A draft report, “Global Climate Change Impacts in the United States,” is being offered by the Bush administration as a “single coherent analysis of the current understanding of climate change science.” Written in plain English and full of graphic illustration, the Unified Synthesis Product presents a range of troubling consequences we can expect in the US from climate disruption. A closer look reveals that important procedural corners are being cut, presumably to streamline production for a September or October debut, inviting wide criticism. What is the White House motive behind this compelling digest of climate impacts? While the effort is laudable and the authors some of the best in the land, it is difficult not to wonder why this administration is rushing to release a portrayal of climate-related impacts that, taken together, can only be viewed as a call to action by an administration known for climate inaction.
by Anne Polansky, Sr. Associate (CSW Director Rick Piltz is on a book-writing sabbatical until the end of August)
On July 17, the Climate Change Science Program (CCSP) published in draft electronic form for review and comment, a “Unified Synthesis Product” (USP) titled “Global Change Impacts in the United States.” This report is not one of the set of 21 “Synthesis and Assessment Products” (SAPs) that are the main staple of the entire interagency federal climate program under the two-term Bush administration, nor should it be confused with the Scientific Assessment of the Effects of Global Change on the United States published on May 29, in the nick of time to meet an August 2007 court order (see related posts: here, here and here) after the federal government was sued for noncompliance with Sec. 106 of the Global Change Research Act to produce a national assessment of climate change impacts. Rather, the USP was apparently conceived of in the early weeks of 2008 and initiated with a Decision Memo approved Feb 29, 2008 by NOAA head Vice Admiral (ret.) Conrad Lautenbacher noting “discussions with the White House.”
Unlike the 21 SAPs—11 of which are long overdue and on a fast track for publication before the presidential term ends—both the “Scientific Assessment” and the “Unified Synthesis Product” are products of the Committee on Environment and Natural Resources (CENR) of the National Science and Technology Council. (The CENR’s Subcommittee on Global Change Research is the entity that coordinates the activities of the CCSP, and has its origins in the Global Change Research Act of 1990). This distinction is important because the National Science and Technology Council’s CENR has representation that goes above and beyond that of the CCSP to include not just the dozen or so agencies of the CCSP but also six different entities of the White House including OMB, CEQ, and OSTP, the Domestic Policy Council, the Council of Economic Advisors, and the National Economic Council.
The Feb 2008 memo (emphasis added) reads:
1. ACTION-FORCING EVENT:
In view of recent events including release of the IPCC Fourth Assessment Report and completion of twenty-one Climate Change Science Program (CCSP) Synthesis and Assessment Reports, discussions with the White House have resulted in a decision the National Oceanic and Atmospheric Adminstration (NOAA) should produce a synthesis document that will integrate and evaluate the findings of the U.S. CCSP in the context of current and projected global climate change trends.
NOAA proposes to establish the Unified Synthesis Product Development Committee (USPDC) under the provisions of the Federal Advisory Committee Act (FACA) to assist in developing the report needed to address this development.
To this, a comment and a question. Comment: The “completion” of the 21 SAPs is not a recent event! In fact, some most familiar with the CCSP have strong reservations that the remaining SAPs will be finished before Bush leaves office. Question: What was the nature of the “discussions with the White House” ? That is, who in the White House was interested in producing this report, especially given that the “Scientific Assessment” of climate impacts in the US was already underway to satisfy the terms of Sec. 106 of the GCRA and, more importantly, the US District Judge who ordered a second national assessment of climate impacts that under law was due in 2004, four years after the 2000 publication of the US National Assessment of the Potential Consequences of Climate Change? Given the well-established legacy of the Bush administration in resisting nearly every attempt to address climate change squarely and in line with the science, we must ask, what is the thinking and motive behind the order for this bold and assertive document that many readers are likely to view as a call-to-action? Given the Bush-Cheney track record on all previous calls to action to address global warming, what gives?
The various publicly available documents charting the steps taken to produce the USP reveal little about the underlying objective for this report. Normally, a Prospectus would be prepared that would explain the purpose of the report and its origins and topics to be covered, however, a prospectus was not done for the USP.
This raises a second question: Is the USP an official “Synthesis and Assessment Product,” subject to the Guidelines for for Producing CCSP SAPs? The answer appears to be both yes, and no.
Evidence supporting the “yes” answer includes 1) the unequivocal declaration in the report’s legally required charter establishing the “Synthesis Product Development Committee” that the document is a Synthesis and Assessment Product, and 2) the description of the USP as a Synthesis and Assessment Product in the July 17 invitation to comment.
