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April 14, 2005:

The Honorable John McCain:

The Honorable John F. Kerry:

United States Senate:

Subject: Climate Change Assessment: Administration Did Not Meet 
Reporting Deadline:

For many years, scientists have observed a warming trend in the earth's 
climate and have projected additional changes in the coming decades, 
with potential implications for human society. To provide for the 
development and coordination of a comprehensive and integrated U.S. 
research program that will assist the nation and the world in 
understanding, assessing, predicting, and responding to such changes, 
the Congress, in the Global Change Research Act of 1990 (act), required 
the administration to, among other things, prepare a national global 
change research plan, a summary of the achievements and expenditures in 
the area of federal climate change research, and a scientific 
assessment. The scientific assessment is to be prepared at least every 
4 years and is to:

(1) integrate, evaluate, and interpret research findings on climate 
change of the Global Change Research Program (implemented under the 
Global Change Research Plan) and scientific uncertainties associated 
with such findings;

(2) analyze the effects of global change on the natural environment, 
human health and welfare, and other specified areas; and:

(3) analyze current trends in global change and project major trends 
for the next 25 to 100 years.

The first scientific assessment under the act was completed in November 
2000, when the Office of Science and Technology Policy (OSTP) in the 
Executive Office of the President[Footnote 1] transmitted to the 
Congress a 600-plus page report entitled Climate Change Impacts on the 
United States: The Potential Consequences of Climate Variability and 
Change. The report sought to identify the key climatic vulnerabilities 
of particular regions of the country and sectors of the economy in the 
context of other changes in the nation's environment, resources, and 
economy. In addition to the full report, the administration published a 
154-page summary of the findings for a more general audience. Detailed 
reports were also published on the possible impacts of climate change 
on specific regions and the possible effects of climate change on 
various environmental, economic, and social sectors. Some of these 
reports were published after November 2000, the final one in 2003.

In 2002, the President announced the creation of the interagency 
Climate Change Science Program (CCSP) to coordinate and direct U.S. 
research efforts in the area of climate change. CCSP is now responsible 
for producing and submitting the climate change assessment and is led 
by the Assistant Secretary for Oceans and Atmosphere at the Department 
of Commerce. In July 2003, CCSP's strategic plan was transmitted to the 
Congress. The strategic plan contained a schedule for preparing the 
next assessment by publishing 21 reports, each focusing on a specific 

The act also requires preparation of a national global change research 
plan. In 2002, under the auspices of CCSP, 13 federal departments and 
agencies contributed to the drafting of such a plan, and in December 
2002, CCSP held a climate science workshop in Washington, D.C., at 
which climate scientists and other information users provided comments 
and suggestions on the draft plan. At CCSP's request, under an 
agreement called for in the act, the National Academy of Sciences-
National Research Council convened an expert committee to review the 
draft. According to the committee's February 2003 review of CCSP's 
draft strategic plan, the draft plan was not likely to produce 
deliverables, such as written reports, within 4 years. In response, 
CCSP officials developed a set of potential research topics that they 
believed would both satisfy the need for deliverables and meet the 
act's reporting requirements. These research topics were subsequently 
reduced to 21 topics, which became the foundation of the current 

You asked us to evaluate the extent to which CCSP's planned assessment 
meets the requirements of the act regarding the timing and content of 
such an assessment. In conducting our work, we reviewed and analyzed 
the act, its legislative history, and agency documents. We also 
interviewed the CCSP Director and other Department of Commerce 
officials. We conducted our work between June 2004 and February 2005 in 
accordance with generally accepted government auditing standards.

