Critical public review comments on the administration’s Fourth Climate Action Report

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Critical comments by guest contributor Lynne Carter (Co-Director, Adaptation Network) on the draft U.S. Fourth Climate Action Report, submitted to the State Department as part of the public review process, offer one good example of the kind of input that we would like to see more of from individuals and organizations.  [Editor’s Note: See also the 30 July 2007 posting, Bush Administration submits evasive Climate Action Report to the UN.]

See our earlier posts on this report:
Sept. 18, 2006 Where is the U.S. Climate Action Report required under the climate treaty?
Jan. 7, 2007 Congress: Ask Condi Rice, Why has the U.S. Climate Action Report been held up for more than a year?
May 6, 2007 Public review of administration’s Fourth U.S. Climate Action Report
May 7, 2007 “Impacts and Adaptation” chapter of U.S. Climate Action Report 2007 is an evasive failure
May 8, 2007 IPCC North America climate change impacts chapter shows evasiveness of U.S. Climate Action Report
May 18, 2007 Comment deadline on U.S. Fourth Climate Action Report extended until June 1

We have been calling attention to the Bush administration’s dilatory approach to releasing the long-overdue U.S. Fourth Climate Action Report to the UN Framework Convention on Climate Change.  It has seemed apparent to us that a key reason for this delay had to do with the required chapter on Vulnerability, Climate Change Impacts, and Adaptation Measures, a topic on which the President and administration officials have never beeen willing to engage in straight talk.  The draft of the new report currently out for review ducks a discussion of likely impacts of climate change on the United States (in Chapter 6) by confining itself mainly to a discussion of ongoing research projects and reports in preparation.

In her comments to the State Department, Lynne M. Carter, Ph.D., Environmental Consultant and Co-Director, Adaptation Network, challenges the draft report on this and other issues [we have added a few NOTES]:

Thank you for the opportunity to comment on CAR4.  A few general comments first then a few specific comments.

General comments:

First: I would like to understand why the US is 17 months behind its internationally agreed upon report delivery date. Why is the US one of only 4 countries to be so delinquent in an important international agreement-reporting deadline? That is completely unacceptable to those of us who as taxpayers support this work and expect it to respect deadlines that others need to meet.

Second: Why have we members of the public been given only 14 days in which to read this document and others to be able to adequately comment on its contents?  You have taken at least 17 extra months and have allowed us only one half of the time previously allowed for such commenting (CAR3). Again, as a taxpayer, this is unacceptable and insulting to what is supposed to be a transparent process. Please extend the deadline to comment.  [NOTE: The deadline for comments was subsequently extended by two weeks until noon on June 1.]

Third: It seems very odd that the US government should report on work that it is not funding nor supporting such as actions of cities and states.  It appears as though we need to take credit for others’ work because we as a government are doing next to nothing in applied work – impact assessments, vulnerability assessments, and adaptation actions.  This is the area where the US public most needs information and assistance.  We can take a page from the UK report and see that they have implemented a great many adaptation actions in the form of developing tools and useful guidelines, and locally-based likely climate impacts.  This is exactly the type of work that we need here.  Our outspoken climate scientists have said that adaptation is the action that will help us to become resilient in the face of the present and future climate changes and yet we as a nation are nearly blind to developing and providing the needed knowledge.  Without focusing and translating the excellent scientific capabilities that we have and support in the US we will, as a nation, continue to be behind where we could be in preparing to live in a different world.  Please encourage and support more work that will provide Americans with the information they need to be the proactive, get-it-done folks that we are known to be.  Without appropriate general and location-specific impacts and adaptation information, we as a society are at a huge and potentially costly loss.

Specific comments:

Chapter 4:  Policies and Measures
All of the policies and measures described here relate to reducing emissions.  This is an incredibly important part of the climate change issue.  However, there is another equally important part and that is understanding impacts and adapting to them.  Impacts that we cannot avoid no matter how much we reduce emissions, due to the long lifetime of heat-trapping gases in the atmosphere, are the climate changes that are underway and will become even greater as we move along the emissions trajectory.  Regardless of how well we curb our emissions, according to Dr. Robert Corell, we will have changes that we will have an opportunity to adapt to for at least the next 50 years – and probably many generations.  So we need to include in our policies and measures that impacts from climate changes need to be taken into account in any policies that are developed and implemented and adaptation approaches need to be developed and supported as well.

