RE: Scenarios Used in NGFS/OSFI Climate Risk Assessments have been Retired as Implausible

ATTN: Superintendent Routledge, OSFI
CC: Olaf Sleijpen, Chair, NGFS

See the PDF version for the full CC list.

Sirs,

The recent release of the Guide for supervisors: Integrating climate and nature-related risks into prudential supervision, claims to be “Reflecting supervisory developments and experience since 2020, the Guide provides a practical and adaptable reference for integrating climate and nature-related financial risks into prudential supervision.”

Within these documents, we do not find reference to the recent material changes in climate science and climate economics of the past year several of which are documented in our August 19, 2026, open letter to OSFI1:

  1. The official climate science modelling community has retired the catastrophic climate scenarios known as SSP3-7.0, SSP5-8.5, and RCP 8.5.
  2. The climate economics paper which forecast catastrophic global economic impacts due to climate change known as Kotz et al. (2024) has been formally withdrawn by the journal Nature.
  3.  The 2004 paper known as “Stabilization Wedges” which claimed annual ‘wedge’ diminishmentof fossil fuel use could be replaced by renewables to reliably achieve decarbonization has beenshown to be inaccurate – we do not have suitable replacement technology. It is not a matter ofpublic will or national policy.
  4.  The burgeoning efforts to scientifically attribute extreme weather events to human-inducedclimate change has been shown by Roger Pielke, Jr.to be a form of computer modelling where“under the WWA methodology any time series with a trend, up or down, — and in any context— can be “attributed to climate change.”2
  5.  So-called “green” or “clean” technology is provably more energy intense, requires far morerare/critical minerals than conventional technologies and thus more mining and processing, andthe produced devices (i.e. wind turbines, solar panels, EVs, batteries) are impractical and energyintensive to recycle. Due to the nature of rare mineral mining in developing nations, humanrights violations like child labour are often involved; nature is often punished in such countrieswith no environmental standards.

The latest documents in “Guide for supervisors: Integrating climate and nature-related risks into prudential supervision”3 (hereinafter “Guide”) do not appear to reflect these material changes.

Without the climate catastrophe scenarios of SSP3-7.0, SSP5-8.5, and RCP 8.5, there is no climate emergency, something that The Netherlands-based international network of CLINTEL scientists and scholars have been saying since 2019 in the World Climate Declaration.4 Thus the alleged climate crisis and Net Zero urgency are invalidated.

Continue reading in the PDF version.

Open Letter to OSFI and NGFS on New Guide Climate and Nature RisksDownload