See also:

• Release of Public Comments on Draft Strategic Plan.  Announcement (dtd 21 Dec 2005) from the U.S. Climate Change Technology Program.  Also available in PDF format.
• List of Commenters.  Also available in PDF format.
• List of Supplemental documents.  Also available in PDF format.
• Strategic Plan, Draft for Public Comment.  Review draft (dated September 2005).

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Comment

1

General

The Draft Plan Appears To Be Dependent on the Continued Existence over this Century of the CCTP.

A review of the companion Vision document shows (pp. 3-6) that in January 2002 "the President reorganized Federal oversight, management and administrative control of climate change-related activities" by establishing a "Cabinet-Level Committee on Climate Change Science and Technology Integration" (CCCSTI), which "makes recommendations to the President on matters concerning climate change science and technology plans, investments, and progress." In addition, the Vision explains that under the CCCSTI "two multi-agency programs were established to coordinate and integrate Federal activities, review progress and make recommendations." These programs are the CCSP and the "technology counterpart to the CCSP," the CCTP, which has as its "principal aim. . . to accelerate the development of new advanced technologies to address climate change."

According to the Secretaries (p. iii), the Plan "articulates a vision of the role for advanced technology" in addressing climate change, "defines a supporting mission" for the CCTP, "establishes strategic direction and a framework of guiding principles for Federal R&D agencies in formulating a CCTP research and development portfolio" and "outlines approaches" to "attain CCTP’s six strategic goals." The Secretaries add that the Plan "[a]ppropriately. . .takes a century-long look at the nature of the climate change challenge and the potential for technological solutions across a range of uncertainties" (emphasis added). The Foreword explains (p. iv) that "the Plan provides a long-term planning context. . .as well as the opportunities for technology, which will better inform future Federal R&D planning" and, along with the companion "Vision" document, "lays the foundation for setting priorities through its technology strategies and criteria for investment" (emphasis added). Moreover, the Plan "will guide and galvanize the Federal Government’s extensive and diverse technical efforts." Id.

While there certainly are significant advantages in such long-term planning, we are concerned that the draft Plan appears to be organizationally dependent on the continued existence and inter-relationship over the "long term" of the CCTP and, for that matter, the CCSP and the CCCSTI. In this case, the "long term" is apparently intended to span this century, which, during that time, will encompass numerous Administrations, any number of which could decide to change the "mission" of the CCTP or even dismantle it entirely. While the CCTP can be useful, it is important to us that this planning be "led" by the DOE, which, unlike the CCPT, is a cabinet-level agency. Moreover, DOE has a broadly established RDD&D mission provided by Congress in the Department of Energy Organization Act of 1977 (including related statutes referred to therein), which was greatly enhanced by the Energy Policy Act of 1992 and the recently enacted Energy Policy Act of 2005 (EPAct 2005), 42 U.S.C. § 15801 et seq. This congressional framework provides a more stable organizational basis for such planning. Indeed, nowhere in the draft Plan or the Vision is there any mention or reference to a statutory basis for the CCTP. We trust that that is an oversight and that the final version will include a discussion of statutory authority. Moreover, DOE’s overall involvement and lead should be made more prominent in the draft.

2

General

CCTP is in urgent need of organizational strengthening. In the short-run, launching a properly funded exploratory research program would ameliorate the problem. In the longer-term, creating a climate technology ARPA or a climate component of an ARPPA-E will almost certainly be an essential step.

3

General

First of all, congratulations on getting this document out at all. That said, however, now is the chance to really improve the Plan by responding to the public comments and criticisms. You might even want to consider publishing the comments and criticisms along with your response.

4

General

The Plan is not a plan in the budget sense. It does not detail how much is being spent on each RD3 area, nor does it project what is needed to achieve the stated goals. It does not list or explain priorities.

5

General

We) appreciate the establishment by the Administration of the U.S. Climate Change Technology Program (CCTP), which we understand from a "companion document," titled "Vision and Framework for Strategy and Planning" (Vision), is the "technology counterpart" to the U.S. Climate Change Science Program (CCSP) and a "multi-agency planning and coordinating entity, led by the Department of Energy" (DOE).1 We particularly welcome the publication for public "review and comment" of the CCTP’s "preliminary. . .Strategic Plan" (Plan), which, according to the draft Plan’s cover letter (p. iii) signed by the Secretaries of Commerce and Energy and the Director of the Office of Science and Technology Policy (Secretaries), is intended to provide "strategic direction" to all federal agencies in "formulating a coordinated approach to climate-change-related technology research, development, demonstration, and deployment" (RDD&D). We commend DOE and your federal agency partners for your foresight in preparing this draft Plan, and specifically for the vast majority of very helpful contents. We also take this opportunity to express some general concerns with the draft Plan and CCTP, and urge DOE to make appropriate changes to address these concerns.

1 The Vision document is referred to in the draft Plan’s Foreword (p. iv). It is dated August 2005 and was not made available for public comment. We note that much of its contents are restated in the Introduction to the draft Plan.

6

General

We suggest adding language such as "This model does not fully characterize renewables and so underestimates their potential contribution. A more detailed renewable module is under development." [This could be modified depending on what parts of the model are actually used in the update. We know that wind may be included, but solar would not have been added yet.]

7

General

Chapters 4-7

The chapters provide interesting summaries of ongoing and planned federal R&D efforts, but the descriptions of possible effects reflected in the "Technology Strategy" sections are typically overly positive and lack a serious discussion of the probable obstacles to deployment in each individual case. For example, Chapter 5, pg 5-19 outlines a very optimistic growth strategy for a variety of renewable energy technologies. The section discusses only what positive elements would be derived from expanded use of these technologies and that expansion is driven solely by "reduced costs." The assessments of available technologies and programs in Chapters 4-7 give little indication of how the portfolio planning and investment criteria are being applied in practice or will be applied in the future.

8

General

First of all, the Plan is an exceedingly thorough and comprehensive accounting of the RD3 currently being supported by the federal government. It puts the problem of greenhouse gases in the atmosphere in global and national perspective, and it gives a good justification for the government expenditures and involvement. This document will be very important and influential throughout the world.

9

General

We agree with the premise in this plan that a broad range of new energy options will needed to be developed to resolve this Nation’s and the world’s long term energy needs. We are glad to see fusion included in the portfolio of seriously considered approaches for new energy sources. Although fusion still faces significant technical and scientific challenges there has been significant progress and the potential payoff is immense.

10

General

CCPT should consider the risk that international GHG control regimes may remain narrow in coverage, relatively ineffectual, and slow to evolve. This possibility implies that CCTP should regard it as essential to develop technologies to neutralize harmful climate change and to lower its costs. It also reinforces the point that, while carbon capture and storage remains an important potential tool, CCTP should hedge its bets on this technology.

11

General

The Draft Plan Appears To Be a One-time Document, with No Provision for Further Review and Update of the Plan, the CCTP and their Progress.

Chapter 10 of the draft Plan (pp. 10-6 - 10-7) states that the "CCTP’s next steps focus on two broad thrusts." One is for the CCTP to "continue to provide support" to the CCCSTI and the other is for the CCTP to "continue to work with and support" the federal agencies "in developing plans and carrying out activities needed to advance the attainment of the CCTP’s vision, mission, and strategic goals." It then provides that for each "CCTP strategic goal, to the extent suitable,

. . .agency plans and activities will be guided by the seven core approaches" listed, as noted above, in the beginning of the chapter (p. 10-1) in order to ensure progress toward "attainment of the CCTP’s vision, mission, and strategic goals." As already noted, it then lists several "activities that follow these seven approaches" under the title "Next Steps."

