Prime Mover Institute’s Comment on the Department of Energy’s Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate

In July 2025, the Department of Energy (DOE) published its report titled A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate. A notice of availability of the DOE Critical Review was published in the Federal Register on August 1, 2025, and DOE opened a comment period to request comments on the Critical Review.

Prime Mover Institute writes to express its appreciation to the DOE for undertaking this important study. The DOE Critical Review represents a crucial opportunity to examine the current consensus on climate change and chart new energy and environmental policies based on what the science actually says.

Prime Mover Institute makes the following recommendations to DOE:

1. Explore making the critical review a Highly Influential Scientific Assessment, or alternatively produce a follow up review of climate science through the HISA process.
2. Regularly issue new evaluations of the state of climate science and of associated outside reports and assessments. The DOE Critical Review could become an important new process of evaluating ideologically biased scientific research with significant implications for U.S. energy policy.
3. Review policies involving climate science across the federal government, and potentially state governments, for scientific validity. Make recommendations for improvement, in line with Executive Order 14303, Restoring Gold Standard Science.
4. Review past official scientific assessments for consistency with Gold Standard Science and the findings of this review, possibly to include prior National Climate Assessments, the Environmental Protection Agency’s Framework for Evaluating Damages and Impacts (FrEDI), and the Office of Management and Budget’s “Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis.”
5. Evaluate gaps in the scientific record regarding climate science, climate policy, and the impact of climate policy on the electrical grid and other energy markets. Make suggestions on lines of research, and fund new research where possible, in order to incorporate the best possible evidence and modeling into government policymaking, including into benefit-cost analysis.