Woodwell Climate Research Center (Woodwell) appreciates the opportunity to comment on the proposed rule regarding the Organization, Functions, and Procedures; Public Notice and Comment for Standards, Criteria, and Guidance Applicable to Forest Service Programs. As a scientific research organization dedicated to conducting science for solutions at the nexus of climate, people, and nature, Woodwell consistently advocates for robust, science-informed, and transparent programs for long-lasting sustainability and the benefit of the public.
Introduction
Public participation in formulating land management policies and guidelines, including consultations with Indian Tribal governments, has been a feature of the U.S. Forest Service for more than 100 years, and is codified in the Forest and Rangeland Renewable Resources Planning Act of 1974, as amended (16 U.S.C. 1612(a)). Public participation in federal land management allows policies to be based on considerations of those most affected by the policies, and generally results in more effective land management decisions.
Currently, the Forest Service is obligated to notify the public and seek comments on changes related to “standards, criteria, and guidelines,” or more specifically, any rescissions or removals from the Forest Service Manual or any changes to the Forest Service Handbooks. Under the proposed rule, these requirements would be substantially narrowed. Implementation of these new rules would replace public participation with directives from political appointees having little knowledge of the scientific basis for land management decisions, threatening the many public benefits of public forests, including protection of wildlife habitat, recreation, water supplies, and mitigating climate change, among others.
Woodwell strongly recommends the rescission of this proposed rule as the scaling back of public engagement contradicts the interests of the American people and the principles of scientific integrity. However, Woodwell does support the revision of the overly complex Forest Service Directive System to increase flexibility for local land managers to make decisions based on unique ecological conditions and land-use history, and urges the Forest Service to review and propose appropriate changes to this system to streamline Forest Service operations.
Scientific objection to the scaling back of public engagement
Transparency is an underpinning of scientific integrity, as well as ethical public service. Without strong public engagement, forest management will be driven by partisan agendas and political appointees rather than the relevant and impacted constituencies and technical experts. In any sweeping action conducted by the Forest Service, it is imperative that the process be fully transparent to ensure quality and integrity for the American people. The solicitation of public comments on such actions offers a well-rounded pool of expertise to advise decisions, offering perspectives that may not have otherwise been considered. This openness to interdisciplinary discourse is a core principle of science and the management of public lands.
The large body of ongoing scientific research that takes place on Experimental Forests located within Forest Service lands is an important consideration. These long-term studies have informed management practices for decades based on continuous data collection following management treatments to assess how different approaches affect timber production, wildlife habitat, carbon stocks, and other forest values over time. For example, long-term research at the Hubbard Brook Experimental Forest nestled within the White Mountain National Forest in New Hampshire has yielded world-class research on the impacts of management practices on nutrient cycling that is the foundation of forest growth. Without public support, sustainable resource use on federal forest lands will be threatened and replaced with extractive practices like timber and mining that are favored by this Administration, without consideration of long-term benefits.
The critical role of forests in carbon sequestration
Nationwide, the Forest Service manages about 24 million acres of old growth and about 67 million acres of mature forest—nearly two-thirds of the total area of all forests managed by the agency. Mature and old-growth forests, with their much older and larger trees, hold more carbon. Mature and old-growth forests are also more resilient and adaptive in the face of disturbances such as wildfires, which makes them a high priority for environmental protection.
Since 2001, forest fire carbon emissions have increased by 60 percent. It is projected that by mid-century, wildfires in the northern region of North America would alone contribute to a cumulative net source of nearly 12 gigatonnes of carbon dioxide emissions into our atmosphere, further exacerbating temperatures and subsequent wildfire ignitions.
Impacts on climate resilience and economic risk
Rules are weighted by considering cost-benefit analyses. An analysis of short-term economic gain, without a clear analysis of the longer-term impacts on economics, human health, livelihoods, etc., weakens the argument against this rule. Actions such as the rescission of the 2001 Roadless Rule have already demonstrated the harm that increased logging and other commercial activities pose to protected forests, with the anthropogenic influences that increase under these conditions (such as population density, a human footprint index, and roadless extent in our forests) having significant statistical correlations to wildfire occurrence.
These harmful short-term approaches to forest management will have irreversible negative impacts on climate resilience, the economy, and public health. Forest ecosystems provide a plethora of economic co-benefits, including livelihoods, biodiversity, food, and air and water filtration, all of which are threatened by the exacerbation of wildfires and forest degradation due to climate change. Over the last 15 years, 15,000 deaths have been attributed to wildfire particulate matter. Further, Woodwell research has found that from 2006 to 2020, the economic burden linked to climate change-induced wildfire particulate matter alone accumulated to $160 billion. These repercussions will only be amplified under conditions of increased carbon emissions driven by deforestation. Woodwell strongly objects to the narrowing of the disclosure requirements in regard to Forest Service operations so that the public may continue to advocate, in their own self-interest, against irresponsible forest degradation.
Reforming the Forest Service Directive System
While Woodwell strongly objects to the scaling back of public engagement outlined under this proposed rule, Woodwell supports the reformation of the Forest Service Directive System. The current Directive System encoded in the Forest Service Manual and the Forest Service Handbooks is exceedingly complex and fails to adequately reflect the unique circumstances of land management history and ecological processes, especially considering climate change and effects on future forests. Reforming this outdated guidance by consulting the latest science, and without increasing the influence of short-term political considerations, would undoubtedly help ensure the long-term sustainability of the use of public forest resources for the wider public rather than the enrichment of a few businesses or wealthy individuals.
