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Environment - Climate Change [Folder 1]
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Records of the Council of Economic Advisers (Clinton Administration)
Joseph Stiglitz's Files
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FOIA Number: 2017-1095-F
FOIA
MARKER
This is not a textual record. This is used as an
administrative marker by the William J. Clinton
Presidential Library Staff.
Collection/Record Group:
Clinton Presidential Records
Subgroup/Office of Origin: Council of Economic Advisers
Series/Staff Member:
Joseph Stiglitz
Subseries:
OA/ID Number:
9554
FolderID:
Folder Title:
Environment - Climate Change [Folder 1]
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Row:
Section:
Shelf:
Position:
S
20
5
6
3
Withdrawal/Redaction Sheet
Clinton Library
DOCUMENT NO.
SUBJECT/TITLE
DATE
RESTRICTION
AND TYPE
001. memo
To Joseph Stiglitz from John Shlaes, re: Meeting with representatives
09/21/1994
b(6)
of the Global Climate Coalition [PII] [partial] (1 page)
COLLECTION:
Clinton Presidential Records
Council of Economic Advisers
Stiglitz, Joseph
OA/Box Number: 9554
FOLDER TITLE:
Environment - Climate Change [Folder 1]
2017-1095-F
bg241
RESTRICTION CODES
Presidential Records Act - [44 U.S.C. 2204(a)]
Freedom of Information Act - 15 U.S.C. 552(b)]
PI National Security Classified Information [(a)(1) of the PRA|
b(1) National security classified information [(b)(1) of the FOIA]
P2 Relating to the appointment to Federal office [(a)(2) of the PRA|
b(2) Release would disclose internal personnel rules and practices of
P3 Release would violate a Federal statute [(a)(3) of the PRA|
an agency |(b)(2) of the FOIA|
P4 Release would disclose trade secrets or confidential commercial or
b(3) Release would violate a Federal statute [(b)(3) of the FOIA]
financial information [(a)(4) of the PRAJ
b(4) Release would disclose trade secrets or confidential or financial
P5 Release would disclose confidential advice between the President
information |(b)(4) of the FOIA]
and his advisors, or between such advisors [a)(5) of the PRA|
b(6) Release would constitute a clearly unwarranted invasion of
P6 Release would constitute a clearly unwarranted invasion of
personal privacy |(b)(6) of the FOIA]
personal privacy |(a)(6) of the PRAJ
b(7) Release would disclose information compiled for law enforcement
purposes |(b)(7) of the FOIA]
C. Closed in accordance with restrictions contained in donor's deed
b(8) Release would disclose information concerning the regulation of
of gift.
financial institutions [(b)(8) of the FOIA]
PRM. Personal record misfile defined in accordance with 44 U.S.C.
b(9) Release would disclose geological or geophysical information
2201(3).
concerning wells [(b)(9) of the FOIA|
RR. Document will be reviewed upon request.
Lisa- - We
Please
Make in
tab 6
of Joe's
notebook on
climate
negotiations. Thanks,
I
Jally
A15
THE WALL STREET JOURNAL MONDAY, APRIL 3, 1995
"Waterworld," Bootleg Freon and a Berlin Plot
The U.N.'s latest save-the-earth festival
The cost to Americans for retrofitting air
Fund, even succinctly described his own
larly carbon dioxide, over the last 100
now underway in Berlin has averted one
conditioners and refrigerators to use non-
problem. If skeptical scientists can per-
years. But Ms. Baliunas says flatly that,
perceived disaster, an oil nation boycott of
Freon coolants (which do not entirely over-
suade the public that ozone wasn't worth
"No evidence can be found in the temper-
nonsense. Considering the flimsy science
come Freon's alleged threat) is estimated
acting on, he said, "there is no reason for
ature measurements to support the theory
mobilized for these events and the huge
at $100 billion. As a result of the ban, Freon
the public to believe anything about any
of catastrophic global warming caused by
and urine
and unnecessary costs they are inflicting
now has become a much-in-demand boot-
environmental issue."
human activities." The evidence she cites
safeguard
on the global economy, preventing mass
leg item, with thieves reportedly hijacking
That comment grossly underestimates
in support of this assertion is exhaustive.
inue studies
defections is no small accomplishment.
air conditioner repair trucks to steal this
the ability of voters to distinguish between
For one thing, most of the small earth tem-
It may be, however, that eco-catastro-
latest valuable "controlled substance."
hokum and real problems, such as the pol-
perature rise since 1880 (0.5 degrees Centi-
being of all
tion gained
phe hyperbole is losing its punch. Politi-
Eco-fearmongering may even have
lution of streams and rivers by untreated
grade) occurred "before the greenhouse
e to similar
cians are beginning to see that kowtowing
passed its peak in Hollywood, where the
municipal and industrial wastes. But it is
gases from human activities existed in the
cluding hu-
to enviro-extremists can lose votes, big-
"Earth Communications Office," run by
true that eco-fearmongers had things their
atmosphere." Serious environmental sci-
own way for a long time-in part because
entists know, of course, that the ecosystem
time, as well as win them. One of the pre-
liberal Democrats, has had incredible suc-
re placed on
scriptions for fighting "global warming"
cess in getting producers and writers to in-
so many reporters and editors were sus-
itself dwarfs human activity in terms of
rs to ensure
that came out of the U.N.'s 1992 "Earth
ject eco-fears into movie and TV scripts.
ceptible to sensational claims from self-
generating or absorbing carbon dioxide.
ials to care
Summit" in Rio was a carbon tax to dis-
Fiction thus becomes fact in the minds of
It is widely accepted that a higher con-
more than
courage the burning of fossil fuels. Eco-
15-year-olds and couch potatoes. But not all
centration of carbon dioxide in the atmos-
sulating and
eco-fiction succeeds and Kevin Costner has
Serious scientists have fi-
phere increases plant and animal life, con-
am even at
Global View
every reason to worry about his new flick,
fushers pro-
"Waterworld," which postulates the ulti-
nally involved themselves in
trary to some of the scare claims. Some
American readers may have evidence of
per team to
mate catastrophe of a "global warming"
debates over "ozone deple-
that, admittedly unscientific, in the num-
By George Melloan
melting the polar icecaps, forcing everyone
ber of Canadian geese flocking to their
ut the race.
to become mermen and mermaids, or
tion" and "global warming."
ponds and lakes or the deer that have be-
a positive
who are ex-
merms's. Big cost overruns, some inflicted
come a hazard for drivers on the east coast.
of sled dogs,
munchkins claimed, without benefit of
by Mother Nature, have put the film's bud-
styled "scientists." Only belatedly have
As to ozone depletion, Ms. Baliunas finds
this sport is
valid evidence, that our home furnaces,
get even deeper underwater than its script.
real scientists begun to see the threat the
"no observational evidence that man-made
Indeed, the world has come a long way
politicization of scientific inquiry is posing
chemicals like CFCs are dangerously thin-
al-rights ex-
cars and trucks and electrical power plants
I about the
were turning the earth into a hothouse. Oil
since the Montreal Protocol, since EPA ad-
to their credibility and to Insist that sen-
ning the ozone layer over most of the world."
vesome ani-
nations, electric utilities and coal compa-
ministrator William Reilly was spouting
sational claims be subjected to profes-
Moreover, she notes that the kind of ultra-
"put their
nies aren't the only ones unconvinced. Bill
nonsense about cancer deaths that would
sional rules, such as peer review, replica-
violet rays that would be let through by a
i." Ongoing
Clinton couldn't push the U.N.'s recom-
result from "ozone depletion" in 1991 and
tion of experimental data and rigorous ex-
thinner ozone layer, UV-B, is not the UV
earch capa-
mended energy tax heist through Con-
even since the "Earth Summit." Mainly
amination of data sources.
that causes melanoma. "On two counts, the
enthusiasti-
gress at the outset of his reign. Overtaxed
that is because serious scientists have fi-
One of those real scientists is Sallie Bal-
hysteria and costly regulations are entirely
) truly care
Europeans also are saying no. "Tut, tut,"
nally involved themselves in debates over
iunas, chairman of the Harvard-Smithson-
unfounded." Ms. Baliunas, by the way, was
the eco-fearmongers mutter in Berlin.