CCSP Did Not Submit an Assessment in 2004, as Required:

CCSP did not submit a scientific assessment in November 2004, 4 years 
after the previous assessment, as required by the act. Instead, CCSP's 
July 2003 schedule called for issuing 21 shorter reports between 2005 
and 2007. According to that schedule, the first 9 reports are due on or 
before September 30, 2005, and the other 12 are due on or before 
September 30, 2007. Thus, by the time the last of these reports is 
published, about 7 years will have elapsed since the publication of the 
2000 report--nearly twice the interval specified in the act. Further, 
the CCSP Director told us that he was not certain that even the first 9 
reports would be published in accordance with this planned schedule. Of 
these 9 reports, a specific timeline is in place for only the first 
report, and that report is on schedule. For 3 other reports, draft 
prospectuses, the first step in the writing process, have been released 
for public comment, but for the remaining 5 reports, originally planned 
for September 2005, no prospectuses had been published as of February 
2005. Those reports are now expected to be completed up to a year later 
than planned, September 2006. The remaining 12 reports are currently 
expected to be completed by September 2007, according to the CCSP 
Strategic Plan. The Director said the completion of these 12 reports 
would be affected to some extent by the delay in issuing the first 9 
reports, but the delay would be less than 12 months.

According to the CCSP Director, work on the reports was delayed for 
three reasons: (1) the CCSP Committee, consisting of senior members of 
13 federal departments and agencies overseen by three entities of the 
Executive Office of the President, underestimated the complexity and 
scope of the work involved to produce the reports; (2) the guidelines 
for preparing the assessment were delayed as a result of extensive 
legal discussions that included discussions about compliance with the 
Data Quality Act and Office of Management and Budget guidance on peer 
review; and (3) the director was severely ill for the better part of a 
year when the assessment was getting started, which slowed early 

The CCSP Director also told us that, considering the number of 
advancements in science and technology today compared with 1990, 4 
years may not be enough time to complete a comprehensive assessment, 
such as that called for under the act. Further, over the past decade 
and a half, federally sponsored climate research has greatly expanded. 
For example, in fiscal year 1991, 9 agencies spent $954 million on 
climate change science, compared with fiscal year 2004, when 12 
agencies spent about $2 billion on climate change science. This has 
increased the burden of analyzing and synthesizing all of the research. 
The director also noted that the Intergovernmental Panel on Climate 
Change, an international body that assesses scientific, technical, and 
socio-economic information on climate change, uses a 7-year reporting 

Unclear How CCSP's Planned Reports Will Explicitly Address All Required 
Assessment Topics:

It is unclear how the 21 reports proposed in CCSP's July 2003 strategic 
plan will address all three of the components of the assessment 
required under the act. The planned report topics generally appear to 
focus on either of these components: (1) the evaluation and 
interpretation of research findings on climate change and associated 
scientific uncertainties or (2) the analysis of current trends in 
global change and projection of major trends. (See the enclosure for 
the planned reports and their estimated publication dates.) However, 
CCSP has no comparable explicit plan for addressing the other major 
required component, assessing the effects of global change on the eight 
areas enumerated in the act: the natural environment, agriculture, 
energy production and use, land and water resources, transportation, 
human health and welfare, human social systems, and biological 
diversity. The National Academy of Sciences-National Research Council 
noted in its February 2004 review of the final CCSP strategic plan 
that, "The purpose of the plan's proposed [reports] must also be 
clarified, because it is unclear whether the 1990 
Global Change Research Act requirement for impact assessments...." The 
Council noted that "...some areas specified in the Act, such as 
analyzing the effects on energy production and use, human health and 
welfare, and human social systems, are only peripherally addressed by 
this portfolio of products. Not a single [report] explicitly addresses 
the nation's water supply."

CCSP officials agreed that some of the required topics are not 
explicitly included on the current list of planned reports, but told us 
that they are committed to reporting on all eight areas and are 
considering using various means of doing so. For example, a Commerce 
Department senior counsel said that as the authors of the 21 reports 
prepare their outlines, they will be asked to document how they intend 
to respond to the act and will have the opportunity to modify or extend 
their reports' coverage. Moreover, the CCSP Director noted that 
additional reports could be commissioned if necessary to cover any 
assessment areas not otherwise addressed. However, we believe that, 
without a well-developed plan that links the reports to the eight 
assessment areas--and especially because the currently planned reports 
will be issued over a 3-year period--the Congress and other users will 
not know how, when, and where the eight areas will be addressed. 
Further, the CCSP Director stated that there are currently no plans to 
integrate and summarize the findings of the 21 individual reports into 
a single volume, as was done in 2000.


