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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Demonstration projects eat up large amounts of money that could be used for more fundamental research and development. Insert a sentence such as "Demonstration projects should be at the smallest scale necessary to demonstrate the technological feasibility of a proposed technology or approach. Demonstration projects should have a limited lifetime." Safeguards are needed to avoid turning demonstration projects into pork. I would like to see a process wherein the funding cycle would continue as if there were no demonstration project and then the proposers of the demonstration project would need to argue that their project is more valuable than all of the projects that would not get funded should the demonstration go forward.

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Ensuring a viable technology workforce for the future is critical to meeting a broad range of U.S. goals, not just to the addressing the risks of climate change. We hope that the CCTP approach is linked to a much larger Federal effort to meet this need. If so, those linkages should be mentioned.

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While the goals and intent of this prioritization process are laudatory, these goals can be undermined if there are conflicts of interests between the prioritizers and those getting the money. I would like to see an open peer review process wherein the panels making funding decisions are composed of people who are not getting any money, or proposing to get money, directly or indirectly, from CCTP. Recusal for specific proposals is not enough. Safeguards must be in place so that CCTP does not turn into a bunch of DOE-managers dividing the money up among themselves. CCTP should look to retirees, uninvolved academics, interested and knowledgeable citizens, etc. to judge the merits of proposed projects, not people who stand to gain or lose personally from CCTP.

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Suggest inserting that "some may fail" after "as hoped." Undoubtedly, some efforts may not produce as expected. The prospect of failure should be recognized so as not to create incentives to underachieve so as to avoid failure. The evaluation regime established for the CCTP as a whole and the individual programs/projects should also be tasked with exploring why failure occurred, so others can learn from those lessons.

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Box 2-1

The criteria for public vs. private investment should be stated more clearly. Public investment should only be made in those areas of R&D which a) require too much capital for individual corporations or consortia of corporations or b) are too long-term for the protection of intellectual property rights. In essence, these investments should meet the "but for" criterion - these major new technologies would not be developed "but for" federal investment. Accelerating the implementation of even much improved technologies which would be developed anyway by private enterprise, but somewhat more slowly, does not in effect meet criterion #3. Large scale should not be measured in GtC per year, but in GtC - meaning that a few-year acceleration of even an attractive large-scale technology should not qualify.

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Who will be applying these criteria? It is all good to state nice principals, but if you get a room full of DOE managers applying these rules, it is likely to conclude that the money should be divided up among DOE labs. There is a need to avoid real or perceived conflicts of interests in the application of these criteria.

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Box 2-1

We support these four criteria for CCTP portfolio planning and investments. We are particularly pleased to see the Program’s acknowledgement of the role of the private sector in technology R&D. However, we suggest the criteria be enhanced with the following changes. Criteria 1 should include a statement that projects with low risk and quick payout need to be included in the portfolio. Criteria 4, as part of (iii) should include mention of the exploratory research discussed on Pg. 2-7.

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box 2-1

The four criteria are generally acceptable, but sufficiently ambiguous to create important interpretation questions in the future. For instance, Pg 2-13, lines 1-5 concede that the reduction to quantitative analysis is difficult, but yet the first criteria depends on exactly that line of reasoning. Criteria 1 should include a statement that projects with low risk and quick payout need to be included in the portfolio. Criteria 2 requires a discussion of how or who will decide the proper and distinct roles on a case-by-case basis. The plan is commended for recognizing the importance of partnerships, however. Criteria 4, as part of (iii) should include mention of the exploratory research discussed on Pg. 2-7.

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An amplifying statement that this process will include shifting resources between goals and between agencies involved in CCTP, as appropriate, would be helpful.

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The plan states that "... by agency deputies, who can adopt ..." in discussing executive direction to federal departments and agencies. The use of the verb "can" implies discretion on the part of the participating agencies. The plan should discuss the instruments that the IWG and the CCCSTI will use to enforce compliance with and fulfillment of CCTP objectives.

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Box 2-2

Section 2.5: Management, Page 2-15, Box 2-2

The Climate Change Technology portfolio includes a section on Carbon Capture. The large point CO2 sources are primarily power plants, oil refineries, and other industrial facilities as stated on page 6-3, line 2-3. It is understandable that the USDA is assigned to lead the working group for CO2 sequestration because of the potential land use issues, however if that is the case, CO2 Capture should not be group under the leadership of the USDA since that technology does not concern land use or agriculture. We suggest that the CO2 Capture should be separated and led by the DOE.

