The effects of climate change on agriculture, land resources, water resources, and biodiversity

General Comments

EEI GEN-1

“EEI is puzzled by the designation in the SAP title (and sometimes elsewhere in the draft) of the words “agriculture” and “biodiversity” as “resources.” In the SAP title, “agriculture,” “biodiversity,” “land” and “water” are all characterized as “resources.” Clearly “land” and “water” are resources. However, we question the designation of either “agriculture” or “biodiversity” as a “resource.”

In the draft, they are also sometimes referred to as “resources” (e.g., “The resources that will be addressed in this product include:,” p. 2, lines 4-5). In some cases the draft also refers to “systems,” which, in some contexts, seems also to mean agriculture, etc. However, land and water are not generally viewed as “systems.”

The draft also uses the formulation “agriculture, land resources, water resources, and biodiversity” (e.g., p. 2, lines 7-17; p. 3, questions 1 and 5). This is the better formulation from both a substantive and technical standpoint. In any event, both the SAP title and the draft need clarification.”

Response:  This comment improves the clarity of the prospectus and will be adopted.  

Action:  The title of the report has been changed to

“The effects of climate change on agriculture, land resources, water resources, and biodiversity.”

EEI GEN-2

“According to the draft (p. 1 n. 1), the CCSP “agreed” on July 15, 2005, to “modify its SAP list to explicitly incorporate coverage of all assessment areas listed under section 106 of the Global Change Research Act.” As a result, SAP 4.3 was changed from a focus “on the relationship between observed ecosystem changes and climate change” to a “focus on effects of climate change on agriculture, biodiversity, land and water resources.” The draft explains (p. 1) that “[t]hese areas are addressed under the ecosystems, land use, and water research elements of the CCSP; that “[o]ne of the primary goals these research elements had is to enhance understanding and the ability to estimate impacts of future climate change on these systems;” and that the SAP- 4.3 “report will focus on our ability to identify, observe, and monitor the stresses that influence agriculture, biodiversity, land and water resources” (emphasis added).
EEI welcomes this change of “focus,” especially with respect to its emphasis on “water resources” and “water research,” as water is very important to the operation of the electric utility facilities of EEI’s members and to energy development and use generally. We fully agree that if the report is able to “be the synthesis of information on resource conditions, observation systems, and monitoring capabilities that can be used to gauge future change,” it has the potential of providing a “lasting contribution” that could be very important to our economic sector as well as others.”

Response:  No response required.

Action: No changes were made.

EEI GEN-3

“The draft explains (p. 1) that the “potential scope of the material in SAP-4.3 is “very broad,” and thus proposes to limit the scope first to “an assessment of the United States” and then to a “timeframe of interest. . .weighed toward the near term (e.g., the next 20-30 years)” (emphasis added).

While we would generally agree that a limitation to the U.S. is probably more appropriate for agriculture, biodiversity and possibly land resources, we question whether it is appropriate for water resources, particularly since many of the sources of water for a wide variety of uses -- including agriculture, recreation, residential use and energy -- in the U.S. are shared by Canada, such as the Great Lakes and the Columbia River. Similarly, Mexico is important regarding the supply and use of water of the Colorado River and, of course, the Rio Grande borders the U.S. and Mexico. Indeed, it is our understanding that there are several international agreements with both Canada and Mexico regarding these and other waterways that address issues of supply, accessibility, quality and quantity of water, as well as other issues.”

Response:  Cross border issues are relevant to some extent for all of the issues to be addressed by this report.  The prospectus will modified to incorporate cross-border issues with Mexico and Canada in the context of the broader scope of the prospectus.  The focus of the report will remain on the U.S.  However, to the degree to which these effects are driven by forces outside the U.S.’s political boundaries, those international considerations will receive attention.

Action:  The following statement has been added to the passage: 

“To the degree, however, that the systems and resources of concern to SAP 4.3 may be affected by occurrences outside the political boundaries of the U.S. (particularly within Canada and Mexico), those international considerations will receive attention.”

EEI GEN-4

“Regarding the proposed time frame, a “near term” focus may be more relevant and realistic, although 20-30 years is too short with respect to water resources and energy use and development, particularly since generation facilities and other energy projects generally operate economically for longer periods. Therefore, 40-50 years may be a more appropriate time frame.

