Letter to the House Science and Technology Committee on global change research legislation

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On June 27 the House Science and Technology Committee reported the
Global Climate Change Research Data and Management Act of 2007 (H.R.
906). Climate Science Watch and the Union of Concerned Scientists have communicated to the Committee our concern that the
bill remains underdeveloped in two key respects: (1) It does not
address the need to protect the integrity of scientific communication
from political interference; and (2) It does not adequately address
the need for an explicit focus on national assessment of U.S. climate
change impacts and response strategies.

H.R. 906 is an update of the Global Change Research Act of 1990, the current statutory basis for the federal climate and global
change research program.

Section by Section Summary of H.R. 906 as reported by the
full Science and Technology Committee.

H.R. 906 as reported [PDF] by the House Science and Technology
Subcommittee on Energy and Environment on June 6.

H.R. 906 amendments [PDF] adopted at Full Committee markup on June 27.

The House Science Committee is well aware of the problems of
political interference with federal climate change communications.
Climate Science Watch believes the Committee should have included
provisions in the bill to ensure more transparency in the
communication between federal science professionals and Congress (as
well as other audiences for the research program’s publications). The
current version of the bill does nothing to protect the research
program from White House political manipulation of science
communication in program reports.

Climate Science Watch supports the Committee’s intention to
strengthen the program’s mandate to produce relevant assessment
reports. However, we believe the current version of the bill is
undercooked and too indirect in spelling out what Congress and
society need most from the research program — specifically, a
well-established, ongoing scientifically based national assessment
process focused explicitly on the problem of climate change and
global warming. This assessment process should include the potential
consequences of climate change for the United States and also the
implementation of mitigation and adaptation response strategies at
the regional and state levels.

We will continue to raise these concerns in connection with any subsequent House floor action or Senate action on this or similar legislation.

Climate Science Watch and the Union of Concerned Scientists sent the
following letter to the chairman and ranking member of the Committee,
the chairman of the Energy and Environment Subcommittee, the
co-sponsors of H.R. 906, and senior Committee staff members:

 

Climate Science Watch
Government Accountability Project
1612 K Street, NW, Suite 1100
Washington , DC 20006


          1707 H Street, NW, Suite 600
          Washington , DC 20006

 June 26, 2007

The Honorable Bart Gordon, Chair
Committee on Science and Technology
U.S. House of Representatives
2320   Rayburn House Office Building
Washington , DC   20515

Dear Chairman Gordon:

We are writing to submit formal comments on H.R. 906, the Global Change Research and Data Management Act of 2007, as reported by the Energy and Environment Subcommittee.  

We support the attempt to strengthen the mandate to the USGCRP to produce assessment reports.   However, we believe the bill remains underdeveloped on two key matters:

  • The bill focuses on making the USGCRP more relevant to policymakers but does not address key hard-won insight about the need to include a corresponding focus on protecting the integrity of science communication from political interference.
    • The sections on Vulnerability and Policy assessments do not draw enough on what has been learned from previous USGCRP assessment activity, in particular from the National Assessment of Climate Change Impacts, and do not provide sufficient integrating focus and guidance on assessments of climate change response strategies.

    Protecting the Integrity of Science Communication from the Program

    The bill must be amended to address science communication integrity concerns by specifying appropriate guidelines to ensure that scientific assessment reports submitted to Congress by the President consist of text that has final approval by the scientist-authors.

    The apparent decision by the sponsors of H.R. 906 to pass up a golden opportunity to address issues of structural and management reform of the federal research program is regrettable, though at least the bill appears to do no active damage in this respect. However, we believe it is really a failure of congressional oversight that must be remedied that the bill specifies, with regard to the required assessment reports, only that “the President shall submit to the Congress…,” with no language aimed at ensuring that assessment reports are made available as authored and ultimately approved by the relevant scientists and other experts, without inappropriate political interference by White House and Executive Branch officials.

    This clearly involves more than whistleblower protection, which is being addressed in other legislation. It is about protecting communications between scientists and the Congress (and with other stakeholders and the general public) from instances of political interference, so that whistleblowing is not needed in order to bring problems to light, as we have had to do in the past. The bill reads as though its authors have not taken into account and seen the relevance of the testimony at hearings held by House Science and other committees earlier this year about administration interference with federal climate science communication.

