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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51

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1-2

1-2

32

32

Insert "and Climate" before the comma after "Development."

52

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1-7

1-7

8

8

"...meeting climate goals." The use of the word climate is meant to imply something, but what isn’t stated. Does it refer to emission level reductions, stabilization of CO2, or some other policy-related objectives? A modifier should be inserted clarifying what is meant by "climate goals."

53

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1-7

1-7

19

19

Insert: Uncertainties about causes and effects of climate change and other environmental impacts will be better understood and the potential

54

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1-7

1-7

19

19

Need to injected (somewhere) that ocean acidification is another motivation to stabilize atmospheric CO2. This is not just a climate change issue, it is an environmental and global change issue.

55

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General

Once specific targets have been set they must be reiterated in every place possible, even in an overview Chapter like this.

56

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General

While climate change is again the only reason given for the need for CO2 mitigation, it would be good to point out that there are environmental, non-climate reasons to mitigate CO2, i.e., ocean acidification - see comments on preceding and following chapters esp 6. Finally and gratefully acknowledged by you later in the chapter is the need for broad consideration of potential technology pathways and that the best ultimate solutions may not be the ones presently being pursued.

57

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General

If research and technology is to have an impact on the future of our climate then it must be directed and managed by specific quantifiable goals. Chapter two is fundamentally void of quantifiable goals. At minimum there should be a specific reduction goal number and a set time when these goals must be achieved. Specific emission reduction numbers are instrumental in identifying the direction research needs to take and the resources necessary to accomplish the desired results. A time frame allows a plan to self-evaluate at appropriate intervals and without self-evaluations there is a high risk for waste, duplication and inefficiencies.

58

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2-1

2-1

In the Vision Statement on P 2-1 what is meant by "substantial reductions?" Can you be more quantitative?

59

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Vision Box

CCTP Vision text box last line, replace with:

climate and environmental change.

60

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39

CCTP Mission: While development of new technology is critical, there is a huge pool of existing low-GHG emission technology that is not being used to its full potential. Existing U.S. domestic programs, e.g. Energy STAR, include promoting the use of this technology, as do our partnerships with others (See: Dec. 3, 2004 Department of State Fact Sheet on Bilateral and Regional Partnerships). In the short-term, increased use of existing low-GHG emission technology will provide greater benefits than technology development, which will pay off in the medium- to long-term. The CCTP Mission Statement should include promotion of existing technology. We suggest that the end of the CCTP Mission be rewritten: aimed at accelerating the development of new and advanced technologies, and the utilization of existing technologies, that can attain the CCTP vision.

61

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39

Vision Box and Mission Box

CCTP Vision: The CCTP vision statement focuses too narrowly on the provision of energy services. A wide variety of other anthropogenic activities can impact the climate system, and technology development should focus on mitigating the full range of these potential impacts. The CCTP draft strategic plan recognizes this need in Strategic Goal 4, reduce emissions of non-CO2 gases, which includes reducing N2O and methane emissions from agriculture as one of its highlights. Chapter 7 defines other GHGs to include tropospheric ozone and black carbon. In this respect the draft Strategic Plan is comprehensive. Its visions statement should also be comprehensive. We suggest that the CCTP Vision be rewritten:

The CCTP vision is to provide the technology needed to ensure that the goods and services required by society, especially abundant, clean, secure, and affordable energy and related services, can be provided while simultaneously achieving substantial reductions in emissions of greenhouse gases and other anthropogenic impacts on the climate system.

The Vision statement could be further modified to reflect an endorsement of a comprehensive approach to climate change. The vision avoids discussion of technological approaches that would facilitate adaptation, for example, and indeed adaptation is specifically rejected as a strategic goal on Pg. 2-2, line 32, footnote 2. 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.

62

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2-1

2-1

19

21

"... substantial reductions in emissions..." How is this to be measured? The strategic plan should state what metric (absolute reductions v. intensity reductions - or some other measure) will be used to evaluate the programs.

63

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2-1

2-1

23

23

strike word ‘potential’ It is ‘risk of invasion by Martians’ not ‘risk of potential invasion by Martians’. If the outcome is unlikely, the risk is small. Adding the word ‘potential’ does not add content.

