Report on the Contested Use of Climate Science in U.S. Regulatory Proposals and its Implications for Sustainable Development Goals

This report analyzes the recent use of climate science research in a proposed rule by the Environmental Protection Agency (EPA) and a critical review by the Department of Energy (DOE). It finds that the research has been selectively interpreted to support a narrative that minimizes climate change risks, thereby undermining key United Nations Sustainable Development Goals (SDGs), particularly SDG 13 (Climate Action).

Analysis of the Environmental Protection Agency (EPA) Proposed Rule

Contention Regarding the 2009 Endangerment Finding

The EPA’s proposed rule, “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards,” argues that the original finding was “unduly pessimistic.” To support this, it cites research, including Hausfather and Peters (2020), which critiqued the use of worst-case emissions scenarios (e.g., RCP8.5/SSP5-8.5) as “business as usual.” The EPA suggests that empirical data aligns with more optimistic IPCC scenarios, thus lessening the anticipated dangers to public health and welfare.

Clarification of Emissions Scenarios and Policy Implications

The scientific position is that while worst-case scenarios are unlikely, more plausible outcomes like SSP2-4.5 are not baseline scenarios but are contingent upon the implementation and continuation of global climate policies. These policies are foundational to achieving SDG 13 (Climate Action) and SDG 7 (Affordable and Clean Energy).

• The EPA’s proposal rests on a flawed premise: it uses an optimistic, policy-dependent scenario to justify the repeal of the very policies that make the scenario plausible.
• If climate policies are repealed, as proposed, the world could be pushed toward higher-emissions scenarios, invalidating the basis for the EPA’s argument.
• Progress in reducing emissions projections does not negate the urgency of climate action required to meet the 1.5°C target, a central element of SDG 13.

Impact on Sustainable Development Goals

The EPA’s approach directly threatens progress on several SDGs:

1. SDG 13 (Climate Action): The proposed rule uses a misinterpretation of climate modeling to argue against necessary climate action, threatening progress towards emission reduction targets.
2. SDG 3 (Good Health and Well-being): By seeking to overturn an endangerment finding based on risks to public health, the proposal downplays the severe health implications of climate change, from respiratory illnesses to heat-related mortality.
3. SDG 7 (Affordable and Clean Energy): The optimistic SSP2-4.5 scenario assumes continued cost declines and deployment of clean energy. Repealing policies that support this transition jeopardizes the global energy transition central to SDG 7.

Analysis of the Department of Energy (DOE) Critical Review

Selective Use and Misrepresentation of Scientific Evidence

The DOE’s report, “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” is accused of cherry-picking evidence to support a preconceived narrative.

• The report cites an obscure figure from the supplementary materials of Hausfather et al. (2019) to claim that observed CO2 concentrations tracked the low end of projections.
• This ignores the primary conclusion of the cited paper: that the majority of historical climate models evaluated were accurate in predicting the rate of future warming.
• Furthermore, the DOE report incorrectly identifies the scenarios in the figure and overlooks other data showing that older models often underestimated total forcings by omitting non-CO2 greenhouse gases.

Implications for Institutional Integrity and SDG 16

This selective use of data represents a significant challenge to the principles of good governance and institutional integrity, which are central to SDG 16 (Peace, Justice and Strong Institutions). By prioritizing a political narrative over objective, comprehensive scientific assessment, such actions weaken the credibility of the institutions responsible for informing public policy and protecting public welfare.

Systemic Issues: Suppression of Comprehensive Climate Assessment

The Removal of the National Climate Assessment (NCA)

A critical issue is the removal of all congressionally-mandated National Climate Assessments from government websites. The NCA is a comprehensive, consensus-based report produced by hundreds of scientists over several years, with extensive review by the public, federal agencies, and the National Academy of Sciences. Its removal constitutes the suppression of the most authoritative U.S. government assessment on climate change.

Undermining Collaborative Science and SDG 17

The NCA process is a prime example of SDG 17 (Partnerships for the Goals), embodying a large-scale partnership between the scientific community and government to achieve a common goal. Replacing this collaborative, peer-reviewed work with a rushed, one-sided report written by a small number of authors actively undermines the principles of partnership and evidence-based policymaking.

Conclusion: A Process Threatening Sustainable Development

The actions undertaken by the EPA and DOE appear to be a politically motivated effort to overturn the scientific finding that CO2 is a pollutant that endangers public health and welfare. This process relies on the misrepresentation and selective citation of scientific research while simultaneously suppressing comprehensive, consensus-based assessments.

This approach poses a direct and significant threat to the achievement of multiple Sustainable Development Goals:

• SDG 13 (Climate Action): By creating a pretext for regulatory inaction and the rollback of existing climate policies.
• SDG 16 (Peace, Justice and Strong Institutions): By eroding the integrity and transparency of scientific and governmental institutions.
• SDG 17 (Partnerships for the Goals): By rejecting collaborative, multi-stakeholder scientific processes in favor of one-sided, politically driven narratives.