However, it is essential that the Directive System retain its importance as more than just advisory. The phrase “This proposed rule would redefine the Forest Service Handbooks as advisory and informational guidance that employees may deviate from without documenting a justification,” dangerously weakens the role of the Directive System and must be stricken from the final rule. A justification documenting the scientific basis of decisions as well as the concerns of the public must remain a requirement of forest and project planning. In addition, Woodwell strongly urges continued consultation and coordination with Indian Tribal governments.
Conclusion
The proposed rule to revise the procedures in regard to the standards, criteria, and guidance applicable to Forest Service Programs would eliminate effective public input to forest and project plans in favor of the heightened influence of short-term political agendas. In practice, this would significantly weaken the role of science in decision-making, ultimately threatening the long-term sustainability of federal forest resources. In order to protect public participation, as well as ensure scientific integrity of forest management decisions, Woodwell urges the Forest Service to significantly revise this proposed rule as follows:
- Restore the value of public participation to federal forest decision-making for policy and management to ensure sustainable benefits from public forests, including protection of wildlife habitat, recreation, water supplies, and mitigating climate change, among others.
- Strike the proposal to “redefine the Forest Service Handbooks as advisory and informational guidance that employees may deviate from without documenting a justification” and eliminate the process by which political appointees having little knowledge of the scientific basis for land management decisions can issue directives.
- Reinforce the importance of scientifically guided directives and consultation with Indian Tribal governments within the Forest Service Directive System for the responsible management of forest resources for the public benefit.
Woodwell urges the Forest Service to revise this proposed rule to restore the values of public participation and scientific integrity to inform responsible and sustainable federal forest management. This proposed rule threatens the wellbeing of our forests and the wellbeing of our citizens and Indigenous communities in favor of benefiting an elite few. Instead, Woodwell advises the Forest Service to look to its own mission of “caring for the land and serving people” as it moves forward in this much-needed update to the Forest Service Directive System.
A message from President & CEO Dr. Max Holmes
My house was built in 1870. It has been heated by wood, coal, oil, natural gas, and now electricity drawn from the sun. In one sense, that is a mundane property record. In another, it is the entire history of human energy, compressed into a single address.
Wood came first. It always does. Since our ancestors learned to control fire, biomass has been the default answer to cold and darkness. The house would have had a cast-iron stove, fed by wood cut from nearby forests. This is how virtually every human being on earth stayed warm for tens of thousands of years, and many still do. It worked, but it was labor-intensive, land-hungry, and contributed to deforestation.
Coal replaced wood in the industrializing Northeast not because it was loved but because it was dense, cheap, and abundant. A ton of coal contained far more energy than the equivalent volume of wood and could supply cities that had long since stripped their surrounding forests. Then came oil – heating oil delivered by truck, burned in a furnace that could be thermostatically controlled. Oil heat was modern. It was convenient. It was what the house was running on when my wife and I bought it in 2000. The following year, we switched to natural gas, piped directly to the boiler—cleaner than oil, cheaper at the time, and widely regarded as a “transition fuel.” Last year, we made what I believe will be the final transition: heat pumps, powered by electricity, with solar panels on the roof and a contract for renewable energy for anything we draw from the grid.
The sequence—biomass, coal, oil, gas, electricity—is not just our home’s story. It is the arc of modern civilization. And the direction of travel has always been the same: toward fuels that are denser, cleaner, and more controllable, and away from those that are dirtier, heavier, and harder to move. Electricity, especially when generated from wind and sun, is the logical end of that arc. The sun and wind are limitless natural resources and our ability to harness them into electricity will only continue to be more efficient. The energy transition the world is now debating is not some radical rupture; it is the next step in a journey that has been underway since the first furnace replaced the first wood-fired stove.
The only real question is speed. And here, the conflict now consuming the Persian Gulf offers an unexpected answer. The closure of the Strait of Hormuz following the outbreak of military conflict with Iran has removed close to one-fifth of global oil supplies from the market. Prices have reached $100 per barrel or higher. Nations that import the majority of their fuel from the Persian Gulf are facing genuine shortages. The head of the International Energy Agency has called it the greatest global energy security challenge in history.
The conventional assumption might be that an oil shock slows the energy transition – that higher prices make everything more expensive and governments retreat to fossil fuels out of desperation. History suggests the opposite. The 1973 Arab oil embargo helped to launch solar research, energy efficiency standards, and nuclear expansion. Countries around the world are again confronting the danger of energy dependence. That recognition tends to produce investment in alternatives, not capitulation to the status quo.
There are headwinds, of course. The current U.S. administration has been openly hostile to renewable energy, rolling back incentives and attempting to prop up coal and oil production. But administrations are temporary. Solar panels and heat pumps are not. The economics of clean energy have already crossed the threshold at which policy resistance can reverse them; what governments can do now is slow the transition at the margin, not stop it. And a geopolitical crisis that makes the cost of fossil-fuel dependence unmistakable—not in future climate projections but in today’s energy prices—has a way of clarifying minds.
My house has been through this before. It didn’t choose its fuels for ideological reasons; it followed the logic of cost, availability, and technology. The world’s energy system will do the same.
At a time when climate victories are scarce, an acceleration of the energy transition is reason for hope. Those with the financial means—and perhaps the broader good fortune to live in a time and place where the choice is available—can lean into this transition, doing what they can to speed the inevitable shift away from fossil fuels and toward what I believe will be humanity’s ultimate energy source: clean electricity generated from renewable sources.
The energy transition alone will not solve the climate crisis, but it is an essential step in that direction.
Onward.