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Pg. 2-15, lines 16-18: The plan must define the term "appropriate priority." The CCTP strategic plan does not articulate how the interagency structure will direct or influence the internal decision making of the constitutive agencies. The plan seemingly relies on the persuasive abilities of the CCTP representatives to direct budgets and policy in the directions identified by the strategic plan. This approach has rarely proven successful.

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section 2.5.4

Suggest clarification of the nature of the external interactions. The CCTP would benefit from the adoption of a formal external review process. A two-prong approach would provide useful insight and perspective on the direction and accomplishments of the research effort. Given the dual emphasis on supporting R&D activities to meet national goals and the strong endorsement of private sector involvement, and by extension their economic goals, the CCTP should be reviewed periodically by (1) a group representing the university and national laboratory stakeholders identified as participating in the CCTP and (2) a group representing the industrial partners. These two external review groups would provide diverse reviews of the program and evaluate it using much different perspectives. Each group would be tasked with providing evaluations of ongoing efforts, summaries of the utility and use of past efforts, and offer recommendations for future research efforts and ways to improve the management and efficiency of the research enterprise supported under the CCTP.

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Add another bullet point: Non-energy sources of CO2. While energy supply and use creates the majority of anthropogenic CO2 emissions, significant amounts of CO2 result from land use practices and from some the non-combustion industrial processes, e.g., calcination of carbonates to produce cement and lime.

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General

The conclusions of this chapter nevertheless are reasonable and appear to follow from the myriad analyses quoted even if the three scenarios above were not included. It remains a challenge therefore to be explicit as to what further insights the PPNL analysis brings to the table beyond their general clarity and expertise.

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General

Chapter 3 Need a brief summary in this chapter of the range of impacts that could constitute dangerous interference with the climate system, perhaps by borrowing from IPCC second and third assessment reports. This would give the reader an indication why climate change mitigation is important.

Chapter 3 does not give a range of primary energy use for the range of carbon emission scenarios. A plot equivalent to Fig 3-4 for primary energy would be useful.

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General

The aim of the chapter, to aid in formulating a technology agenda by synthesizing scenario results from a variety of models, is highly appropriate.

The issues raised here concern some of the choices in structuring the specific scenarios highlighted in support of the CCTP. They are labeled, Closing the Loop on Carbon, A New Energy Backbone, and Beyond the Standard Suite.

The current CCTP technology agenda and projects, as detailed in other chapters of the report, largely contains elements that appear either in the Closing the Loop scenario or in the New Energy Backbone scenario. There is therefore no specific scenario that directly relates to the overall CCTP.

It would therefore be quite useful and potentially quite instructive to run a scenario using the PPNL MiniCam model that includes the majority of the CCTP technology elements. The extent to which such a scenario approaches the UNFCC goals could be a real test of the CCTP plans.

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General

While the CCTP primarily focuses on technology as the primary driver for dealing with Climate Change, many hundreds of scenarios have their primary focus on policy formulation. Somewhat in that vein, the recent analysis of the National Commission on Energy Policy combines the two and appears to offer a revenue neutral path toward energy security that also moves toward a lower carbon dependant world. Recent analyses by EIA appear to strongly support the findings of the Commission.

If a MiniCam analysis were applied to the NCEP technology formulation and agreement were found, it would suggest that the CCTP agenda could be mounted in a fashion which would lead to a revenue neutral situation at least for some period of time.

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General

The last scenario, Beyond the Standard Suite, requires rather dramatic breakthroughs in a significant number of technologies. Facetiously, it might be called Far Beyond the Standard Suite.

In particular, it calls for reliance on "BIO-X" that is described as a conglomeration of new biological based technologies. The only result from a Google search is a new program at Stanford University with this name whose goal appears to be similar to the description in this chapter. But there is found absolutely no mention of any energy connection. It becomes difficult to understand how BIO-X plays out in this scenario given so little specific information.