"ozone depletion" and "global warming"
ian Center for Astrophysics and a member
described by Discover magazine in 1991 as
EN SCHMIDT
Their arrival, by the way, was greeted by
and have exposed just how little real sci-
of the Science Advisory Bord of the George
one of America's most outstanding women
a spring snowstorm.
ence these scenarios have contained.
C. Marshall Institute, a leading public pol-
in science.
17 other
Some U.S. Congressmen also now know
The resulting nervousness of eco-fear-
icy research group. At a roundtable dis-
Now back to the 1,000 delegates from
that they were rolled by the U.N.'s 1987
mongers has been palpable. Eco-Field
cussion last December in California spon-
130 nations gathered in Berlin. It is esti-
mated that the U.N.'s agenda to limit
"Montreal protocol." Docilely succumbing
Marshall AI Gore early last year urged
sored by the Marshall and Claremont in-
lition of the
to the protocol's absurd claims that refrig-
television's Ted Koppel to investigate the
stitutes, Ms. Baliunas proceeded to demol-
emissions of greenhouse gases, if actually
$ dog-racing
erants containing chlorine were destroy-
dark forces behind the "anti-environmen-
ish both the "giobal warming" and "ozone
carried out, would cost several trillion dol-
is. Feral, the
ing the earth's protective ozone layer, they
tal" movement. The ploy backfired. Mr.
depletion" scare campaigns.
lars by the year 2100. Ms. Baliunas figures
passed a law banning the most widely used
Koppel reacted badly to this blatant at-
The science is as follows: With regard
it would soak up about one fourth of the
ised Friends
the dogs that
refrigerant, Freon. Freon manufacture
tempt to use him politically. One guest on
to global warming, atmospheric sampling
GNP of the U.S. on an annual basis. That
participants
must cease by the end of this year. Exist-
Mr. Koppel's "Nightline," Michael Oppen-
does indeed show that there has been a
would be expensive even for a Kevin
skies have a
ing supplies can be used until they run out.
heimer of the Environmental Defense
buildup of "greenhouse" gases, particu-
Costner production.
them much
tures of mi-
a residence.
re at no time
a sled. Ms.
ell to restrict
which they
:. Most of us
ave little re-
d by the spe-
side. In fact,
because of a
ich is politi-
Climate
lace will con-
IS who annu-
is they chal-
ents.
AN C. OWEN
Keeps
WB
THE WALL STREET JOURNAL MONDAY, APRIL 10, 1995 A1
res
Rio Summit Group
S Firm
Sets Date for Limits
cast
On Some Emissions
Joe cent article units but
By TIMOTHY NOAH
Staff Reporter of THE WALL STREET JOURNAL
EIRA
WASHINGTON - The U.S. and other
STREET JOURNAL
optimistic de M that be set by 1997
nc. tumbled 14%
signatories to an international treaty on
global warming agreed to set firm limits on
ing a company
emissions of carbon dioxide and other
samy
ost break-even
greenhouse gases by 1997.
Nauonal Financial Auto Funding Trust,
f of fiscal 1995,
Environmental groups expressed mild
optimism - and business groups some dis-
a subsidiary of
t income of $6.3
may - about the agreement, which came
are, in the half
Friday at a Berlin conference attended by
representatives of most of the 120 nations
Acton, Mass.,
that signed the United Nations global-
onth to expect
warming treaty at the 1992 Rio summit.
cents a share.
Environmentalists and many develop-
ons pushed the
ing countries had hoped the conference
NATIONAL
$7.50 in heavy
would produce specific international limits
it $7.875, down
on emissions. Although the goal wasn't
Auto Finance Company L.P.
achieved - partly because of opposition
Thursday that
from the U.S., which produces 20% of all
ng chain and
global carbon-dioxide emissions - the sig-
ere both hurt
natories did agree to establish greenhouse-
while sales of its
gas limits in 1997. Until now, the treaty has
The undersigned originated, structured and
cise equipment
had goals for reducing greenhouse gases,
tild winter.
but no legally binding limits.
has been engaged to place this transaction.
Whatever specific limits are set under
the 1997 protocol, they are likely to include
g NordicTrack
language allowing countries that have
ter, which ends
companies operating plants abroad, such
om a year ago,
as the U.S., to count in their greenhouse-
First Union Capital Markets Group
iate analyst for
gas-reduction tallies the lowering of emis-
now expects an
sions at overseas plants. The new Berlin
e added. CML
agreement sets up some guidelines for
such a system, known as "joint implemen-
ek's announce-
tation," but says overseas reductions may
wered his 1995
not be counted toward any country's tally
FUNTON
is a share from
of pre-2000 reductions.
vised his fiscal
Joint implementation is controversial
Capital Markets Group
I million from
with many Third World nations because it
lets developed countries avoid some of the
L shares have
This announcement appears as a matter of record only.
sacrifice involved in reducing global-
/sts repeatedly
greenhouse emissions. But Undersecre-
©1995 First Union Corporation
i. Some of the
tary of State Tim Wirth, who led the U.S.
the last four
delegation, hailed the new accord's joint-
mpany's work
implementation language as a major vic-
en disappoint-
tory for the U.S. and the global environ-
ment. "Joint implementation today is her-
esy. It will become the conventional wis-
K price levels,"
dom," he said.
d the share-re-
Under the Rio Treaty, nations said they
e company to
would aim to reduce greenhouse gases to
Heron Point Manor
e million.
1990 levels by the year 2000. In April 1993,
rs ago sold off
President Clinton pledged that the U.S.
lar businesses
would meet that goal. Subsequently, the
administration unveiled a plan to achieve
Myrtle Beach, S.C.
I the company
ar move.
it that relied heavily on voluntary agree-
ments with utilities. But although the
st week that it
Energy Department has forged many such
New Health Care facility. 24 hours security, surrounded
nority interest
agreements, administration officials now
Communica-
by three golf courses. Upscale facilities. Private pay health
concede that U.S. reductions aren't keep-
CML would put
ing up with President Clinton's promise.
services available at no expense to residents. Small in
id products in
Nonetheless, Vice President Gore has
size, not over 30 beds. For more amenities, brochure.
continued to express strong concern about
ve that it may
global warming and support for the treaty,
(803) 650-5632
othing chain.
and in speeches has urged that treaty
ritches will be
signatories reduce greenhouse gases be-
Administrator
is fiscal year
low 1990 levels, by an unspecified amount,
1.
after 2000.