Woodwell Climate Research Center (Woodwell) appreciates the opportunity to comment on the Security and Exchange Commission’s proposed rescission of climate-related disclosure rules. As a scientific research organization dedicated to conducting science for solutions at the nexus of climate, people, and nature, Woodwell consistently advocates for robust, science-informed, and publicly accessible data for long-lasting sustainability and the benefit of the people.
Introduction
The mission of the Securities and Exchange Commission (SEC) is “protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation.” The proposed rescission of the final climate-related disclosure rules stands in stark contrast to this mission. The proposed rescission argues that climate change is not a material risk to registrants or investors, but this is a false claim. Climate risk is business risk, and climate risk is financial risk.
Companies are already taking action to mitigate these financial risks, with over 80 percent of large, publicly registered companies disclosing their climate-related risks. Their willingness to take on the extra cost to engage in these voluntary disclosures is evidence of the broad industry awareness that climate change poses a significant financial threat. Investors also show wide-reaching recognition of the importance of climate-related disclosures, with 97 percent of those who mentioned Scope 1-3 emissions in their public comments in response to the 2022 proposed climate-related disclosure rules expressing support for the inclusion of those disclosures in the Final Rules. Investors and companies understand that, in order to adequately adapt to the threat of climate change, markets must know how industry is preparing for these challenges.
Under the current SEC disclosure rules, S&P 500 companies that volunteer to provide climate disclosures do so very briefly with little discussion of material issues or quantification of impacts or risks, while a large portion of companies disclose nothing related to climate in their annual filings. However, most S&P 500 companies that voluntarily disclose through the Carbon Disclosure Project provide a much more thorough analysis compared to the SEC process, demonstrating that while companies do have access to this information, they do not have access to a standardized process by which to disclose this information.
The SEC is choosing to put the desires of the registrants over those of the investors, citing increased costs and unnecessary effort for repetitive information for companies while downplaying the increased costs of acting on incomplete and asymmetric data for investors. In fact, the SEC repeatedly suggests that the investors who seek these more detailed and required disclosures are not “reasonable” investors as this information does not materially impact registered companies. This is doubtful considering that more than 41 countries, accounting for about 60 percent of the world’s GDP, have approved or proposed climate-related disclosure rules. Moreover, if the majority of investors, who possess a majority of the stock in public corporations, have expressed their desire for these climate-related disclosures, the disclosures should be presumed to be material. While 83 percent of comment letters received by the SEC supported the 2022 proposed climate-related disclosure rules, Feit v Leasco Data Processing Equipment Corp. determined that just 10 percent of public support is sufficient to define materiality.
The short-term political interests that color this proposed rescission do not usurp the decades of precedent inscribed in law or the interests of the American people. Woodwell urges the SEC to consider the scientific evidence and economic analysis that shows that climate change is a financial and material threat to industry, so that it may segment, critically examine, and revise individual provisions of the Final Rules. This process will better reflect an effort to protect investors and benefit the economy, as opposed to rescinding the Final Rules in their entirety.
Scientific objection to the rescission of climate-related disclosure rules
Woodwell’s research demonstrates that climate change and warming temperatures drive environmental hazards that threaten the everyday lives of Americans, as well as industry and the economy. Winter storms, extreme precipitation, and summer heat waves are just some examples of these increasingly frequent and intense weather patterns.
Extreme heat that exceeds the limits of what the human body can tolerate already occurs in the hottest parts of the world. Parts of every continent, except Antarctica, will see a rapid increase in these heat events under only moderate global warming scenarios, threatening outdoor working conditions in industries like agriculture and manufacturing. Wildfires will increase in frequency and intensity under these heated conditions, contributing to life-threatening poor air quality and further workplace disruptions, as well as the destruction of homes and buildings that require large insurance payouts. This warmer air holds more water vapor, which in turn condenses into clouds and drops flooding rains, similarly threatening physical infrastructure to the financial detriment of the insurance industry. Increasing heat also thaws permafrost, which causes infrastructural damage estimated at $37 billion to $51 billion in the state of Alaska under intermediate and high emissions scenarios, respectively.
Increasingly unpredictable weather patterns are already having a detrimental impact across the economy. Almost all sectors, including agriculture, real estate, insurance, and energy, are vulnerable to these climate risks. A hotel chain may have assets in areas that are vulnerable to coastal flooding, agriculture companies may see labor disruption due to extreme heat, and insurance companies may see rising property and casualty insurance payouts. Without productive action, industries will continue to suffer the financial consequences, making their climate disclosures critical knowledge to the average investor.
The critical role of climate risk to industry
The ever-escalating and increasingly frequent number of climate-related disasters has cost the United States upwards of $1.5 trillion dollars within the last decade. Recently, over 3,800 companies have reported a combined $2.9 billion in losses due to extreme weather, such as from heavy precipitation, operational shutdowns, and increased direct costs, in a single year. In 2024, natural catastrophes in the United States caused an estimated $145 billion in economic losses, of which $80 billion was insured. Further, insurers’ costs were higher in areas at higher climate risk, with the highest risk ZIP codes having about a $24,000 average claim as compared to an average claim of about $19,000 in the lowest risk ZIP codes. 83 percent of U.S. insurers recognize these dire circumstances and have widely adopted the Task Force on Climate-Related Financial Disclosure framework to provide disclosures across risk management, strategy, governance, and setting and tracking metrics and targets.