The inclusion of fusion in the "exotic" category in this scenario appears to be a mischaracterization. A major study by DOE's Fusion Energy Scientific Advisory Committee indicated that a first commercial fusion reactor could be online in 2040. Various studies also show that fusion development could lead to fusion power taking up a significant fraction of the load in the Beyond the Standard Suite scenario.

It is recommended that inclusion of such statements relative to fusion be included in the descriptive material for this scenario

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General

The results of the Pacala and Socolow "wedge" analysis are referred to in this chapter as a technology limiting issue. However, the analysis is brushed aside as not adequately representative from a market, regulatory, etc. etc. perspective. Since CCTP appears to agree that the Pacala-Socolow technology choices are valid ways of achieving gigaton scale reductions and presumably agrees with the Pacala-Socolow statement that these technologies have passed the benchmark state, then what is needed is a more sophisticated scenario analysis.

MiniCam calculations should be carried out to see whether the "wedge" concept produces a promising 50-year program as the authors claim. If so, it would allow a redistribution of R&D funding and allow greater support for longer-range technologies such as fusion, hydrogen, etc.

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Fig 3-12

Chapter 3 What is the range of other greenhouse gases on top of CO2. This needs to be exposed. Fig. 3-12 gives a best case scenario where OGG are equal to about 2.5 gtC equivalent in 2100. A plot that shows the combined range of CO2 and OGG is needed to indicate the relative importance of these other gases.

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Overview Comments on Chapter 3 Synthesis Assessment of Long-Term Climate Change

1) Need to at least mention ocean acidification is an addition rationale for CO2 mitigation, i.e. this is truly a global change issue not just a climate change issue. 2) Need to point out that the technologies that are ultimately successful in mitigating CO2 may bare little resemblance to those currently being pursued and rather narrowly discussed here. The national R&D effort must be open to new ideas and approaches and not assume that technologies current research thrusts are the only ones worth considering. The objective is to solve the CO2 problem, and not to assume that the required advances in the specific technologies favored today may be possible or even relevant in the future.

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Delete the sentence beginning on line 15 through line 21. Again, it is not appropriate for the Plan to discuss, in the context of a RDD&D technology strategy for the U.S., a "level" of GHG concentration that "would meet the UNFCCC’s ultimate objective," which, as we pointed out repeatedly above, is an unknown global goal for all Parties to the FCCC, not just the U.S. In addition, if Article 2 is quoted, we reiterate that it should be quoted in full.

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Delete the discussion of stabilization level. As noted on Pg. 2-2, lines 11-13, stabilization requires net emissions of GHGs to be very low or near zero. From a technology planning standpoint, it makes very little difference what stabilization level is chosen. The challenge for technology is so large that all technologies that will reduce GHGs need to developed. From a practical level, the question of stabilization level has been on the world’s political agenda for more than a decade without resolution, or the realistic expectation of resolution. It is unreasonable to assume that there will be a resolution of this issue in a timeframe that would affect the technology development plans in this draft.

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figure 3-1

This discussion is inconsistent. The figure it contains shows global GHG emissions, and the text give information on U.S. emissions from some, but not all GHGs. It would be useful to present a figure in the same format as Figure 3-1 for U.S. GHG emissions.

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Section 3.2

Section 3.2

Section 3.2 makes clear that climate change is a 200 year issue, not just a 100 year issue. While in some scenarios the atmospheric concentrations largely level off in 100 years, even in these same scenarios dramatic further reductions in carbon emissions are needed between 2100 and 2200, while energy production is presumably continuing to increase. Thus the plan must position the nation and the world with large scale technologies that can grow significantly after 2100 to further reduce carbon emissions, while producing more energy.

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Figure 3-1

In figure, break out fuel and cement as two separate wedges. One is an energy producer and the other is a consumer of energy, one is large and one is small. Mixing these together is like mixing apples and golf balls. Communicate that the big target is CO2 emissions from the energy sector, not cement production.

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footnote 2

Again, if you are to use this odious measure, at least mention that the GWP is equivalent to using a zero discount rate for 100 years and an infinite discount rate thereafter and may not be the best way to compare the climate effect of various greenhouse gases.