WHY DEATH FAILS
The
THE NEW MARKETING?
Economist
FISCAL IRRESPONSIBILITY
pages 14 and 59
APRIL 1ST-7TH 1995
DEMOCRACIES AND WAR
pages 17-18
Stay cool about our
changing climate
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APRIL 1ST 1995
The
Economist
Stay cool
E
NVIRONMENTALISTS are dismayed.
life based on the present climate-against po-
Their efforts to scare the world over global
tential benefits, ie, the opportunities for
warming seem not to have worked. Three years
growth in places where the climate improves.
ago, in Rio, governments agreed to hold down
Few expect the benefits to carry the day, espe-
their output of "greenhouse" gases, such as car-
cially if the temperature rises quickly.
bon dioxide, that are thought to be raising the
Economists have, however, pointed out
earth's average temperature. But when this
that even substantial net costs can and should
week's Berlin conference (see page 33) asks
be tolerated if the alternatives are worse. Even
what progress has been made since Rio, the an-
a pessimistic prediction that climate change
swer will be: virtually none. Rich countries are
could knock 20% off world income in a hun-
unlikely to meet the Rio target of reducing out-
dred years' time would imply merely that the
put of greenhouse gases to 1990 levels by 2000.
world economy expands a little more slowly
Even if they do, growing emissions from coal-burning poor
than otherwise. To set this in perspective, consider another ex-
countries will more than offset their success. Few poor coun-
trapolation: the world economy could, if recent growth contin-
tries are even considering restraining their output of green-
ues, be over 300% bigger in 2095 than today-and so that much
house gases. And thus, say the greens, will a short-sighted world
better able to bear the costs of coping with climate change.
stroll insouciantly a; calamitous future of storms,
One of the few certainties about global warming is that the
floods and drought. Ils credits
costs of severely curbing emissions of greenhouse gases now
Well, maybe. It certainly be a pity if the world's gov-
would be huge. The world relies on carbon-based fuels for 90%
ernments retreated from the promises made at Rio, for that
of its energy needs. A quick, enforced switch to non-polluting
would bode ill for any attempts to deal collectively with global
alternatives would savagely cut people's living standards. In
environmental problems. Nonetheless, penguins and people
developing countries reliant on fossil-fuelled economic growth
can afford to relax for many years yet. For all the green clamour,
to lift them out of poverty, the pain would be acute. Why should
it is far too early to be panicked into Draconian actions to avert
people make such a sacrifice for a problem whose extent and
global warming; especially when most actions would pose a
cost are so uncertain? There are more pressing environmental
bigger threat to human wellbeing than does global warming.
concerns such as urban smog, the spread of disease and inade-
quate sanitation in poor countries. Unlike global warming,
Two clouds, and a hot prediction
these cause enormous suffering for millions of people now.
Consider, first, the uncertainty of scientists about the extent of
And it would cost less to alleviate or even eliminate them than
global warming. Despite recent advances (see pages 65-67),
to reduce sharply the world's output of greenhouse gases.
science still understands little about the world's climate, a sys-
This does not mean that world governments should do
tem that depends on a huge range of variables, with causation
nothing about the possibility, however remote, of climatic ca-
flowing in every direction. Most scientists agree that, provided
tastrophe. Many policies that would reduce greenhouse emis-
other variables remain the same, big increases in carbon diox-
sions are desirable on their own terms. For example, most state
ide will boost temperatures. But the extent of the boost is widely
subsidies for energy industries should be scrapped on grounds
disputed. And nobody can predict whether other variables will
of economic efficiency. That would lead to less coal being
remain the same. Some scientists reckon that rather than just
burned (the coal industry is often heavily subsidised) and to
growing gradually warmer, the climate may become subject to
higher electricity prices, encouraging conservation. Proper
sudden lurches. That makes it even harder for countries to pre-
road pricing should be introduced to reduce congestion in cit-
pare for climate change. The Intergovernmental Panel on Cli-
ies. Policies designed to deal with one environmental problem
mate Change, the body of scientists studying global warming,
may not necessarily help with others, however. Scrubbing sul-
reckons that a doubling of carbon in the atmosphere could lead
phur dioxide out of power-station emissions curtails acid rain,
to a temperature rise of anywhere between 1.5°C and 4.5°C.
but it may enhance warming; sulphur compounds in the atmo-
There is also much uncertainty about the costs of global
sphere cool the earth.
warming. Some areas of the world would benefit from a
Besides encouraging energy efficiency, governments
warmer climate. Cold wastelands, for example, might become
should also continue to finance research into the science of cli-
fertile farmland. Other areas would suffer. If global warming
mate change, and into how to reduce the costs of non-polluting
raised the sea level, valuable inhabited land (eg, in Bangladesh,
fuels. Such actions could pay dividends if more drastic mea-
the Nile delta and the Maldive Islands) would be submerged.
sures to counter global warming ever became necessary. Even
Estimates of the overall economic impact of global warming
the occasional jamboree such as Berlin's may be justified, so
depend on weighing these costs-the dislocations of ways of
long as it does not foster panic: the wheels of global co-opera-
11
THE ECONOMIST APRIL 1ST 1995
LEADERS
tion should be kept oiled in case climate change turns nasty.
as building higher sea walls) might still prove lower than the
Other than that, however, patience should be the watchword.
costs of prevention.
Within a couple of decades, scientists should have a firmer grip
Greens will no doubt continue to paint their scary pictures
on the influences on climate. By then the costs of altering the
of the future. What, they will ask, if climate change were to en-
world's economic structure are likely to be lower: although
tail a sudden lurch that led to half the world starving to death in
prices of most non-polluting fuels, such as solar power, are still
50 years' time? The best answer is that anything can happen in
higher than fossil fuels, the gap is narrowing. And if climate
half a century: even an invasion by aliens, say. On present evi-
change turned out to mean no more than a slow but steady rise
dence, though, any huge catastrophe looks highly improbable.
in temperatures, the costs of adapting as warming occurs (such
There is still time to bask in the sun.
Candidate Chirac
Has he changed enough to become the next president of France?
L' be president of France, is a master of tactics, timing and
IKE the sumo wrestlers he admires, Jacques Chirac, would-
his supporters, is these days a more mature, sober politician. To
his detractors, Mr Chirac is erratic and impulsive, a man who
deadly bursts of speed. Dismissed as a has-been, for months Mr
will jump at the first idea thrown at him.
Chirac trailed in the opinion polls. Now, with less than a
The great unanswerable question is whether such a com-
month to go before voting starts for the presidency, he has
pulsive tactician could make a good president. Yet Mr Chirac's
sprung back as the contender to beat. By presenting himself as a
policy zigzags over the years have been no worse than those of
man of deep experience yet with the common touch, he has
President Mitterrand. Since Mr Mitterrand's most spectacular
made the Socialist candidate, Lionel Jospin, seem merely dull
U-turn, in 1983, when he junked his reflation convictions for
and the prime minister, Edouard Balladur, look like a nose-in-
the austerity and stable-franc policiestha have prevailed since,
the-air bourgeois. Candidate Chirac is on the rebound. But
he has been a pillar of stability. The moral constraints of the
would he make a good president?
presidency-the incumbent is, after all, president of all of
One issue was bound to dominate the election: unemploy-
France, not just of one of its political factions-would restrict
ment, which has stuck at over 12% for more than a year (see page
his freedom to wobble.
