FOR IMMEDIATE RELEASE
September 22, 2026
American Energy Institute Urges White House Science Office to Finish the Job on Discredited Climate Scenarios
Public comment supports the proposed amendment to the Fifth National Climate Assessment, but warns that a correction stopping at RCP8.5 is neither scientifically coherent nor legally durable
WASHINGTON, D.C. — The American Energy Institute is urging the White House Office of Science and Technology Policy to broaden its proposed amendment to the Fifth National Climate Assessment, pointing to a public comment filed with the office by the American Energy Association on September 9 in response to the request for information published at 91 Fed. Reg. 54893.
The comment supports the amendment and asks the U.S. Global Change Research Program to complete it. The amendment correctly diagnoses what the letter calls a fatal flaw in the assessment: the presentation of implausible high-emission scenarios as central planning futures. But an amendment that retires RCP8.5 and SSP5-8.5 while leaving the rest of the same tier in place, the letter argues, will not hold.
The statute asks for major trends, not worst cases. The Global Change Research Act directs the assessment to project “major trends” for the next 25 to 100 years. The comment argues that word does analytical work: Congress asked for the principal expected trajectory of global change, not the full envelope of conceivable outcomes. A separate provision of the same statute already requires the assessment to discuss scientific uncertainties. Treating retired worst-case pathways as “major trends” collapses one mandate into the other and leaves policymakers without the usable information the law requires.
The correction has to reach the whole retired tier. The same international modeling decision that retired SSP5-8.5 also left SSP3-7.0 behind, with no successor at its forcing level. The assessment’s own scenario table pairs RCP6.0 and SSP3-7.0 as a single “High Scenario” tier, so retiring one and keeping the other is internally inconsistent on the report’s own terms. The letter asks that SSP3-7.0, RCP6.0, SSP4-6.0 and SRES A2 be named expressly in every operative list, and that RCP4.5 and SSP2-4.5 be retained only if the authors affirmatively find, on the record, that they fall within a likely projection range.
The comment identifies specific statements now overstated as a result. The assessment’s chapter on coastal effects tells readers that temperatures are “headed for a warming level of about 5.4°F (3°C) by 2100 under the current trajectory,” resting that claim in part on SSP3-7.0. The report’s Overview frames the same 3°C threshold on SSP3-7.0 and SSP5-8.5 together.
The fix cannot stop at the report itself. Outputs from the retired scenarios propagated into the LOCA2 and STAR-ESDM downscaled datasets, the assessment’s public Atlas, the Global Change Information System, and agency technical support documents built on top of them. The letter asks that the amendment reach those products, and that scenario screening become an ongoing obligation rather than a one-time relabeling exercise, because the underlying literature keeps growing.
On that point the comment cites the Institute’s own continuously updated public record, Continued Misuse, They Knew: The RCP8.5 Record, which catalogs studies, reports and news articles published after the scenarios were retired that still rely on them without disclosing their status. As that record puts it, use of a retired scenario is not itself the offense; the offense is presenting its outputs as the expected future with no disclosure that the scenario has been ruled out by the very institutions that created it.
Congress asked for an assessment, not an agenda. The letter also asks the program to delete Chapter 32, “Mitigation,” in its entirety. The statute directs the assessment to analyze the effects of global change on energy, agriculture, water, transportation, health and other enumerated subjects. It does not authorize federal assessors to prescribe emissions-reduction strategies or preferred mixes of wind, solar, electric vehicles, hydrogen or carbon removal. The comment notes that the chapter itself concedes its outcomes depend on uncertain technology, public acceptance, consumer choice and future policy, and argues that cataloging municipal climate pledges is not analysis of anything Congress asked about.
The letter closes with a request that the program stop the policy cheerleading and produce the scientific assessment Congress required.
Read the full comment letter here
About the American Energy Institute
The American Energy Institute is an educational and advocacy organization dedicated to advancing affordable, reliable, and abundant American energy, and to holding institutions accountable for the science and the policy they put in front of the public.
Media Contact:
Hon. Jason Isaac
American Energy Institute
512-815-2207
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