In discussing the challenges of separating the “effects of climate change from those due” to “human activities” regarding water, the draft states (p. 2) that they “are made all the more problematic by the current paucity of long-term monitoring data and information” (emphasis added). It is unclear whether the report with its “near term” scope would help to address that “long-term” need.”

Response:  The prospectus indicates that the assessment should be weighed toward the near-term (e.g. the next 20-30 years).  The prospectus does not exclude a discussion of longer term effects of climate change.  All of the sectors / systems / resources addressed by this report would find a similar level of interest in both the short, medium, and the longer terms.  The prospectus will be modified to reflect that the assessment will include discussions of mid- and long-term effects.  However, because of the relevance of anticipated effects the near future, and the usefulness of such an assessment, the report will give weight to the near-term. 

Action:  The statement has been amended to state

“The timeframe of interest will be weighed toward the near-term (e.g. the next 20-30 years), but will include limited discussions of longer-term issues.”

EEI GEN-5

“As to both the time frame and geographic application, the draft states (p. 1) that “[o]ver the past several decades, numerous scientific assessment reports have described and discussed historical and potential impacts of climate change and climate variability on managed and unmanaged systems and their constituent biota and processes” and that “[t]his report will build on recent assessment.” (emphasis added). The draft indicates (p. 1 n. 2) that “[a] description of relevant assessments and reports is included in section 7 of this Prospectus.” Indeed, section 7 states that “[t]his CCSP product will draw on” assessments of, for example, “the Intergovernmental Panel on Climate Change (IPCC)” and that it “is expected that this CCSP product will provide input to future IPCC assessments” (emphasis added).

It is unclear what it means to “build on” such assessments. Moreover, it is our understanding that the IPCC assessments cover much longer time frames than “20-30 years” or the “near-term.” Accordingly, we have some difficulty understanding how this limited scope report could “build on” and “draw on” such “recent assessments” that have a far broader scope from a time stand point. Furthermore, their geographic application is also far broader. They are not focused regionally, let alone on one country, such as the U.S. They are, in essence, global. Indeed, we question whether such assessments will be particularly helpful with respect to the focus on water resources.”

Response:  SAP 4.3 authors will consider past assessments in preparing this document.  SAP 4.3 will build on and further elaborate the work of previous assessments. We anticipate that SAP 4.3 will advance understanding of the effects of climate change on agriculture, land resources, water resources, and biodiversity.  We do not see a need to change text indicating the SAP 4.3 will draw on previous assessments. 

While the time and geographic scales of reports such as the IPCC assessments are not identical to those of this report, there is potentially great value in subjecting the issues and trends identified by those assessments to a narrower examination, in order to best identify the scientific issues and driving factors at a management and policy-relevant scale.  Furthermore, such smaller-than-global-scale understandings as this are expected to become fundamental to the larger scale assessments, as they are developed and become available.

Action:  No changes were made.

EEI GEN-6

“The draft states (p. 2) that “[w]e do not anticipate that the report will include specific scenarios of future conditions. Rather, the report will highlight the changes in resource conditions that recent scientific studies suggest are most likely to occur in response to climate change, and when and where to look for these changes.”

While we generally agree that a report whose scope is limited to the “near term” probably should not include “specific scenarios,” the alternative – namely, reliance on “recent scientific studies” in the context of water resources – is unclear. As the draft points out, “[c]ompetition for water is driven by many factors that have little to do with climate change, including development and population growth.” While the draft states that the “availability” of water “could also be affected” by climate change and that demand “could change in response to higher temperatures and supply could change due to changes in precipitation volume and timing,” it nevertheless adds that “[i]t is difficult to separate the effects of climate change from those due to these other human factors” and that “[t]hese challenges are made all the more problematic by the current paucity of long-term monitoring data and information for most managed and unmanaged system types” (emphasis added). The draft goes on to note a number of actions that will be taken to highlight where the expected effects of climate change should be seen.

