Comment on FR Doc # 2026-10729

RE: Comment for Zero-Based Regulating Proposed Rule [Docket No. DOE-HQ-2025-0603] Dear Secretary Wright, On behalf of all of our youth clients, including our clients in Lighthiser v. Trump and Venner v. EPA, and in the interest of America’s children and youth, Our Children’s Trust provides these comments on the DOE’s “Zero-Based Regulating” proposed rule which would facilitate fossil fuel development that is unjustified by law, science, economic prosperity, energy security, or any other reason, by sunsetting environmental and energy efficiency regulations. In addition to being illegal, this proposed rule would facilitate the unleashing of fossil fuels. The consequences of this proposed rule would worsen the adverse health effects of fossil fuel pollution our clients are currently suffering directly through their inhalation and exposure to the localized pollution and the heat-trapping greenhouse gases from fossil fuels, resulting in further dangerous disruptions of the climate system on which these youths’ health and lives depend. As the Nation’s only law firm dedicated to representing children and youth whose constitutional rights are being infringed by government conduct that causes and contributes to climate change, we write to advise you that your proposed rulemaking must be consistent with protecting the rights to life, personal security, family autonomy, bodily integrity, the practice and transmission of cultural and religious traditions, children’s equal protection of the law, and free exercise of religion. U.S. Const. amend. V, XIV, § 1, I; 42 U.S.C. § 2000bb-1 (Religious Freedom Restoration Act). Here, the DOE is engaged in unconstitutional rulemaking to implement the President’s Executive Orders 14154, 14156, and 14261 in violation of U.S. Const. amend. V, XIV, § 1, I; 42 U.S.C. § 2000bb-1 (Religious Freedom Restoration Act). This rulemaking effort, also violates the separation of powers, by exceeding the authority the DOE has been delegated by Congress and by engaging in conduct that has a significant effect on U.S. public health, welfare and the economy, while lacking any scientific integrity as Congress has mandated. Congress has not given the DOE the statutory authority to deprive children and youth of their fundamental rights listed above, nor does the DOE have the delegated authority to interpret statutes in a manner that contravenes the U.S. Constitution. Please see attachment. Sincerely, /s/ Julia Olson Co-executive Director and Chief Legal Counsel julia@ourchildrenstrust.org Our Children’s Trust P.O. Box 5181 Eugene, OR 97405