The 4-year interval between assessments, which was established 15 years 
ago, may not allow sufficient time for CCSP to prepare an assessment 
that meets all of the act's requirements. We believe that, if the 
deadline cannot be met for any future assessments, the CCSP Director 
should recommend that the CCSP interagency committee request an 
extension from the Congress.

CCSP's approach for reporting on the eight assessment areas contrasts 
with its more structured approach for addressing scientific 
uncertainties and trends. Without a well-developed plan for how it will 
address the eight assessment areas--and especially because the 
currently planned reports will be issued over a period of 3 or more 
years--the Congress and other users will not know when and where all of 
the issues will be addressed or whether the reports meet the 
requirements established by the act. Accordingly, we believe that a 
well-developed plan for addressing all eight assessment areas would 
provide assurance to the Congress and others on when and where all 
eight areas will be covered.

Because the 21 individual reports are planned to address scientific 
uncertainties associated with climate change and other technical 
subjects and are to be issued over a period of 3 or more years, it may 
be difficult for the Congress and others to use this information 
effectively as the basis for making decisions on climate policy. We 
believe it would be helpful to the Congress and other users if CCSP 
summarized the 21 reports in a single volume for a general audience, as 
was done in 2000.


To ensure that the climate change assessments required under the Global 
Change Research Act of 1990 present information in a manner that is 
most useful for the Congress and the public, we recommend that the CCSP 
director take the following three actions:

* develop plans to prepare the next assessment within the prescribed 
time frame, or if 4 years are insufficient to complete the assessment, 
recommend to the CCSP interagency Committee that CCSP request an 
extension from the Congress;

* develop a specific plan to address all eight of the assessment areas; 

* recommend to the CCSP interagency Committee that a summary report be 
prepared to integrate the findings of the 21 or more individual reports.

Agency Comments and Our Evaluation:

We provided the Assistant Secretary of Commerce for Oceans and 
Atmosphere, who also serves as the Director, CCSP, with a draft of this 
report for review and comment. He generally agreed with our 
recommendations, but he provided no specific information on whether and 
when he intends to develop a plan that addresses all eight assessment 
areas. We continue to believe that such a plan should be developed. The 
Director also provided technical comments, which we incorporated. His 
comments and our response are included in enclosure II.


As agreed with your offices, we plan no further distribution of this 
report until 30 days after the date of this report. At that time, we 
will send copies to the Director, CCSP, and other interested officials. 
The report will also be available on GAO's homepage at [Hyperlink,]. If you have questions, please contact me or David 
Marwick at (202) 512-3841. Anne K. Johnson was the major contributor to 
this report. John Delicath and Amy Webbink also made important 

Signed by:

John B. Stephenson:

Director, Natural Resources and Environment:


Enclosure I:

Planned Reports on Topics Related to Climate Uncertainty:

In its July 2003 strategic plan, CCSP identified five broad research 
goals for climate change, shown in the table below. Under each goal are 
the specific topics, 21 in all, that will comprise the national 

Estimated completion date (starting Oct. 2003);: Report topics.

Reports that extend knowledge of the Earth's past and present climate 
and environment, including its natural variability, and improve 
understanding of the causes of observed changes.

1; Within 2 years; Temperature trends in the lower atmosphere--steps 
for understanding and reconciling differences.

2; Within 2 years; Past climate variability and change in the Arctic 
and at high latitudes.

3; 2-4 years; Re-analyses of historical climate data for key 
atmospheric features. Implications for attribution of causes of 
observed change.

