Uses and Limitations of Observations, Data, Forecasts, and Other Projections in Decision Support for Selected Sectors and Regions
Public Comments on Draft Prospectus for Synthesis and Assessment Product 5.1

These comments relate to the draft prospectus for Synthesis and Assessment Product 5.1

Reviewer

Name: Michael MacCracken
Organization: Climate Institute
Mailing Address: 1785 Massachusetts Avenue, NW, Washington DC 20036
Phone: 202-547-0104
Fax: 202-547-0111
E-mail(s):
Area of Expertise: Climate Change

General Comments

Michael MacCracken, Climate Institute:

First General Comment

While the proposed set of studies sounds quite interesting and productive, it is not at all clear, given their content, why so many potential problems are being created by subjecting this report to the full set of CCSP guidelines. As I understand it, these reports will be illustrative studies of what is being done now—essentially how particular groups are using observations and other information. There is no contention that these are somehow the ultimate approach to be used—in fact, these are snapshots and one would hope that rapid development continues over time. The scope, in fact, reads much like the type of report that an NRC panel might put together—providing documentation and examples of cutting edge use of observations for productive purposes. Why in the world complicate everything by coupling this to the CCSP process that it is indicated will require every agency to agree to something (when many might not have the foggiest idea of best practices and the results might not even apply to their agency)?

Response

NASA is committed to working with our Federal partners and CCSPO to determine the appropriate guidelines and practices that will be followed in the production of SAP 5.1.

Second General Comment

With regard to the potential need for setting up an advisory committee, it is my impression that the GSA panel watching over such committees generally wants to avoid them if possible—and this is certainly a case where that is possible as there is really no policy connection or agency position relating to these matters. The simplest way around the FACA requirements would be to ask the NRC to prepare such a report; a second way would be to have individual contracts to each of the authors for their own report, and they can consult as they will—and if CCSP wants to it could publish the set of individual papers in a single CCSP report. But once you insist this go through a process which has the agencies signing off that this represents their views, having more than one meeting of the set of authors to advise and prepare their report would seem to necessitate the invocation of FACA. But there is really no need for the agencies to sign off on this—individual agencies can send in review comments, but this sign-off idea really introduces potential complications unnecessarily and should be dropped. NASA can ask the authors to ensure they get reviews, etc., but I see no purpose served by going through the CCSP guidelines process for this report

Response:

NASA has determined that the appropriate mechanism for production of SAP 5.1 will be though a contract vehicle. Under this option, the lead authors will be organized and compensated through the placement of a contract or grant to industry, academia, or other Non-Governmental Organization (NGO) through an approved NASA procurement. The contract will specify the questions to be addressed (as part of its statement of work), as well as the required budget. The contract will also specify any other requirements of the SAP 5.1 prospectus, such as lead author meetings that are to be open to the public. There is precedent for this type of contractual arrangement under the CCSP (i.e. SAP 2.2).

Specific Comments

Page 2, Line7-9:

Michael MacCracken, Climate Institute:

This is really a research project (or needs an in-depth survey). With the IPCC (TAR and FAR each in their own way) and the US National Assessment having each, among other studies, have been attempts to test approaches for this, there is fertile ground for studies to be done. Indeed, Penn State had made a proposal to do such a study to NSF early last year, as I recall (I was to be an unpaid adviser to it if it succeeded). I would certainly encourage this type of research, and, indeed, the National Assessment research section on page 127 of the Overview document called for it. So, indeed, a nice paper reviewing all of these would likely be very useful.

Response:

Comment so noted.

Page 2, Line 15:

Michael MacCracken, Climate Institute:

The term “known uncertainty” really does not make much sense. We are barely at the stage of being able to estimate them—to somehow ask that an “uncertainty” be known, especially in dealing with how society functions, is just not a possibility—there are always some sorts of unknowns or the possibility that something is being left out.

Response:

The adjective “known” has been deleted from the prospectus.

Page 2, Line 45:

Michael MacCracken, Climate Institute:

I would urge changing the word “factual” to “useful”—how is one ever going to get agreement on that anything important is actually a fact? Sure, one can get information on the amount spent on a particular projector maybe even the number of projects an agency supports, but getting anything much more is very likely to have a fair amount of subjectivity and incompleteness, at least implying that it is not factual.

Response:

The term “factual” has been replaced with “useful”.

Page 3, Lines 110-18:

Michael MacCracken, Climate Institute:

It is fine to name these general programs, but is there really much, if any, money associated with them. Basically, most of these efforts are trying to figure out how best to organize themselves, and there is precious little going into actually developing the support tools to make things happen and determine how the stakeholders are making use of the data. Thus, the “extent that these programs [actually] develop tools and resources for decision support” is generally pretty limited—they help organize the gathering of data, and what is needed is a good deal more support of efforts to make the information really useful.

Response:

Comment so noted.

Page 3, Line 21 to Page 4, Line 46:

Michael MacCracken, Climate Institute:

This all reads much more like the scope of an NRC study or set of review papers than a critical assessment and synthesis of some scientific topic. I reiterate—why go to the trouble of and advisory committee and the CCSP process for such a study?

Response:

Comment addressed above.

Page 5, Lines 20-37:

Michael MacCracken, Climate Institute:

It is not clear here if the authors will be meeting together more than once (see page 6, lines 9-10)—if so, and one really is insisting that their individual papers receive the unanimous imprimatur of all of the agencies (thereby making this an official government report written by a set of appointed outside authors), it is likely necessary to have an advisory committee, but why go to that degree of difficulty on these papers reviewing how observations are used?

Response:

Comment so noted.

Page 6, Lines 29-31 and Page 7, Lines 10-24:

Michael MacCracken, Climate Institute:

Why does this report need to go through the full set of CCSP guidelines? It is not at all clear that the outcomes of these reports will be having some large influence on expenditures so that it should qualify under the OMB guidelines, etc.? It is not clear why agency approval is needed, or even desired—these are survey papers on the use of data, not some recommendations on Homeland Security? In my view, the reasons for this have not been made, and doing so really makes for unnecessary complications.

Response:

Comment addressed above.