Evidence supporting the “no” answer lies in the lack of consistent adherence to the normal SAP Guidelines. The lack of a prospectus is the first glaring omission, and helps to explain the lack of stakeholder input to the USP, as one of the very first steps is to “solicit input from users and other stakeholders.” (This is a good place to note that of the two USP planning meetings so far and one planned for Woods Hole this week, time for public input is scheduled for a half hour beginning at 8 am, during registration and coffee-and-bagels. Needless to say, no one has showed to offer stakeholder input.) Secondly, the Guidelines require that first drafts of SAPs be peer-reviewed before going out for public comment; however, the USP is being reviewed by a “Blue Ribbon” panel in parallel with the public review (allowing for a collapsed schedule but inconsistent with protocol). Third, the CCSP SAP Guidelines state: “The lead agency(ies) post the second draft of the product for public comment for not less than 45 days.” Instead, a first, non-peer-reviewed draft was posted with a 28-day comment period, cutting the time allowed by a third. Why the rush? And why was no explanation offered for the abbreviated procedure? The failure to abide by the Guidelines is concerning, especially since the invitation to comment states: “comments received during the current 28-day public comment period will be taken into consideration by the Lead Authors in the preparation of a second draft, as required by the Guidelines for Producing CCSP Synthesis and Assessment Products,” insinuating that the entire set of Guidelines is being followed, and offering no explanation for the exceptions being made.
Another fundamental question we pose here is: Does the Bush administration intend to use the USP to comply with Sec. 106 of the Global Change Research Act? Again, the evidence arguing one way or the other is equivocal. On the one hand, the Feb. 29 Decision Memo states that “The product will analyze the effects of current and projected climate change on: ecosystems and biological diversity; agriculture; energy production and use; land and water resources, transportation, and human health and social systems,” which is strikingly similar to provision of law in the Global Change Research Act of 1990, PL 101-606, Section 106(2) which stipulates that there shall be an assessment which, in part, “(2) analyzes the effects of global change on the natural environment, agriculture, energy production and use, land and water resources, transportation, human health and welfare, human social systems, and biological diversity.” On the other hand, our understanding is that the CCSP has already complied with the August 21, 2007 US District Court order (No. C 06-7062 SBA) requiring a national assessment of climate change impacts by May 31, 2008 with its May 29, 2008 “Scientific Assessment of the Effects of Global Change on the United States.” At various times throughout the administration, the CCSP and the White House have also tried to assert that the collection of the 21 SAPs satisfies Section 106. Moreover, it is our understanding that the Team of Authors have been told explicitly that the USP is not a satisfaction of the climate impacts assessment provisions of the GCRA. Why all this confusion?
Lastly, the White House (through the CENR, CCSP, and NOAA) has set itself up for legitimate criticism by those with both admirable and less-than-honest intentions. The complaint is that the assertions being made are not adequately substantiated and the document lacks sufficient citations from published, peer-reviewed literature. While it is refreshing to see such a plainly worded, graphically illustrated digest of climate impacts across the US from this administration, it is troubling that the USP draft has become a magnet for more controversy surrounding climate science. A case in point is the objection, first reported by ClimateWire (available here), by the US Chamber of Commerce to the depiction on page 15 showing icons of the 21 SAPs with the caption: “The icons above represent some of the major sources drawn upon for this synthesis report.” In an August 1 letter from the Chamber’s Vice President for Environment, Technology, and Regulatory Affairs William L. Kovac addressed to Acting CCSP Director William Brennan, Kovac complains:
“The above illustration leaves little doubt that the Synthesis Report is heavily dependent on the findings and information contained in the CCSP SAPs. However, only eight of the CCSP SAPs have so far been completed [as of July 28, 2008]. This problem clearly raises the question of how the public can possibly assess the reliability and objectivity of the Synthesis Report when in fact many of the major reports on which the Synthesis Report relies have not yet even been completed?some of the SAPs are not even scheduled to be completed until October 2008. For this reason, the Synthesis Report lacks transparency, and therefore it does not comply with the Information Quality Act or Guidelines?for as the SAPs on which it relies have not yet been produced, there is no way for public commenters to assess the objectivity of the report as the underlying information is not available.”
This is reminiscent of the US National Assessment coming under (illegitimate) attack for a technicality, all the more reason that the report’s authors and managers should have been hyper-vigilant to produce an unimpeachable product.
While it is increasingly clear that the requisite degree of care and attention to procedural detail was not taken, it is also probable that the stellar group of 30-some authors relied on thoroughly vetted, peer-reviewed scientific material, even if it was in the form of published papers used to produce as-yet unpublished SAPs.
Brendan Cummings, a senior attorney with the Center for Biological Diversity, one of the main plaintiffs in the national assessment court case, took issue with the Chamber’s objections in the ClimateWire article:
“The Chamber of Commerce is pursuing a last-century, head-in-the-sand strategy to suppress climate information….They are doing a disservice to all the businesses and communities they purport to represent.”
In defense, William Kovacs responded recently to Cummings’ charges:
“Why did we ask for its withdrawal? Mainly because only 8 of the 21 studies referenced in the report have been released! Far from suppressing information, we were asking that all of the information be made available prior to commenting. Seriously, before the world spends trillions of dollars to address climate change, it is essential that we have the data. How else can we develop the best solutions to address this issue?”
These exchanges are but one small battle of a larger conflict still being fought out, using science as the “whipping boy” for debate over the appropriate societal response to the climate change threat. This little public skirmish could easily have been avoided if a slower, more methodical pace was chosen for the USP, rather than a rush job to produce a report with a purpose that has not been made explicit enough. Could politics be involved? The upcoming presidential elections feed speculation; however, the public should not be relegated to speculation about a topic with such serious implications for society.
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