However, as far as we can determine, there is no timetable for the Plan’s "vision, mission, goals" and "activities," other than the reference to the 21st century. Nor is there a commitment by the CCTP to report on the progress of the vision, mission, six strategic goals, seven core approaches, etc. annually or at any time in the future. Thus, the draft Plan appears to be a one-time event that provides no opportunity for stakeholders, the public or Congress to learn periodically what has and has not been achieved and to discuss what more needs to be done. In short, there are no real "next steps." The draft plan is seriously lacking in this regard, and we urge that the term "next steps" be expanded at a minimum, with provisions for reporting on progress, achievements and effectiveness, not only of the Plan, but also of the CCTP.

12

General

While the multi-decadal approach of the Strategic Plan represents an admirable change from recent U.S. energy policy, the levels of R&D spending in your plan are not commensurate with the challenges posed by the increases in greenhouse-gas concentrations that are outlined in Chapter 3. For example, we agree with the recommendations in Chapter 10 that include: "Strengthen Climate Change Technology

R&D" and "Strengthen Basic Research Contributions." Yet, the only specific funding levels provided in the Strategic Plan for future years are for 2006, which amount to $3.011b, and which represent a decrease from current levels of climate-related R&D

investment.

A more serious long-term commitment to research funding [1] will be necessary to commercialize and deploy on a large scale the advanced technologies described in Chapters 3 through 9. We have recently completed work that shows that the investment required will be on the order of 5 to 10 times the levels that you outline in Appendix A [2, 3]. While such an increase would represent a non-incremental change

from current trends, we have shown that it is well within the bounds

of previous federal efforts to apply science and technology to

address national concerns. We append our assessment and

documentation of our calculations as attachments to this email.

Please refer to the following references:

[1] Margolis, R. M. and Kammen, D. M. (1999) "Underinvestment: the

science and technology policy challenge", Science , 285, 690-693.

[2] Kammen, D. M. and G. F. Nemet (2005). "Reversing the Incredible

Shrinking U.S. Energy R&D Budget." Issues in Science and Technology

22: 84-88.

see EnergyR&D-IssuesFall2005.pdf)

[3] "Appendix: Estimating energy R&D investments required for

climate stabilization" http://socrates.berkeley.edu/~rael/

RandD_appendix.pdf

13

General

First Overview Comment: I believe the subject report provides little or no predicate demonstrating the concern for controlling Green House Gases (GHG). The authors appear to make the tacit assumption the reader is convinced GHG are a phenomenon of fusil fuel consumption. Early in the history of the Earth, the CO2 concentration was high and in spite of using fusil fuel the CO2 concentrations are lower now. Perhaps the is a natural variation governing the climate.

14

General

The Time Frame of the Plan Is Focused Primarily on the Long Term and on New and Advanced Technologies, with Little Attention Paid to Near- and Mid-Term and Existing and Improved Technologies.

As noted above, the draft Plan states that the "CCTP’s strategic goals. . .encompass a range of levels under conditions of uncertainty" (p. 2-2). DOE’s "Invitation to Review" the draft states that the "purpose of the CCTP is to accelerate the development and reduce the cost of new and advanced technologies that could avoid, reduce, or capture and store" GHG emissions "and contribute to U.S. climate change goals" (emphasis added). The Introduction emphasizes (p. 1-3) that "[t]his Plan takes a century-long look at the nature of this challenge," "explores an array of opportunities for technical solutions," "articulates a vision for new and advanced technology in addressing climate change concerns, defines a supporting planning and coordination mission for the multi-agency CCTP, and provides strategic direction to the Federal agencies in formulating a comprehensive portfolio of related technology" RDD&D (emphasis added). The statement by the Secretaries (p. iii) that the "overwhelming majority of anthropogenic GHG emissions that will occur over the course of the 21st century will arise from equipment and infrastructures not yet built" is even more futuristic.

While we support long-term planning, as well as the development of "new and revolutionary technologies," a century is a lengthy time frame to focus upon, and building expectations that new and advanced technologies will successfully address GHGs over that time frame is risky, at best. Moreover, planning over such a long period raises issues of reliability, as well as serious uncertainty. Relying heavily in such planning on the success of one or more such technologies at sometime in this extended period gives the appearance, at least, of the U.S. government "putting all of its eggs in one basket" and, in essence, hoping to hit a "grand slam" or "home runs," when hitting "singles, doubles or triples" might show significant results and consistent progress over the near- and mid-term.

Yet, according to the Secretaries (p. iii), the Plan "provides a strategic direction" for the federal agencies "in formulating a coordinated approach to climate change-related technology" RDD&D. They add that the "CCPT activities" are to "form the technology component of a comprehensive U.S. approach to climate change." That approach includes three other components:

• "[S]hort-term actions to reduce" GHG "intensity" (emphasis added).

• "[Advancing climate science."

• "[P]romoting international operations."

However, scant attention is paid in the draft Plan to these other components, particularly the first. Indeed, Chapter 10 states (p. 10-2) that six of the 10 chapters of the Plan (i.e., Chapters 4-9) are all devoted to examining "the potential role for advanced technology," leaving the possibility of only Chapters 2 and 3 to address near- or mid-term "actions," since Chapter 1 is the Introduction and Chapter 10 addresses conclusions and next steps (although there is some brief discussion in that chapter of the CCTP’s "encouraging integrative system design, with near- and long-term advances in technology"). While Chapter 2 notes that the U.S. "approach" includes such "short-term actions," it emphasizes (p. 2-1) that "this CCTP Strategic Plan articulates a vision of the role of new and advanced technology in addressing climate change concerns" and that the "CCTP aims to inspire broad interest, within and outside of government. . .in an expanded global effort to develop, commercialize and deploy such technology toward attainment of the UNFCCC’s ultimate objective." Chapter 3, titled "Synthesis Assessment of Long-Term Climate Change Technology Scenarios," is closely associated with Chapters 4-9 and the relationship of such technology to the FCCC’s "ultimate objective."4

Chapter 4.4, titled Electric Grid and Infrastructure," states (p. 4-16) that "[l]arge reductions in CO2. . .may require that a significant amount of electricity be generated from carbon free or carbon neutral sources," such as nuclear and renewables, and that "[s]ome renewable energy resources are concentrated in regions" of the U.S. "that are distant from large urban markets," and thus the "future. . .distribution infrastructure (the ‘grid’) would need to extend its capacity and evolve to an intelligent and flexible system that enables the use of a wide and varied set of . . .generation technologies." As to the potential role of technology, the chapter notes (p. 4-17) that there are many transmission and distribution "technologies that can improve efficiency and reduce emissions" and refers to several such technologies "[i]n the near term," but then states (p. 4-17) that "[r]ealizing these opportunities requires a research portfolio that focuses on balance of advanced transmission grid and distributed-generation technologies" (emphasis added). However, once again that "portfolio" does not include any real emphasis on the "near term."