The proposed rescission attempts to argue that climate-related disclosures do not represent material risk, which it defines as “a substantial likelihood that a reasonable investor would consider it important or significant in deciding whether to buy or sell a security.” However, the flood of public support in response to the 2022 proposed climate-related disclosure rules stands in direct contradiction to that claim: 95 percent of the 320 institutional investors who issued a public comment supported its key provisions. Blackrock, Vanguard, and Fidelity, and State Street, four of the world’s largest institutional investors, as well as the SEC’s own Investor Advisory Committee supported the rulemaking while calling for some revisions, most of which were adopted in the Final Rule. One of the world’s leading independent asset managers, Wellington Management, which oversees over $1 trillion in assets, stated that climate disclosures are “critical” to its “ability to make informed investment decisions on behalf of our clients.” It also emphasized that its current evaluation of the financial impacts of climate change on issuers are limited by “inadequate information and the absence of a standardized framework for disclosure.” In total, at least 129 investors used their comment letters to describe the benefits of the rulemaking.
Further, the Adopting Release outlines a plethora of specific evidence and examples of the material benefits provided by climate disclosures that the proposed rescission chooses to ignore, including improved investment firm revenues, better aligned capital structures, lower loan losses and higher profits for banks, improved asset pricing and allocation of capital, and reduced costs for investors and companies to analyze climate-related information to inform investment strategy.
Rescission impacts on investor protections, financial risk, and climate resilience
This proposed rescission provides no basis to contradict the evidence presented in the March 2024 release that demonstrates how the vast majority of investors would benefit from a set of standardized climate-related disclosures. The FCC v. Fox Television Stations, Inc. ruling determined that any federal agency policy that aims to replace a previous policy by claiming it is based on incorrect factual findings must provide a detailed justification. This ruling was cited in the case National Association of Manufacturers and Natural Gas Services Group v. SEC, in which, in a very similar fashion to this proposed rescission of climate-related disclosure rules, the SEC rescinded a rule before it took effect. The judge in this case determined that without adequate evidence or explanation of the disregard of the factual findings of the previous policy, the rescission was “arbitrary and capricious.” Similarly, this proposed rescission of the climate-related disclosures rules does not detail why the factual determination of the Final Rules, which saw that the 2010 voluntary disclosures regarding climate risk were inadequate, is incorrect.
Under the 2010 rules, the quality and format of voluntary disclosures vary widely, with many companies presenting their climate plans and challenges through curated reports that more so reflect marketing strategies rather than a financial risk disclosure submission to the SEC. The Adopting Release is intended to provide a standardized framework and metrics to make these disclosures clear and comparable. While a line of argument in the proposed rescission claims that comparability is not an adequate reason to require these disclosures, former SEC Chair Jay Clayton has previously stated: “Disclosure and the concepts of materiality, comparability, flexibility, efficiency and responsibility have been, and continue to be, the bedrock principles that make our public capital markets the most fair and efficient markets in the world.” By rescinding the Final Rules, the SEC makes it more difficult for investors to compare across companies and make informed investment decisions.
One argument presented by the SEC in this proposed rescission is that the disclosure rules are far too granular, which they claim will overwhelm investors with unnecessary information. On the contrary, current business disclosures are often not detailed enough to present a useful method by which investors can adequately assess a company. Enhanced standards with specific details regarding market risk disclosures, quantitative analysis, and other granular statistics will root these disclosures in materialities. In the modern era of artificial intelligence (AI), innovations such as digital tagging offer accessibility to less financially literate investors. All things considered, it is better to provide a plethora of information for the sake of transparency than none at all.
There is also a benefit in the ability to compare companies across countries, especially as the world experiences an increasingly global market. Although international standards have been scaled back in recent years, they are more robust than the voluntary 2010 climate disclosure rules in the United States. The International Sustainability Standards Board (ISSB) is in the process of creating global standards for climate-related financial disclosures, which would make the investing landscape much simpler for companies and investors alike. Mandating climate disclosures in a format consistent with the ISSB standards would provide an ease of comparability that would significantly lessen the burden on investors. Other governing bodies such as the European Union and the State of California have already implemented their own climate-related financial disclosure rules in attempts to align with the ISSB. By not providing climate disclosures comparable to these international standards, US companies will be less attractive to the global investors who are concerned about climate financial risk, ultimately leading to a loss of benefits that outweigh the cost of disclosure.
The SEC argues that the costs of the implementation of these disclosures far outweigh the benefits, and in the process disregards all of the studies that the SEC previously identified to support the cost-benefit analysis of the Adopting Release. It is especially telling that the SEC highlights the increased costs on registrants as a result of the Final Rules while negating the increased costs on investors as a result of the rescission. Further, the proposed rescission focuses on increased costs of legal fees for registrants while failing to recognize that as other countries require disclosures, compliance with the rules will be less costly and less burdensome on the registrants. The proposed rescission does not contain a full and fair economic analysis of these disclosure requirements, despite the Adopting Release providing a detailed roadmap on how to reduce the burden and costs of this rule.
On the subject of policy, Section 7(a)(1) of the Securities Act of 1933 authorizes the SEC to require registration statements that contain any information it deems “necessary or appropriate in the public interest or for the protection of investors.” The Securities Exchange Act of 1934 further specifies SEC authority as “disclosure, investor protection, and fair markets,” which clearly extends beyond strictly financial disclosures. This contradicts the proposed rescission, which states: “disclosure mandates under the Federal securities laws had to relate to the financial condition of, and matters of economic significance to, the disclosing company.” Even if the authority of the SEC was as narrow as the proposed rescission describes, this argument is still insufficient as the Final Rules do fall within the purview of financial reporting. In response to the proposed climate-disclosure rule in 2022, 15 former senior SEC officials, 17 senior scholars of corporate, securities, and administrative law, and several leading advisors for public companies submitted a comment letter that outlined their “unanimous view the SEC has clear statutory authority to mandate additional climate-related disclosures for publicly traded companies.”
