I. Introduction
The Global Change Research Act of 1990 (“GCRA”) was nothing if not ambitious. It
established the U.S. Global Change Research Program (“USGCRP”) and directed it to help
policy makers intelligently respond to “global change,” which the statute defines as “changes in
the global environment (including alterations in climate, land productivity, oceans or other water
resources, atmospheric chemistry, and ecological systems) that may alter the capacity of the
Earth to sustain life.” The USGCRP receives billions of dollars annually and is required to
submit, at least every four years, a report on “global change” to Congress and the President that
“(1) integrates, evaluates, and interprets the findings of the Program and discusses the scientific
uncertainties associated with such findings; (2) analyzes the effects of global change on the
natural environment, agriculture, energy production and use, land and water resources,
transportation, human health and welfare, human social systems, and biological diversity; and (3)
analyzes current trends in global change, both human-induced and natural, and projects major
trends for the subsequent 25 to 100 years.”
That report was intended to be a sophisticated synthesis of best scientific evidence about how
both human-induced and natural changes had impacted the world across a broad swath of
categories, and how those changes were expected to continue over the next century. The report
would “combine and interpret” that data in such a manner that it would be “readily usable by
policymakers attempting to formulate effective strategies for preventing, mitigating, and
adapting to the effects of” those changes.
But past reports have fallen far short of the mark. The latest USGCRP report, the Fifth National
Climate Assessment (“NCA5”), is a political document intended to support the Biden
Administration’s pre-ordained climate policy agenda rather than an objective analysis that helps
inform rational policymaking. As the name indicates, rather than addressing “global change” as
defined in the GCRA, NCA5 only looks at climate change. And while it dresses itself in the
language of science and probability, it is not a scientific assessment of how the world, or even
just the climate, is changing. For example, NCA5 myopically focuses on the least likely global
warming scenario, fails to adequately frame the uncertainty of its prognostications, and uncritically relies on studies that fail the information quality standards to which the USGCRP is
bound by law.
The Sixth National Climate Assessment (“NCA6”) is an opportunity for the USGCRP to correct
these past faults and provide lawmakers with the information necessary to make the tradeoffs
inherent in the type of policy options that the GCRA had in mind. There are at least four things
the USGCRP must do to fulfill their statutory mandate in this next report.
First, the report must address “global change” as it is defined in the statute. Past reports
including NCA5 have interpreted the term to mean something like “climate change and its
related global effects.” But while “global change” includes climate change, it is not limited to it.
By narrowing NCA5 and its predecessors’ focus to only climate change, USGRP has deprived
policymakers and the public of the context necessary to understand climate impacts and are
misled about current trends in global change. Providing that context would remedy this defect.
Second, the report must reflect the most likely global change scenarios. Past reports have placed
an outsized emphasis on the most extreme and unlikely climate change scenarios while
simultaneously ignoring the ways in which predictable adaptation will limit the costs associated
with those changes. As a consequence, these reports systematically overstate the harm that
climate change has caused to date and that climate change could reasonably be expected to cause
in the future. These errors prevent the reports from fulfilling their statutory mission to provide
“usable information” for policy decisions.
Third, the report must adequately address scientific uncertainty. If there are lessons to be learned
from the COVID-19 epidemic, chief among them is that experts have imperfect knowledge and
must clearly communicate to both policymakers and the public the extent to which their
pronouncements are grounded in supposition. While past USGCRP reports employ a
complicated system for labeling the likelihood and confidence of certain predictions, these labels
are deeply misleading. NCA5, for example, describes its likelihood labels as “based on statistical
analysis of observed or projected results.” But these are only likelihoods if a certain emissions or
warming scenario comes to pass. The scenarios themselves—by far the most important part of
the projection—“do not have relative likelihoods assigned.” As a result, something that is only
likely in the event of a very unlikely future is still labeled by NCA5 as “very likely, high
confidence.” This is deeply misleading.
Fourth, the report must ensure information quality and scientific integrity. The report is required
by the Information Quality Act (“IQA”) to present information in an “accurate, reliable, and
unbiased” manner. But by neglecting to provide appropriate context for findings, by relying on4
substantively flawed studies, and by failing to address broad conflicts of interest issues, NCA5
fell far short of the IQA’s standard. Unless these errors are remedied by NCA6, its findings will
be similarly undermined.
