climate chaos is real

Docket No.: DOE-HQ-2025-0207
Document Title: A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate
Agency: U.S. Department of Energy
Comment Period Closes: September 2, 2025


Comment from:

Another Gulf Is Possible Collaborative
anothergulfispossible@gmail.com

Executive Summary

Another Gulf Is Possible Collaborative—an environmental justice and cultural organizing collective rooted in the Gulf South—submits this comment to express deep concern with the DOE’s draft report A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate. The draft selectively cites climate research, minimizes well-documented regional impacts, and risks undermining critical safeguards like the EPA’s Endangerment Finding.

The Gulf South—particularly Florida, Louisiana, and Texas—is already experiencing disproportionate and accelerating harms from sea-level rise, extreme storms, inland flooding, and economic disruption. The report’s omission of such place-based realities fails to meet the scientific and ethical standards needed for policymaking that protects both public health and environmental integrity.


Detailed Comments

1. Limited and Non-Representative Authorship

The draft was prepared by a small, hand-picked group, without the transparency, diversity, or peer review processes typical of major climate assessments like the IPCC or National Climate Assessment. This increases bias risk and undermines credibility.

2. Cherry-Picking and Misrepresentation of Evidence

Multiple scientists have stated that the report selectively quotes their work in ways that misrepresent conclusions. For example, Zeke Hausfather has clarified that while the report cites his research to question model accuracy, it omits his finding that models perform reasonably well overall.

3. Downplaying Documented Harms in the Gulf South

Texas, Florida, and Louisiana are the top three states that suffer from climate disasters in terms of dollars. Texas leads the US in the number and cost of billion-dollar weather and climate disasters. Alabama and Mississippi have also experienced a high number of billion dollar climate disasters as well and data from NOAA indicates that these events are increasing in each state.

  • From 1980-2024, Texas experienced 171 such events, with a total cost of $436 billion, primarily due to tropical cyclones and severe storms. The 1980–2024 annual average Texas is 4.2 events (CPI-adjusted); the annual average for the most recent 5 years in Texas (2020–2024) is 13.6 events (CPI-adjusted).
  • Florida ranks second in total costs, also largely from tropical cyclones, with $452 billion, according to Climate Central. The 1980–2024 annual average Florida is 2.1 events (CPI-adjusted); the annual average for the most recent 5 years in Florida (2020–2024) is 6.8 events (CPI-adjusted).
  • Louisiana is third, with $315 billion in total costs from 97 events, with tropical cyclones being the most significant factor. The 1980–2024 annual average in Louisiana is 2.4 events (CPI-adjusted); the annual average for the most recent 5 years in Louisiana (2020–2024) is 6.8 events (CPI-adjusted).
  • Alabama Summary: From 1980-2024, there were 116 confirmed weather/climate disaster events with losses exceeding $1 billion each to affect Alabama. These events included 16 drought events, 2 flooding events, 3 freeze events, 58 severe storm events, 26 tropical cyclone events, 2 wildfire events, and 9 winter storm events. The 1980–2024 annual average in Alabama is 2.6 events (CPI-adjusted); the annual average for the most recent 5 years in Alabama (2020–2024) is 6.4 events (CPI-adjusted).
  • Mississippi Summary: From 1980-2024, there were 108 confirmed weather/climate disaster events with losses exceeding $1 billion each to affect Mississippi. These events included 17 drought events, 5 flooding events, 3 freeze events, 50 severe storm events, 22 tropical cyclone events, 1 wildfire event, and 10 winter storm events. The 1980–2024 annual average in Mississippi is 2.4 events (CPI-adjusted); the annual average for the most recent 5 years in Mississippi (2020–2024) is 6.0 events (CPI-adjusted).

Reports also suggest that Texas, Louisiana, and Florida are among the top states for climate disasters in 2025. Specifics for each state include:

  • Texas: Has the highest probability of future natural disasters among all states (23.64%), and is the most tornado-prone state, recording 1,774 tornadoes between 2008 and 2023.
  • Florida: Expected to have the second-highest average annual losses from natural disasters (approximately $416 per person). 
  • Louisiana: Homeowners face the highest expected financial losses from severe weather and natural hazards nationwide, with estimated annual losses of $547 per person, according to Newsweek. Louisiana also holds the title for worst natural disaster displacement in 2022, with Florida not far behind.

Additionally, these same Gulf South states will continue to experience other negative environmental impacts from climate change in the years to come.

  • Florida – Rising Seas & Everglades Threats: Projections show 10–12 inches of sea-level rise by 2050 in South Florida, endangering the Everglades’ wetlands, mangroves, and biodiversity (EPA).
  • Louisiana – Global-Scale Coastal Land Loss: Nearly 2,000 square miles of land have been lost since 1932, with some coastal areas experiencing sea-level rise up to 4× the global average (EPA).
  • Texas – Storm and Inland Flooding Risks: The July 2025 Central Texas floods, fueled by over 20 inches of rain, caused more than 130 deaths and $1.1 billion in damages (Houston Chronicle).
  • Coastal flooding has already taken its toll on Alabama, Dauphin Island in particular. Erosion. The 14-mile island is slowly sinking into the Gulf of Mexico.

Regional – Accelerated Sea-Level Rise: Since 2010, sea-level rise in the Southern U.S. has been double the global average, with localized increases of 6 inches in Gulf Coast cities (Washington Post). Over 7,000 square miles of Gulf Coast land lie below five feet of elevation (Coastal Resilience).

Economic & Equity Impacts: Projected losses in coastal property-tax revenue could total billions by 2050, threatening public services like schools and emergency response (TIME). Nearly 1,100 critical infrastructure sites are at risk of monthly flooding by 2050, with disproportionate harm to marginalized communities (The Guardian).


Recommendations

  1. Integrate Comprehensive Science – Align with the full body of peer-reviewed research rather than selective citation.
  2. Center Place-Based Evidence – Include documented Gulf South climate impacts to ensure national policy reflects regional realities.
  3. Protect Existing Climate Safeguards – Maintain the EPA’s Endangerment Finding and emissions regulations.
  4. Prioritize Justice & Resilience – Fund adaptation, green infrastructure, and equitable disaster preparedness in frontline communities.

Conclusion

The DOE’s draft report falls short of scientific rigor and fails to reflect the lived realities of climate impacts in frontline communities. As an organization grounded in the Gulf South, we urge DOE to reject selective framings, elevate comprehensive science, and advance climate policy rooted in equity, resilience, and truth.


Submitted by:
Another Gulf Is Possible Collaborative
Jayeesha Dutta, Rebecca Hinojosa, Liana Lopez, Bryan Parras, Yudith Nieto, Ramsey Sprague
619 St Ferdinand Street
New Orleans, LA 70117
anothergulfispossible@gmail.com