Additionally, the proposed rescission claims that these climate disclosure requirements do not address investor protection, but rather surround the “divisive and unsettled political and social issue of climate regulation.” However, the Final Rules do not dictate how companies respond to climate change, they simply call for climate-related disclosures. The rules only require disclosures regarding specific transition plans or goals if a company has previously created them, they do not dictate a requirement to create those plans. Following the proposed rescission’s line of logic that these disclosure rules unjustly “regulate issuers’ internal affairs” and thus must be rescinded, all corporate disclosure requirements would need to be rescinded. This is because any disclosure requirement may lead to a change in conduct: if a company reports disappointing earnings, it naturally follows that an investor may demand changes to its business strategy. However, this does not mean that the disclosure mandated changes to the operations of that company. This argument sets a dangerous legal precedent if the climate-disclosure rules are rescinded on these grounds, threatening the authority of the SEC to dictate any and all disclosures.
Finally, climate regulation is not simply a “divisive and unsettled political and social issue,” as the proposed rescission claims. It is also a legitimate basis on which to analyze investment strategies. Not forgetting the robust scientific evidence presented earlier in this comment that outlines the material risk associated with climate change, “socially responsible investing” is a well established investment strategy that considers both financial and ethical goals. There is no reason that the information presented in these climate risk disclosures is not material simply because it also integrates social or environmental elements that many investors consider important to their investment portfolio. By acting ethically and responsibly in light of the increased transparency provided by these climate-related disclosures, companies can increase investment and investor return, as well as limit their contributions to the ever-worsening climate crisis that threatens their operations and financial prosperity.
Conclusion
The Securities and Exchange Commission’s proposed rescission of climate-related disclosure rules contradicts the congressionally obligated responsibilities of the SEC by threatening investor protections. The overwhelming evidence demonstrates the benefit that these disclosures provide to both investors and registrants as climate risk increasingly threatens financial stability.
Woodwell urges the SEC to review the Final Rules on a provision by provision basis to address its specific concerns. Despite the proposed rescission’s claims that “the individual items of disclosure in the Final Rules are pieces of a larger whole and cannot operate sensibly without the others,” the Adopting Release specifically outlines how portions of the Final Rules can be severed and individually revised. This process could offer opportunities to clarify certain aspects of these rules, enhance flexibility, or provide companies with more time to prepare for these disclosures as a way to decrease burden. Woodwell suggests following this guide offered by the Adopting Release as the SEC moves forward in its revision of these climate-related disclosures, rather than rashly rescinding the rule in its entirety. It is imperative that these actions are in pursuit of the protection of investors and American financial markets, rather than political motivations.
Dr. Zhongqi Chen has dedicated his career to understanding how fish handle environmental stress. Now, as a Research Scientist at Woodwell Climate Research Center, he is bringing his expertise in fish physiology, stream ecology and data sciences to the Science on the Fly project as the new Science Lead. We sat down with Zhongqi to discuss why a two-degree water temperature shift is a game-changer for wild trout, how local water sampling scales up to global conservation, and why the single bottle of water collected by our community scientist is a critical piece of a much bigger puzzle.
Read more on Science on the Fly.
For more than 40 years, Woodwell has dedicated itself to objective scientific analysis for the benefit and safety of people and nature. The science we conduct seeks to mitigate and adapt to the amplified threats of extreme weather events, wildfire, food insecurity, and others due to our changing climate. These threats pose immense economic consequences. Thus, not only do we have traditional STEM scientists, but also economic experts who ensure accessible and applied research. We understand the direct economic and societal impacts that our research has on the American people, and we understand that these benefits extend not only from the subject matter of our organization but from all scientific exploration and innovation in the fields of health, technology, and engineering, amongst others.
Woodwell strongly opposes OMB’s proposed rule of Federal Finance Assistance as a whole, and most specifically the provisions outlined below (§200.202; §200.204; §200.205; §200.340; §200.432; §200.454; §200.461; and §200.220). The stated objective of these revisions to “improve transparency, accountability, and oversight for Federal awards across the Federal government” directly contradicts the content of the provisions that color this proposal. “Oversight” is the only objective that this proposal truly strives for, yet the distinction of political oversight rather than scientific oversight is conveniently absent. The space of federally funded scientific research is already heavily regulated, and this proposed rule threatens to suffocate it beyond recovery. This increase in faulty, politically motivated science would negatively impact American livelihoods, the economy, and national security.
§200.202 – Programs Must Align with Administration Priorities
By requiring every grant program to be designed so its goals “align with administration policies and priorities,” the Administration seeks to align research with its own interest areas, manipulating scientific investment for partisan priorities. Tying federal financial assistance to the shifting priorities of any given political administration inherently threatens the continuity of essential, objective research and risks defunding critical studies based on partisan agendas. Subordinating independent, data-driven scientific inquiry to political mandates undermines scientific integrity, jeopardizes vital longitudinal datasets, and ultimately deprives policymakers and the public of the unbiased evidence necessary to effectively combat the very real escalating, evolving, and emerging concerns related to climate, public health, biomedical research, technology, and others that may be inconvenient for an administration’s agenda.
