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CEI's Comments on National Oceanic And Atmospheric Administration/U.S. Climate Change Science Program’s “Strategic Plan for

Regulatory Comments and Testimony

Title

CEI's Comments on National Oceanic And Atmospheric Administration/U.S. Climate Change Science Program’s “Strategic Plan for

Full Comments Available in PDF Format

Executive Summary

Overview Comments on Chapter 1: Introduction  Climate and Global Change: Improving Connections Between Science and Society

CCSP’s document asserts “sound science” principles once presumed in endeavors such as this, though grossly abused in recent years, most egregiously in the “National Assessment on Climate Change” (NACC).  These “Guidelines” must more strongly assert adherence to, and the requirement that any product meet the requirements of, the Federal Data Quality Act (FDQA)(enacted as Section 515(a) of the FY ’01 Treasury and General Government Appropriations Act (P.L. 106-554; H.R. 5658).  They must be stated more firmly, and provide an internal enforcement mechanism, as well as review and appeal mechanisms pursuant to the White House Office of Management and Budget’s (OMB) “government-wide” Interim Final Guidelines for agency compliance with FDQA requirements (66 FR 49718), finalized by OMB’s January 3, 2002 Final Guidance (67 FR 369), providing a strong foundation for improving the overall quality of information which the federal government disseminates to the public.  Past USGCRP efforts manifested flagrant violation of these basic standards, as detailed in this Comment, and which CCSP must avoid including through instituting advance, FDQA-compliant precautions.