Chapter 1 includes a summary of some near-term "actions" as follows (p. 1-2) (footnotes omitted):

The technological elements of this approach, outlined in this Strategic Plan, build on America’s strengths in innovation and technology. These longer-term elements are augmented by near-term policy measures, financial incentives, and voluntary and other Federal programs aimed at slowing the growth of U.S. GHG emissions and reducing GHG intensity. These include the Climate VISION, Climate Leaders, Energy STAR and Smart Way Transport Partnership programs, all of which work with industry to voluntarily reduce emissions. The Department of Agriculture’s conservation programs provide incentives for actions that increase carbon sequestration in trees and soils. Energy efficiency, alternatives fuels, renewable and nuclear energy, methane capture and other GHG reduction programs and financial incentives are also underway.

Unfortunately, that summary clearly indicates that such "actions" are not a part of the CCTP functions, nor are they even a small part of the Plan itself. However, note that Appendix A (p. A-2) refers to RDD&D "activities" that are "classified as part" of the CCTP for funding purposes. Appendix A includes a footnote 2, which provides a very comprehensive definition of such activities, including a reference to the "near term" as follows:

In this context, "research, development, demonstration, and deployment activities" is defined as: applied research; technology development and demonstration, including prototypes, scale-ups, and full-scale plants; technical activities in support of research objectives, including instrumentation, observation and monitoring equipment and systems; research and other activities undertaken in support of technology deployment, including research on codes and standards, safety, regulation, and on understanding factors affecting commercialization and deployment; supporting basic research addressing technical barriers to progress; activities associated with program direction; and related activities such as voluntary partnerships, technical assistance/capacity building, and technology demonstration programs that directly reduce greenhouse gas emissions in the near and long term.

(Emphasis added.) It is unclear whether this definition is intended to apply to the Plan itself or just to Appendix A. Moreover, even if it applies to the Plan, the definition alone would not be an adequate substitute for the lack of a serious consideration of near- and mid-term "actions" in the Plan.

Unquestionably, new and additional breakthrough and transformational technologies are very important and should be supported and encouraged. However, they should be only a part of the total effort. The other part that is equally, if not more, important is the continued development, demonstration and deployment of existing technologies and practices - together with improvements thereof - in the short and medium time frames.

As the Vision document observes (p. 2), "Over the longer term, significant progress would likely require fundamental changes in the way the world provides energy, as well as changes in other processes and infrastructure used in industry, agriculture, forestry, and other human activities that result in GHG emissions." Unfortunately, those "changes" appear to be relatively far off, as there is not now a known "silver bullet" or "magic bullet" for such technologies or fuel changes. In the short and medium terms, we should address global GHG emissions with a portfolio or suite of existing and improved technologies to 1) reduce, avoid and sequester GHGs and 2) adapt to climate change.

In addition, in the short, medium and long terms, fuel diversity - particularly in the power sector - and the technologies that underlay such diversity, are imperative. Indeed, we reemphasize that fuel diversity is critical to our sector and our customers. Considering the availability, abundance and reliability of the supply of various fuels and their infrastructure needs, as well as their economics and regulatory and other factors, it is not practicable or reasonable to be overly dependent on a short list of fuels.

The Plan needs to include a chapter devoted to the incremental approach in the development, demonstration and deployment of climate change technologies because of the long time frame of climate change and any potential global warming. (Temporal flexibility is recognized in the Wigley-Richels-Edmonds curves.) Such an approach would fit domestic needs and is also sound from an international perspective. Indeed, many developing countries need to incorporate existing technologies and practices now and cannot wait 25, 50 or 100 years or more for new and advanced or revolutionary technologies. See p. 26, infra. While developing countries desire such technologies, the incremental approach is probably more realistic.

Indeed, we urge that the Plan include a focus on the short- and medium-term incremental approach to climate change for the U.S. As a start, such a focus should be encapsulated in revised CCTP Vision and mission statements.

15

General

It is the fashion to say ‘portfolio’ but we should consider the potential for truly revolutionary technologies to actually provide the silver bullet. For example, perhaps fortified breeder/burner complexes or solar arrays on the moon. Sometimes ‘portfolio’ is a synonym for ‘pork barrel’ and a chance for everyone to get a little piece of the pie without actually solving the problem

16

General

Climate change is a global problem. R&D that may makes controlling it less expensive should be global in nature. It is wasteful for 10 countries to be working simultaneously on the same reactor, for example. The Plan points out numerous examples of collaborative and coordinated R&D. Perhaps new ways should be explored to keep up with the energy R&D expenditures of all of the nations of the world and to enter into agreements for sharing results and encouraging deployment of technologies that reduce GHG emissions. The Plan could be more comprehensive and imaginative in this regard. International R&D strategy could also save a lot of money.

17

General

Future Research Directions sections are generally of poor quality, and they are often so non specific that they are useless. Also, each of these sections begins with a standard paragraph including the sentence: "Within constrained Federal resources, this portfolio addresses the highest priority current investment opportunities." Since the priorities are obscure, how can you make this statement. This is a very self serving sentence. I believe it should be eliminated from all the Future Research Directions sections.

18

General

CCTP is in urgent need of organizational strengthening. In the short-run, launching a properly funded exploratory research program would ameliorate the problem. In the longer-term, creating a climate technology ARPA or a climate component of an ARPPA-E will almost certainly be an essential step.

19

General

It is incorrect and confusing to mention carbon reduction or sequestration when in all your plan you mean reducing or storing carbon as carbon dioxide.

Carbon sequestration can be either as carbon or as carbon dioxide. Your decarbonizarion technologies all refer to removal of carbon AS CARBON DIOXIDE not as CARBON as elemental carbon.

However, there are technologies for removal, storage and sequestration of carbon as elemental carbon from fossil fuels which are completely ignored in your plan. Look up papers on decabonization of carbon under Meyer Steinberg as author in Journals and in Brookhaven National Laboratory reports and in the book on CO2 Mitigation - the Science and technology.

20

General

RD3 needs to be focused on the needs of developing countries to assure that the poor of the world can choose technologies that are sustainable, i.e. energy systems with low GHG emissions.

21

General

FOR THE LONG RUN, I support the approach that the "United States has placed special emphasis on the fundamental importance of technology investment as a means of achieving climate goals in ways that simultaneously support broader societal goals, and in particular that will meet the world’s need for abundant, clean, secure, and affordable energy to provide a continuing engine for global economic advancement in this century." But I could find no specific road map which gives me any hope that we will meet the NECESSARY climate goal. I find the report too broad and lacking a specific road map. I recognize that the solution will not be a simple one; and I am afraid that as with so much done by the government, it will probably be driven by crises. HOWEVER, THERE IS SOMETHING WE CAN DO FOR THE SHORT RUN which can give us time to solve the climate goal in the long run - and I hope consideration will be given to doing this as described below: I find the charge by President Bush "to consider approaches to reduce greenhouse gas emissions" TO BE TOO LIMITING. The issue we are dealing with, per the plan title, is one of climate change. There may be approaches other than limiting greenhouse gas emissions - and in fact the "Plan" does include other approaches such as sequestration of carbon dioxide. IN DEALING WITH THE SHORT RUN, As we look at the possibility that the recent hurricanes, Katrina and Rita, have had their intensity increased by global warming, we may already have started to violate the dictum of the text, to achieve "stabilization of greenhouse gas... within a time-frame sufficient to allow ecosystems to adapt naturally to climate change". And so I make a plea that an approach to "stabilizing or reversing the global warming of our climate" be added to the approaches being studied by this "Climate Change Technology Program". This approach is to look at moving the radiation balance of the Earth back toward the pre-industrial situation by reducing solar flux using such methods as placing long lived benign particles in the upper atmosphere. This approach has been looked at repeatedly and its technical and economic viability has been assessed as valid. The approach has then been put on the shelf - "to be used if we need it". Issues such as whitening of the sky and the effects of increased carbon dioxide on ocean ph and plant growth have been stated as reasons to not look at this approach. I have never seen a trade-off comparing these negative effects with what is happening today recognizing that the world IS NOT REDUCING ITS PRODUCTION OF GREENHOUSE GAS TO ANY SIGNIFICANT DEGREE.

