In a January 2 letter to Sharon Hays, Deputy Director of the White House Office of Science and Technology Policy, Climate Science Watch said “unnecessary delays continue to impede the timely release of the final Synthesis and Assessment reports that constitute a core component of the U.S. Climate Change Science Program’s commitment under the Bush administration to inform Congress and the public on the scientific underpinnings of climate change.” We said “the appearance of White House influence on the scientific content of the reports during the clearance process calls into question the integrity of the final products.” We called on the White House to “take all necessary steps to ensure that all five of these reports [which were originally scheduled to be released between 2005 and 2007] are cleared and released before January 20,” and “to make public all editorial comments and/or proposed changes submitted to the authors during the final clearance process.”
The text of the letter, which may also be downloaded here as a PDF document, follows:
Climate Science Watch
Government Accountability Project
1612 K Street, N.W., Suite 1100
Washington, DC 20006
January 2, 2009
Dr. Sharon Hays
Deputy Director for Science
Office of Science & Technology Policy
Washington, DC 20502
William J. Brennan
Acting Under Secretary of Commerce for Oceans and Atmosphere
Acting NOAA Administrator
Director, U.S. Climate Change Science Program
Kristin C. Scuderi
Director of Communications and Public Affairs
White House Office of Science & Technology Policy
Dear Dr. Hays:
We are writing in reference to your official capacities as co-chair of the Committee on Environment and Natural Resources (CENR) of the National Science and Technology Council and deputy director of the Office of Science and Technology Policy (OSTP).
Our concern is two-fold: (1) unnecessary delays continue to impede the timely release of the final Synthesis and Assessment reports that constitute a core component of the U.S. Climate Change Science Program’s commitment under the Bush administration to inform Congress and the public on the scientific underpinnings of climate change, and (2) the final clearance process, which you ultimately control, is failing to adhere to the CCSP guidelines, recommendations of the National Research Council, and published timelines for the reports. The clearance process is taking months instead of weeks and, unlike prior stages in the reports’ production, is not transparent and open to public scrutiny. The appearance of White House influence on the scientific content of the reports during the clearance process calls into question the integrity of the final products.
The set of 21 reports, or Synthesis and Assessment Products (SAPs), addressing various scientific aspects of climate and global environmental change, have been the major Climate Change Science Program assessment work product over two presidential terms. The overall work plan for these reports as laid out in the CCSP Strategic Plan issued in July 2003 stipulated that all 21 reports would be completed and issued in less than four years, or by July 2007. This date was then pushed back to June 2008, as communicated in a July 2005 letter with a revised schedule to Senator James DeMint from James Mahoney, then director of the CCSP.
As of this date, one fourth, or 5 of the 21 reports, have not been published. All are awaiting final clearance with scant time remaining before the expiration of the Bush administration. By the time the reports are submitted by the authors and lead agencies for final review, they already have gone through extensive peer and public review, transparently, with all comments and authors’ responses publicly posted.
According to the clarification of the guidelines issued by the CCSP, approved by your office, interagency clearance is to “rely on the lead agency’s certification regarding compliance with CCSP’s ’Guidelines for Producing Synthesis and Assessment Products,’ FACA [Federal Advisory Committee Act], and IQA [Information Quality Act] (including the Bulletin for Peer Review). As such, an additional expert review is not expected. The focus of the CCSP/CENR clearance is to ensure that the policy officials with legal responsibility for the documents have reviewed and approved them…” (emphasis added)
According to the currently published schedules for the remaining reports, clearance will need to take place within about two weeks, yet the clearance process overseen by the White House for the first 16 SAPs has lasted an average of 16 weeks. No public explanation has been offered for these delays. The remaining five reports, already up to three-and-a-half years overdue, will not be released by Inauguration Day if they are not expedited. We believe the scientists who have worked on the reports deserve better – as does the American public.