42). Mr Chirac's solution is a radical expansion of employment
But President Chirac would also have the advantage of a
subsidies, sharp cuts in payroll taxes and increased spending
large centre-right majority in parliament. How might he use it?
on education and health. He cannot keep these promises,
He is not a radical in the modern British or American sense. He
while also reducing the public-sector deficit, as he says he will,
is a Radical in the historical French one-a man of the centre,
from 5.7% of GDP to below 3%, without increasing taxes
of toleration and modernisation. Although he has taken a
sharply. But Mr Chirac has promised to cut taxes. To the charge
tough line on immigration, more than most leading conserva-
of innumeracy can be added that of sogginess: he wants to give
tives he has kept his distance from Jean-Marie Le Pen's xeno-
still more protection to France's farmers.
phobic National Front. Sceptical about the sort of European
Mr Chirac's numbers may not add up, but nor do those of
political union favoured by some German conservatives, Mr
his opponents. Especially when it comes to the battle for the
Chirac nonetheless campaigned for the Maastricht treaty in the
presidency, the French take politicians' promises for what they
1992 referendum, though many of his allies opposed it.
mostly are-hot air-and concentrate instead on the personal
qualities of the candidates.
Stand up, and be counted
Mr Chirac's claim to be a man of experience is borne out by
Mr Chirac is far from a shoo-in for president (if only because
his record of office. He first became a minister almost 30 years
many voters have yet to make up their minds). Yet his constant
ago. He was prime minister twice, in 1974-76 and then in 1986-
campaign theme-France's need to "break with the past"-has
88 (though without notable success). He has been an effective
touched a chord among the electorate. France faces big chal-
and admired mayor of Paris for almost 20 years. Though he has
lenges. At home, the welfare state, the social-security system
tried twice before for the presidency, in 1981 and 1988, and lost,
and the public-health and education systems are all in urgent
this is now presented as necessary preparation: like François
need of reform. Meanwhile Germany, the country against
Mitterrand, and De Gaulle before that, Mr Chirac has endured
which France measures itself, has grown larger and more pow-
a long "crossing of the desert" in mid-career.
erful. The relationship with Germany needs to be recali-
His famous resilience, however, is not matched by consis-
brated-a tough task at the best of times, but one that will be-
tency. Once known as a nationalist Eurosceptic, a point he was
come trickier still if European monetary union turns out to
happy to highlight last year when he thought Jacques Delors
have the political consequences that many French politicans,
would bid for the presidency, Mr Chirac now presents himself
including Mr Chirac, hope to avoid.
as a good European and a supporter of a single currency. Once
This is the first opportunity French voters have had to
a right-wing budget-slasher who abolished the wealth tax in
choose a president to meet these new challenges. Mr Chirac's
1986 (and before that a proponent of trade unions and workers'
bid to be that president seems a strong one-always assuming
rights), he has reinvented himself once again, this time as a one-
that the real Jacques Chirac has finally stood up.
nation Gaullist with a social conscience. The real Chirac, say
12
THE ECONOMIST APRIL IST 1995
INTERNATIONAL
and Germany, will probably do so by acci-
Global warming and
dent. Unification has killed off antique
coal-burning industries in eastern Ger-
cooling enthusiasm
many. Britain has shut most of its coal
mines to save taxpayers' money, not the
world's environment.
BERLIN
Unable to keep their promises, rich
countries have reacted in three ways. First,
H
AS the great global-warming bubble
they have squabbled over definitions. For
burst? The 1992 "Earth summit" in
Hot air
example, should countries be allowed to
Rio, at which the world committed itself to
meet their targets by, say, planting forests,
avoid the threat that is said to overhang it,
which would absorb carbon dioxide? The
was conducted in a spirit of zeal. The globe
United States, with plenty of space to do it
had just experienced some of the warmest
in, says yes. So does New Zealand. More
years on record. In many countries voters
crowded countries disagree. Some countries
were flush with green idealism. Politicians
have adjusted their targets, arguing that
made eager promises about curbing green-
1990 was an unusual year. Others want to
house gases. This week, as politicians, bu-
exclude emissions from certain sources, for
reaucrats and the ever-growing fringe of
instance aircraft fuel.
non-governmental organisations gathered
Second, many rich countries have
in Berlin for the second summit on climate
pushed the idea of "joint implementation".
change, reality sent a chill breeze through
This would allow them to pay for emission-
their deliberations.
reducing projects in poor countries-pollu-
Talks on the global climate are now vis-
tion control or indeed tree-planting, say-
cous with regional politics and national
and then to count the reductions against
self-interest. For all its output of warm guff,
bilising emissions, the omens are poor. Vot-
their own targets. This would save them
the conference was expected, at best, to thaw
ers are more concerned about jobs than the
money: the marginal cost of reducing emis-
out only a few of the problems. Too much is
environment. So governments have taken
sions in poor countries is low. But many-
at stake, and quite different things for differ-
few costly measures. America, Canada, and
not all-poor countries oppose the idea, ar-
ent countries. Broadly, these:
the European Union (EU) admit that, on
guing that would merely allow rich coun-
Small island states. The threat of global
current trends, they will not reach their
tries to avoid tough action at home.
warming terrifies a group of 30 Caribbean,
targets.
Third, and most important, rich coun-
Indian Ocean and Pacific islands. They fear
At Rio, the EU was the world's most
tries have begun to ask why they should
it would lead to a rising sea level that would
forceful advocate of strong targets. Since
make any effort against global warming
flood low-lying areas, and might over-
then sundry proposed EU policies to reduce
when poor ones have committed them-
whelm some of them, such as the Maldives,
emissions-a carbon tax, for instance-have
selves to nothing. Indeed, by 2010, carbon-
altogether. This group wants the rich coun-
been pigeon-holed. Those EU countries
dioxide emissions from developing coun-
tries to promise to reduce their carbon-diox-
likely to meet their targets, such as Britain
tries will probably be more than the rich
ide emissions by at least 20% from
world's output. Fifty years hence,
1990 levels by 2005. Fat chance.
coal-burning by economic giants
The rich countries promised at
such as China and India could
Rio to stabilise at the 1990 level by
make today's rich world emis-
2000. Most are unlikely to achieve
sions look insignificant.
even that.