It is my contention that the proof of "need" will continue to be creeping - including periodically more severe weather which may or may not be caused by global warming. And so, I propose that we create an international program to study any side effects so that we can trade off whether using this approach of reducing incoming solar flux represents more risk than letting the world slowly see rising sea levels and more severe weather including hurricanes and drought. For the time constant of such events is sufficiently long - both to create them and to counter then that we cannot wait for irrefutable proof. As to the mechanism for these tests and implementation, it seems to me that the Kyoto treaty could be amended to provide the desired study direction and implementation if study indicates its expected viability; and very reasonably this "geoengineering:" approach can be considered stop-gap while we continue to move toward change of the world’s energy base and industrial processes as a long term solution. Below are a few specific comments related to this overview which I found in a non-thorough search of the document

22

General

The Plan Needs To Be Harmonized with DOE Statutes, including EPAct 2005, and with the Climate Vision MOU RDD&D Partnership.

The draft Plan does not discuss or even refer to the broad array of statutes that are quite relevant to the implementation of this Plan and that are important to the electric utility industry and other sectors of the economy. Indeed, just recently Congress enacted the Energy Policy Act of 2005 (Pub. L. No. 109-58), which contains a number of new statutory provisions that are be relevant to our industry. Most prominent among these are title XVI, Climate Change; title XVII, Incentives for Innovative Technologies; title IV, Coal; and title VI, Nuclear Matters. In addition, there are provisions in title IX (Research and Development) for the Secretary of Energy to:

• Publish annually measurable cost and performance-based goals for electric generation, transmissions and storage.

• Fund programs that "address advanced energy technologies and systems and advanced grid reliability technologies."

• Establish RD&D programs "to ensure the reliability, efficiency, and environmental integrity of electrical transmission and distribution systems."

• Carry out a Nuclear Energy Research Initiative and a Nuclear Energy System Support Program.

• Establish an Advanced Power System Technology Incentive Program.

• Develop standards and best practices for calculating, monitoring and analyzing GHG intensity.

Further, title XVII authorizes a loan guarantee program for advanced nuclear facilities; efficient electrical generation, transmission and distribution technologies; coal gasification; and other purposes. EPAct 2005 also includes several tax incentive provisions in title XIII, Energy Policy Tax Incentives.

Similarly, the draft Plan appears to pay little attention to how and to what extent the CCTP will work with, utilize and form public-private partnerships and collaborative activities as a means of leveraging and maximizing the development of climate technologies in the short, medium and long terms. On December 13, 2004, seven power sector groups and DOE signed an umbrella climate VISION Memorandum of Understanding as part of the Climate VISION program that, among other things, features the establishment of an RDD&D partnership with DOE’s program offices and the CCTP. Its purpose is for both Parties to "work collectively" to identify: (i) climate technology needs for the electric power sector; (ii) gaps in current power sector climate technology RDD&D; (iii) priority areas for new or supplemental power sector climate technology RDD&D; and (iv) options for potential funding mechanisms for early commercial use of advanced technologies. It includes RDD&D of advanced zero or low-carbon emission electric generation technologies and advanced, high-efficiency electric generation, transmission and end-use technologies.

In short, the CCTP Plan must be based on and be consistent with the applicable statutes and take into consideration joint public-private actions. In the case of the latter, Chapter 2 states that the CCTP "will employ seven core approaches to stimulate participation by others" and that Chapter 10 "outlines next steps. . .for each of these core approaches" (p. 2-8) (emphasis added). Approach 3, titled "Enhance Opportunities for Partnerships," notes (p. 2-9) that public-private partnership "can facilitate the transfer of technologies from Federal and national laboratories into commercial application" and "partnering is a common mode of operation in most Federal R&D programs, but the partnering process can be improved" (emphasis added). However, there is no discussion in the draft Plan on how and when to achieve such improvement. As to the "next steps," Chapter 10 merely calls for a "[r]eview" of the "status" of partnerships "and encourage[s] further formation" of them (p. 10-7). The draft Plan is wholly inadequate with respect to this third approach. What is needed is direction from the CCTP that implementation of partnerships, once formulated, is to be pursued aggressively by the CCTP and the federal agencies - including DOE - and that any barriers to that, whether real or imagined, should be addressed promptly by all involved.

23

General

The Plan Should Not Focus on Mitigation, But Should Encompass Technical Advances that Address Various Facets of Climate Change, Including Adaptation.

Chapter 2 (p. 2-2 n. 2) states that the Plan "focuses on mitigation. . .consistent with the context of the UNFCCC" and "does not address adaptation." The footnote invites public comment on this "focus" and on the absence of other elements, including adaptation.

In the first place, it is wrong to imply that the "context" of the FCCC is on "mitigation." That is clearly not the case. As the "Principles" of Article 3 indicate, the FCCC "context" is to address climate change comprehensively and cost-effectively. That includes research; systematic observation; and the development, application, diffusion and transfer of technologies, practices and processes that control, reduce and prevent man-made GHG emissions, promote sustainable development and provide for adaptation. The FCCC focuses on all of these and more. Moreover, the word "mitigation" has a regulatory connotation that is not helpful in a document on RDD&D. We do not understand why this footnote is included in Chapter 2 or in the Plan.

As to adaptation, the absence of any reference to it in the Plan is a serious omission that needs to be corrected. Adaptation and relevant technologies are a matter of great interest and concern to all countries, as evidenced by the "Delhi Ministerial Declaration on Climate Change and Sustainable Development," which was adopted by the FCCC’s Conference of the Parties, and which calls adaptation a "high priority for all countries" that "requires urgent attention and action on the part of all countries." Indeed, the Global Environment Facility, the financial mechanism for the FCCC, is developing an Adaptation Fund. In addition, the FCCC recently completed a three-day workshop on the development of the five-year program of work on impacts, vulnerability and adaptation. Moreover, at an October 3, 2005, conference in Vienna, Austria, the European Union Commissioner for Environment called for the development of policies to adapt to climate change. Finally, in preparation for Canada hosting COP-11 later this month, the International Institute for Sustainable Development in August released a paper titled "Climate Change and Adaptation" that provides a "summary of research and policy developments relevant to determining a long-term, integrated approach to addressing adaptation," while noting the "emergence of adaptation as an issue within the UNFCCC." It would be wise for the U.S. and DOE to reinforce these international trends.

24

General

Specific Comment on an Important Omission in the Strategic Plan - Recovery and Reuse of Waste Materials

As drafted, the Strategic Plan does not address the issue of recovery and reuse of waste materials. Included could be R&D to address technology improvements in waste recycling such as separation methods, improvements to municipal curbside collection methods, and waste recovery. For example, aluminum production spent potliners (SPL) are a carbonaceous waste material with high BTU content, the potential to improve cement kiln production efficiency, improve clinker formation qualities, and reduce cement kiln emissions due to mineralizing benefits. Efforts to promote the reuse of waste materials and R&D to advance technology in this area would have beneficial impacts on reducing greenhouse gases, improving energy efficiency and lessening the waste stream burdens on society and the environment.