One factor not highlighted in the SAP was referred to in the New York Times article “Weather Report” on July 15, 2006 (p. B11):

Focus: Asphalt Desert Phoenix had a record warm night late Wednesday and early yesterday when the temperature fell no longer than 93 degrees. On July 15, 2003, the city had its hottest night on record, when the mercury failed to fall below 96 degrees. Phoenix has grown vastly in the last 25 years. Desert terrain has been covered by concrete and asphalt, which absorbs and retains additional heat. Infrared satellite pictures show that the official thermometer at Sky Harbor Airport is near the hottest part of the Phoenix area, at the center of the large expanse of asphalt. (Emphasis added.)”

Response:  The urban heat island effect is well documented in the climatological and meteorological literature.  It is considered by some to be a factor responsible for human-driven climate change--which is to say that it is itself a cause rather than an effect.  However, it is the effects of climate change which comprise the scope of SAP 4.3.  SAPs 1.1 and 1.3 would be more appropriate beneficiaries of any concern regarding this issue.

Action:  No change was made.

EEI GEN-7

“While reliance on “recent scientific studies,” peer-reviewed literature, interpretation of data and the other actions highlighted in the draft may be useful for agriculture, biodiversity and land resources, it is unclear how they will “highlight changes” regarding water resource “conditions” because of the difficulty, as recognized by the draft, of separating the possible “effects” of climate change from those “due to” human factors. The draft needs to be expanded in this regard.”

Response:  The goal of SAP 4.3 is to address climate change effects.  To the extent practicable, the role of climate relative to other stressors in changes to those systems/resources of interest to SAP 4.3 will be addressed by the report.  It is more appropriate to discuss the methodologies for doing so in the report itself rather than in the prospectus, which simply identifies the relevant issues.

Action:  No change was made.

Specific Comments

EEI  Page 4, lines 9-36

“Regarding the focus on water resources, for SAP 4.3 the Department of Agriculture  (USDA) has been designated as the “Lead” agency and that several other federal agencies are listed in the draft as “Supporting Agencies.” These include the Department of Energy, which we agree should have a significant role in light of its energy expertise. We agree also with the inclusion of the U.S. Geological Survey (USGS), which is a constituent agency of the Department of the Interior. However, the Interior Department’s capabilities and responsibilities, especially regarding land and water resources and their relevance to energy needs, go beyond those of the USGS. It has several other constituent agencies, such as the Bureau of Land Management, Bureau of Reclamation, U.S. Fish and Wildlife Service and Western Area Power Administration, which have significant responsibilities and expertise regarding the management of these resources and their use and application for energy development and utilization and other purposes. Similarly, the absence of the Army Corps of Engineers, which also has significant water supply and management capabilities, is noteworthy. In short, it is unclear why the Interior Department and the Corps of Engineers are not also listed as “Supporting Agencies.” They should be.”

Response:  The Ecosystems Interagency Working Group (EIWG) of the CCSP includes representatives from the Department of Interior (DOI) and the Department of Defense (DOD).  Because of their prime involvement in scientific issues related to climate change, DOI is represented by the USGS on the EIWG, and DOD is represented by the Office of the Navy.  It is not customary within the CCSP structure for other agencies to be singled out for inclusion as “supporting agencies,” in the prospectus, and we regret that this convention may be misleading.   Through USGS, subject-area experts within DOI’s agencies are actively engaged, as is the case with the Navy and DOD’s agencies.  The reviewer’s (and USDA’s) wish that each of the specific agencies listed above be invited to participate in the review of milestone-marking drafts of SAP 4.3 has been communicated and is recognized by DOI and DOD’s EIWG representatives, who have provided assurance that they will take the lead responsibility in communicating and coordinating reviews of SAP 4.3 with the appropriate representatives at other DOI and DOD Bureaus.

In addition to this supporting function, it is possible that expertise at each of these agencies may be put to the purposes of this report through the participation of resident experts as report authors.  As such, nominations for experts to serve as SAP 4.3 authors have been sought from the Federal service (via email to the EIWG, 8/14/06), including the request for experts at assessing the effects of climate change from those agencies listed by the reviewer. 

Action:  On August 8 and August 14, 2006, through the EIWG, the agencies listed by the reviewer were invited to support the preparation of SAP 4.3 directly, and via nominations for the participation of expert authors.   No change was made to the prospectus text.

EEI  Page 4, lines 9-36 (continuation #1)

“As to the term “water resources,” the draft lists (p. 2) “Supply” and “Quality” to be “addressed.”