64

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2-1

2-1

23

23

Replace with

"mitigating the risks of potential climate and environmental change"

65

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2-1

37

39

Insert a period after "technology" and delete the words "toward attainment of the UNFCCC’s ultimate objective";

66

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2-2

footnote 1 and 2

Delete the first sentence of footnote 1 and all of footnote 2. These changes are consistent with our Overview Comments on the Article 2 ultimate objective and adoption.

67

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2-2

2-2

Footnote 2

Footnote 2 explains that adaptation technology and offset technologies will not be considered. No real explanation of this gap is given. Since the world will experience the consequences of anthropogenic increases in GHG concentrations in the atmosphere global systems will need to adapt. This is true no matter how good we become at mitigating emissions. I can not understand why adaptation technologies are not a part of the CCTP Strategic Plan. You need to explain this much better than is done in footnote 2. Also, offset technologies should at least be explored and tested. They may be needed. They are a kind of insurance policy in case we can't control emissions to avoid dangerous interference with the climate.

68

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2-2

2-2

2

7

On page 2-2, change lines 2-7 to read as follows:

"For the purposes of planning for CCTP’s long-term technology development strategy, two considerations arise. First, the level of stabilized concentrations of GHGs in the Earth’s atmosphere is not known and will likely remain for some time a key uncertainty.1 Accordingly, CCTP’s strategic goals".

69

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4

14

It is unnecessary to raise the issue of the stabilization level needed to avoid dangerous anthropogenic interference with the climate system. As the text points out, stabilizing GHG concentrations at any level requires that net emissions of GHG slow and eventually stop. This is a huge challenge that will require all of the technology discussed in this plan and more. Delete the first consideration and the references to it.

70

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2-2

2-2

14

14

Amend to read "... achieve this goal affordably." As has been pointed out, the goal could be achieved if we all returned to pre-industrial technologies. The problem is that the costs of doing so are too high. The goal of CCTP is to achieve the goal affordably, with acceptable costs.

71

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2-2

2-2

17

17

Change the text to "reducing emissions of CO2 from energy end-use and infrastructure, energy supply, and other sectors;". According to the IPCC Third Assessment Report, CO2 emissions from land-use practices accounted for about 20% of total CO2 emissions during the 1990s. Control of some of these CO2 emissions would be enhanced by development of appropriate agricultural technology. Small amounts of CO2, about 2% of the global total, are also emitted as process emissions, e.g. reduction of metal ores, and calcination of carbonates to produce cement and lime. Technology can be developed to reduce some of these emissions. For example, Chapter 4 (Pg. 4-16, lines 7-15) discusses R&D to reduce non-combustion emissions from cement manufacture. To indicate the comprehensive nature of this plan, control of these non-energy related emissions should be part of the strategic goals.

72

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2-2

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18

18

Replace with:

"storing CO2 from various emissions sources or from the air and sequestering it from the atmosphere; and"

73

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2-2

2-2

19

19

Add "and other contributors to potential climate change from all sectors" after non-CO2 GHGs. The draft’s focus on CO2 from the energy sector is too narrow. Other GHG emissions and other anthropogenic emissions contribute to potential climate change. Since a large portion of non-CO2 GHG emissions are not related to energy use, the draft must clarify whether all sectors are included and, if some are excluded, why that is the case. The specifics under CCTP Goal 4 acknowledge the importance of non-CO2 emissions from agriculture and emission of black carbon, but since the strategic goals are likely to appear in many places without the details presented in this plan, it is important that the goal itself include a broader view.

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footnote 2

The CCTP should not limit its focus solely to an interpreted mandate from the UNFCCC. The framework laid out in the strategic plan should help define the scope of all possible technological responses to climate change, particularly in recognition of momentum factors that may be present and uncertainties in the underlying science of climate change.

75

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2-2

2-2

21

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Replace with:

"any acceleration of technology development is the identification of promising pathways and the use of basic research to illuminate technical opportunities, barriers, and alternatives in solving the CO2 problem."

76

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2-8

Discussion of Goals 1-6

From our electric utility sector perspective, the first three goals are a priority.

77

2

2-3

2-3

1

1

Change to: "Reduce CO2 emissions from energy use and infrastructure and other sectors." According to the IPCC Third Assessment Report, CO2 emissions from land-use practices accounted for about 20% of total CO2 emissions during the 1990s. Control of some of these CO2 emissions would be enhanced by development of appropriate agricultural technology. Small amounts of CO2, about 2.5% of the U.S total, are also emitted as a result of non-combustion industrial processes (e.g., calcination of carbonates to produce cement and lime). Some of these emissions can be reduced by substituting other materials either for the carbonates used in cement or for cement and lime in their end-use applications.