Reports that improve quantification of the forces bringing about 
changes in the Earth's climate and related systems.

4; Within 2 years; Updating scenarios of greenhouse gas emissions and 
concentrations, in collaboration with the Climate Change Technology 
Program (CCTP). Review of integrated scenario development and 

5; Within 2 years; North American carbon budget and implications for 
the global carbon cycle.

6; 2-4 years; Aerosol properties and their impacts on climate.

7; 2-4 years; Trends in emissions of ozone-depleting substances, ozone 
layer recovery, and implications for ultraviolet radiation exposure and 
climate change.

Reports that reduce uncertainty in projections of how the Earth's 
climate and related systems may change in the future.

8; Within 2 years; Climate models and their uses and limitations, 
including sensitivity, feedbacks, and uncertainty analysis.

9; 2-4 years; Climate projections for research and assessment based on 
emissions scenarios developed through CCTP.

10; 2-4 years; Climate extremes, including documentation of current 
extremes. Prospects for improving projections.

11; 2-4 years; Risks of abrupt changes in global climate.

Reports that improve understanding of the sensitivity and adaptability 
of different natural and managed ecosystems and human systems to 
climate and related global changes.

12; Within 2 years; Coastal elevation and sensitivity to sea-level rise.

13; 2-4 years; State-of-knowledge of thresholds of change that could 
lead to discontinuities (sudden changes) in some ecosystems and climate-
sensitive resources.

14; 2-4 years; Relationship between observed ecosystem changes and 
climate change.

15; 2-4 years; Preliminary review of adaptation options for climate-
sensitive ecosystems and resources.

16; 2-4 years; Scenario-based analysis of the climatological, 
environmental, resource, technological, and economic implications of 
different atmospheric concentrations of greenhouse gases.

17; 2-4 years; State-of-the-science of socioeconomic and environmental 
impacts of climate variability.

18; 2-4 years; Within the transportation sector, a summary of climate 
change and variability sensitivities, potential impacts, and response 

Reports that explore the uses and identify the limits of evolving 
knowledge to manage risks and opportunities related to climate 
variability and change.

19; Within 2 years; Uses and limitations of observations, data, 
forecasts, and other projections in decision support for selected 
sectors and regions.

20; Within 2 years; Best practice approaches for characterizing, 
communicating, and incorporating scientific uncertainty in decision-

21; Within 2 years; Decision support experiments and evaluations using 
seasonal to inter-annual forecasts and observational data.

Source: Climate Change Science Program.

[End of table]

Enclosure II:

Comments from the Department of Commerce:

United States Department Of Commerce:
The Assistant Secretary of Commerce for Oceans and Atmosphere: 
Washington. D. C. 20230:

April 4, 2005:

Mr. John B. Stephenson:
Director, Natural Resources and Environment:
United States General Accounting Office:
Washington, D.C. 20548:

Dear Mr. Stephenson:

Thank you for the opportunity to review and comment on the General 
Accounting Office's draft report entitled: Climate Change Assessment: 
Administration Did Not Submit Assessment When Required and Needs Well-
Developed Plan to Meet Content Requirements (GAO-05-338R). The National 
Oceanic and Atmospheric Administration's comments on the draft report 
are enclosed.

These comments were prepared in accordance with the Office of 
Management and Budget Circular A-50.


Signed by:

James R. Mahoney, Ph.D.:
Assistant Secretary of Commerce for Oceans and Atmosphere:


DOC/CCSP Comments on the Draft GAO Report Entitled "Climate Change 
Assessment: Administration Did Not Submit Assessment When Required and 
Needs Well-Developed Plan to Meet Content Requirements" (GAO-05-338R/
April 2004):

General Comments:

The report on the Climate Change Assessment does an adequate job in 
representing the status of production of the climate change assessment, 
which is a requirement in 1990 Global Change Research Act (GCRA). 
Although the assessment is being developed and is not yet complete, the 
GAO report does recognize the four-year interval between assessments, 
established 15 years ago by the GCRA, may not be sufficient time to 
prepare an assessment meeting all of the Act's requirements. The GAO 
report also correctly characterizes the challenges faced by the Climate 
Change Science Program (CCSP) in producing this assessment.

