Climate Science Watch and the Center for Biological Diversity formally submitted sets of critical public review comments on the draft summary of a revised research plan for the US Climate Change Science Program. CCSP’s issuing of a revised plan for the federal research program is pursuant to a federal court order in the Center for Biological Diversity et al. lawsuit against the President’s Office of Science and Technology Policy and the leadership of the program.

See our January 6 post: Call for public comments on revised U.S. climate science research plan

A Summary of Revised Research Plan (and here in PDF format) for the U.S. Climate Change Science Program was posted in the Federal Register for public review and comment during January and February. Following the August 2007 victory in federal court in the Center for Biological Diversity et al. lawsuit against the Climate Change Science Program and the President’s Office of Science and Technology Policy, the administration is scrambling to meet a court ordered deadline to produce by May 31, 2008 a new federal climate and global change research plan and a scientific assessment focusing on climate and global change impacts—two documents that they previously had no intention of producing during this year. The public comment period, which ended on February 26, was an opportunity to raise issues about what kind of climate and global change research and assessment program is needed to meet the challenges of the coming period.

Climate Science Watch/Government Accountability Project comments by Rick Piltz and Anne Polansky on the review draft of the revised research plan are below.

Comments by Climate Science Watch/Government Accountability Project on the
Summary of Revised Research Plan for the U.S. Climate Change Science Program

General Comments

General Comment #1. 

Climate Science Watch wishes to associate itself with and endorse the full set of comments submitted separately by Shaye Wolf and Kassie Siegel of the Center for Biological Diversity.
[Text of comments by the Center for Biological Diversity]

General Comment #2.  

It is now well-established that the US Global Change Research Program, renamed the Climate Change Science Program under the Bush Administration (hereafter referred to as USGCRP/CCSP), since 2000 has consistently failed to meet the existing statutory requirements of the Global Change Research Act of 1990 (GCRA), primarily by failing to revise its Research Plan every three years (Sec. 104) and failing to produce a scientific assessment of global change impacts every four years (Sec. 106).  Climate Science Watch submitted a formal declaration in support of the plaintiffs in a suit filed jointly by the Center for Biological Diversity, Greenpeace, and Friends of the Earth on November 14, 2006 to compel the USGCRP/CCSP to comply with the GCRA.  The court sided with the plaintiffs by issuing a decision on August 21, 2007 requiring the USGCRP/CCSP to publish the summary of a revised proposed Research Plan in the Federal Register no later than March 1, 2008, and to submit the proposed Research Plan itself to Congress no later than 90 days thereafter (Center for Biological Diversity, et al. v. Brennan, et al.)  There is no mention of these court-ordered deadlines in the Federal Register notice. We believe the USGCRP/CCSP, in the interest of transparency and full disclosure, should have cited the court decision and court-imposed deadlines in the Federal Register notice.  Furthermore, the notice should have disclosed the US District Court’s requirement that a Scientific Assessment (required under Sec. 106 of the GCRA) must be submitted to the President and the Congress by May 31, 2008, and incorporated a more thorough discussion of the USGCRP/CCSP’s plans for meeting this critical deadline. 

General Comment #3:

Climate Science Watch recognizes that the overall structure and current functioning of the USGCRP/CCSP makes it difficult for the USGCRP/CCSP programs and the USGCRP/CCSP Office to meet current demands for useful information on adaptation and mitigation.  With no real control over participating agency and department budgets, a high degree of vulnerability to political tampering and censorship from the highest levels of the Bush administration (well-documented on our website,, and a lack of commitment from the White House to address the climate change problem openly, honestly, and directly, the USGCRP/CCSP Office’s hands have been tied.  Moreover, many of the basic scientific questions embodied in the IPCC Working Group I have been the main focus of the US climate science programs and have now been fairly well addressed; Climate Science Watch recognizes the high value that the US programs have added to the IPCC process and to overall scientific understanding of the climate system.  However, Working Group II and III issues (impacts, adaptation, and mitigation) are in desperate need of focused, expert attention involving not just the physical and biological sciences, but the social sciences as well. 

It is our view, and one shared by many veterans of US federal climate science programs, that the USGCRP/CCSP is in need of renovation and restructuring, likely supported by accompanying new legislation.  Several Congressional bills along these lines have been introduced and are under consideration, and an informal working group has been established to formulate recommendations for the incoming administration in 2009. As part of this group, Climate Science Watch is proposing a National Climate Change Preparedness Initiative designed to create a meaningful role for the federal government in helping society to better prepare for and deal with the inevitable consequences of “global climatic disruption.”

(See here and here.)

General Comment #4:

A strong need exists for meaningful, timely, relevant, usable, and useful federal decision support and other assistance to state and local governments, businesses, and individuals in their attempts to prepare for and ultimately adapt to global climatic disruption; and to provide scientific, technical, and economic analysis of greenhouse gas emissions reduction (i.e. mitigation) options. To its credit, the summary Research Plan summary essentially acknowledges this need.  However, it fails to acknowledge that the USGCRP/CCSP, as it is currently configured and managed,  has proven that it is simply not able to meet current needs for climate change impacts assessments, and the decision support needed to enhance national preparedness to cope with and adapt to, as well as to mitigate, these impacts. In more terse terms, federal climate science in the US has been largely disconnected from the rest of society. This disconnect must be repaired if we are to manage and cope effectively with the hardships that climate disruption threatens to impose.  In this proposed summary, there is no explicit recognition of the Program’s fundamental structure as it relates to Program effectiveness, and therefore no suggestions for changes that might remedy these problems. 