The list could be expanded to include addressing of both the words “accessibility” and “quantity.”

Random House Webster’s College Dictionary (2d ed. 1997) defines (p. 1295) “supply” to mean “1. to furnish or provide. . .with what is lacking or requisite: “supplying the poor with clothing,” which suggests an action by someone to provide the resource to the user, while the word “accessible” is defined (p. 8) to mean “3. obtainable; attainable”, which suggests an action by the user.”

Response:  The reviewer’s comment supposes that the water resources chapter is dedicated to human consumption, when in fact, aquatic ecosystems and other applications of water resources are intended, as well.   

Action:  The term water “supply” in the overview outline has been changed to water “Quantity, Availability, and Accessibility.”

EEI  Page 4, lines 9-36 (continuation #2)

“The draft lists (p.2) the four “resources” to “be addressed in this product”. However, the list is preceded by the word “include” (p. 2, line 5), which suggests that the list could be expanded in preparing the SAP. We presume from the SAP title that the CCSP does not intend such an expansion and suggest that the word “include” be changed to a more limiting word such as“are:””

Response:  Agreed.

Action: The passage has been reworded as suggested, to state
“The resources that will be addressed in this product are:”

EEI Page 3, line 26 and page 5, line 45 to line 1, page 6

“In section 1.1, the draft states that the “report will be based on an objective evaluation of the peer-reviewed literature (p. 3, line 26). However, section 3 first reiterates that the “authors will base all their writing” on “peer-reviewed literature.” It then adds the criteria that such literature must be “published” and “scientific” (p. 5, lines 45-46). Finally, it provides an exception that “[h]ighly relevant non-peer reviewed literature may be used with permission from USDA and the CCSPO” (p. 5, line 46 to p. 6, line1) (emphasis added). This appears to be a very broad exception. Indeed, the only criterion is that the literature must be “[h]ighly relevant,” which is open-ended. It is silent as to whether such literature must be both “published” and “scientific.” The requirement of permission is helpful, but with the criteria so open-ended that requirement is not likely to be very meaningful.

While the procedures for the preparation of reports of the IPCC recognize that some relevant sources “have not been published or peer-reviewed (e.g., industry journals, internal organizational publications, non-peer reviewed reports or working papers of research institutions, proceedings of workshops, etc.),” we do not know from the draft what types of sources the CCSP has in mind with this broad exception. There is a need for a better explanation of the reasons for relying on such sources as well as more objective criteria for utilizing them. In addition, the source reference sections of the report should clearly distinguish between sources that are published, peer-reviewed and scientific from other sources that are not scientific, not published and not peer-reviewed.”

Response:  Guidance on the use of materials in the production of SAPs is provided in the “Guidelines for Producing CCSP Synthesis and Assessment Products”, which states: 

“Authors will use the published, peer-reviewed scientific literature in drafting the products. In the rare case that any materials used in preparing a product are not already published in the peer-reviewed literature, the lead agency(ies) must get approval from the CCSP Interagency Committee and these materials must be made available by the lead agency(ies) and/or CCSP Office. The use of any such non-peer-reviewed materials may be questioned by reviewers during the expert review or public comment period. Authors should seek to publish any materials used in preparing drafts of the products.”

The complete guidance on the use of materials that are not already in the peer-reviewed literature will be added on page 6 of the prospectus. 

Action:  The following passage has been added to the prospectus: 

“As stated in the Guidelines for Producing CCSP Synthesis and Assessment Products, ‘Authors will use the published, peer-reviewed scientific literature in drafting the products. In the rare case that any materials used in preparing a product are not already published in the peer-reviewed literature, the lead agency(ies) must get approval from the CCSP Interagency Committee and these materials must be made available by the lead agency(ies) and/or CCSP Office. The use of any such non-peer-reviewed materials may be questioned by reviewers during the expert review or public comment period. Authors should seek to publish any materials used in preparing drafts of the products.’”

EEI Page 4, lines 40 through page 5, line 35

“Section 3 of the draft states (p. 4) that “[g]iven the breadth of the SAP 4.3,” USDA foresees significant benefit from cooperation between federal, academic, and private scientists and researchers in producing the report” and explains in some detail the “benefit” of the report to public and private organizations (emphasis added). It then states

The production of the document will be best served by an exchange of resources and substantial involvement between USDA, other federal agencies, and a cooperator (including activities such as drafting, providing reviews, financial assistance, and technical input). Based on these considerations, USDA decided to pursue the production of this report through a cooperative agreement.