25

General

The draft document does not constitute a strategic plan. The objectives of the Climate Change Technology Program are not adequately specified and the "plan" fails to define the timeframe and scale of technology deployment needed to prevent dangerous global warming.

While the document quotes the objective of the United Nations Framework Convention on Climate Change, to which the United States is a party, the full implications of this objective are not reflected in the "plan."

There is now compelling evidence that global warming in excess of 2 degrees Celsius (3.6 degrees F.) would be dangerous, which implies that heat-trapping gases should be stabilized at a level no higher than 450 ppm CO2-equivalent. Among other threats, warming in excess of 2ºC is likely to set in motion the disintegration of the Greenland ice sheet, eventually raising sea levels by as much as 20 feet (Alley, et al., 2005). Hurricane intensity would also increase significantly, compounding the danger to millions of citizens in the Southeast and Gulf coasts (Emanuel, 2005). Water resources in the Western United States would also be dangerously depleted due to reductions in winter snow pack (Mote, 2003). Finally, thousands of species would be threatened with extinction (Thomas, et al., 2004), particularly those dependent on highly sensitive habitat, such as polar bears, threatened by the melting of the arctic ice pack; pika, threatened by the desiccation of alpine meadows, and corals threatened by thermal stress and ocean acidification.

Despite these clearly documented dangers, the administration asserts that there is not an adequate basis to determine the concentration at which heat-trapping gases need to be stabilized to prevent dangerous global warming. Yet even if the administration is not willing to set a stabilization target, a responsible strategic plan would recognize that near term investments in high-emitting infrastructure, such as conventional pulverized coal power plants, would quickly preclude the option of preventing warming of more than 2ºC. Conversely, the need to keep open the option of stabilizing concentrations at 450 ppm defines the pace and scale of technology deployment that the plan should be designed to achieve. Failing that, the revised plan should at least describe in detail the pace and scale of technology deployment needed to achieve each of the stabilization levels considered in Chapter 3. Well defined objectives for the pace and scale of technology deployment would allow the plan to assess whether the proposed strategies are adequate to the task. Again, if the administration is unwilling to establish a stabilization target, even for planning purposes, the revised plan could at least assess strategies against the pace and scale of technology deployment needed to achieve each option. Without this critical analysis the draft document appears to be largely a post-hoc justification for the existing R&D program, with at best a hint of some need for reprioritization.

Lacking an assessment of the adequacy of the strategies in the plan, the draft ignores critical policies that would be needed to deploy low emissions technology in time to prevent dangerous global warming. Historical experience shows clearly that R&D alone is not an adequate driver of the private sector investment needed to commercialize pollution-reducing technology. Rather, emission caps (with trading), efficiency standards, and portfolio requirements have been critical to stimulating innovation, cost reductions, and scale up needed to commercialize new technology and achieve measurable economy-wide results (Burtraw, 2005).

Unfortunately, business as usual will quickly preclude the possibility of preventing dangerous global warming as illustrated in our Figures 1 and 2. The International Energy Agency projects that more than 1000 GW of new coal capacity will be built worldwide during the next 25 years. If this capacity is built with conventional technology with no controls on CO2 emissions, each year’s new capacity build will carry a lifetime commitment to carbon emissions equal to total annual emissions today. That means that by 2030 we will have locked in additional carbon emissions from coal combustion equal to the total cumulative emissions up to the year 2000 (Figure 1).

If we continue with business as usual virtually all of the coal build through 2030 will use conventional steam technology with CO2 vented to the atmosphere. The Future Gen project and other elements of the portfolio described in the draft "plan" are simply too little, too late to bend the curve (Figure 2).

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Budget Implications Must Be Addressed.

Appendix A (p. A-1) states that for the CCTP to "carry out its mission, it is necessary to access on a periodic basis the adequacy of Federal investments in the CCTP-relevant research portfolio and make recommendations." The Appendix includes a "budget table" of RD&D "activities classified" as part of the CCTP, with, as noted above, footnote 2 (p. A-2) defining RDD&D activities to include "related activities such as voluntary partnerships, technical assistance/capacity building, and technology demonstration programs that directly reduce" GHG emissions "in the near- and long-term." Table A-1 (pp. A-4 - A-5) indicates that for FY 2005 a total of about $3 billion was available for all the federal agencies in the CCTP.

However, the table does not include a breakdown of what portion of that total is for "new and advanced" long-term technologies and what portion is available for near- and mid-term technologies and practices. In addition, the Appendix does not explain how the CCTP will "assess" the "adequacy" of funding for both the long-term and near- and mid-terms. We are concerned that the latter, particularly in the context of the recently enacted EPAct 2005, may not be funded adequately in light of the emphasis in the draft Plan on the long-term and new and advanced technologies, which could result in reduction of funds in real terms for the near- and mid-terms, particularly in times of budget and appropriations constraints.

Moreover, the draft Plan does not indicate how budget monies for climate technologies are related to authorizations and appropriations (actual and projected) under EPAct 2005 and other statutes. Without an explanation of such linkages, budget numbers could bear little relationship to implementation of the Plan and the CCTP. We do not understand how DOE can develop an RDD&D budget for existing and advanced technologies without knowing where the money to implement that budget is coming from.

In summary, we urge a better discussion in the Plan about 1) the budget implications for both the long-term and the near- and mid-terms, and 2) the relationship of the climate technology budget to authorized and appropriated monies (actual and projected).

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Care should be taken to be even handed with regard to technology policy advocacy. E.g. on p 5-26 under nuclear fission, 2nd paragraph, 4th line seems to encourage Federal Financial Risk Management Tools. I have no problem with such advocacy (see the preceding paragraph), but it must be carefully considered and even handed wrt other technologies that could accomplish the same objectives.

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This plan emphasizes looking at each technology in isolation. I suggest an alternate route: Start by building detailed visions of technically feasible sustainable carbon-emission-free planetary-scale energy systems based on what we know about physics, engineering, economics, social systems, etc. For each of these visions one could examine the technical barriers, resource barriers, etc, and then figure out what research would be needed to achieve that vision. If this is done for several visions, some items will reappear on several lists and others will be specific to an individual vision. Research items that are common to a broad spectrum of visions should be emphasized. You’ll never get there unless you keep your eyes on the prize. Present coherent visions of where we would like to be and then decide what we need to do to achieve those visions. Ideally, this would involve geographical specificity (i.e., where exactly would this biomass farm be sited?) and deal with power generation, storage, transmission, etc. This activity should be a major focus of the first phase of CCTP.

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The Plan is not very holistic in its approach.

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The Fact that the U.S. is a Party to the Framework Convention on Climate Change Should Not Suggest that its Ultimate Objective Serves as a U.S. Goal for Plan Purposes.