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Figure 3-1

This figure is made probably using 100 year GWPs. I would advise against using such a measure as it has no foundation in science or economics. If 100 year GWPs are used, the figure caption should say that these are radiative forcing values integrated out to 100 years and ignores longer-term consequences of CO2 emission. For example, a figure showing the radiative effect of year 2000 emissions in year 2100 would have almost no slice for nitrous oxide and a tiny slice for methane. If this is a century scale problem (which it is) GWPs with a 100 year time horizon overestimate the effect of the importance of non-CO2 greenhouse gases.

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This discussion ignores all of the caveats regarding the use of GWPs. Please do not promulgate a bad measure. Talk about instantaneous radiative forcing and atmospheric lifetimes if you must, but using a zero discount rate for 100 years and an infinite discount rate thereafter is not only misleading but will mislead to bad policy.

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Insert between Line 3 and 4:

In addition to the climate implications of increasing atmospheric CO2, there are also concerns about chemical and biological impacts to the ocean. As discussed in Chapter 6, rising atmospheric CO2 concentrations, via equilibrium processes, is leading to greater CO2 concentrations in the ocean. Unfortunately, once in the ocean much of this added carbon does not remain in this molecular form, but rather dissolves to form carbonic acid. Ocean acidity is therefore increasing, and as a parameter with fundamental influence on ocean chemistry and biology, such increases could be potentially catastrophic to ocean ecosystems if our current fossil fuel use and CO2 emissions continue unabated. While the true scope and magnitude of such effects have yet to be fully understood, they in combination with climate effects provide additional motivation to stabilize atmospheric CO2 concentrations.

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3.3-B 3.3-A

It should be mentioned that going from figure 3.3-B to figure 3.3-A involves the use of a carbon cycle model with its own set of uncertainties. If you like you could add that reducing these carbon cycle uncertainties is one of the goals of the CCSP.

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Insert a period after "levels" on line 9 and delete the following words: "that might be consistent with the UNFCCC ultimate objective." This clause injects speculation as to what might be "ultimate objective" levels when in fact the FCCC’s supreme body, the COP, has never even considered any such levels.

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Change "mitigate" to "address"; on line 3, delete "anthropogenic"; and on line 4, insert before the period the following: "from natural variation and anthropogenic sources." The word "mitigate" has a narrow regulatory connotation that does not include RDD&D technologies or adaptation. In addition, emission increases are not likely to be solely due to anthropogenic sources. Natural sources and natural variation will likely be contributors.

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"social and economic development (e.g., gross world product and standard of living); increases changes in fossil fuel use; changes in energy efficiency; changes in non CO2-emitting fossil, nuclear, and renewable energy supply; changes in land use; increases changes in other GHG-emitting activities of industry, agriculture and ..." This sentence would work better if it was rewritten along the lines of "...the more significant factors driving increases in future GHG emissions growth include demographic change (e.g., regional population growth); social and economic development (e.g., gross world product and standard of living), increases in fossil fuel use, and changes in land use; and the more significant factors limiting increases in future GHG emissions include improvements in energy efficiency; increases in non-CO2-emitting fossil, nuclear, and renewable energy supply, decreases in GHG-emissions from industry, agriculture, and forestry, and more rapid technological change in energy technology reducing GHG-emissions."

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P.3-5, Line 12: "highest CO2 emissions are those that assume the highest energy demand (including the slowest improvement in energy efficiency) along with the highest proportion..."

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Figure 3-4

p. 3-6, line 15: Figure captions, in general, should say whether the figures refer to the US or the world.

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p 3-7 For the wide range of scenarios can one give the range of temperature increases. One could use Ken Caldeira's plotting approach built around a range of temperature sensitivities.

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box 3-2

This is a good summary of the SRES scenarios, but it lacks one important aspect; the energy intensities of the various scenarios and how they compare with historical reductions in energy intensity. As documented on Chapter 4, Pg 4-1, lines 11-16, over the period 1971-2002, final energy intensity declined about 0.9%/year. The various SRES scenarios have different rates of energy intensity decline, but almost all are larger than the historical average.

Global final energy intensity in 1990 was 16.7 x 106 J/US$. Scenario A2 projects the highest global final energy intensity in 2100, 5.9 x 106 J/US$, a decline of 0.95%/year, about the historical average. The next highest value for global final energy intensity in 2100, Scenario B2, projects a rate of 4.0 x 106 J/US$, a decline of 1.3%/year, higher than the historical average. Scenario B1 projects the lowest global final energy intensity in 2100, 1.4 x 106 J/US$, a decline of 2.6%/year, far greater than historical trends.