Recommended Changes for Factual/Technical Information:
Page 1, bullet (1), lines 1 and 2:

The name of the program is Global Change Research Program. "Change" was 
not included and should be added.

Page 3, lines 2 and 3:

There was never a concrete number (30) of potential research topics 
cited or confirmed. Remove the reference to "30" in lines 2 and 3.

Page 5, first paragraph, lines 3 and 4:

The report mentions the "third" major component and goes on to describe 
the contents of that component. The description in the following lines 
(lines 4-7) actually refers to the "second" major component in Section 
106 of the GCRA. Replace "third" with "second."

Editorial Comments:


DOC/CCSP Response to GAO Recommendations:

The GAO states, "...we recommend that the CCSP Director take the 
following three actions."

Recommendation 1: "Develop plans to prepare the next assessment within 
the prescribed time frame, or if 4 years are insufficient to complete 
the assessment, recommend to the CCSP interagency committee that CCSP 
request an extension from the Congress."

DOC/CCSP Response: DOC/CCSP agrees with this recommendation. CCSP will 
determine the necessary time frame required to meet the assessment 
requirements of the Act, taking into account the schedule of report 
production for the prior assessment (between late 2000 and 2003) and 
the anticipated schedule for the 21 Synthesis and Assessment products. 
CCSP will request an extension from Congress, if necessary. It took the 
previous Administration nearly a decade to issue the first element of 
its first assessment (November 2000) after the Act came into effect in 
1990. And even then, the more detailed, significant reports were 
published as late as 2003. This is a sure indication the complexity of 
the effort envisioned by Congress cannot be reasonably accomplished 
within four years. CCSP believes the approach and timeline it has 
outlined with the 21 Synthesis and Assessment products being released 
on a rolling basis and updated every four years represents an essential 
and prudent balance of quality and timeliness.

Recommendation 2: Develop a specific plan to address all eight of the 
assessment areas.

DOC/CCSP Response: DOC/CCSP agrees with this recommendation. The 
dissemination of the Synthesis and Assessment reports will provide a 
snapshot of knowledge of the environmental and socio-economic aspects 
of climate variability and change. We are engaging the National Academy 
of Sciences-National Research Council to provide advice on the 
relevant aspects of the Climate Change Science Program, including 
recommendations on areas needing further emphasis. Moreover, the lead 
authors of the reports will be asked to document how their efforts 
address one or more assessment areas of the Act as they develop their 
prospectuses and will have the opportunity to modify or extend their 
report's coverage, if needed. We may also commission additional 
reports, if needed, to cover specific topics found to be insufficiently 

Recommendation 3: Recommend to the interagency CCSP Committee that a 
summary report be prepared to integrate the findings of the 21 or more 
individual reports.

DOC/CCSP Response: DOC/CCSP is committed to provide policy-relevant 
summary information within each product. As the reports are staggered, 
we will consider the practicality and utility of also providing an 
overall summary at a single point in time.

GAO's Comments:

The following are GAO's comments on the Department of Commerce letter 
dated April 4, 2005.

1. We revised the text to include the word "Change," as suggested.

2. We deleted the number 30, as suggested.

3. We revised the text, as suggested, replacing the word "third" with 
the word "other."

Although the Director, CCSP, stated that he agrees with our 
recommendation, he did not provide specific information on whether and 
when a specific plan will be developed to address all eight assessment 
areas. We continue to believe that such a plan should be developed.


[End of Section]


[1] OSTP submitted the assessment, which was prepared by the National 
Assessment Synthesis Team, a committee of experts.