78

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2-3

2-3

6

6

After Line 6, add "Study mitigation of global warming impacts for possible implementation using geoengineering

79

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2-3

2-3

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24

These statements bring the question of how to promote deployment and use of advanced technologies by industry and consumers. Subsequent discussion, either in the strategic plan or related implementation documents, needs to explicitly define how these deployment objectives will be met. The discussion that follows in Chapters 4-7 does an excellent job of summarizing existing federal research and development programs, but offers very little discussion of how the technologies supported (presuming the stated goals are achieved) will be put into service.

80

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2-4

8

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. Appropriate agricultural technology can reduce CO2 emissions from land-use, and process changes can reduce non-combustion emissions. For example, using non-carbonate materials (e.g. blast furnace slag, fly ash) to replace part of the carbonate used to make cement will reduce CO2 emissions from cement manufacture.

81

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2-4

2-4

20

20

Replace with: "electricity generation technologies, deployment of renewable technologies, use of CO2 capture and sequestration (see below), increased use of nuclear"

82

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2-4

2-4

26

28

There is a logical confusion here. Ethanol and other bio-based fuels are not low carbon energy carriers. If ethanol were made from coal without CCS, we would not think it a great leap forward. Ethanol could be good if it were made from biomass, but gasoline produced by biomass would be good also. Anyway, the point is that carbon-free energy carriers are good (H2 and electricity). Any carbon containing energy carrier is good if the carbon released upon the combustion of the energy carrier is offset by uptake elsewhere in the system (as would occur if the carrier were made from biomass). The point here is that we should be choosing goals: non-carbon energy carriers or carbon-based energy carriers where the carbon (or an equivalent amount) is removed from the atmosphere. Let’s specify goals etc and not prejudge which technology would best meet this goal.

83

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2-4

2-8

29

7

With respect to goal 5, since the enactment of section 821 of Pub. L. No. 101-549 in 1990 (the Clean Air Act Amendments), our industry has reported CO2 emissions annually to the Environmental Protection Agency. That requirement, coupled with voluntary reporting of GHG reductions under section 1605(b) of the Energy Policy Act of 1992, addresses emission measurements for the electric utility industry, and thus the goal should not apply to our sector.

Note that goal 5 only refers to R&D regarding GHG emissions monitoring and measuring. The goal should be expanded to cover measuring and monitoring R&D technologies for GHG reductions.

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84

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2-4

2-8

29

7

As to goal 6, we are supportive. However, it is not our highest priority.

85

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2-4

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29

7

At the beginning of the paragraph, insert: "Fossil fuels will likely remain a mainstay of global energy production well into the 21st century."; and on line 30, after "would," insert "enable the continued use of the world’s plentiful coal and other fossil energy resources. Such a transformation would. . ." These inserts are from the p. 15, paragraph one of the "Vision" document from which the paragraph beginning on p. 2-4, line 29 and ending on p. 2-5, line 4 appears to be derived. We presume these inserts were inadvertently dropped from the paragraph. In any event, these inserts are important and should be reinserted.

86

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7

In the case of goal 4, CO2 emissions are 99.9 percent or more of electric utility GHGs, and thus we are not particularly concerned with non-CO2 emissions from our sector.

87

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4

4

Replace with:

"current focus areas are:"

88

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2-5

9

9

Replace with:

"saline aquifers, or other deep injection reservoirs. The carbon could also be stored in the ocean as CO2 or other chemical form."

89

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2-5

2-5

12

13

Reference to ocean sequestration is unclear. Most people who have looked at the issue believe that carbon capture and storage in the ocean is technologically feasible but may pose political and environmental challenges. Most people who have looked at ocean fertilization question its viability and efficacy, and thus it probably should not be highlighted at this level of the report (as this level should focus on things likely to hold some promise). The most promising ocean option in the opinion of this reviewer involves using power plant flue gases in combination with seawater and crushed limestone with effluent release in the surface ocean. Sulfur removal with seawater and limestone are both promoted as clean energy options by the World Bank. These technologies could be combined to remove CO2. This is another case where the report is choosing technologies based on prior DOE funding history and not an objective analysis of engineering and other constraints.