§200.204 – Grant Competitions Exempted from Public Notice
Transparency is an underpinning of scientific integrity. By allowing for exceptions to not post grant opportunities on Grants.gov under the condition that the head of an agency subjectively deems the opportunity as serving the “national interest,” this provision sows distrust within the scientific community and the general public. In order to best serve the national interest, the selection process should be open to competition. Candidates hand-picked by the agency will create grantees who are subject to the political whim of the Administration, rather than to the true “national interest” of the American people. Moreover, this provision fundamentally contradicts the “aim to ensure that basic American principles of equality and equal opportunity are upheld throughout all stages of the award making process” that is advertised in this proposed rule, as all applicants are not equitably provided the opportunity to apply for these specific grants.
§200.205 – Political Appointee Review of Grants
The foundation of credible, high-impact climate science relies entirely on the objective, merit-based peer review of research proposals by qualified scientific experts. Granting political appointees the authority to review and potentially cancel federal grants introduces dangerous partisan bias into the scientific process, threatening to derail critical, long-term research that may be politically inconvenient but is vital for national and global security. This provision fundamentally undermines scientific independence, degrades the integrity of federal financial assistance, and jeopardizes our nation’s ability to respond to evolving and emerging threats, like the climate crisis, with unbiased, data-driven solutions.
§200.340 – Grant Termination
This provision allows an agency to cancel a grant mid-project if it determines that the award no longer aligns with agency priorities or the “national interest.” Complex scientific inquiry inherently requires multi-year planning, continuous data collection, and significant, sustained resource investment. Broadening federal agencies’ and political appointees’ authority to unilaterally terminate grants for reasons unrelated to grantee performance or compliance, such as shifting administrative priorities, introduces uncertainty into the research ecosystem. Similar attempts to freeze grants for subjects and institutions disliked by the President throughout 2025 resulted not only in tremendous economic losses and waste of previously approved investments, but also a critical loss of scientific knowledge.
By subjecting researchers to the whim of the Administration, scientists will hesitate to publish findings important to the American people that challenge the status quo and may inform necessary scientific revisions to long-term policies. By suffocating any hint of scientific dissension, the Administration will promote faulty science that will put America’s scientific reputation, as well as American lives, in harm’s way. To preserve the continuity, stability, and global competitiveness of American scientific innovation, we urge the removal of these expanded termination powers to ensure that merit-based research is protected from abrupt and unwarranted cancellations.
§200.432; §200.454; §200.461 – Indirect Costs
These provisions significantly limit, or openly ban, the use of federal grant funding to cover the vitally important indirect costs of conference attendance, journal subscriptions, and publications, among others. Woodwell strongly opposes the outlined preference towards institutions with lower indirect cost rates in this proposed rule. These costs support the competitive nature of a project through the maintenance of necessary equipment and facilities, as well as public-facing collaboration and debate.
Without the opportunity to share research with other experts, and the general public, researchers lose out on vital knowledge and feedback that leads to improved and more legitimate scientific conclusions. Without the financial ability to publish findings, a scientific experiment may never be reproduced and thus not be seen as a legitimate basis on which to conduct additional research on complicated topics. The myriad of indirect costs necessary for a successful project present extraordinary financial barriers that will make the American federally funded research landscape inherently inequitable, shutting out scientists and institutions who would not otherwise be able to afford these assets.
§200.220 – Prohibition of International Collaboration
This provision, which prohibits the spending of federal funds in relation to foreign collaboration, including on travel or indirect costs, would severely inhibit the ability of the United States to scientifically compete on a global scale and to work with international counterparts who often have specific skills or resources that facilitate and amplify scientific outcomes and innovation. The most pressing scientific challenges of our time, from tracking global climate patterns and biodiversity loss to mitigating public health crises, are global and rely on the exchange of data, resources, and expertise across nations.
Prohibiting federally funded researchers from partnering with international colleagues would isolate the American scientific community, deny experts access to vital global datasets and specialized facilities, and severely stifle innovation. Such a restrictive mandate threatens to dismantle decades of cooperative progress and will inevitably force the United States to cede its position as a global leader in scientific discovery.
The range of countries that fall under this provision of banned collaboration is exceptionally wide and highly variable over time: the qualifying characteristics are those countries considered foreign adversaries or those subject to sanctions or restrictions related to national security, defense, or intelligence activities. Under these rules, even the 17 European Union countries subjected to semiconductor export restrictions at the end of the Biden Administration would be banned from scientific collaboration. The limited outlined exceptions, as dictated by a political appointee, are not sufficient to protect international collaboration.
This provision would override the existing processes to prevent undue influence or security threats, as well as the processes for granting exceptions. Specifically, the restrictions would disqualify federally funded research from the fundamental research exclusion. This exclusion has long exempted basic or applied research from export control regulations to allow for the free exchange and publication of research results. Instead, researchers would need to apply for licenses at the State Department and the Commerce Department’s Bureau of Industry and Security. The proposed changes would significantly increase the costs, timelines, and workloads of international collaboration for these researchers as well as these federal agencies.
Impacts on Climate Resilience and Risk Mitigation
In the field of climate science and risk mitigation, this proposed rule would have exceptionally deep impacts. Although activities such as extreme weather tracking and preparedness, sustainable agriculture, and wildfire are all vital to the lives of everyday Americans, this Administration has a documented history of repressing these efforts in favor of harmful industry activities, including increased logging in previously protected areas.
Fire is a natural and integrally important process in the life cycle of our forest ecosystems. Woodwell scientists study and promote traditional methods of fire management of local and indigenous peoples who recognize the environmental benefits of fire via prescribed burns to reduce the buildup of natural fuels. Conversely, this Administration emphasizes fire tactics that have led to oversuppression, contributing to the buildup of dry fuel on the forest floor. Combined with the ever-warming temperatures destabilizing atmospheric conditions and extreme drought, increasingly frequent lightning strikes ignite these more flammable forests. Without regular fires to periodically clear out this fuel, the land has become more vulnerable to intense and widespread fires that present extreme threats to human health. Over 15,000 deaths have been attributed to wildfire particulate matter over the last 15 years. Without federally funded scientific research to bolster natural wildfire solutions, Americans are increasingly at risk.
