After the federal Climate Change Science Program posted on its Web site the government review draft of the IPCC assessment report, “Climate Change 2007: The Physical Science Basis,” critics suggested variously that the Bush administration is making it possible for the review process to be hijacked by special interest groups, and that the administration is posting the report in draft form to defuse its news value when the final report is published.  Such concerns are off the mark and are based on a misunderstanding of the review procedure and its value.  We should be on the side of an open process with broad-based input to the U.S. Government’s review of this extraordinarily important report. The Climate Change Science Program Office should be commended, not criticized, for making the report readily available for review. 

We reported on April 13 that the Intergovernmental Panel on Climate Change (IPCC) Working Group 1 draft assessment report had been posted on the U.S. Climate Change Science Program (CCSP) Web site for government and expert review.

Here, in this entry and the one to follow, is a case study in how a good procedure has been misinterpreted:
The May 4 issue of Nature (by subscription only), the prestigious and widely-read international science journal, carries an article entitled “US posts sensitive climate report for public comment: Scientists concerned by online publication of IPCC draft.”

The article leads with:

Climate experts have expressed surprise and concern about a US government decision to release a politically sensitive report when it is still in draft form.

Access to the first section of the Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report, due for publication in 2007, has been open for around a month….

The US government says its move will allow the broadest range of experts to comment, and will avoid accusations that any groups have been denied access. But the decision effectively to publish the report worries some researchers, who say it could undermine what has previously been a confidential review process.

“If the US government is going to allow lobby groups, or persons associated with them, input into the government review, there is a serious chance that the whole thing could get hijacked,” says one US government scientist involved in the process.

Let’s clarify a few points here:  The IPCC uses a multi-stage review process.  The first review is by selected technical experts—hundreds of scientists from around the world who submit an extensive set of comments.  The chapter authors revise the entire draft report drawing on these review comments.  The revised draft, which is now quite far along in terms of technical content, is then circulated to the governments that are part of the IPCC process for another round of formal review, by whatever procedures participating governments choose to use.  Governments then submit their sets of formal comments to the IPCC for consideration by the report authors.  It is this revised draft, for review by governments, that has been under review for the past month in the U.S.  If past practice is followed: Drawing on comments provided by a broad range of reviewers and the deliberations of interagency teams of federal managers with various expertise, the U.S. Government will adopt a set of official comments for the State Department to transmit to the IPCC. 

Now, the question:  Who should be allowed to submit review comments on the IPCC draft report as input to the government’s deliberations?  IPCC guidelines for the review process state that the process should be “objective, open and transparent.”  Consider this:  It is our understanding that, through the IPCC distribution process, this draft of the report is provided, not only to all the governments, but also to all nongovernmental organizations that have registered with the IPCC.  This includes a wide range of groups, including both business and environmental groups.  So the concern expressed by the federal scientist, quoted in Nature, about the current procedure allowing “lobby groups” to participate in the review is misplaced.  Such groups have always been invited to submit comments at this stage of the preparation of IPCC assessment reports. 

If the draft can be reviewed by all these groups, on what basis should comments by other experts and “stakeholders” be blocked?  After all, this draft report does include a “Summary for Policymakers” in addition to a set of detailed scientific review chapters.  Does the Summary for Policymakers communicate clearly, effectively, and understandably to those with responsibility for societal decisionmaking? We can imagine valuable comments coming from a variety of quarters.  In fact, we are informed by an authoritative source with long inside experience with these government reviews that public reviewers have often made points about clarity of presentation; environmental group reviewers have often had excellent insights about issues such as ecosystem behavior and related pollution issues, and industry reviewers have often had excellent insights about issues such as emissions and approaches to mitigation.  Our source says that initial fears that the process would be abused (e.g., by large numbers of coordinated special interest comments) have not materialized.  (Not yet, at least—we’ll see how it goes this time around.) Off-the-mark and gratuitous comments should be filtered out by the professional-level internal federal interagency review process.

If the Bush administration ends up submitting scientifically ill-founded or otherwise misleading or unconstructive comments to the IPCC authors, that will be a problem to be dealt with by the IPCC and the U.S. submission should be criticized if need be.  But IPCC report authors are not required to incorporate any comments that they believe will not improve the report. 

The State Department posted a Federal Register notice on April 7 to the effect that the IPCC draft was available for review comments. The Climate Change Science Program Office, in the spirit of openness and transparency, made the report readily available on the CCSP Web site for review, by experts, “stakeholders,” and interested citizens. They are to be commended for this, not criticized.