    These problems have been documented in detail in reports by the Government Accountability Project and the Union of Concerned Scientists, with which the Committee is quite familiar. Those reports make clear the need to ensure that scientist-authors of climate change reports have the right of final review and approval of published text, and that this right may not be appropriated by the White House. The Intergovernmental Panel on Climate Change has well-institutionalized procedures to protect the scientific integrity of IPCC assessment reports.

    Assessment Reports

    Assessments: Process and Products

    The bill should distinguish between the assessment process and the assessment reports and specify requirements for both . Moreover, both the assessment process and the reports should emphasize a regional approach, so that the recommendations and the products will be useful at a state and regional level.  

    Process: The bill should make explicit that it is directing the establishment of what is to be an ongoing program capability and process, in which the program will support a linking of scientists and other experts with policymakers and other stakeholders/citizens around the country in an ongoing process of assessing climate change impacts and response strategies. Periodic assessment reports to be transmitted to Congress are an essential output of this process, but not the only one.  

    The bill should specify that this process should occur at regional (and ideally also state and local) levels, and in various socioeconomic sectors, revitalizing and evolving from the process initiated under the first National Assessment, “Climate Change Impacts on the United States : The Potential Consequences of Climate Variability and Change.”  The essential point is that the program should establish and support an ongoing assessment and decision-support process that focuses scientist-stakeholder communication (and reports/consultation as appropriate) in the arenas in which relevant climate and global change decision-making occurs.

    The model used to generate the first and only set of Regional Assessments that comprised the National Assessment on climate change, while not perfect, could inform the establishment of a set of “Centers of Excellence” for assessing regional impacts of climate change, possible adaptation strategies, and mitigation options. These Centers should also prioritize criteria for “outreach” – how best to ensure that the information is disseminated in a manner that will be used at a state and regional level.  

    Reports to Congress: The periodic reports to Congress mandated in the bill should involve a national level synthesis, analogous to the first National Assessment. They should draw on the ongoing regional, state, local, and sectoral assessment activities and reports. Further, as noted above, the bill should provide for a strong outreach component, such that the dissemination of these products will be useful to decision-makers at a state and regional level..

    Vulnerability Assessment – National Assessment of Climate Change Impacts

    The bill should include an explicit mandate for the production of national assessments of climate change impacts , i.e., not use only the catch-all term “global change” in specifying the requirement for assessments.

    Since the establishment of the USGCRP in 1989, concern about the implications for policymaking of global warming, climate change, and associated changes in the global environment – and particularly the implications for the United States – has always been the primary driver of interest by national policymakers in supporting the research program, and has formed the essential core of the research agenda. The program is, first and foremost, a climate change science program. By far the most significant and relevant assessment report produced by the USGCRP was the first National Assessment report, which is now in need of updating and broadening. The centrality for research and policymaking of climate change, its consequences and response strategies, is more the case today than ever and should be reflected in the bill’s requirements for assessment deliverables from the program.

    The vulnerability and policy assessment language could also include broader elements, e.g., “climate and associated global change,” or “climate in the context of multiple stresses,” and could also include assessments on other global change issues. But the continuing exclusive use of the term “global change” in defining the assessment requirement is too broad and even evasive in the contemporary context, and does not make clear enough what the essential decision-relevant focus of USGCRP research and assessment agenda needs to be: the assessment for policymakers and society of climate change impacts, vulnerability, and response strategies. Under the current bill language, the USGCRP could potentially satisfy the requirement to produce vulnerability and policy assessments without focusing on the climate change problem. There should be no ambiguity in the statute that climate change assessments are being called for.

    Policy Assessment – Mitigation and Adaptation Response Strategies

    The bill should provide more guidance in specifying the Policy Assessment requirement and clarify the relationship between the USGCRP and the Policy Assessment . Is the intent for the USGCRP to serve as the vehicle for the production of the Policy Assessment? The bill specifies that the USGCRP interagency committee shall serve as the forum for developing the Vulnerability Assessment but does not reference the Policy Assessment in defining the committee’s role, so the matter appears to be left open. If not, the bill should assign responsibility more clearly.

