this wind pattern shifts direction every 1 to 2 years and can play a major role in shaping seasonal weather patterns.
Past winters with a similar setup have seen a weakened Polar Vortex, leading to colder and snowier conditions across parts of the United States, Canada, and Europe. Fresh forecasts now suggest that Winter 2025/2026 could be influenced in a similar way.
https://www.severe-weather.eu/long-range-2/winter-2025-2026-qbo-stratospheric-polar-vortex-cold-forecast-pattern-united-states-canada-fa/?fbclid=IwY2xjawL_zixleHRuA2FlbQIxMQABHuLLa5inXVF8cEgdxnEw-_-Cmwh5UwZAcQRQJhCUuHk275JJFn_4NIaibO15_aem_vRrn6aXFT5lL_TR_mu-nLQ
Leading scientists told Agence France-Presse (AFP) on Thursday, July 31, that their research, cited in a landmark report from the U.S. Department of Energy, had been misused to minimize the role of human activity in climate change.
This report, published on July 29, sets out the arguments that led the Trump administration to reverse a key 2009 decision regulating greenhouse gas emissions on Tuesday, further undermining the fight against climate change in the United States.
It was written by a working group that included John Christy and Judith Curry, both associated with the Heartland Institute, a lobby group that frequently challenges the scientific consensus on climate change.
The document “completely misrepresents my work,” Benjamin Santer, a climate scientist and honorary professor at the University of East Anglia in the United Kingdom, complained to AFP. He explained that a section of the report devoted to “stratosphere cooling” contradicted his conclusions.
AFP and other media outlets, including the US news website Notus, found inaccurate quotes, flawed analyses, and editorial errors in the report.
This is the third time in 2025 that scientists have complained to AFP that a US government agency misrepresented academic research to justify its decisions. In May, the White House notably moved quickly to amend a report on diseases affecting young Americans, which was initially based on nonexistent scientific studies. “Misinterpretation of numerous studies”
“I am concerned that a government agency has published a report intended to inform the public and guide policy without undergoing a rigorous peer-review process, while misinterpreting numerous studies that have been,” Bor-Ting Jong, assistant professor at the Free University of Amsterdam, told AFP.
She pointed out that the document contained false statements about the climate model studied by her team and used different terminology, which led to misinterpretations of its results.
James Rae, a climate researcher at the University of St Andrews in Scotland, who also denounced the misrepresentation of his work in the US Department of Energy report, told AFP that the change in the administration’s use of science is “truly chilling”; it “has been at the forefront of scientific research for decades.”
Yet his report resembles a student exercise aimed at distorting climate science,” he added.
*
Yeah.
It’s amazing how Trump gets it right, yet has very little science background. Maybe he can just recognize fraud when he sees it.
The thing is, Bindi, REAL science is about reality, not beliefs. For example, not one of your heroes mentioned can explain scientifically how CO2 can “heat the planet”. Specifically, link to where Benjamin Santer, Bor-Ting Jong, or James Rae ever explained the REAL physics behind their CO2 beliefs.
You won’t find it.
Also, you have yet to present a viable model of “orbital motion without spin”.
Here’s a layperson’s view of all this, and when I say layperson, I mean someone who designed and built data analytics platforms for large healthcare companies for 15 years. I have lost faith in scientists. I watched firsthand as big pharma companies distorted the data coming out of our systems to market their products. The handling of the mRNA fiasco was nothing more than a butchery of the truth. I remember seeing professors at a major university lie like thieves to get funding. I strongly believe in the scientific process when applied honestly, but I don’t trust anything most “scientists” say these days. Most of you are no better than the snake oil salesmen of 100+ years ago. But I do trust the scientists behind this report, mainly because they paid a huge price to speak their views of the truth when it would have been so much easier for them just to cave in to the mob.
I love gas and diesel engines, and believe that CO2 helps the planet. We have enough fossil fuel for thousands of years. However, I do hope one day that Commercial Fusion Power is developed and battery technology continues to improve. EV’s would make a lot of sense, and possibly send combustion engines the way of the horse and buggy.
stephen p anderson
What is your source for thousands of years for fossil fuels remain (assuming you are talkong about current levels of sonsumption). The current assesment is about 50 years left for oil and natural gas and a little over 100 years for coal. I certainly would like to see your source material for the thousands of years!??
Wayne Williams
I fully understand and respect what you wrote.
{Except for the paragraph about mRNA, because of the scientifically undeniable successes in the field of cancer, which preceded those with COVID-19 by years.
Furthermore, doubts about mRNA-based vaccines here in Europe are essentially limited to ultra-right groups who are against everything; and I doubt that ALL the anti-vaccine people in the US ALL have actually refused the COVID-19 vaccine.}
*
I come back to what I wrote above:
https://www.drroyspencer.com/2025/08/notice-of-availability-a-critical-review-of-impacts-of-greenhouse-gas-emissions-on-the-u-s-climate/#comment-1710283
*
It’s one thing to correctly contradict results that one considers technically or even scientifically incorrect, on the same technical or even scientific level.
