EDF Responds to “Irredeemably Flawed” Report That Trump Administration is Using in Effort to Eliminate Vital Climate Protections

(Washington, D.C. – September 4, 2025) A team of scientists and legal experts at Environmental Defense Fund has submitted to the Trump Department of Energy a detailed, chapter-by-chapter response to an “irredeemably flawed” climate report that was created at that department’s request. 

“Climate change is a serious and growing danger to Americans’ health, safety and well-being, but the Trump administration is trying to use this deeply flawed report to eliminate protections that reduce climate pollution,” said EDF Associate Chief Scientist Lisa Dilling. “Decades of peer-reviewed research by thousands of scientists has confirmed, over and over, what so many Americans are now experiencing firsthand – climate change caused by greenhouse gas emissions is driving more extreme weather and other dangerous impacts that are increasing costs and harming Americans. This hastily constructed report does not represent the state of climate science. The report is also riddled with errors and distortions and many scientists have already described how the report fundamentally misrepresents their work. It should be immediately withdrawn.”

Earlier this year, Trump Secretary of Energy Christopher Wright quietly arranged for five hand-picked climate action opponents to form a “Climate Working Group” and tasked them with writing a report challenging the mountain of evidence that shows climate change is a threat to human health and well-being. That report was held secret from the public until July, when it was unveiled as a cornerstone of Trump EPA Administrator Lee Zeldin’s proposal to eliminate the Endangerment Finding – EPA’s scientific determination, based on that mountain of evidence, that that climate pollution harms current and future generations. The Endangerment Finding supports commonsense pollution standards that protect people from the more powerful floods, more extreme heat waves, more destructive fires, higher insurance costs, and other climate-driven hazards that make life for Americans less safe and more costly. Zeldin’s proposal relies extensively on the Climate Working Group report, citing it 22 times.

The Climate Working Group’s report was immediately denounced by scientists whose research it cites for using scientific data inaccurately and fundamentally misrepresenting many of their findings. Yesterday more than 85 scientists issued a scathing rebuttal to the report, and EDF and the Union of Concerned Scientists have already filed a lawsuit challenging its use as contrary to federal law.

Now EDF has filed comments with the DOE further detailing the numerous, severe, and pervasive problems with the Climate Working Group report, including sections on:

• What the current state of the science really is on climate impacts – in contrast with the report’s “selective and misleading representations”
• The “numerous ways that the process for developing the … [r]eport violated legal and scientific standards”
• A catalogue of the ways each chapter of the report is “incomplete, inaccurate, or otherwise flawed”

EDF’s comments find that the Climate Working Group report “fails to engage with the vast body of scientific evidence documenting the clear harms associated with climate change and the direct role that the burning of fossil fuels has played in causing them. It instead focuses on a heavily distorted and cherry-picked presentation of a small subset of the scientific literature, as well as stale theories that the scientific community has already thoroughly considered and refuted, to wrongly downplay the pace and scale of the harms associated with climate change.”

EDF also finds that the Climate Working Group report has “systematic and pervasive errors across multiple chapters,” and concludes that the report is “deeply and incurably flawed, and any reliance on it by federal agencies is arbitrary and unlawful. EDF urges DOE to withdraw the Report immediately.”

Read EDF’s entire comments here.

Last week EDF also submitted comments to the National Academies of Sciences, Engineering, and Medicine, which requested information for its review of evidence on the link between manmade pollution and climate change. You can read those comments here.