Our second concern is that the White House (both the OSTP and the Office of Management and Budget) may be abusing the clearance process by imposing additional technical and scientific review and putting forward suggested substantive changes directly to the authors, outside the public review process. Such departure from agreed-upon guidelines contradicts recommendations made by the National Research Council in a report commissioned by the CCSP, Analysis of Global Change Assessments: Lessons Learned (2007): “a deliberate and transparent boundary is necessary to avoid the perception of interference in scientific conclusions.” It specifically states that “those providing the funding and authorization for the assessment should not be in a position to influence the scientific conclusions.” The NRC goes on to say:
CCSP’s assessment activities have raised credibility and legitimacy issues with some stakeholders, particularly in the science community, because of the way the boundary between science and policy was designed. For example, each assessment product is reviewed by the government and requires approval by high-level government officials, raising the questions of whether the users of the assessments not only control the questions being asked but, at least potentially, also the scientific conclusions. This concern is addressed to some extent because CCSP posts the report in both the pre and postreview version to allow tracking of the changes. Nonetheless, there remains skepticism about the degree to which government influence may affect scientific outcomes, not only through funding but also through review of final products. Perceptions about the degree of government influence can diminish the value of an assessment in the eyes of many stakeholders.
In the interest of preserving the scientific integrity of these reports, especially given this administration’s marred track record in separating political bias from scientific objectivity, all requests for changes made by White House officials and all responses by the authors and their superiors should be made publicly available. Even in the best case, in which all suggested changes are scientifically defensible and credible and are met with approval by the authors, any amount of nontransparency raises the specter of politically motivated censorship. Moreover, it raises concerns regarding noncompliance with the Information Quality Act and the Federal Advisory Committee Act. It is difficult to imagine that such legitimate suspicions would be something the White House would wish to add to its legacy in the final days of the Bush administration.
The five reports in question are as follows:
• SAP 1.2, Past Climate Variability and Change in the Arctic and at High Latitudes , was originally scheduled to be completed “within two years” of the publication of the July 2003 Strategic Plan (i.e., by July 2005). Not until August 2008 was a draft report produced for public review, which concluded on 25 September 2008. A third draft was posted on the CCSP website on 28 October, at which time it was submitted by the lead agency (US Geological Survey) for final review and approval. According to the published timeline for the report it was supposed to have been published two weeks after being submitted for clearance. However, it has now been stalled in the clearance process for more than nine weeks, with no explanation for the delay. Are OSTP staff directly responsible for this delay?
• SAP 4.1, Coastal Sensitivity to Sea-Level Rise: A Focus on the Mid-Atlantic Region , was scheduled originally to be completed by July 2005. It finally was submitted for clearance on 22 October 2008. According to the Minutes of the 6th Meeting of the Coastal Elevations and Sea Level Rise Advisory Committee (held on 16 October 2008), “the report was essentially complete,” it would take “two to three weeks” for clearance, and “the report would be released around late November.” It still has not been cleared and published after over more than 10 weeks, with no apparent justification.
• SAP 4.2, Thresholds of Change in Ecosystems , originally was promised for completion within 2-4 years, i.e., by July 2007. It finally was submitted for clearance on 4 November 2008. According to the final prospectus for the report, it was to be published in the same month that it was submitted for clearance, in November. Instead, it has been awaiting clearance for two months.
• SAP 5.2, Best Practice Approaches for Characterizing, Communicating, and Incorporating Scientific Uncertainty in Decisionmaking , originally was promised by July 2005; it finally was submitted for clearance on 22 December 2008. According to the report prospectus, it is to be posted publicly the month after being submitted for clearance, in January 2009.
• SAP 2.3, Aerosol Properties and their Impacts on Climate, originally was promised by July 2007 but submitted for clearance on 15 December 2008.
We strongly urge that you take all necessary steps to ensure that all five of these reports are cleared and released before January 20. We also call on OSTP to make public all editorial comments and/or proposed changes submitted to the authors during the final clearance process, along with any other correspondence among OSTP staff, the CENR, the CCSP, and the authors during the time period following the posting of the final drafts of these reports to the present. We will look forward to a written response to this inquiry at your earliest convenience.
Director, Climate Science Watch
Senior Associate, Climate Science Watch