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CEI's Request For Comments From The National Oceanic And Atmospheric Administration On The National Assessment On Climate C

Regulatory Comments and Testimony

Title

CEI's Request For Comments From The National Oceanic And Atmospheric Administration On The National Assessment On Climate C

Dear Admiral Lautenbacher and Dr. Mahoney,

 

I write regarding the US Global Change Research Program’s (USGCRP) “Planning Workshop for Scientists and Stakeholders”, scheduled for 3-5 December 2002.  This gathering is in pursuit of the USGCRP’s two statutory functions of producing a climate research plan and a National Assessment on Climate Change (NACC).

 

On behalf of CEI I strongly urge the Department of Commerce and particularly NOAA to ensure that all those who played a formal role in developing the deeply flawed First NACC play no formal role in continuing NACC efforts.  These efforts include, inter alia, your Workshop.  The individuals who are particularly associated with the clearly unacceptable activity that was the USGCRP’s NACC process are those who constituted, and presumably still constitute in whole or in part, the National Assessment Synthesis Team (NAST).  We submit that you should take this step in order to avoid exacerbating the legal, political and public perception problems that afflicted the National Assessment, for reasons described herein.

 

The very sad lessons taught by the publication of NACC, formally styled as "Climate Change Impacts in the United States:  The Potential Consequences of Climate Variability and Change" underscore the need for diverse and politically neutral leadership in climate change research.  The same factors arising from this effort that imperiled USGCRP’s budget, and which led to litigation (CEI et al v. Clinton (CV:00-02383 DC DC)), militate toward your intervention.  Unfortunately we are of every confidence that, should even remnants of the same NAST that produced the NACC play a role in continuing efforts, a similar result -- and thus congressional and private response -- would ensue.

You no doubt are aware of most of the reasons why the first NACC – and those who directed that original effort -- simply cannot be allowed to impact the continuing government efforts in this important area.  This Synthesis Team, headed by Thomas Karl, Director of the National Climatic Data Center, Jerry Melillo, Woods Hole Laboratory, and Anthony Janetos, director of the Heinz Foundation's lobbying efforts on global warming, oversaw what has been publicly revealed to be one of the greatest abuses of science in the history of the climate change issue.  In fact, CEI intends to petition under the new Federal Data Quality Act to prohibit further dissemination of NACC. 

 

Nonetheless, to ensure that past transgressions do not fade quickly from memory as critical work continues, I enclose a copy of our June 3, 2002 comments to NOAA regarding its proposed FDQA Guidelines.  Pages 27-35 of this document detail the various glaring weaknesses of the NACC that USGCRP rushed into publication.  Particularly relevant are pages 32 and 35, excerpting FOIA’d comments from government scientists addressing the USGCRP products which emerged as NACC.  The USGCRP Synthesis Team received yet disregarded these and other damning indictments of the product, ultimately resulting in the litigation exposing the NACC and the USGCRP process.

 

The Synthesis Team was created from a concatenation of multiple committees within the Clinton Administration, ultimately reporting to Vice-President Gore and Science Advisor John Gibbons, a chain of command fully known to the members.  Our discoveries, under the Freedom of Information Act and through our efforts to gain cooperation and correction prior to litigating, beg the question:  Did NAST bend the rules of science because of political pressure?Circumstantial evidence argues NAST did; what is inarguable, as our public-record pleadings in CEI et al. v. Clinton make clear, is that the process proceeded incompletely, hurriedly and in violation of numerous congressional expressions of intent.  As can be seen in the NACC itself, a number of climate models were considered for use as drivers for subsidiary impacts such as the effects of climate change on forests, agriculture, and health.  Two models were ultimately accepted.  One, the Canadian Climate Center model, produced more warming over the U.S. than any of others.  The other, from Britain's Hadley Center, produced greater precipitation changes than any of the others.  Temperature and precipitation are the primary output variables from the models.  It is indisputable that NACC leadership chose to accept what are charitably described as “outlier” models.As our comments also set forth, outside reviews revealed that both models failed to perform better than a table of random numbers in their attempts to simulate the behavior of U.S. temperatures under a changing greenhouse effect.  In public comment, the Synthesis Team refused to acknowledge this problem.  However, NAST was sufficiently concerned to replicate the experiment cited by the particular reviewer making this point, and found it was indeed correct.  NAST nonetheless proceeded forward with the NACC as they had planned.Serious questions of scientific and policy ethics are raised by the prospect of knowingly employing models that do not work, which putatively would serve as the basis for policy.  In this case, these actions provoked a hearing by the House Oversight and Investigations Subcommittee, in which Messrs. Karl and Janetos did not deny that the models could not replicate U.S. temperatures.  As a result, the NACC established a public record that clearly can threaten the integrity of federal science in the entire climate change issue.  We believe this example, coupled with NAST’s refusal to abide congressional requests regarding peer review of regional and sectoral analyses, led to congressional reluctance to satisfy the requested funding increase.

 

NAST disregarded all comments referenced herein, and numerous others in a long series of warnings about the politicized and non-scientific nature of USGCRP’s rush to produce an “Assessment”, many of which are detailed in our pleadings.  This is illustrative of NAST’s problem that is both past and, barring intervention by your offices or Congress, we do not doubt future as well.

 

Given all of this, we would find it highly questionable to not specifically rule out anyone associated with the production of the NACC in continued scientific oversight on climate change.

 

Should you have any questions or wish to discuss this matter, please do not hesitate to contact me at 202.331.1010 ext. 252.

 

Sincerely,

 

Christopher C. Horner

Counsel

 

enc

 

cc:        Senator James Inhofe

Representative Jo Ann Emerson

Representative Joseph Knollenberg

Chairman Ken Calvert