ACC Public Comment to DoE on Climate Report

September 2, 2025
U.S. Department of Energy
1000 Independence Ave SW 
Washington, DC 20585

Response to Docket No. DOE-HQ-2025-0207 

The American Conservation Coalition (ACC) appreciates the opportunity to comment on the Department of Energy (DOE) Climate Working Group’s (CWG’s) draft report entitled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate.” ACC is a nonprofit organization working to build the conservative environmental movement, with grassroots members nationwide. ACC is submitting a response to highlight the need for strong, conservative leadership to lead on energy dominance while reducing emissions.

Our Philosophy
ACC was founded in 2017 by young conservatives frustrated by the alarmism and top-down mandates of the mainstream environmental movement. Like Secretary Wright, we recognize that climate change is a real issue, but we reject the doomsday narrative and heavy-handed solutions that dominate the national conversation. From the start, we’ve championed market-driven, bottom-up, and pro-innovation approaches to environmental challenges that serve the national interest. That message has resonated. Today, ACC is a national network of 85,000 young people who care deeply about environmental issues and are advancing a new, conservative approach to solving them.

Rejecting Alarmism, Embracing American Leadership
We’ve long acknowledged that the mainstream environmental movement has too often leaned into doomerism and extremism. The world is not ending in 12 years, despite what some activists claim. As the report rightly notes, the IPCC and broader discourse have consistently and misleadingly overstated worst-case scenarios, such as RCP 8.5. That’s why calls to rapidly ban fossil fuels, suppress economic growth, or upend lifestyles aren’t serious solutions. They’re distractions. 

But rejecting alarmism doesn’t mean we should cast doubt on the problem altogether. From the increased frequency of heatwaves and longer, more severe droughts, to more frequent and intense wildfires, rising sea levels, ocean acidification, and habitat loss threatening wildlife, we do face a real challenge. Yet, America has never backed down from big challenges. 

We’ve led the world through them—from putting a man on the moon to inventing the Internet. Achieving emissions reductions while solving energy poverty is no different. It demands leadership, ingenuity, and pride in the American spirit—not fear or regression.

Over the past couple of decades, the United States has led the world in emissions reductions—cutting more than all other developed countries combined. That progress is largely the result of American innovation and the power of markets. Notably, the shale revolution was made possible by major technological breakthroughs that unlocked cheap natural gas and reduced emissions. Meanwhile, the cost of wind and solar dropped at an unprecedented rate, next-generation geothermal energy is nearing commercial scalability, and breakthroughs in advanced fission and fusion are gaining momentum.

The Path Forward
Climate models are extremely complex, and no projection will ever be entirely accurate. Still, the overall trend is clear: reducing emissions is needed. Even with some uncertainty around the extent of the risks, American leadership is the path forward. This should not come at the cost of reliable, affordable energy. We share Secretary Wright’s passion for alleviating energy poverty. He is exactly right that restricting access to affordable, reliable energy—whether at home or abroad—is a non-starter. However, that doesn’t mean we should shy away from the climate challenge. In the absence of American leadership, China will fill the void, and in some cases, already is. With some of the world’s worst labor and environmental standards, and clear geopolitical motives, China’s dominance in energy markets of the future is a threat not only to our environment but also to human well-being, national security, and energy access for ourselves and our allies.  To ensure we are not at the whims of the Chinese Communist Party, the administration should boldly embrace practical, pro-growth climate solutions that reduce emissions while promoting economic prosperity and energy security for all. 

Such an approach should include embracing nuclear energy—America’s largest source of emissions-free electricity and its most reliable energy source, with the highest capacity factor.^, It also means eliminating regulatory barriers that delay or block the deployment of all forms of 

energy infrastructure projects—from solar and transmission to natural gas and geothermal—especially since the average time it takes to complete the highest level of environmental review is four years. Comprehensive reform of the environmental permitting system would especially benefit the cleanest forms of American energy. 

It should also reflect the reality that, as the U.S. continues to lead in emissions reductions, China has become the world’s largest emitter. The United States produces some of the cleanest and safest energy and products in the world—we should be exporting our technology, not outsourcing. As ACC’s President, Chris Barnard, wrote in an essay for National Affairs, “American manufacturing and energy production are among the cleanest in the world. We should prioritize exporting cutting-edge clean energy technology and the energy we produce to the rest of the globe. By working with our allies to reduce export barriers and diminish their reliance on China, we can strengthen our energy security and our economy while reducing worldwide emissions.”

Beyond energy, we should prioritize stewarding our natural heritage, as the President’s Executive Order  “Establishing the President’s Make America Beautiful Again Commission” aims to do. Poor forest management has left our forests overgrown, unhealthy, and increasingly prone to catastrophic wildfires. Our forests should be carbon sinks, not carbon sources. That’s why we must expand active forest management. It also requires recognizing the vital role that farmers and ranchers play as America’s original conservationists and empowering them as the stewards they are. The land they manage is critical not only to feeding our country, but to ensuring environmental progress. And it includes protecting ecosystems—such as wetlands and mangroves—not only to reduce emissions but also to create resilient communities.

Rebuilding Trust in Climate Science
A healthy level of discourse is foundational to sound science. DOE’s efforts to bring greater transparency and accountability into the climate science conversation are admirable. However, this report should not be the last word, but rather the first step toward rebuilding trust in climate science. One way the administration could build on this progress is by commissioning a National Climate Assessment that brings all scientific viewpoints and lines of evidence to the table. Doing so would create an opportunity to foster the open and honest dialogue this report seeks to advance.

Conclusion 
While ACC appreciates the DOE’s efforts to foster open and honest dialogue around climate science, we also urge the administration to focus on leading with bold, forward-looking solutions to the climate challenge. Unlike the mainstream environmental movement—and past attempts to address this issue—ACC recognizes that there is a path to American energy dominance, economic prosperity, and lower emissions. Thank you again for the opportunity to comment. Please let us know if you have any questions or concerns.