Poor countries. The mere sug-
OPEC. This is the group most
gestion that the third world
vehemently opposed to action on
should make any commitments is
climate change. The economies of
a "diplomatic dead end", says
many OPEC countries have al-
one green activist. It argues that
ready been badly hit by low oil
the rich have contributed most to
prices. If their industrialised cus-
greenhouse-gas emissions so far,
tomers commit themselves to fur-
and should therefore suffer the
ther reductions in greenhouse-gas
most pain. "We take global warm-
emissions, demand for oil and gas
ing seriously", says one Asian dip-
will fall. Green groups suspect that
lomat. "But we are disillusioned
Saudi Arabia ratified the Rio
by the way it is being handled by
treaty only in order to disrupt ne-
the developed world."
gotiations. "Whatever's on the ta-
However, the poor can smell
ble, they say no," says one
money in the climate-change ne-
diplomat.
gotiations. If the rich world wants
Rich countries. Although indus-
them to reduce emissions, they ar-
trialised countries still have five
gue, let it both pay the cost and
years left to meet their target of sta-
provide them with non-polluting
THE ONOMIST APRIL 1ST 1995
33
INTERNATIONAL
technologies. "We are talking about a huge,
ernment and fellow African National Con-
a victory that guaranteed her a seat in parlia-
huge transfer of resources," says one Latin
gress (ANC) members of being less con-
ment and a post in the future elected gov-
American climate-negotiator. Really? The
cerned to assuage black grievances than
ernment.
rich are not. Few are ready to supply new
white anxieties. She attacked their eagerness
Can she now stage another spectacular
technologies for free. And the Global Envi-
to make a deal with the white establishment
recovery and re-emerge as a serious con-
ronment Fund-the body which distributes
and to "sleep between silk sheets". She her-
tender for the presidency after Mr Mandela,
money to poor countries-has so far re-
self, her critics remark, indulges a taste for
who is now 76, is gone? Some think so. Yet
ceived pledges of only around $2 billion for
fine clothes and expensive cars. But that
her main potential is probably as a backer-
1994-97; enough, maybe, to pay for the poor
does not seem to diminish her popularity
or wrecker-not a candidate. For there is a
to find out what they are emitting anyway.
with the black electorate. And now she can
new, perhaps decisive, factor in the calcula-
Some poor countries see "joint imple-
freely make her populist rhetoric the focus
tion. In the past, Mr Mandela has either
mentation" as a way to draw in rich-world
of a campaign.
stood by his wife (during the crisis over the
investment. Chile, Costa Rica and Pakistan
At the ANC'S national conference in De-
kidnapping) or remained publicly neutral
have all signed agreements with the United
cember, she came fifth in the vote for the ex-
(after their separation). Now he has dis-
States. Others are playing hard to get. An
ecutive, after the election of key office hold-
owned her politically. She cannot claim
Asian diplomat reckons that his country
ers including Mr Mandela himself and his
that her only critics are the "cabal".
will earn a higher price for this sort of pro-
deputy-in the party as in the nation-
The ANC and its allies-the Communist
ject if it delays agreement until 1999. By that
Thabo Mbeki. Other populists too did well.
Party, the Congress of South African Trade
time, he reasons, rich countries will be des-
Bantu Holomisa, formerly military ruler of
Unions and the South African National
perate for ways to fulfil their Rio targets. Pos-
Transkei, topped the poll; Peter Mokaba,
Civic Organisation-have rallied around
sibly; but in collaboration with whom?
past president of the ANC Youth League,
Mr Mandela, promising "unequivocal sup-
Those whose claim to take a threat seriously
came third; Harry Gwala, a fiery Stalinist
port". Even the ANC Women's League has
does not include doing anything about it?
from Natal, ninth. If the populists hold to-
acknowledged his right to dismiss his es-
gether, they could create grave difficulties
tranged wife. With these forces against her,
for the present ANC leadership.
Mrs Mandela may find her position in par-
South Africa
Mrs Mandela has always been a fighter,
liament threatened if she persistently chal-
against white rule in the past, recently
lenges the ANC leadership. Members are
Fighting Winnie
against her foes-the "cabal" as she labels
elected from a party list. If the leadership
them-within the ANC. By late 1992 she ap-
dislikes them, down or off the list they go.
peared to have lost. She had been found
Meanwhile the police are looking into
JOHANNESBURG
guilty in 1991 of involvement in the kidnap-
allegations that Mrs Mandela used her cabi-
I
S SHE finished? Or on the way to the top?
ping of a black youth later murdered by one
net job to aid a building company, in return
Winnie Mandela certainly felt her dis-
of her bodyguards. Mr Mandela in April
for kickbacks. A Supreme Court judge last
missal from the cabinet on March 27th as a
1992 announced that he and his wife were to
week ruled that the search warrant used by
personal blow. But the loss of her post as
separate. She resigned as head of the ANC
policemen when they raided her house was
deputy minister of culture, science and tech-
social-welfare department and, in Septem-
invalid, but the investigation continues.
nology, for defying President Nelson
ber 1992 was pushed from all her ANC posi-
So she looks an unlikely successor to Mr
Mandela and criticising the government of
tions, after the publication of a love letter re-
Mandela. But she could certainly help or
which she was part, does not end her long
portedly written to her by her dashing
hinder likelier hopefuls. The front-runner
political career. It may help her.
young number two in the department. Yet
today is Mr Mbeki. He rose with the backing
In her nine months of office, Mrs
by December 1993 she was back, elected to
of the populists. Will they now turn against
Mandela more than once accused the gov-
the presidency of the ANC Women's League,
him, for his role as Mr Mandela's trouble-
shooter in the run-up to Mrs Mandela's dis-
missal? If so, the balance could tip toward
the ANC secretary-general, Cyril Rama-
phosa, for all that Mrs Mandela used to call
him a member of the cabal.
Rwandan refugees
Crime and
nourishment
GOMA, ZAIRE
T
HE Mugunga camp in Goma, near to
the border with Rwanda, supposedly is
a refuge for people, nearly all of them Hutus,
who fled that country last summer and dare
not go home, now that it is run by Tutsis. In
reality, the camp looks more like a military
training ground. Soldiers from the army of
Rwanda's former Hutu government loll
about in full uniform. Militiamen wave
axes menacingly at white-skinned foreign-
Never underestimate her
ers. Weapons are hidden close by and vehi-
34
THE ECONOMIST APRIL 1ST 1995
MEMORANDUM
COUNCIL OF ECONOMIC ADVISERS
Lisa June 9, 1995 M file
Talkings
TO:
LAURA TYSON
FROM:
MARK MAZUR work
SUBJECT: ADDITIONAL TALKING POINTS ON DIFFERENCES BETWEEN OMB AND
CBO MEDICARE AND MEDICAID BASELINE ESTIMATES
Joe Stiglitz suggested that I add a couple items to the talking
points attached. I gave you earlier today. These additional points are
Please let me know if you have any questions.
CC: JES, MB, MJolin, TO'D,
Medicare
Annual growth rates for Medicare expenditures have exhibited a
lot of variability. For example, from 1981-1995, annual growth
rates range from 4.8 percent (in 1988) to 22.3 percent (in 1981).
The median growth rate over the past nine years is 7.5 percent,
considerably less than either the CBO or OMB forecasts.
Medicaid
The high growth rates for Medicaid expenditures during the early
1990s (e.g., 27 percent in 1991 and 29 percent in 1992) reflect two
features that are not likely to be repeated. First, the number of
Medicaid recipients increased due to eligibility expansions and the
last recession (there was a 4.7 million increase from 1989-91).
Second, States attempted to take advantage of the Medicaid program
through aggressive use of "voluntary" donations that were matched
by Federal funds. Neither of these is likely to be repeated in the
foreseeable future. Therefore, OMB is confident that the rate of
Medicaid growth will be limited by increases in underlying costs of
providing medical services and beneficiary growth.
Medical CPI
Related to the medical CPI issue -- Data for the first four
months show a further decline in the rate of increase in medical
care prices, from 4.9 percent in 1994 to a 3.6 percent annual rate
for January through April 1995.
RIMENT OF
Department of Energy
STATES AMERICA
Washington, DC 20585
OF
JUN 0 I 1985.