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Delete the sentence beginning on line 12 and ending on line 15. Again, referring to the "UNFCCC objective" is inappropriate. Incidentally, we have not attempted line-by-line review of the entire draft to determine whether there are any other references to the FCCC objective. We do not believe it belongs anywhere in the Plan.

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This reference case clearly has a lot of energy efficiency improvement and carbon-emission-free energy built into it. Thus the reference case may be considered optimistic. This discussion should include numbers saying how the reference case differs from a "no technological change" case with the same economic growth. What we need to do to get to the stabilization curve includes both what is in the reference case and what is in the "avoided emissions" wedge. Please tell us this number because this number is what we will need to actually do. (We can leave it to the philosophers to decide what would have happened in a counterfactual world.)

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box 3-3

This is a useful part of the presentation, since most readers have no idea how much technology must be used to control 1 GtC. However, the text either in the box or on Pg. 3-13 needs to make it clear to the reader that the SRES scenarios assume that all of these technologies will be used extensively prior to 2100. Reducing emissions from the SRES scenario baseline requires that more technology than is included in the SRES baseline be implemented.

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box 3-3

For wind and photovoltaics reference to current small installed base is not useful. That would be like writing in the 1950’s that a computer infrastructure would involve a zillion-fold increase in the number of transistors. For wind and photovoltaics, tell us in area terms (for example, use the Iowa farmland comparison as per biomass). Why are the coal plants 500 MW but the nuclear 1 GW? Why not make them both the same size to make it easier for the reader?

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Somewhere in this section there should be a paragraph on the impossibility of century-scale technology prediction. If we were going through this exercise a century ago, we would not have predicted jet air travel, computers and the internet, the ubiquity of automobiles, nuclear fission, etc. We can assume there will be great technological innovation in this century and we can assume that we cannot predict what character this innovation will take. Thus, the modeling exercises are presented to help us think of robust strategies that will represent sound investments regardless of what technologies are developed later. If we were in 1905 and wanted to improve our century-scale transportation infrastructure what would we do? Design improved feed stations and manure removal technologies? One of the best things we could have done is invest in science and engineering education. Protect intellectual property rights. State goals (i.e., high speed intercity transport) and not technologies (trains, planes, and automobiles).

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8

The reference to technology that "would be able to achieve the level of GHG emissions reductions that are likely to be required to stabilize GHG concentrations" fails to put this "level" in a global context, particularly in a Plan that is for the U.S., not for the world.

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Replace Line 5 with:

"are likely to be required to stabilize GHG concentrations in the atmosphere, nor at this point do we necessarily know what specific technologies or combinations of technologies will prove to be best for this task. Given the diversity of the"

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Footnote 31

We suggest adding the following to the footnote:

"The reference case assumes substantial cost decreases in renewables and nuclear [that] bring their costs below today's levels." [Please note that this was the subject of our concerns expressed at the last meeting. See below for direct quotes from the April draft. This sentence was taken from the Appendix that described the assumptions in the reference case -- see the end of the direct quotes).

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also Fig 3-10 and 3-11

It would be more appropriate perhaps to refer to scenario #3 as "major advances in fusion energy and/or novel applications for solar and advanced biotechnology," since fusion alone could provide the 180 EJ/year projected for 2095. The Fusion Energy Sciences Advisory Committee proposed a Plan for the Development of Fusion Energy which would first put electricity on the grid in 2037, with commercial power plants beginning around 2050, consistent with the beginning of energy production shown for "Exotics" in the figure. A reasonable rate of growth would allow 6 TW(th) by 2095. Since fusion is specifically called out in the plan, perhaps rather than referring to it as "Exotics" in figures 3-10 and 3-11, this category could be called fusion, for short.

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Replace line 25 with:

"A primary purpose of CCTP is to identify and accelerate the advancement of promising technologies and reduce their"

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27

The first sentence of the paragraph again raises the issue as to why the CCTP seems to be so focused on "advanced technologies." The purpose of the CCTP should be to "accelerate" advancement and "reduce" the costs of all technologies, not only advanced technologies.