Development of SAP 4.3 will require an interdisciplinary group of lead and supporting authors with expertise and experience directly related to the subject matter. The cooperator, in coordination with USDA, will select a convening lead author and lead authors for each chapter of the report, consistent with the . . . required expertise. The public may submit nominations for consideration.

USDA will publish the biographical information for the convening lead author and lead authors in a Federal Register notice. The convening lead author and lead authors for each chapter of the report— organized by the cooperator, will draft answers to the five key questions addressed in the product.(Emphasis added.)

While we do not question that there could be significant benefits to a wide variety of organizations, both public and private and including business and industry, from this SAP 4.3 report, it does not follow that those “considerations” justify or support a decision by the USDA -- which from the context the draft has apparently already been made -- “to pursue the production of the report through a cooperative agreement.” In addition, while we could agree that the “production of the document” could be well-served “by an exchange of resources and substantial involvement” of USDA and other “Federal agencies,” it does not necessarily follow that such “production” is also “best served” by a “cooperator.” To our knowledge, the several other CCSP SAPs have not engaged private contractors for the development of reports.

Moreover, the draft fails to either explain the criteria for engaging a “cooperator” by cooperative agreement or indicate when and how that person or entity was or could be selected.

Clearly, such a person or entity should not be involved in any way with drafting,” “providing reviews” or providing “technical input.” As to the reference to “financial assistance,” we do not understand what financial assistance could be provided by such cooperator or why it is needed. In short, the use of a cooperator is not sound and should be abandoned.”

Response:  Several other SAPs have engaged outside expertise.  The range of involvement of outside expertise has varied from experts that participate on Federal Advisory Committees to contractors that are responsible for all aspects of product preparation.  For example, SAP 2.2, The North American Carbon Budget and Implications for the Global Carbon Cycle, will be prepared under contract.  The final prospectus for SAP 2.2. states that “the funding award for SAP 2.2 has been set up such that the U.S. Government will not exert management or control over the activities of the contractor nor will U.S. Government officials play a role in selecting authors, holding meetings, setting the agenda, or drafting the final report”.

The Guidelines for Producing CCSP Synthesis and Assessment Products (SAP Guidelines) states that: 

To ensure that the products incorporate as much expertise as possible, the lead agency(ies) will be open to the participation of other individuals or entities with relevant expertise and information. The entities can include other government units (Federal or non-Federal), Interagency Working Groups of the CCSP or other Federal programs, international organizations and government units, non-governmental organizations (NGOs), and other groups.

A variety of mechanisms are being employed to produce the 21 SAPs to ensure that the products incorporate expertise found outside of the government.  USDA’s decision to pursue a cooperative agreement was, in part, due to the broad scope of the material to be addressed in SAP 4.3 and the benefits from engaging outside expertise in cooperation with Federal experts. 

According to the SAP Guidelines,

“the lead agency will be responsible for developing an open and transparent process for soliciting user input, author nomination and selection, expert peer review and public comment, and production/release of the products, as described in these guidelines.” 

The SAP Guidelines do not require that the lead agency select the authors for the report.  In fact, other SAPs that are being prepared under contract will not have U.S. Government officials involved in the author selection process.  The SAP Guidelines are explicit in stating that the expert reviewers should be selected by the lead agency / department.  USDA intends to select the expert reviewers of the report and convene a Federal Advisory Committee to perform the expert review. 

USDA has determined that a cooperative agreement is an appropriate mechanism to utilize in the preparation of SAP 4.3.  USDA has determined that the purpose of the cooperative agreement is to engage experts outside the government to carry out a public purpose with substantial involvement being anticipated between USDA and the recipient during the preparation of the product.  A mutual interest exists because the outcome of SAP 4.3 significantly supports the mission of the cooperator and each party to the cooperative agreement independently has an interest in obtaining the good or service, shared by each of the other parties to the agreement. 

Action:  No change was made.

