Consistent with and following upon CEI’s 3 June 2002 “Comments on Commerce’s Proposed Data Quality Guidelines”, we request “correction” of NACC’s fatal data flaws which, which upon review appears to be only obtainable by ceasing dissemination of the entirety.
The following represents “an accurate citation to or description of the particular information disseminated which is the subject of the request, including: the date, point and form of disseminations and source from which the requester obtained the information” – NACC was originally disseminated electronically and in print December 2000, continuing to present, at http://www.usgcrp.gov/usgcrp/nacc/default.htm. That the entirety of the relevant USGCRP is now effectively located in and out of NOAA’s Global and Climate Change Program (see, e.g., “Program Guide to Federally Funded Environment and Natural Resources R&D”, available through http://www.nnic.noaa.gov/CENR/, CENR itself being housed out of NOAA as that and other documents and web addresses attest) satisfies the inquiry into the “indication of which NOAA office or program disseminated the information; and any other details that will assist NOAA in identifying the specific information which is the subject of the request and locating the responsible office”.
As CEI detailed in its Comments on Commerce’s Proposed FDQA Guidelines, the White House Office of Management and Budget’s (OMB) Interim Final Guidelines for agency compliance with FDQA requirements (66 FR 49718), finalized by OMB’s January 3, 2002 Final Guidance (67 FR 369), were expressly “government-wide” (see FDQA Section 515(b)(1)). We continue our proceeding under Commerce’s now-final Guidelines, and particularly NOAA’s “Information Quality Guidelines”, to the extent these Guidelines further and are not in conflict with OMB’s organic government-wide guidelines and/or FDQA.
As also detailed in the attached, FDQA prohibits – and therefore, Commerce/NOAA must cease — dissemination of NACC as the sole feasible “correction” given the errors’ endemic nature due to that document’s rampant violations of the data quality requirements of “objectivity” (whether the disseminated information is presented in an accurate, clear, complete and unbiased manner and is as a matter of substance accurate, reliable and unbiased), and “utility” (the usefulness of the information to the intended users (per the US Global Change Act of 1990, these are Congress and the Executive Branch).
This invokes NACC’s inappropriate use of and reliance upon computer models and data that upon scrutiny are demonstrably meaningless. Further, in developing the published version of NACC, the US Global Change Research Program (USGCRP) also admittedly failed to perform the necessary science underlying regional and sectoral analyses (that Congress contemporaneously notified USGCRP was a condition precedent to the release of even a draft National Assessment, as the absence of such yields the absence of sound science). FDQA ratifies those objections, and is violated by continued dissemination of this product by any federal agency.
An extensive record obtained through the Freedom of Information Act (FOIA) provides additional evidence requiring a prohibition on further NACC dissemination. This record exposes that the purported internal “peer review” of the draft NACC did not in fact occur, and also ratifies the inappropriate use of computer models, detailed herein. As the obtained documents demonstrate, commenting parties expressly informed USGCRP that they were rushed and given wildly inadequate time for substantive review or comment. USGCRP published and continues to disseminate the product nonetheless, as do all agencies such as Commerce/NOAA which reference, cite, link or otherwise disseminate NACC.
All of these failings ensure that dissemination of NACC violates FDQA’s requirement, manifested in OMB’s Guidelines and as necessarily manifested by Commerce’s and NOAA’s final guidelines, that data disseminated by Federal Agencies meet standards of quality as measured by specific tests for objectivity, utility and integrity.
As the statutorily designated steering document for policymaking – despite that the particular document at issue admittedly failed to complete the statutory mission required to qualify as a “National Assessment,” and was disavowed by the White House Office of Science and Technology Policy in order to resolve litigation also brought by, inter alia, CEI — NACC qualifies as “influential scientific or statistical information” for purposes of FDQA. Therefore it must meet a “reproducibility” standard, setting forth transparency regarding data and methods of analysis, “as a quality standard above and beyond some peer review quality standards.”
Pursuant to these prior filings, CEI requests that Commerce/NOAA immediately comply with FDQA and cease dissemination of the National Assessment on Climate Change in whole or part and in any form including any product relying on NACC. We therefore also request that you notify us at your earliest convenience of Commerce/NOAA’s substantive response to the violations set forth in this series of communications and the docket number assigned.