Like most climate sciences, wildfires are not constrained by political boundaries. This means that international collaboration is critical to our work at Woodwell. This is especially true of our Arctic partnerships with communities across Alaska, Canada, Mongolia, and more as we study traditional wildfire mitigation tactics in the boreal forest region. Woodwell research has found that from 2006 to 2020, the economic burden linked to climate change-induced wildfire particulate matter alone accumulated to $160 billion. This potential economic payoff of exploring alternative solutions is only one example of the startling economic benefits of wide-reaching scientific research.
The Critical Role of Federal Financial Assistance to Economic and Global Competitiveness
Between the National Institutes of Health (NIH) and the National Science Foundation (NSF), the grants so far frozen or terminated since 2025 have resulted in economic loss across the United States estimated at $2.8 billion.10 The total job loss is estimated at more than 13,000. Texas faces the greatest economic loss of $366.1 million and around 2,000 jobs lost.11 Massachusetts faces an estimated $126.9 million in economic losses and 555 jobs lost. These losses are not exclusive to states on either side of the aisle: they are all-encompassing.
No institution is safe from these financial threats: two-thirds of land-grant universities and nearly half of all Historically Black Colleges and Universities have been affected. Even community colleges have had funding targeted for termination. Public universities and colleges suffered the steepest losses, with financial losses from grant disruptions totalling an estimated $2.1 billion. According to NSF data, the cancelled grants disproportionately affected early career researchers, women, people of color, and those with disabilities.
Private funders cannot step in to fill this funding gap. Basic research generates knowledge that diffuses beyond its original source and the current time, ultimately benefiting competitors. This “knowledge spillover” is great for the broader economy and thus broader population, but bad for companies trying to capture a return on their investment, leading the private sector to underinvest.
Government investments in scientific research and development are, and have historically been, an integral part of our nation’s economy, with returns estimated between 150% and 300% since World War II. In 2024, the knowledge and technology industries in the United States produced $3.3 trillion in added value, accounting for 11% of the U.S. GDP. From 2017 to 2024, the field’s financial contributions to the economy grew faster than the domestic U.S. nonfarm economy as a whole.
Federally funded research not only yields financial returns, but also provides for increases in our standard of living via biomedical advancements, a more favorable startup environment with increased job opportunities, and enhanced national security through the creation of advanced defense technologies. Economy-wide, long-term returns are calculated at $5 for every $1 invested in research and development. Further, $1 of public investment in research and development has been found to yield an additional $3 in follow-on private research and development investment. Economic researchers have concluded that the United States should invest much more in science and innovation than it does currently, especially given findings that federally funded research and development yields substantially higher returns than other forms of federal investment, including even physical infrastructure.
In cutting federal funding for scientific innovation, the United States puts its status of technological dominance in jeopardy. China’s annual research and development growth rate has rapidly outpaced that of the United States by more than 200% for over two decades. In 2024, the United States and China were neck and neck as the top producers of knowledge and technological industry, with $3.3 trillion and $2.9 trillion, respectively. However, that same year, China topped the US as the largest knowledge and technological manufacturing producer with 10% more of the global share.25 Under current projections, Chinese scientists will overcome US dominance in the fields of AI, semiconductors, materials, and high-performance computing in only 5 years. When considering the implications of this Federal Financial Assistance proposed rule, with its many problematic and restrictive positions, it can only be assumed that China’s dominance would be more inevitable and even faster-approaching than ever before.
Conclusion
The proposed revisions of the OMB Guidance for Federal Financial Assistance abandon scientific integrity. Woodwell urges the Office of Management and Budget to rescind the proposed revisions of the Guidance for Federal Financial Assistance so that science remains independent and free of any partisan agenda. The politicization of science is completely contrary to scientific value, and will irreparably damage America’s international reputation in this field. Most importantly, the stifling of scientific innovation will endanger American citizens through detrimental impacts on livelihoods, the economy, and national security.
HOWLAND, Maine — Scientist Kathleen Savage leaned out from the basket of a boom lift, a red safety helmet perched on her head.
She sealed a few needle-covered stalks from an Eastern Hemlock tree inside a clear plastic cylinder and pulled out her phone. On the screen, a meter rose and fell as the level of gases inside the cylinder fluctuated. The question she was asking: What were the microscopic bugs on the stalks and leaves doing in there?
But looked at another way, it could also buy the planet critical time as the world races to address the climate crisis.
“These small, microscopic organisms are everywhere,” she said. “When you translate that to an entire forest, they add up and pack a big punch.”
Savage, a senior research scientist at Woodwell Climate Research Center in Woods Hole, is part of a team of experts trying to better understand which of these microscopic bugs — or, as they’re technically called, microbes — consume potent methane gas, and whether they could eventually be marshaled as a tool to combat climate change. Methane is among the world’s most potent greenhouse gases, accounting for roughly 30 percent of global warming. Once emitted, it only lasts in the atmosphere for a little over a decade, but in that time, it is 80 times more potent than carbon dioxide.
Read more on Boston Globe.
A recent study provides new evidence of increasing life-threatening heat waves, focusing on the accumulation of dangerous heat that is known to cause severe health impacts. Researchers have developed a new metric – the accumulated dangerous heat index (ADHI) – that includes the combined effects of temperature and humidity to identify summer hours that surpass a dangerous threshold. Hourly exceedances are summed over each day, month, and season across the Northern Hemisphere.