    If so, i.e., if the USGCRP is to be tasked with engaging in mitigation and adaptation research and assessment (using “mitigation” in the IPCC Working Group III sense), and comparative analysis of mitigation and adaptation response strategies – which the program leadership claimed in Our Changing Planet FY 2003 would be the future focus of the program, but has never delivered on – then the bill should address the capacity-building need in this area of the USGCRP, which has never focused on research and assessment of policy options and response strategies.

    We believe the bill should specify an integrated national climate change assessment activity that includes a focus both on impacts and vulnerability and on mitigation and adaptation response strategies, and that the role of the USGCRP should evolve to support, in collaboration with other entities as appropriate, this full range of (IPCC Working Groups II and III) assessment.

    The bill should define “climate change,” using the UNFCCC definition, and also should define “mitigation” and “adaptation” to make clear legislative intent as to the scope of these aspects of climate and associated global change response options.

    It was a significant – though understandable at the time it was conducted – limitation of the first National Assessment that it focused exclusively on societal and environmental consequences of climate variability and change, with only limited coverage of adaptation issues, and explicitly did not address emissions-reduction mitigation response strategies. We need to move beyond this limitation. Given how scientific understanding and the concerns of policymakers have advanced since 2000, it makes sense for climate change assessment activity henceforth to address both adaptation and mitigation strategies in addition to impacts and vulnerability issues.   This will likely require parallel sets of activities and reports, with interactions involving a wide range of scientific and technical expertise and various groups of policymakers and resource managers.

    A national assessment of mitigation and adaptation response strategies (and NOT merely of “policy options”) should be carried out in an integrated manner – not in terms of a “Vulnerability Assessment” to be produced as a deliverable of the USGCRP and a separate “Policy Assessment” of unspecified provenance . Adaptation and mitigation response strategies may involve policymaking and resource-allocation tradeoffs that should be considered in an integrated manner.   As just one example, climate change impacts on water resources, forests, and agriculture may affect the regional availability of renewable energy resources. Just as climate change impacts will vary by region (and even locality) and by socioeconomic sector, so mitigation response strategies – and by this we refer to practical implementation actions, not just “policy options” – must be addressed at regional and sectoral levels. Assessments of this nature need to be coordinated nationwide, not just compiled from the experience of state and local governments that are already developing policy options.    

    Need for Realistic Timetables and Wider Accountability

    The timetable for producing the first assessment reports to Congress needs to be made much more realistic – calling for these major deliverables to be completed from a cold start within one year does not reflect a knowledgeable perspective on how a complex federal program and assessment process actually function. Granted, the Climate Change Science Program under the current administration has been notoriously ineffective at keeping schedules on report deliverables.   However, to establish a new interagency structure and process for supporting the production of the kinds of reports called for in the bill, and, more broadly, establishing a structure and process for national assessment scientist-stakeholder interaction, at the national, regional, and sectoral levels, will require more realistic guidelines and timetables than are currently in the bill, even if the program moves expeditiously and effectively.

    To help ensure that assessment reports are timely and accountable for meeting the needs of a broader range of policymakers and stakeholders than solely the Congress, the bill should specify that the reports are to be prepared with public participation, and create a statutory requirement that the reports are to be made widely available to specified stakeholders and the public. The bill specifies that the preparation of the USGCRP strategic plan for research shall include public participation and evaluations by the National Academy of Sciences and the National Governors Association. Such stakeholder involvement in the assessment process is at least as relevant as it is for the research planning process. Specifying a statutory right of the public to have access to required assessment reports could be a useful tool for enhancing program accountability to a wider range of stakeholders. (The failure of the original Global Change Research Act of 1990 to make explicit that required USGCRP assessments are intended for a wide public audience may have led to some ambiguity on the question of whether the public has a right to the assessments.)   

    Thank you for your consideration of our comments; we would be pleased to meet with you and your staff to discuss these.

    Sincerely,

    Rick Piltz
    Director, Climate Science Watch
    Government Accountability Project

    Peter Frumhoff
    Director of Science & Policy and
    Chief Scientist, Climate Campaign
    Union of Concerned Scientists

    cc: Chuck Atkins, Majority Staff Director
          Dan Pearson, Professional Staff
          Jean Fruci, Professional Staff

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