Joseph Stiglitz
Member
Council of Economic Advisors
Room 314
Old Executive Office Building
17th St. & Pennsylvania Ave., NW
Washington, DC 20503
Dear Mr. Stiglitz,
Please find the attached April and May 1995 testimonies from Tom Grumbly,
Assistant Secretary for Environmental Management at the U.S. Department of
Energy. If you have any questions, please contact me at 202-586-4253.
Sincerely,
Stephanie for K Bennett
Dave Simon
Program Coordinator
Environmental Management
Printed with soy ink on recycled paper
STATEMENT OF
THOMAS P. GRUMBLY
ASSISTANT SECRETARY for ENVIRONMENTAL MANAGEMENT
DEPARTMENT of ENERGY
before the
SUBCOMMITTEE on SUPERFUND, WASTE CONTROL, and RISK ASSESSMENT
of the
COMMITTEE on ENVIRONMENT AND PUBLIC WORKS
UNITED STATES SENATE
MAY 9, 1995
Mr. Chairman and Members of the Committee, I appreciate this opportunity to
appear before you today to discuss the Superfund program and how it affects
the Department of Energy's Environmental Management program. In its current
form, Superfund has flaws that lead to unnecessarily high costs and long time
frames for cleanups. Since Superfund plays a large role in the Department's
environmental programs, current shortcomings of the law will impede our
ability to achieve the cost savings and productivity increases we have set.
Today I will briefly describe the Environmental Management program, the
progress we have made, the substantial business changes we are implementing,
and our budget outlook. Then I will explain how implementing certain changes
to the Comprehensive Environmental Response, Compensation, and Liability Act -
- or Superfund law -- can help reduce the costs and improve the effectiveness
of this program.
THE ENVIRONMENTAL MANAGEMENT PROGRAM
The Department of Energy's Environmental Management program was created in
late 1989 to manage the legacy of 50 years of nuclear weapons production and
research at over 130 sites and facilities in over 30 states and territories.
The scope of our activities -- the world's largest environmental stewardship
program -- involves far more than just "cleanup of contaminated land." The
Environmental Management program handles some of the highest risk
environmental, health, safety, and nuclear nonproliferation problems in the
world, such as unstable plutonium and potentially explosive underground
radioactive waste tanks. In addition, we have inherited an enormous backlog
1
of nuclear waste and contaminated facilities that do not necessarily present
immediate risks, but require funding to stabilize and even more funding for
ultimate disposition. All of these risks -- urgent as well as long-term --
are part of the Government's obligation to deal with the legacy of the Cold
War.
The task ahead remains formidable, and yet presents many opportunities for
improving upon how we, as a Nation, respond to the challenges of remediating
the environmental legacy of almost five decades of nuclear weapons production.
The Department favors the use of sound science in the conduct of risk
assessments, the use of risk assessments and appropriate consideration of
cleanup costs for decision-making, and the consideration of risk to human
health and the environment in establishing priorities for its Environmental
Management program. While the full nature and extent of contamination at the
sites may not be fully known for many years, we are taking some tangible steps
now to identify and mitigate the environmental and health risks associated
with exposures to these dangerous materials.
PROGRESS AND CHANGES IN THE WAY WE DO BUSINESS
I would now like to highlight some of the Environmental Management program's
accomplishments. These results not only demonstrate significant progress, but
also reflect a new way of doing business by addressing urgent risks first
while simultaneously controlling the long-term contamination and other hazards
present at our sites. For example, recently we have addressed urgent risks in
the following areas:
At the Rocky Flats site in Colorado, we completed safety improvements to
a building and began to stabilize inventories of pyrophoric plutonium
2
contained inside it. This material poses a fire hazard since, under
certain conditions, plutonium ignites in air;
Safely transferred 303 spent nuclear fuel elements to safer storage
facilities in Idaho over the past 18 months; and
Returned 153 spent nuclear fuel elements containing weapons-grade
uranium of United States origin from foreign research reactors.
Accepting these fuel elements helps support the Nation's nuclear
nonproliferation policy because they contain weapons-usable highly-
enriched uranium.
Since 1989, we have also achieved cumulative results that begin to reduce the
backlog of accumulated waste and long-term contamination problems across the
country:
Decommissioned approximately 100 facilities across the complex;
Cleaned up 18 former nuclear weapons and industrial sites and 14 sites
associated with uranium mining and milling; and
Treated 2.4 billion gallons of ground water and 1.8 billion gallons of
surface water.
Despite these results, we know we can do more. We are in the midst of broad
new initiatives across the Department's complex that will change the
fundamental methods for accomplishing our environmental mission. We are
changing the way business historically has been done at the Department by
introducing proven economic and business techniques such as recompeting con-
tracts at our sites to provide new incentives for performance. We are also
reducing our contractor workforce to eliminate unnecessary layers of workers
while retaining the right people with the right skills for our environmental
mission, and hiring experienced cost estimators and project managers to
increase the efficiency of ongoing work. These initiatives are just beginning
to be implemented, but already they have demonstrated impressive savings --
over $2 billion in savings are anticipated from FY 1994 through FY 1996.
3
CONTRIBUTING TO DEFICIT REDUCTION
The Environmental Management program is playing a significant role in
contributing to a leaner federal government and deficit reduction as part of
the President's proposed FY 1996 budget. The entire Departmental budget is
being reduced by $10.4 billion over the next five years. The Environmental
Management program budget request will account for a large portion of this
reduction. For fiscal years 1997 through 2000, our request is being reduced
by $4.4 billion in outlays, which translates into a $5.5 billion reduction in
requested budget authority over the same period based on earlier
Administration plans. I believe these are very aggressive, but ultimately
achievable reductions.
Our program will continue to be driven by a results-oriented, risk-based
approach that seeks to address the most urgent public health and safety
problems first. However, after this fiscal year, even with the continued
productivity savings that are expected, there will be a gap between available
resources and requirements in the future. In order to continue to meet our
legal obligations, we will need to address these outyear challenges with new
analytical tools, pursue renegotiation of some of our compliance agreements,
and statutory changes. Superfund is one statute that presents opportunities
for change that will help the Environmental Management program better achieve
its goals at less cost.
FUNDAMENTAL PROBLEMS
In the past I have discussed how the Department was fundamentally reevaluating
how we go about the process of "cleanup" at our facilities. I have stated
that our reassessment was based upon the lessons learned by the Environmental
4
Management program over the past five years, as well as the lessons learned
from the Superfund Program. We have found that:
(1) we do not have adequate technologies to fully remedy many
contamination problems -- and the investigation technologies,
while more developed, are inherently experimental and often run
into unexpected problems;
(2) there are inadequate data available to fully characterize human
and environmental risks associated with contaminant exposures;
(3) few consensus standards exist for determining "how clean is clean"
at Superfund sites; and,
(4) the number of sites to be remediated exceeds the resources
expected to be available.
The nation has learned a great deal about dealing with the problems of old
waste sites since Superfund was enacted in 1980. When the law was first
passed, news of "orphaned" waste sites were prominently featured in the news
media. Public anxiety about the problem increased with each new discovery.
The government lacked adequate authority to take timely action or the hold
responsible parties liable for the cleanup costs. In the wake of Superfund's
enactment, the Environmental Protection Agency worked to create a substantial
response and enforcement capability. The time has long passed, however, when
the initial response to the problem is adequate to deal with the problem cost-
effectively.