The Introduction refers first to the United Nations’ Framework Convention on Climate Change (FCCC), quotes a portion of Article 2 of the FCCC - which sets forth the "ultimate objective" of the FCCC - and then states (pp. 1-2 and 1-3) that "[c]limate change is a serious, long-term issue, requiring sustained action over many generations by both developed and developing countries," that "[d]eveloping innovative technologies and approaches that are cleaner and more efficient is the key to addressing our long-term climate challenge" and that the "U.S. approach to climate change, which is consistent with and supports the UNFCCC’s ultimate objective, forms the long-term planning context for the CCPT." In Chapter 2, the draft Plan again refers to the FCCC’s "ultimate objective" and asserts (p. 2-2) that it "provides a planning context for CCTP’s long-term technology development strategy," while recognizing that the level of "stabilized concentrations" of greenhouse gases (GHGs)2 "in the Earth’s atmosphere implied by the ultimate objective is not known and will likely remain for some time a key planning uncertainty." Page 2-2, footnote 2 expressly states that the "CCTP Strategic Plan focuses on mitigation of GHG emissions and atmospheric concentrations, consistent with the context of the UNFCCC."3 Chapter 2 goes on to say (p. 2-2) that "the CCTP strategic goals are not based on any hypothesized level of stabilized GHG concentrations, but rather encompass a range of levels under conditions of uncertainty," and that the "technological challenge is to enable systems that could help achieve" a goal of "net emissions" that would approach levels that are low or near zero" (emphasis in original and emphasis added).

In the Introduction (p. 1-1 n. 2), there is a definition/discussion of the term "greenhouse gases," which, among other things, refers to the Kyoto Protocol in a way that suggests that three named gases therein are not also covered by the definition of the term in Article 1 of the FCCC because they are "dealt with under the Montreal Protocol." That reference is misleading and should be avoided because the FCCC Article 1 definition of GHGs covers all gases, while some Articles thereof, such as Article 4, refer to "greenhouse gases not controlled by the Montreal Protocol." However, that phrase is not contained in either Articles 1 or 2. In addition, note that Appendix A (p. A-2 n. 3) appears to be another definition/discussion of the term "greenhouse gases." Both definitions state that gases subject to the Montreal Protocol are "excluded" from the definition of GHGs and, in the case of page 1-1 footnote 2, from the "CCTP purview." While we are not concerned with gases covered by the Montreal Protocol, we do not understand why they should be "excluded" from the CCTP "purview." Furthermore, while the Appendix definition/discussion of GHGs appears to apply only to the Appendix, nevertheless these two differing footnotes on GHGs need to be reconciled.

The U.S. is a Party, along with nearly 200 other countries, to the FCCC and Article 2 thereof. Article 2 applies to all Parties to the FCCC, not just the U.S., and sets forth the FCCC’s "ultimate objective":

The ultimate objective of this Convention and any related legal instruments that the Conference of the Parties may adopt is to achieve, in accordance with the relevant provisions of the Convention, stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. Such a level should be achieved within a time-frame sufficient to allow ecosystems to adapt naturally to climate change, to ensure that food production is not threatened and to enable economic development to proceed in a sustainable manner.

The draft Plan even includes a Figure 3.3 that "shows one set of relationships between CO2 emissions and CO2 concentrations over time, across a range of CO2 stabilization levels" derived from "scenario literature" dating back to 1996 and states that they are "illustrative. . .stabilization levels," although they do "not include all possible stabilization levels that might be consistent with the UNFCCC ultimate objective." (p. 3-4).

Dr. Harlan L. Watson, Senior Climate Negotiator and Special Representative of the State Department, testified on October 5, 2005, before the Senate Committee on Environment and Public Works that "[a]s a Party to the UNFCCC, the United States shares with many other countries its ultimate objective" and that in 2002 the President "reaffirmed America’s commitment" to the entire "Framework Convention" and "its central goal."

However, while the Article 2 ultimate objective "provides a planning context" for the CCTP’s long-term strategy, that objective is global, not oriented to any one Party, open-ended, uncertain and unknown, and therefore should not be a central basis for CCTP planning purposes. Moreover, the FCCC’s supreme body, the Conference of the Parties (COP), which is a governmental policy-making body, not a scientific body, has never considered or adopted any conclusions or decisions regarding a global concentration level, a time frame to achieve that level or any other aspects of the FCCC’s Article 2. Furthermore, our review of Article 2 and other Articles does not show any support for the assertions in the first sentences of page 2-2, footnotes 1 and 2 of the draft Plan that the CCTP’s focus on "mitigation" of GHG emissions is "consistent with the context of the UNFCCC" or that the FCCC "states" that "additional scientific research is required to determine the level of GHG concentrations that would prevent dangerous anthropogenic interference with the climate system." In short, the draft Plan’s references to, and reliance upon, Article 2 regarding the U.S. are inconsistent with the FCCC and are inappropriate. More appropriate for the Plan are the six strategic goals set forth in Chapter 2, which we support:

• Reduce emissions from energy end-use and infrastructure.

• Reduce emissions from energy supply.

• Capture and sequester carbon dioxide (CO2).

• Reduce emissions of non-CO2 GHGs.

• Improve capabilities to measure and monitor GHGs.

• Bolster basic science contributions to technology development.

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The following is in response to your request about previous text that described the assumptions either in the reference case or in specific cases that have been removed in this version. We think that those textual explanations helped the reader understand the assumptions in the reference vs. scenarios.

p. 6 In this CCTP Reference Case, by 2100 total energy demand is projected to increase more than three-fold, from about 400 EJ today to 1200 EJ by the end of the century (Figure 3-4). Fossil fuels are projected to remain the backbone of the global energy system. However, as a result of technology improvement and growth in demand for energy, the Reference Case also shows significant global expansion in the use of renewable energy (solar, wind, geothermal, and hydroelectric energy), nuclear energy, and energy derived from biomass (biomass used for production of electricity, gaseous, and liquid fuels).

p. 14 (see bolded language): The "story lines" behind the three CCTP advanced technology scenarios are:

1. Closing the Loop on Carbon is an advanced technology future in which the viability of engineered CO2 sequestration enables the continued use of fossil fuels, which in turn is substantially complemented by other energy sources and derivative energy carriers, including hydrogen. In this scenario, engineered sequestration meets key technical, economic, and environmental goals. Coal-based energy-plexes produce electricity, hydrogen, fuels and chemicals, with near-zero emissions. As a result, a large part of the existing fossil-based systems have the ability to become carbon-neutral and remain the backbone of the energy system through the century. There are high efficiency gains in coal combustion. There is also considerably increased use of nuclear, biomass and renewable energy, but these forms of energy do not dominate the energy future as do coal, oil and gas based systems. 2. A New Energy Backbone is an advanced technology future in which nuclear and renewable energy sources become dominant, reducing the proportionate role of fossil fuels and replacing them as the backbone of the energy system. This future would most likely come about as a result of either extraordinary improvements in renewable and nuclear energy technology performance that enable them to capture a larger share of the energy market based purely on their inherent advantages, or limitations that would inhibit sequestration from more significant market penetration. In this scenario, the increase in market share for biomass, renewable energy, and nuclear energy leads to a peak and decline in coal use. While diminished in terms of relative market share, fossil fuel use in 2100 would still be comparable to that of today in absolute terms.