Trends in ADHI are attributed to temperature, humidity, or a combination to better understand the cause of increased life-threatening heat conditions regionally. The researchers found areas historically prone to excessive heat have experienced longer-lasting, more intense, and expanded dangerous conditions, with some regions becoming uninhabitable. They found temperature to be the dominant factor driving increased ADHI during the daytime in most regions, while increasing humidity plays a more important role at night.
“We know that extreme heat causes by far the most fatalities of any type of hazardous weather, and it is crucial that we are able to fully assess and understand its risks,” said the lead author, Dr. Jennifer Francis, Senior Scientist at Woodwell Climate Research Center. “Brutal heat waves have already wreaked havoc across the Northern Hemisphere in 2026, even though summer has barely begun. Record-smashing temperatures are blamed for thousands of deaths in Europe, while dangerous heat invaded major eastern cities of the U.S. during celebrations of the 250th anniversary of the nation’s independence.”
“Escalating extreme heat is putting communities, ecosystems, and livelihoods at risk across many areas of the globe,” added co-author Dr. Natasa Skific. “The Accumulated Dangerous Heat Index gives scientists a new and straightforward tool to warn leaders and help them prepare for life-threatening heat events.”
Co-author and MIT Research Scientist Dr. Judah Cohen noted, “As we found in our companion study that focused on severe winter conditions, the warming Arctic also appears to be contributing to the longevity of dangerous heat waves in many areas at lower latitudes.”
The findings in this new study provide further motivation to reduce emissions of heat-trapping gases, and the regional trends will assist decision-makers and planners in preparing for a future with a better understanding of the threats from deadly heat.
Find the full paper here.
In 2023, Canada experienced its worst wildfire season to date. Fires raged across all 13 provinces and territories, breaking national records for burned area and carbon emissions.
Fires have a complex impact on both the global and regional climate. While fires contribute to warming through the release of stored carbon from trees and soil, they also create an unexpected cooling effect. Postfire changes to vegetation composition and coverage have an impact on albedo—the amount of sunlight reflected by a surface. The absence of the tree canopy no longer conceals snow, thus reflecting more incoming solar radiation which can cool the local environment.
“If you have a more reflective surface, like ice or snow in particular, it’s going to reflect more of that sunlight back to space, and so it’s going to have a cooling effect compared to if it wasn’t there,” says Rogers. “Because if it wasn’t there, then the darker land or the ocean would have absorbed more of it and heated.”
These changes in albedo have historically partially offset the warming caused by fire-induced emissions; however, climate change is disrupting this balancing effect.
In a newly published paper, co-authored by Woodwell Climate Senior Scientist Dr. Brendan Rogers, researchers found a 29% decrease of the regional climate-cooling impact of boreal wildfires since the 1960s. This represents one aspect of a critical shift in past ecosystem dynamics—not only is climate change responsible for rising global temperatures, but it is also weakening the natural mechanisms that once regulated this rise.
“The consequences of retreating snow cover become especially clear at the scale of individual fires,” says Max van Gerrevink, lead author of the study and postdoctoral researcher at Wageningen University and Research. “Historically, nearly half of all Canadian wildfires reached a natural climatic break-even point, where snow-driven surface cooling fully offset the warming caused by fire-related emissions. Today, that proportion has fallen dramatically, to only about one in four or five fires.”
The study used remote sensing to map the predicted changes in surface albedo over a 70-year postfire period assuming carbon dioxide emissions maintain current levels until 2050, then decrease, eventually reaching net zero by 2100. For Canada’s boreal forests, this means earlier snow disappearance rates, later snow onset and warming temperatures—all of which impact albedo.
When considered alongside a previous study co-authored by Rogers, the decreasing power of the cooling effect is projected to continue even further.
“Compared to pre-climate change, we’re talking about, over the next several decades… a 50% to 60% reduction due to earlier snowmelt,” says Rogers. “It’s important to be aware of this when you’re thinking about ‘What does this mean for the earth system,’ and ‘How might you manage these fires.’”
The implications of this finding are of growing concern, as warmer and drier weather conditions associated with continued climate change are subjecting Canada’s boreal forests to more severe and longer fire seasons. During the 2023 Canadian fire season, an estimated 647 teragrams of carbon were released—a number comparable to the annual fossil fuel emissions of the largest-emitting nations and only exceeded by India, China and the United States.
With more carbon being released annually from worsening fire seasons and a diminishing climate-cooling effect, Canada’s boreal ecosystems are facing an amplified threat from exacerbated warming. As the study found, the subsequent weakening of the climate-cooling impact implies that contemporary boreal fires are, on average, twice as likely to result in a net climate-warming influence.
“Fires both warm through greenhouse gas emissions and cool through changes to land surface albedo,” says Rogers. “The cooling impact is declining, but the carbon impact is not, and it might even be growing because we’re seeing more permafrost emissions after wildfires.”
Rogers stressed the importance of considering albedo and carbon as two parts of a larger equation rather than two factors that act in opposition. This is due to the fact that albedo’s impact is limited to the geographic area where these fluctuations occur and therefore is not as widespread. Furthermore, he emphasized the need for measures that directly target carbon emissions in order to comprehensively address climate change.
“The reality is the spatial footprint from the albedo changes in Canada have very little impact on us down here in the lower 48 or other parts of the globe,” says Rogers. “And I think that’s important, because the carbon impacts are global and do impact us and everyone else on the planet.”