General Comment #5:

Through the proposed summary, references are made to encouraging public comment, engaging stakeholders, and informing decision makers.  However, aside from publishing information about draft Synthesis and Assessment Products in the Federal Register, we are not aware of any future planned activities designed specifically to involve, inform, or engage stakeholders, policymakers, or the non-scientific community.  Are any such activities planned, and if so, why are they not mentioned in the summary?

Specific Comments

Specific Comment #1:  Emerging Priorities, page 5, third full paragraph. 

Climate Science Watch takes issue with the statement regarding the 21 planned Synthesis and Assessment Products (SAPs), only four of which have been completed and published to date.  The SAPs, should the remaining 17 be completed before the current administration ends, will help to “integrate many related scientific areas.”  But we disagree with and can find no substantiation for the following statement:  “These assessments [the SAPs] have had a significant influence on the broader climate policy community, and have helped to shape external dialogues and to frame the new questions that face policymakers.”  Conversely, it has been our understanding and experience that very few policymakers – in the US Congress, in State legislatures and governor’s offices, in local governments, and in the NGO and environmental advocacy community – are using these assessments to aid in the decision making process. Many policymakers have not even heard of these assessments.

We agree generally with the subsequent statement (which we view as an understatement) that “discussions within the user community have already begun to place increased demands on CCSP to provide more regionally-resolved and sector-specific information about climate, its societal impacts and vulnerabilities, and to provide the rigorous scientific basis to support increased social planning for adaptation and mitigation of the effects of climate change.”  However, the use of the words “already begun” is curious, given that this demand for information has been well-established for more than a decade; that it was beginning to be met with the first National Assessment of the Potential Consequences of Climate Change; that the Bush administration terminated and even suppressed the information contained in the set of National Assessment reports; and that key members of Congress with oversight responsibility have expressly rejected the notion that the 21 SAPs, even if they are completed this year, will meet the statutory requirement for a scientific assessment of climate impacts.  (Refer, for example, to comments made by Senators John Kerry and Barbara Boxer, and several of the witnesses during a November 14, 2007 oversight hearing held by the Senate Committee on Commerce, Science and Transportation.)

On page 9, first full paragraph, the summary states:  “The coming years will see substantially increased need for CCSP to accelerate progress on Goals 4 and 5…” and “This is an important area of potential growth for CCSP.”  Given that there are only 10 months remaining in the current administration, we would encourage the USGCRP/CCSP to choose a few top priorities for focus, with strong stakeholder input on developing those priorities, and work to make any information produced relevant to the policymaking process at the federal and state level.  For example, better understanding of likely future precipitation and drought patterns in various regions could enable provision of useful, relevant, timely, and valuable information to water managers across the US. 

Specific Comment #2:  Research and Programmatic Plans, page 6, second full paragraph.

There is insufficient explanation of just how the USGCRP/CCSP intends to fulfill the requirement of Sec. 106 of the GCRA and the court-ordered scientific assessment due on May 31, 2008.  The only text provided states that “The current Scientific Assessment is under development” and that “it will integrate and draw from many sources,” including the 2003 Strategic Plan, the SAPs, this Research Plan, and public comments on this summary.  The SAPs provide a potentially useful source for an assessment, but given their delinquency, and their disparate nature, it is still unclear just how the USGCRP/CCSP intends to comply with the court order and to satisfy the relevant Congressional oversight committees. 

Specific Comment #3:  Research and Programmatic Plans, page 7, first paragraph.

We concur with the Center for Biological Diversity’s comment that the statement in the research plan summary,  “investment in and progress towards CCSP Goals 1 through 3 has been greater than that for Goals 4 and 5” is a severe understatement.  Only one of seven planned SAPs under Goal 4 has been completed ( “Effects of Climate Change on Energy Production and Use in the United States”) and not one of the three planned SAPs under Goal 5 has been completed. 

For example, both the western states and the southeastern US have been suffering from prolonged and severe drought conditions that have been linked to climate change.  On page 10, third full paragraph, the summary states: “The need to provide information to water resource managers and other decision makers on issues related to how climate affects water availability, drought, and water quality has long been a component of CCSP activities, and the global water cycle is one of CCSP’s identified research elements.”  There is emerging scientific indication that the Arctic ice melt may be linked to precipitation deficits in southeastern states, and that the drought in this region could be long-lasting. (Dr. Michael MacCracken made this point in a presentation at the National Council on Science and the Environment annual conference on “Climate Change: Science and Solutions” in January 2008).  However, the USGCRP/CCSP has not, to our knowledge, addressed this troubling possibility directly, by, for example, querying existing federal or international research facilities or gathering scientific experts to discuss the current state of our knowledge as it might pertain to this question.  The September 2007 draft of SAP 4.3, “The effects of climate change on agriculture, biodiversity, land, and water resources” does not address this issue, though there are many references to how climate change is now impacting the Arctic region itself, including Alaska.  Assisting the mayor of Atlanta and local water management entities, for example, to better understand just how severe and long-lasting these drought conditions may be could aid them in developing appropriate measures to ensure the residents of Atlanta and surrounding areas have adequate quantities of water going into the future.