3. Beyond the Standard Suite is an advanced technology future in which novel and advanced technologies grow to play a major role in the energy system, complementing the standard suite of energy technologies (including improved versions of the traditional technologies). This future explores the possibilities of new breakthrough technologies, such as: fusion energy; combinatorial applications of genetic engineering, nano-technology, and biotechnology as new ways to produce fuels or hydrogen and sequester CO2; and technologies for power transmission or beaming that might enable unprecedented expansion of large-scale solar applications. Given the size of the global energy system, it is likely that the standard suite of technologies, including energy efficiency, renewable energy, biomass, and fossil fuels would continue to play a dominant role in this future, as these novel or "exotic" technologies would take decades to mature and penetrate the global energy system to a large extent. However, particularly in the latter half of the 21st century, such technologies could potentially play a major role in the energy system, especially if research is effective. Such technologies would likely compete most directly with higher priced renewable energy, biomass, nuclear, sequestration, and efficiency gains, than with lower cost fossil energy systems.

p. 20 The differences seen in technology supply, cost and performance assumed in the three advanced technology scenarios affect the level of penetration of the various technologies that displace unsequestered fossil fuel combustion, across the varying assumptions about carbon constraints, as shown in Figures 3-17and 3-18. For all but the very high emission reduction trajectories, in all of the CCTP advanced technology scenarios, unsequestered use of fossil fuels remains the principal form of energy used during the course of the 21st century, despite considerable substitution in all cases of near net-zero carbon and carbon-neutral energy technologies.

Appendix B: in "Table B-1: Assumptions in the CCTP Reference Case and Baseline Scenarios . .: " under "Reference Case and Baseline Scenarios -- Renewables and Nuclear," "Substantial cost decreases in renewables and nuclear bring their costs below today's levels."

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Overview comment on Chapters 1 and 2

Overview Comment: We support the goals and objectives of the Climate Change Program Strategic Plan. We are pleased to see an integrated program to address cohesively the goals of energy efficiency, emissions reduction and technology advancement through coordinated research and development efforts.

We have been an active participant in the government's efforts to address climate change, energy efficiency and advanced technology initiatives. We are a participant in the EPA Voluntary Aluminum Industrial Program (VAIP) with EPA to reduce perfluorocarbon emissions from primary aluminum production and in the Administration's Climate Vision program to reduce greenhouse gas emissions. Currently the Climate Vision participants at the Association have achieved in 2004 the 2010 goal and reduced GHG CO2 equivalent emissions per ton of production by 53% from 1990 levels, as reported by EPA. The VAIP members also achieved a reduction in perfluorocarbon (PFC) emissions from smelters by 46% between 1990 and 2000. The VAIP has been recognized as one of the most successful voluntary programs the US Environmental Protection Agency has undertaken. Members in the VAIP represent 98% of emissions from primary aluminum production in the U.S. The EPA recognized the aluminum industry's accomplishment with the Climate Leaders award in 2002.

The aluminum industry has also actively participated in the DOE-ITP Industries of the Future program to improve existing processes or develop new processes and equipment with greater energy efficiency and also reduced emissions.

The draft strategic plan is important since its objectives seek to achieve results that are socially responsible, environmentally beneficial and economically viable in the context of climate protection. In our view, climate change initiatives must maintain a balance in all of these sustainability elements to be successful.

The aluminum industry has a key role in climate protection and sustainability. Aluminum is an Environmental Material of choice due to its recycling capability, energy savings potential, sustainable sources, and value to societal objectives. To advance aluminum's potential in mitigating climate change, we see several areas in the Strategic Plan of importance:

o Reducing emissions from energy end-use (Chapter 4)

o Reducing emissions of high global warming gases (Chapter 7.3)

o Enhancing capabilities to measure and monitor greenhouse gases (Chapter 8)

In addition, we recommend that the Strategic Plan include some emphasis on the recovery and reuse of waste materials to conserve energy and improve production efficiency.

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Technology Sharing: I would like to see commitment to an aggressive, comprehensive plan for sharing only our cleanest, most efficient technologies with developing countries, and sharing them without placing additional economic burden on those countries. In particular, the two most rapidly growing economies-- that of China and India-must be targeted, with technologies as advanced as carbon capture and sequestration. These technologies should be gifted to them. This truly is in our best interest, given the likely economic consequences of the climate change which will result from allowing China and India to continue development with their current carbon-emitting technologies.

Please see my changes in Chapter 1 (Introduction) Page 2 of 8, lines 6 - 10. These are indicative of changes that I would like to see made throughout the document.

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I would like to see research devoted to the proper accounting of carbon credits, i.e., when we ultimately enter a carbon-trading market (which we must), what is the most scientifically accurate way to assign carbon credits to, say, organic farming, planting x-acres of y-species tree, etc, switching to 100% pcw recycled paper - the various ‘soft’ numbers in the carbon balance. I see allusion to that in the "measuring and monitoring" portion of chapter 10, but there is no mention of application of that research to carbon credit trading. You must begin setting the stage for that step.

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In general, I find the tenor of this document to be insufficiently urgent. It is true that action must be sustained, but it must also be immediate. I realize that this is a document about funding new technologies, but I would like to see policy recommendations, such as for legislative action. Very soon I would like to see your office produce a document that summarizes the amount of GHG’s that can be saved with the most, medium, and least ambitious possible technology plans and then actively calls for legislation that forces us to the higher road.

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My focus was primarily on Chapter 6 and especially 6.4, but with implications for other chapters. My general comments are: 1) the current range of technologies emphasized in CCS (chapter 6) is very narrow relative to options that have been proposed or may emerge in the future. CCTP must acknowledge (here, as mentioned in Chapters 2, 9 and 10) that the ultimate, successful technologies and pathways may be very different to what is currently being pursued. CCTP must be open to broad and objective consideration of both new and old ideas. 2) The present and the potential future role of the ocean in mitigating CO2 has been significantly understated. 3) Elevated atmospheric CO2 will not only lead to climate change, but by diffusion into the ocean will lead to significantly increased ocean acidity. This could have a potentially catastrophic impact on ocean ecosystems. Thus, while CCTP's initial charter has been to avoid climate change, it is clear that non-climate impacts such as ocean acidification provide additional, compelling rationale to mitigate CO2.

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The draft strategic plan for the Climate Change Technology Program represents an excellent beginning, but it is still missing some of the components of a complete strategic plan. A strategic plan should present:

1. a vision of success,

2. program priorities and how they are developed,

3. criteria for success,

4. allocation of available resources,

5. responsibilities for execution, and

6. an updating process.

Taking each of these requirements in turn:

1.The draft contains a vision statement, but that statement is too narrowly focused on mitigating emissions from the energy sector. The draft plan covers all sectors that contribute to GHG emissions, and the vision statement should reflect that broad coverage. The CCTP should embrace a comprehensive approach to the challenge of climate change. The strategic plan avoids discussion of technological approaches that would facilitate adaptation, for example. As Dr. James Schlesinger noted at the Institute’s 2005 Annual Dinner, "if one believes or assumes that it is the release of the greenhouse gases that is the culprit and not some more cyclical phenomenon, there may be no solution - and we need to begin to adjust to an earth that continues to warm. Those who profess to be able to ‘fix the problem’ may turn out to be like King Canute, commanding the waves of the seas to stand still" (Policy Outlook, "Remarks of Dr. James Schlesinger at the 2005 Annual Dinner and Awards Celebration, June 16, 2005). Whether climate change is driven by natural forces as yet not fully understood or human action or some combination of the two, the technology program designed to help prepare the nation must address those elements of climate change that may be inevitable.

2.The plan indicates four criteria for CCTP portfolio planning and investment, but these criteria cover only the technology development objectives. While technology development is a focus, it is not the only one. How these criteria are applied to the other stated or inferred objectives, such as the development of a viable technology work force for the future and the strategies to commercialize (or otherwise deploy) technologies developed under the plan’s activities must be discussed. The plan needs to address how these objectives will be prioritized vis-à-vis the more traditional technology development objectives.