Which SDGs are addressed or connected to the issues highlighted in the article?

SDG 13: Climate Action

• The article is fundamentally about climate change, discussing greenhouse gas (GHG) emissions, global temperature projections, climate modeling scenarios (like SSP2-4.5), and the urgency of climate action. It directly engages with the scientific basis for policies aimed at mitigating climate change.

SDG 7: Affordable and Clean Energy

• The article mentions the “falling cost of clean energy worldwide” as a key factor making high-emission scenarios based on coal dominance implausible. It also refers to “deep decarbonization,” which relies on a transition to clean and affordable energy sources.

SDG 16: Peace, Justice and Strong Institutions

• A major theme is the critique of governmental institutions (EPA, DOE) for allegedly misusing science, cherry-picking data, and suppressing the official National Climate Assessment (NCA). The author argues this is a “politically motivated pretext” rather than a transparent, accountable, and truthful scientific process, which directly relates to the goal of having strong and accountable institutions.

SDG 17: Partnerships for the Goals

• The article highlights the importance of scientific partnerships and collaboration, referencing international bodies like the IPCC and the national, multi-agency effort behind the NCA. It also mentions the “broader climate science community” working together to provide rebuttals, underscoring the role of partnerships in ensuring policy is based on sound science.

What specific targets under those SDGs can be identified based on the article’s content?

SDG 13: Climate Action

1. Target 13.2: Integrate climate change measures into national policies, strategies and planning.
   • The article’s entire focus is on the U.S. EPA’s proposed rule to reconsider its “2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.” This is a direct discussion of national climate policy. The author argues that repealing such policies, based on a flawed interpretation of current progress, would undermine the goal of integrating climate measures. The existence and defense of the National Climate Assessment (NCA) also falls under this target as a key tool for policy planning.
2. Target 13.3: Improve education, awareness-raising and human and institutional capacity on climate change mitigation.
   • The author is attempting to correct the public record on how his scientific work was used, thereby contributing to education and awareness. The article critiques the DOE and EPA for actions that undermine institutional capacity, such as suppressing the NCA, which is a primary resource for educating policymakers and the public.

SDG 7: Affordable and Clean Energy

1. Target 7.2: By 2030, increase substantially the share of renewable energy in the global energy mix.
   • The article supports this target by noting that “the falling cost of clean energy worldwide makes a 21st century dominated by coal… pretty implausible.” It discusses scenarios like SSP2-4.5 that assume “continued declines in clean energy costs over the 21st century” to achieve deep decarbonization.

SDG 16: Peace, Justice and Strong Institutions

1. Target 16.6: Develop effective, accountable and transparent institutions at all levels.
   • The author’s central criticism is that the process behind the DOE report and EPA rule lacks accountability and transparency. He describes it as a “farce” that “cherry-picks figures and parts of studies to support a preconceived narrative” while ignoring the main conclusions of the cited research. The removal of the NCA from government websites is presented as a clear example of institutions failing to be transparent.
2. Target 16.7: Ensure responsive, inclusive, participatory and representative decision-making at all levels.
   • The article contrasts the inclusive and participatory process of the NCA, which “was a process involving hundreds of scientists over three years” with multiple reviews, against the “very rushed red team document written in two months with only five authors.” This highlights a failure to adhere to participatory and representative decision-making in the creation of scientific reports for policy.

Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

SDG 13: Climate Action

• Global temperature increase: The article frequently uses projected global temperature increases as a key metric, such as limiting warming to “1.5C,” and scenarios projecting “1.8 and 4 degrees Celsius by 2100.”
• Greenhouse gas emissions and concentrations: The article discusses “projected increases in GHG concentrations,” “observed atmospheric CO2 concentrations,” and includes graphs of “annual CO2 emissions” under various scenarios. These are direct indicators of progress on climate mitigation.
• National climate policies and strategies: The existence and status of the “EPA’s endangerment finding” and the “National Climate Assessment (NCA)” serve as indicators of whether climate change measures are integrated into national policy.

SDG 7: Affordable and Clean Energy

• Energy mix composition: The article implies this indicator by contrasting a future “dominated by coal” (as in the SSP3 scenario) with the current trend of “falling cost of clean energy,” which points toward a shift in the energy mix.

SDG 16: Peace, Justice and Strong Institutions

• Public access to information: The article provides a direct, measurable indicator of institutional transparency by stating that the websites for all National Climate Assessments return a “‘This site can’t be reached’ error.” The availability of such government reports is a key indicator.
• Integrity of scientific advisory processes: The author provides qualitative indicators by comparing the development process of the NCA (“hundreds of scientists over three years,” multiple public and agency reviews) with the DOE report (“written in two months with only five authors”), indicating the robustness and inclusivity of the process.

SDGs, Targets, and Indicators Analysis

Source: theclimatebrink.com