对美国能源部气候工作组发布的一份报告中第11章“气候变化、经济和碳的社会成本”发表评论（英）

Brian C. Prest Public CommentSeptember 2025 September 2, 2025 US Department of Energy1000 Independence Avenue SWWashington, DC 20585Attn: Docket ID No. DOE-HQ-2025-0207-0001 Dear Secretary Wright, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to the USDepartment of Energy (DOE) on the draft report produced by DOE's Climate Working Group titledA Critical RFF is an independent, nonprofit research institution in Washington, DC. Its mission is to improveenvironmental, energy, and natural resource decisions through impartial economic research and policyengagement. RFF is committed to being the most widely trusted source of research insights and policysolutions leading to a healthy environment and a thriving economy. While RFF researchers are encouraged to In this case, RFF expert Dr. Brian Prest has provided technical comments on Chapter 11 of the report, titled“Climate Change, The Economy, and the Social Cost of Carbon.” The comments focus on the usage of If you have any questions or would like additional information, please contact Liam Burke atlburke@rff.org. Sincerely, Carlos E. MartínVice President for Research and Policy Engagement Comments on Chapter 11, “Climate Change, the Economy, and the Social Cost of Carbon,” inthe report produced by the US Department of Energy's ClimateWorking Group (CWG) titledA Critical Review of Impacts of Brian C. PrestFellow and Initiative Director, Resources for the Future 1.Technical Comment on Page 119 Page 119 of the CWG report mischaracterizes the results of Newell et al. (2021), which wascoauthored by the present author (Newell, Prest, and Sexton 2021). Newell et al. (2021)’s abstract “The uncertainty is greatest for models that specify effects of temperature on GDPgrowth that accumulate over time; the 95% confidence interval that accounts for bothsampling and model uncertainty across the best-performing models ranges from 84%GDP losses to 359% gains. Models of GDP levels effects yield a much narrowerdistribution of GDP impacts centered around 1–3% losses, consistent with damagefunctions of major integrated assessment models. Further, models that incorporate The conclusion further states, “Models relating temperature to GDP levels yield climate impact estimates that are farmore certain. The best such models imply GDP losses by 2100 of 1–3%, consistent withdamage functions currently embedded in the major integrated assessment models thatunderpin the U.S. social cost of carbon (National Academies of Sciences 2017; Nordhaus2017; Rose et al. 2017; National Research Council 2010). The 95% confidence range for The CWG nonetheless summarizes the same results as follows: “Overall, [Newell et al. (2021)] could not detect a temperature effect on GDP or GDPgrowth, and they estimated the 95 percent confidence interval for the impact on globalgrowth as of 2100 even under the exaggerated RCP8.5 warming scenario spans −86 There are at least three reasons why the CWG summary is inappropriate. The first clause isinaccurate or at best incomplete. The abstract of Newell et al. (2021) states:“We identify statisticallysignificant marginal effects of temperature on poor country GDP and agricultural production, but not The second clause of the CWG summary above focuses solely on the class of models that the Newellet al. paper’s results suggest against relying upon. A key conclusion of Newell et al. (2021) is thatestimates of the effect of temperature on thegrowth rateof GDP are very uncertain, but thatestimates of the effects on thelevelof GDP are more certain. This suggests that the results frompure GDP growth models should be viewed with considerable skepticism, while results from GDP In this context, the final sentence from the CWG’s summary is also incorrect. The estimates from GDPlevels models are reported in the Newell et al. conclusion: “The 95% confidence range for GDP levelsmodels in any model confidence set is −8.5% to +1.8%.” While the paper does not explicitly reportother summary statistics of this distribution, it can nonetheless be seen in the bottom panel of Figure6 in Newell et al. (2021), reproduced below (see blue line). The mean and median values Beyond Newell et al. (2021), the more recent literature (e.g., Nath, Ramey, and Klenow (2025))suggests a middle ground between the extreme cases considered in Newell et al. (2021). Thissuggests that temperature’s impacts on GDP are not fully persistent (as in growth models) or fullytransitory (as in levels models), but partially persistent. Newell et al. (2021) did not consider partially 2.Technical Comment on Page 121 Page 121 of the CWG Report claims: “The concepts of estimation and uncertainty do not readily apply to SCC calculations. Noamount of data collection can change the fact that many components of the SCC areunknown and rely on judgment and opinion based on knowledge of the underlying This claim demonstrates a misunderstanding of empirical inferenc