It’s quite another when people simply distort and misrepresent what their opponents write. This cannot be done without malicious intent.
*
I can’t imagine you supporting that.
wayne…you are right about the mRNA scam. Stands for modified RNA and the rocket scientists who believe in the scam are under the delusion that RNA is the basis of a virus.
An expert in mRNA, Dr. Robert Malone, came right out and stated that mRNA cannot prevent a covid infection. He was barred from places like Google on the pretext that he was spreading misinformation.
The RNA misinformation began with Luc Montagnier in 1983, the scientist who won a Nobel for allegedly discovering the virus that allegedly causes AIDS. Montagnier himself never claimed to have ‘discovered a virus’, in fact he admitted that he could not see HIV on an electron microscope. Later, he admitted that HIV is harmless to a healthy immune system and that the real cause of AIDS is oxidative stress related to lifestyle.
When Montagnier and his team failed to see a virus on an EM, as required by his institute, the Louis Pasteur Institute, they went on to use retroviral theory, that was only 10 years old, to INFER a virus based on RNA taken from a person with AIDS. A pioneer in the field warned that RNA is not a good marker for a virus since…ta da…it is readily found all over the body as a naturally occuring agent.
LPI laid out the gold standard at the time for identifying a virus and the final step was seeing it on an EM and one of the LPI team who helped create the gold standard, Dr. Barre Sinoussi, was on Montagnier’s team. Not a peep out of her when they could not see a virus on an EM and helped infer one using RNA technology.
Then the rocket scientist, Fauci, got in on the scam with David Ho. Since they could not see HIV on an EM, and it was regarded as very scarce, they decided to amplify it using the PCR method for DNA amplification. So, they took RNA, ***THOUGHT*** to indicate a virus, converted it to DNA, and amplified the DNA using PCR.
No one can explain to this day how the test is supposed to identify a virus.
The inventor of PCR, Kary Mullis, said, “wait a minute, you can’t use PCR to amplify a virus that you can’t see on an EM”. Fauci had the audacity to tell him he was wrong. To this day, all viruses are declared using they new inferential scam hypothesized by Montagnier.
The same scam was used to put the world into a hysterical frenzy over covid. The test is a scam as is the alleged vaccine. In fact, the real scare that motivated the hysteria came from…ta da….an unvalidated computer model. Never mind that the model had been wrong about viruses data back to 2000, it was accepted readily by the fear-monger epidemiologists who declared covid a pandemic.
Christian Drosten is credited with developing the RNA-PCR test for covid but he freely admitted he had never seen the virus either. In fact, the scientists who announced the virus in Wuhan in 2020 also admitted they had not seen the virus but merely inferred it from RNA in crap taken from a victim’s lungs. Drosten simply used the info they provided and inferred a test.
After a couple of years of ineffective fear-mongering, they simply made covid go away by declaring it endemic, like the flu. That’s all it was in the first place, a bad case of the flu.
The map of CO2 distribution at the surface shows how terrestrial plants, marine algae, and cyanobacteria use CO2 during the growing season. It is worth noting that the increase in ocean surface temperature in the tropics favors cyanobacteria, which have the ability to assimilate carbon dioxide and nitrogen.
https://earth.nullschool.net/#current/chem/surface/level/overlay=co2sc/equirectangular
Solar cycle 25 is stronger than cycle 24 in terms of sunspots and UV radiation. However, since 2008, the number of geomagnetic storms has dropped dramatically. The graph shows the number of geomagnetic storms per year. This direct impact of solar wind on Earth’s magnetosphere (geomagnetic storm) has a very large effect on waves occurring in the stratosphere and above. I am sure that this may affect circulation in the stratosphere and upper troposphere.
It should also be remembered that we are already in this cycle after the reversal of the poles on the Sun, i.e. after the peak of solar activity.
https://i.ibb.co/gZVHdP61/liczba-dni-z-burz-geomag.png
https://www.spaceweatherlive.com/en/solar-activity/solar-cycle.html
https://www.cpc.ncep.noaa.gov/products/stratosphere/strat-trop/gif_files/time_pres_WAVE1_MEAN_JFM_NH_2025.png
https://www.cpc.ncep.noaa.gov/products/stratosphere/strat_int/gif_files/gfs_o3mr_200_NA_f000.png
https://www.cpc.ncep.noaa.gov/products/stratosphere/strat_int/
” I am sure that this may affect circulation in the stratosphere and upper troposphere. ”
No doubt is allowed: just one 100% scientific proof would be far more convincing than 1,000 Palmowski’s I am sure.
100% scientific proof. That should be easy.