Comments on the National Oceanic and Atmospheric Administration (NOAA)Availability for Public Comment on NCA6 Draft Prospectus
I. Introduction
The Global Change Research Act of 1990 (“GCRA”) was nothing if not ambitious. It
established the U.S. Global Change Research Program (“USGCRP”) and directed it to help
policy makers intelligently respond to “global change,” which the statute defines as “changes in
the global environment (including alterations in climate, land productivity, oceans or other water
resources, atmospheric chemistry, and ecological systems) that may alter the capacity of the
Earth to sustain life.” The USGCRP receives billions of dollars annually and is required to
submit, at least every four years, a report on “global change” to Congress and the President that
“(1) integrates, evaluates, and interprets the findings of the Program and discusses the scientific
uncertainties associated with such findings; (2) analyzes the effects of global change on the
natural environment, agriculture, energy production and use, land and water resources,
transportation, human health and welfare, human social systems, and biological diversity; and (3)
analyzes current trends in global change, both human-induced and natural, and projects major
trends for the subsequent 25 to 100 years.”
That report was intended to be a sophisticated synthesis of best scientific evidence about how
both human-induced and natural changes had impacted the world across a broad swath of
categories, and how those changes were expected to continue over the next century. The report
would “combine and interpret” that data in such a manner that it would be “readily usable by
policymakers attempting to formulate effective strategies for preventing, mitigating, and
adapting to the effects of” those changes.
But past reports have fallen far short of the mark. The latest USGCRP report, the Fifth National
Climate Assessment (“NCA5”), is a political document intended to support the Biden
Administration’s pre-ordained climate policy agenda rather than an objective analysis that helps
inform rational policymaking. As the name indicates, rather than addressing “global change” as
defined in the GCRA, NCA5 only looks at climate change. And while it dresses itself in the
language of science and probability, it is not a scientific assessment of how the world, or even
just the climate, is changing. For example, NCA5 myopically focuses on the least likely global
warming scenario, fails to adequately frame the uncertainty of its prognostications, and uncritically relies on studies that fail the information quality standards to which the USGCRP is
bound by law.
The Sixth National Climate Assessment (“NCA6”) is an opportunity for the USGCRP to correct
these past faults and provide lawmakers with the information necessary to make the tradeoffs
inherent in the type of policy options that the GCRA had in mind. There are at least four things
the USGCRP must do to fulfill their statutory mandate in this next report.
First, the report must address “global change” as it is defined in the statute. Past reports
including NCA5 have interpreted the term to mean something like “climate change and its
related global effects.” But while “global change” includes climate change, it is not limited to it.
By narrowing NCA5 and its predecessors’ focus to only climate change, USGRP has deprived
policymakers and the public of the context necessary to understand climate impacts and are
misled about current trends in global change. Providing that context would remedy this defect.
Second, the report must reflect the most likely global change scenarios. Past reports have placed
an outsized emphasis on the most extreme and unlikely climate change scenarios while
simultaneously ignoring the ways in which predictable adaptation will limit the costs associated
with those changes. As a consequence, these reports systematically overstate the harm that
climate change has caused to date and that climate change could reasonably be expected to cause
in the future. These errors prevent the reports from fulfilling their statutory mission to provide
“usable information” for policy decisions.
Third, the report must adequately address scientific uncertainty. If there are lessons to be learned
from the COVID-19 epidemic, chief among them is that experts have imperfect knowledge and
must clearly communicate to both policymakers and the public the extent to which their
pronouncements are grounded in supposition. While past USGCRP reports employ a
complicated system for labeling the likelihood and confidence of certain predictions, these labels
are deeply misleading. NCA5, for example, describes its likelihood labels as “based on statistical
analysis of observed or projected results.” But these are only likelihoods if a certain emissions or
warming scenario comes to pass. The scenarios themselves—by far the most important part of
the projection—“do not have relative likelihoods assigned.” As a result, something that is only
likely in the event of a very unlikely future is still labeled by NCA5 as “very likely, high
confidence.” This is deeply misleading.
Fourth, the report must ensure information quality and scientific integrity. The report is required
by the Information Quality Act (“IQA”) to present information in an “accurate, reliable, and
unbiased” manner. But by neglecting to provide appropriate context for findings, by relying on4
substantively flawed studies, and by failing to address broad conflicts of interest issues, NCA5
fell far short of the IQA’s standard. Unless these errors are remedied by NCA6, its findings will
be similarly undermined.