I have three questions on The Healthy Forest Initiative: The Healthy Forest Initiative for federal lands “at risk of catastrophic wildfires” has been justified “in large part due to significant changes in forest and woodland structure that have occurred in the last century.”  1) Why was there not so much as a mention of this increase in fire risk as a result of climate change or as a climate change impact? If the Healthy Forest Initiative is in response to an impact from climate change, it should be accompanied by a great deal more language on climate change impacts.  Why is this impact singled out? 2) This is the description of the goal of this program: “to increase biomass and wood fiber utilization as an integral component of restoring the Nation’s precious forests, woodlands, and rangelands.” What does this mean – utilization by whom for what?  3) If it isn’t an emissions reduction strategy (which is not at all clear as it is written) nor an impact due to climate change – then why is it even in this report?

Chapter 6: Impacts and Adaptation
According to the UN Guidelines for inclusion in the Chapter on Impacts and Adaptation there are three specific parts of information to be included here: Expected Impacts of climate change, Vulnerability Assessment, and Adaptation Measures – research is to be included in a separate chapter devoted to research. Compared to the UK report for example, the US Chapter has no overview of likely climate impacts for the US.  Rather it has chosen a few select impacts to focus on leaving it to the readers’ imagination whether there is any new US overview developed or not since the National Assessment. The US foundation for assessing impacts started well with the National Assessment (barely mentioned here), but seems to have degenerated into a non-coordinated, few regions, and few topics approach.  On your own page 6 you point out that a “continuing goal is a coherent program that allows synergies among these many and varied programs.”  Had there been the next National Assessment as called for in the Global Change Research Act for every 4 years, then you might have reached your goal of some amount of coherence and synergies.  As it stands, we are left wondering what are the likely climate impacts to be, where, how might we approach dealing with them, who can supply the needed location-specific information, and what should our people be considering to build resilience to present and coming impacts? These are the sorts of information that should be included in this chapter.  Please add it.

Also, much of what is included in this chapter is research and reports to be done rather than what has been done and accomplished and applied on a wide-scale specific to expected impacts, vulnerability assessment, and adaptation measures.  Page 6 mentions a “variety of useful products,” however, there is no readily available timetable for these products or any discussion of a dissemination plan.  Again in the UK report, it is obvious that they are serious about climate change adaptation, as they have developed tools for use by individuals, communities, and industry to guide folks along the path to making useful and informed adaptive decisions (how to access those tools and who they are for is readily available as well).  I believe this chapter should be reporting on what the US has actually accomplished in adaptation (beyond the University of Washington work that was underway during the National Assessment many years ago) not its research plan.  The new work on adaptation for example in NY is laudable but had this report been developed on time, it probably would not have even been started so it really doesn’t belong here but in the next report when its accomplishments (that I have no doubt will be achieved) can be reported on.

There are certainly a few projects that are incredibly worthy work and I am delighted that they are on-going, however, a good deal of this chapter is research focused and this information belongs in another chapter and it should be moved.

Chapter 9: Education, Training, and Outreach
I wonder if there are any government science education websites that are not listed here?  It seems that any website from any of the cooperating agencies are listed here and they certainly are not all climate change focused.  Please only mention and highlight the websites that are truly focused on climate change information – not those that include it only as a sidde mention or one particular aspect of Earth science.  I also wonder how many of the climate change focused websites have had scientifically credible information about climate change removed from them?  It would take longer than the 14 days allowed for the comment period to check all of these websites to be able to provide any specific examples, but as an interested taxpayer, I am no longer entirely confident in the completeness of climate change information now on government websites due to this administration’s policy of changing scientific information that they don’t happen to like. So please only include the websites that are climate change focused and whose information has not been tampered with.

Thank you for this opportunity to comment.

Lynne M Carter, Ph.D.
Co-Director, Adaptation Network

[NOTE: You have until noon on June 1 to put your comments on the State Department record.]

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