More fundamentally, the criteria outlined in the strategic plan for deciding which technologies to support and how long federal support should continue are not explicit enough. The lack of specificity will make it difficult for policy makers and program managers to select among what will be many competing approaches. As written, the plan leaves the impression that each approach is as important or potentially significant as the others. Without criteria that can prioritize investments and the ability to enforce those recommendations, the CCTP may result in supporting a hodge-podge of programs and projects.

3.The plan is commended for including specific targets for individual technology programs that can be used as criteria for success. Success criteria should be enunciated for all program objectives and projects. In particular, a mechanism for establishing criteria for success for the basic science programs outlined in Chapter 9 needs to be developed. Also, criteria for success need to be established for projects that are not part of the traditional technology development process, e.g., the goal of developing a viable technology workforce for the future.

The CCTP’s discussion of success criteria does not address whether the inability of a particular program or project to meet those criteria will result in its termination. Provisions for ending federal support for any particular program or project must be explicitly included as part of the evaluation process articulated by the strategic plan. The absence of clearly defined and understood standards may allow programs and projects to continue longer than is in the public’s interest. These standards should clearly enunciate when a technology project has matured to the point of no longer requiring or deserving public support and they should describe the general conditions that would constitute a failed or unproductive effort. Without these kinds of decision making criteria, projects and programs may continue indefinitely, decisions to continue or terminate federal support will be made on an ad hoc basis and may reflect the predilections and preferences of individual decision makers, and those seeking to evaluate the effectiveness of the programs and projects will lack clear guidelines to assess the programs against.

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Insert "and Climate" after "Development."

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The plan is commendable for taking a century-long view of the question of climate change. However, figure 3.3 on page 3 - 4 shows that even this is not a long enough perspective. Carbon emissions need to be driven down dramatically after 2100, until about 2200, while energy production is presumably still increasing. Thus the challenge is not only to reduce carbon emissions in the current century, but to position the nation and the world with large-scale technologies to drive carbon emissions to very low levels by 2200.

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The report gives the impression that we have a long time - generations - to develop the technologies needed to deal with the climate change problem. There is no sense of urgency, though many scientists, including me, are convinced that we have a relatively small window of opportunity-perhaps only a decade or two--to substantially reduce GHG emissions (especially CO2). Because of positive feedbacks in the Arctic (the reduction in albedo as the ice cap melts and more heat is absorbed by the ocean that replaces it; and the growing emissions of methane and CO2 from Arctic tundra that has been frozen for thousands of years and is now melting at an accelerating pace) the Earth could reach a tipping point where the situation is no longer under our control and global warming runs away-no matter what actions we take at that point.

The report also gives the impression that new technologies need to be developed to make any substantial reductions in GHG emissions. Professors Pacala and Socolow at Princeton University published a groundbreaking article in Science in 2004, titled, Stabilization Wedges - Solving the Climate Problem for the Next 50 Years with Current Technologies. The authors suggested 15 existing technologies that can save the planet by improving energy efficiency and moving to renewable energy sources such as wind, solar and biomass. See:

http://www.princeton.edu/~cmi/resources/
CMI_Resources_new_files/Wedges%20ppr%20in%20Science.pdf

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Delete and substitute:

- The United States, as a Party to the United Nations Framework Convention on Climate Change (FCCC), shares with all other Parties to the Convention the ultimate objective of the FCCC, which is set forth in Article 2 as follows:

- The ultimate objective of this Convention and any related legal instruments that the Conference of the Parties may adopt is to achieve, in accordance with the relevant provisions of the Convention, stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. Such a level should be achieved within a time-frame sufficient to allow ecosystems to adapt naturally to climate change, to ensure that food production is not threatened and to enable economic development to proceed in a sustainable manner.

- Although the FCCC’s Conference of the Parties has not considered or adopted a stabilization level or a related time frame, the United States recognizes that for the Parties to achieve this objective will require long-term international cooperation.

As noted in our Overview Comments, the Article 2 ultimate objective of the FCCC is a global goal for all Parties, not just for the U.S. Indeed, because of the global nature of climate change, the U.S. alone could not achieve the "ultimate objective," nor should that be expected. In addition, if the Article is to be quoted, it should be quoted in full, as all its provisions are relevant.

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"sustainable development." The term is not described in this context. The phrase has many meanings and connotations. Suggest rephrasing the sentence to " that countries will undertake." The following sentence defines the U.S.’s objectives and provides sufficient context to interpret the preceding sentence.

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Climate change is a serious, long-term issue, requiring sustained action over many generations by both developed and developing countries. Solutions will likely require fundamental changes in the way the world produces and uses energy, as well as in many other GHG-emitting activities of industry, agriculture, land use, and land management. Developing innovative technologies and approaches that are cleaner and more efficient is the key to addressing our long-term climate challenge.

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The strategy outlined on page 1-2 is based on the hope that better technologies achieved through government R&D and strategic collaborations will lower the cost of controlling GHG emissions sufficiently that these better technologies will be widely adopted. In my view this is highly unlikely. Controlling GHG emissions will always be more expensive than not controlling them. The government's strategy should include forcing functions in addition to R&D expenditures. For example, the policies proposed by the National Commission on Energy Policy were modest but with increasing intensity. EIA analyzed this set of policies and found that they involved low cost and were assessed to be generally effective. Also, you should not forget the Sense of the Senate vote as part of EPACT 2005 expressing the view that forcing functions would be necessary in the future. If these policies are not forthcoming the world may be in for a colossal tragedy of the commons.

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"Climate change is a serious, long-term issue, requiring IMMEDIATE AND sustained action over many generations by both developed and developing countries. Solutions MUST require fundamental changes in the way the world produces and uses energy, as well as in many other GHG-emitting activities of industry, agriculture, land use, and land management. Developing innovative technologies and approaches that are cleaner and more efficient AND LEGISLATING STRICT CONTROL ON CARBON EMISSIONS ARE the key to addressing our long-term climate challenge.

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Insert: developed and developing countries. Nor is climate change the only concern with regard to increasing atmospheric CO2. The benefits of technologies like CCS stem from their ability to lower the carbon emissions intensity of conventional fossil-fuel-derived energy resources. As discussed in Chapter 6, roughly one third of excess CO2. The benefits of technologies like CCS stem from their ability to lower the carbon emissions intensity of conventional fossil-fuel-derived energy resources . emissions currently dissolves in the ocean, forming carbonic acid. The resulting ocean acidification is expected to significantly impact marine chemical and biological processes if fossil fuel use and anthropogenic CO2 emissions continue on their present trajectory. Solutions will likely require fundamental changes in the way the...

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"Solutions..." Solutions is an odd word choice as it implies that some set of actions can "solve" a problem. For instance, if climate change is in part a natural phenomenon, then defining what is a "problem" becomes problematic. Suggest replacing "solutions" with "actions" or "steps to address it" which convey the same point, but lack the ambiguity of "solutions."

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Insert: cleaner and more efficient is the key to addressing our long-term climate and environmental challenges.

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Change the sentence that begins on line 12 to read as follows: "It is science- and market-based; and encourages innovation, scientific and technology breakthroughs and global participation.";

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Strike the word "new" and insert "cleaner, more efficient". Both changes bring these sentences in line with page 1, paragraph 2 of the Vision document, which is the source of the paragraph at lines 12-17.