90

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2-5

2-5

12

13

replace with:

low-cost means for long-term carbon storage. Enhancing the ocean's biological CO2 sink could also play a role. An understanding of the efficacy and environmental effects of the preceding approaches is needed.

91

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2-5

2-5

13

13

Add "and other contributors to potential climate change from all sectors" after non-CO2 GHGs. The focus of the strategic plan is on CO2 from the energy sector. Other GHGs and other anthropogenic emissions, e.g., black carbon, also contribute to potential climate change. Since a large portion of non-CO2 GHG emissions are not related to energy use, the plan’s wording should be clear that all sectors are included. The specifics under this goal acknowledge the importance of non-CO2 emissions from agriculture and emissions of black carbon, but since the strategic goals are likely to appear in many places without the details presented in this plan, it is important that the goal itself include a broader view.

92

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2-5

2-5

14

15

Not strictly true. The time integrated radiative forcing in Joules per m2 is the instantaneous radiative forcing of CO2 times a time constant that is close to 20,000 years. This is higher than the radiative forcing of these other gases on a mass basis. The IPCC GWP technique ignores the long lifetime of CO2. The statement as written is true only if we are talking about instantaneous radiative forcing and ignoring atmospheric lifetimes. Language should be clarified to indicate this.

93

2

2-6

2-6

1

1

The GWP is a terrible measure as it is non-scientific. It is equivalent to having a zero discount rate for 100 years and an infinite discount rate thereafter which makes no sense. The United States should not be embracing such a measure with no sound basis in science or economics.

94

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2-7

2-7

5

5

Replace with: "research and development. The dual challenges-addressing global climate/environmental change and providing the"

95

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2-7

2-7

10

10

Replace with: "better prepared to find solutions and create new opportunities, including fostering new ideas and approaches that may be outside current R&D thrusts. CCTP will focus on several ways to meet"

96

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2-7

2-7

26

33

The inclusion of provisions for exploratory research is critical to the success of this plan and should be retained. However, there need to be criteria for judging exploratory research and for terminating unsuccessful projects after they have been given a reasonable chance to succeed.

97

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2-8

2-8

9

9

Missing from the core approaches is learning by doing. If CCTP develops carbon capture and storage and no profit making venture deploys it commercially, a learning opportunity will be missed. A government run demonstration plant will generate a constituency that wants to see the demonstration plant live forever without great incentive to reduce costs. A price on carbon will induce deployment of technologies by enterprises with great incentive to reduce costs.

98

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2-8

28

33

As written, the strategic plan perpetuates the antiquated linear framework of innovation (i.e., basic research leads to applied R&D which leads to technology development). Other models of innovation may be more applicable to the climate change issue, but certainly will be less applicable to the traditional federal budgeting and organizational framework.

99

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2-8

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38

The plan should explicitly note that the discoveries mentioned would be more supportive to the general pursuit of the goals of the plan, and likely would not directly contribute to them.

100

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2-9

1

17

The CCTP must sharpen the discussion of how public and private sector roles will intersect in the course of the R&D activities defined by the plan. The strategic plan places great emphasis on the need for public-private sector partnerships and enhanced cooperation and collaboration, but its discussions do not provide sufficient details or descriptions to determine how such activities will work in practice. Instead, the plan references a number of ongoing collaborative efforts. These efforts represent multiple ways to organize and execute an R&D. The plan does not discuss which factors produce more successful partnering efforts so that future initiatives (i.e., those guided by this strategic plan) can benefit from the lessons of these prior efforts. The plan also does not discuss the factors that complicate public-private cooperative efforts and does not offer guidance for overcoming those complications.

The plan does not discuss what incentives or inducements may be employed to encourage more efficient and effective partnering. The plan appears to promote the view that access to R&D resources/assets and intellectual property is sufficient to encourage private sector involvement. Reviews of prior partnership programs would reveal the limitations of that approach and suggest the need for an additional set of incentives. If it is determined that the range of activities covered by the plan is somehow unique, then the plan must include that discussion.

The plan does not discuss other mechanisms by which technologies developed under the auspices of the plan will be transferred to the private sector. If partnerships are the sole instrument for achieving that end, additional exploration of how effective that mechanism will be is strongly recommended. If other actions are foreseen, discussion of them in the strategic plan is clearly warranted.