PROGRAMMATIC PROBLEMS WITH SUPERFUND
Despite accomplishments at federal and private sector sites, Superfund's
weaknesses have been recognized by virtually all stakeholders, and they
threaten to undermine the efficacy of the statute. The Superfund program has
been criticized for:
5
Poor value for the money: Superfund is widely criticized for costing
too much and delivering too little, and for imposing high costs while
not delivering enough in the way of measurable public health benefits.
Inconsistent and inadequate cleanups: The statute currently does not
specify standard levels of cleanup nationwide; instead, it establishes a
complex cleanup framework under which applicable or relevant and
appropriate state and federal standards are used to set cleanup levels.
Consequently, cleanup goals, remedies, and costs across the country are
inconsistent. This inconsistency contributes to uncertainty, protracted
site-by-site evaluations, debate over cleanup goals, and higher than
necessary cleanup costs.
Overlapping Federal/State relationship: The federal government has
primary responsibility for implementing the Superfund Program, and it
has exclusive access to the money in the Superfund. States, however,
play a significant role in the program's implementation. State
standards apply to all cleanups, and states must pay a share of cleanup
costs at non-federal facilities. In addition, States have significant
input in selecting and carrying out cleanup remedies. Due to this
overlapping authority and responsibility, federal and state governments
often disagree over the degree to which sites should be cleaned up, the
remedy to be used, and the allocation of costs. These disagreements
contribute to the costs and duration of cleanups, and can result in
confusion among stakeholders.
Inadequate community involvement: Many communities near Superfund
sites, including low-income, minority, and Native American communities,
are not provided with the opportunity to participate fully in the
Superfund process. These and other communities believe that the program
does not address local circumstances adequately when evaluating the risk
or determining the method and level of cleanup. Consequently,
communities may conclude that the resulting cleanup is either overly
conservative or insufficiently protective.
Other criticisms have been made of Superfund such as liability provisions that
create economic disincentives to purchase land and/or provide financing for
doing so, among others. These other criticisms may be valid, but do not
affect the Environmental Management program directly.
CHANGING SUPERFUND TO MAKE IT WORK BETTER AND COST LESS
Reforms to Superfund are needed to remedy the weaknesses contained in the
6
current law. Many of these reforms were raised in my testimony before your
Committee last year. These reforms will substantially increase the efficiency
and effectiveness of the Environmental Management program's cleanups, while
protecting human health and the environment. I will address four key reforms
that are especially needed by the Environmental Management program:
Clear, universally applicable cleanup standards
Future land use/remedy selection
Community involvement
Innovative technology
CLEAR STANDARDS FOR REMEDIATION
One serious problem with the current law is that it does not provide a clear
standard for acceptable cleanup or specify what level of risk can remain at a
site after it is cleaned up. This can lead to sites being remediated to
levels far greater than what might be required given the likely future use of
the area and to confusion about what is an appropriate remedial technique for
a particular site. Ultimately, these problems lead to higher costs than are
necessary.
Through rulemaking, several steps could help remedy this flaw in the Superfund
law. First, national goals for the protection of human health and the
environment should be applied to all sites covered by the law. Second,
generic cleanup standards should be developed for the specific hazardous
substances, pollutants, and contaminants most commonly found at these sites.
Third, efforts to define cost-effective, generic remedies for the different
types of sites, and establish procedures for selecting a remedy at a
particular site should be continued. Fourth, as discussed later, a plan to
7
more strongly encourage the use of innovative technologies for remediation
which hold the promise for more effective and less costly cleanup should be
put in place.
During the 103rd Congress, a consensus bill was developed that addressed a
number of the problems discussed above. The most important of these involves
the appropriate standards for the cleanup of radionuclides. Due to the unique
properties of radionuclides, it may not be possible or feasible to detect
specific radionuclides or to distinguish them from natural background at very
low concentration levels; in addition there is a lack of cost effective
technology for the cleanup of many radionuclides. To account for the
potentially huge costs these technical problems with radionuclides pose for
the Department, it is essential that the reformed remedy selection process
address these issues. One option incorporated into the Senate Superfund bill
in the 103rd Congress is to require the establishment of separate residual
risk levels for specific radionuclides. In addition, Superfund reform should
expressly clarify that cleanups under Superfund should not be required to
achieve risk levels that are less than that of the background level of the
contaminant.
FUTURE LAND USE / REMEDY SELECTION
A closely related problem is that Superfund currently does not require that
the projected future use of a site be considered when making decisions about a
cleanup strategy (this affects both cleanup standards and remedy selection).
Anticipated future land use at a site needs to be fully considered when
8
selecting a cleanup remedy for the site. Clearly, this issue affects not only
Federal agencies, but state, local and tribal governments, and the public.
The current situation is difficult. In some cases, no clear decisions have
been made on future land use. This lack of a decision about future land use
can lead to a "default" choice of remediating the site to levels suitable for
immediate unrestricted use. This situation tends to establish default cleanup
levels that are technologically or economically infeasible in the near term
and therefore hampers the progress of cleanup. It is possible that land where
some degree of "cleanup" has occurred may be deemed unavailable.
The current law's preference for treatment/permanence should be narrowed and
replaced with the concept of long-term reliability and a preference for the
treatment of "hot spots."
The effect of these proposed changes will improve the remedy selection process
so that cleanups will occur faster and cost less. It will also assure that
all communities receive the same protection from potential health hazards
associated with our 23 NPL sites and also with our non-NPL sites.
In addition to the changes mentioned above, the use of sound risk assessments
based on land use decisions are needed. The Clinton Administration recognized
early on the importance of applying sound risk analysis procedures to
regulatory decision-making. An interagency regulatory work group has
established a set of risk principles to guide decision makers in the areas of
9
risk assessment, risk management, risk communication and priority-setting.
The Department of Energy has adopted these principles, which were modified to
apply more specifically to the Department's programs and processes. The
Environmental Management program was the chief driver behind the Department's
efforts in this area. These risk principles could serve as a model for
constructing an effective risk assessment mechanism in the Superfund process.
The idea of using land use decisions as a sound basis for remedy selection and
cleanup levels is not an abstraction. The Department recently released the
Baseline Environmental Management Report (BEMR), which showed that more
stringent cleanup standards without full consideration of reasonable land use
will equate to greater cleanup and greater costs. In fact, future land use of
our sites was found to be the single most significant driver of the cost of
the program. The report, which analyzes life-cycle costs based on several
different sets of assumptions, estimates a range from approximately $175
billion -- if we do nothing more than merely stabilize sites within "iron
fences" -- to as high as $500 billion for returning our sites to so-called
modified "green field" conditions over the next 70 years, depending on the
level of cleanup assumed. During development of the BEMR, we discovered that
project managers and state and Federal regulators have already been taking
future land use into consideration in planning and selecting remedies.
Legislative changes are needed to facilitate greater consideration of future
land use in our decisions.
We are committed to making land-use planning a key element in our cleanup
strategy. Without specific statutory authority, we are doing as much as we
can to consider future land use under current authority. In mid-1993, I
10
established a Future Land Use Working Group to develop an integrated approach
to the land-use issue. The Working Group pooled the efforts of numerous
Department organizations, national laboratories, contractors, universities and
independent groups to focus on a single goal to develop and document a
framework for Department sites to develop stakeholder-preferred future use
options that would feed into the planning and decision-making activities of
all Department organizations.