EEI Page 4, lines 40 through page 5, line 35 (continuation #1)

“Further, it is our understanding from our review of other SAP prospectuses that it has normally been the role of the lead federal agency and the supporting agencies to select the lead and supporting authors; list them in the draft Prospectus with their curriculum vitas, publications, etc.; and provide an opportunity for public comment thereon. As to this SAP, it appears that the USDA and the CCSP are proposing to deviate from the normal CCSP practice and to transfer this responsibility from federal agencies to a “cooperator,” who presumably is not a federal official. It is inappropriate for a non-federal entity or person, even through a USDA contractor, to “select” any of the authors or for USDA/CCSP to circumvent public involvement in the selection. Publication as a Federal Register notice of the authors after selection does not afford the public an opportunity to comment thereon, which has been the practice for most, if not all, other SAPs.”

Response:  SAP 4.3 states that “the cooperator, in coordination with USDA, will select a convening lead author and lead authors for each chapter of the report”.  As part of the public comment process on the prospectus, the public had an opportunity to propose authors for the report.  We did not receive any proposals for authors from the public review of the prospectus.  However, the USDA will continue to evaluate recommendations that are received in collaboration with the cooperator.   

Action:  Biographical information for the five lead authors was added to the prospectus (Section 10).  Suggestions for additional authors will be considered throughout the report drafting process. 

EEI Page 4, lines 40 through page 5, line 35 (continuation #2)

“As to stakeholder interaction, the draft states (p. 6) that USDA:

will provide guidance to the cooperator regarding solicitation of additional input from a broader group of stakeholders at the beginning of the drafting process. This could involve convening a focused stakeholder workshop, soliciting stakeholder input through a structured e-mail or web-based process or survey, or other appropriate process. This input, together with other input received from sources noted above will be considered carefully in defining the scope, organization, content, and expectations for the product.  (Emphasis added.)

However, the draft is silent as to what that USDA “guidance” might be or whether it will be public. As stakeholders, EEI and our members have an interest in knowing it now. More importantly, we again do not understand why USDA wants to impose a cooperator” between the agencies and stakeholders, particularly if the cooperator has freedom to decide who may provide “input” and when pursuant to some unstated guidance.”

Response:  The final prospectus will mention specific plans to engage stakeholders both at the USDA Greenhouse Gas Symposium to be held in February 2007, and the intention to send lead chapter authors to meetings of interested stakeholders to present a draft outline of the report’s contents and solicit commentary and suggestions.

Action:  This passage: 

“This could involve convening a focused stakeholder workshop, soliciting stakeholder input through a structured e-mail or web-based process or survey, or other appropriate process.”

Has been replaced with the following:

“Stakeholder input will be sought at the USDA Greenhouse Gas Symposium, to be held in Baltimore, MD in February 2007.  Additionally, during development of the draft report, authors will present report outlines to meetings of identified stakeholder groups to present a draft outline of the report’s contents and solicit commentary and suggestions.”

EEI  Page 7, line 45-page 8, line 1

“As to the third draft of the SAP, the draft notes that “[i]f needed, the Natural Research Council (NRC) will be asked to provide additional scientific analysis to bound scientific uncertainty associated with specific issues” (emphasis added). It does not indicate what those “issues” may be or specify the time allotted for such NRC input. We understand that the third draft occurs after the second draft has been developed and peer-reviewed and has been subjected to a 45-day public comment period, “taking into consideration the comments submitted during” the public period for the second draft.

We seriously question the need for, or the appropriateness of, any role by the NRC, particularly after the public comment period. If there is a need for NRC input, it should take place before public review of the second draft so the public may comment on the draft as affected by the NRC. However, if “scientific uncertainty” needs to be “bounded,” it should be by the SAP authors, not the NRC. Presumably, they will be selected by the USDA and supporting agencies for their scientific expertise and their capacities to perform such a function. Thus, there should not be a need for NRC input, which in addition we understand does not provide such analysis free of charge.”

Response:  The provision to request input from the National Academies of Sciences/National Research Council is consistent with the Guidelines for Producing CCSP Synthesis and Assessment Products, which includes a provision to request additional scientific analysis to bound scientific uncertainty associated with specific issues – after the CCSP Interagency Committee review.  This provision will only be employed if there are differences between the CCSP Interagency Committee and the authors that cannot be resolved. 

Action:  No change has been made.