More than ten meetings and workshops were held throughout the country with a
total participation in excess of 500 people. This effort produced a guidance
document for site managers on how to identify future use options --
establishing Department roles, responsibilities and commitments, establishing
a site-specific process, identifying the stakeholders and engaging in public
participation, compiling adequate data and information, evaluating various
options, and having this process feed into overall planning and decision-
making process for the site.
In addition to the Environmental Management program's efforts, Secretary Hazel
'Leary created the Department's Land Use Initiative to promote effective
stewardship of the Department's land, facilities, and other assets. As part
of that initiative, the Department issued the Land and Facility Use Policy to
augment the original Future Use initiative by requiring sites, with
significant public participation, to develop comprehensive plans that
integrate mission, economic, ecologic, social, and cultural factors. Many
sites are currently well under way with efforts aimed at satisfying this
directive.
11
COMMUNITY INVOLVEMENT
Substantive community involvement in the Superfund process should be
formalized to ensure stakeholder involvement in our site remediation decision-
making. Under the Administration's proposal last year, communities would be
involved in all phases of the cleanup process including the establishment of,
and consultation with, community workgroups throughout the remedy selection
and cleanup process. It is envisioned that these same community workgroups
would also function as an information clearinghouse for the community --
informing the public of current and future site restoration activities being
undertaken by the Department and its contractors.
The need for this provision in the Superfund law is clear. We have recognized
that fifty years of secrecy related to nuclear weapons operations has
contributed not only to widespread environmental safety and health problems,
but also to a widespread distrust of the Department. We have learned that
building trust is essential to the success of the Environmental Management
program -- for negotiating agreements, obtaining permits, achieving consensus
on risks and in defining the future use of the sites.
To support this effort, I have established an Office of Public Accountability
in the Environmental Management program. This office is responsible for
ensuring that all Environmental Management offices conduct substantive,
cooperative planning with all our stakeholders in the development and
implementation of budgets and policies. Approximately 25 percent of our
personnel in the field have received training on public participation, and in
a short time, this office has taken major strides to actively involve the
public in meaningful ways:
12
We are following the recommendations of the "Keystone Committee," by
involving stakeholders in key decisions and establishing site-specific
advisory boards (SSABs) at our major sites. We currently have nine
SSABs in place and expect two additional boards to form within the next
six months.
Through the State and Tribal Working Group (STWG), the Department
provides. a forum for six tribes and 17 states to share their concerns
and provide valuable perspectives on the effectiveness of our programs.
The Environmental Management Advisory Board (EMAB) involves
representatives from labor, the U.S. Environmental Protection Agency,
tribes, states and citizen groups in a variety of issues facing the
Environmental Management program.
We are also committed, in accordance with the new Executive Order on
environmental justice, to working with those individuals and groups who
have been and continue to be disenfranchised around our sites. We are
broadening our commitments, for example, in terms of grants to the
Native American communities around our sites, and are working to ensure
that the Indian Nations are responsibly included in all of our
negotiations with regulatory authorities.
These efforts have made a difference. These steps have allowed us to work
more cooperatively, effectively, and efficiently at our sites. In fact, a
recent survey of Department of Energy stakeholders shows that the trust and
confidence levels with respect to the Department have risen by five percentage
points since 1992. This survey was conducted by Washington State University
in the fall of 1994, and the results were released this spring. Some 300
stakeholders were selected randomly from a compilation of Departmental
stakeholder lists, including an update of the Stakeholder Group list used in
1992 for the earlier survey. But we still have work to do. There are more
opportunities for meaningful public involvement.
Superfund should be reformed to incorporate community involvement earlier in
the remedy selection process. We have often been criticized for not
adequately addressing local circumstances when we evaluate the risks
associated with a site or determining the method or level of cleanup. For too
13
long, community groups have felt shut out of the process of site remediation
decisionmaking, discussions of future land use options, and the risk
evaluation process. Community involvement should be an integral part of the
remedy selection process that will, in the long run, make the risk assessment
and management process more open, and more democratic.
INNOVATIVE TECHNOLOGY
The current Superfund cleanup remedy selection process often favors the
application of existing, proven, technologies over consideration of promising
innovative technologies that could reduce costs and increase effectiveness and
potentially lower treatment costs. Incentives are needed to encourage the
development and use of innovative technologies. We believe that the statute
should be amended to allow the deferral of the remedy selection for remedial
action(s) under certain conditions:
An innovative treatment remedy is likely to become available within a
reasonable period of time;
The hazard can be adequately contained during the deferral period; and
The interim containment includes adequate monitoring to ensure the
integrity of the containment system during the deferral period.
For private sector cleanups, EPA should be required to share technology risks
by approving the use of innovative technologies, and, if the technology fails,
contributing a percentage of the cost of any additional remediation required.
The Department estimates that it could derive dramatic savings in ultimate
cleanup costs if remediation deferrals were allowed through the year 2005 for
the development of innovative cleanup technologies. Our Technology
Development program has already saved over $115 million by using new or
improved environmental technologies, and now that the program is focussed on
14
our most urgent programmatic needs, future savings will likely surpass this
significantly.
As you know, we have begun to implement a strategy that identifies and
develops technologies that can clean up the nuclear weapons complex, and
manage our wastes more safely, quickly, and at lower costs. In many cases,
developing new technologies presents the best hope for ensuring a real
reduction in risk to the environment and improved worker and public safety,
especially given the fiscal constraints of our Nation's economy.
In support of the Department's commitment to the effectiveness of all its
programs, I have implemented a new approach to managing the Department's
environmental research and technology development program that is focused on
overcoming major obstacles to progress in cleaning up the sites and that
involves the best talent in the Department and the national science
communities.
Key features of this new approach include teaming up with the Department's
waste management and environmental restoration programs to: (1) identify,
develop and implement needed technology; (2) focus technology development
activities on major environmental problems; (3) ensure the coordinated
management of all scientific and development activities in support of the
Environmental Management program; (4) focus all available resources in the
national laboratories more effectively; (5) involve industry in developing and
implementing solutions including both technology transfer into the Department
and technology transfer from the Department to the private sector; (6)
strengthen basic research by involving academia and other research
organizations to stimulate technological breakthroughs; (7) enhance mechanisms
15
for regulator and stakeholder involvement; and, (8) enhance mechanisms for
implementing technology development results.
We are involved in a number of efforts to develop these new technologies.
First, of course, are the numerous efforts underway at the national
laboratories. These institutions have some of the best technical talent and
facilities in the world: they are now available for conversion from their
previous defense mission. Second, we are serving on a Federal Advisory
Committee to Develop On-Site Innovative Technologies (DOIT) with several
western state governors, senior representatives from the Departments of
Defense and Interior, the Environmental Protection Agency, and ex-officio
members of the Western Governors Association and the Office of Management and
Budget. Third, we intend to develop positive incentives to encourage the use
of innovative technologies at each site.
CONCLUSION
The future course, length, and cost of the Environmental Management program
will depend on a number of fundamental technical and policy choices, many of
which have not yet been made. Ultimately, these decisions will be made on the
basis of fulfilling Congressional mandates, regulatory direction, and adequate
stakeholder input.
Part of the process of making these national decisions involves re-evaluating
the statutory regime in which we operate our environmental programs. The
Environmental Management program conducts activities under many federal
environmental laws. Superfund has substantial impact on our program. Thus,
implementing needed changes to correct the problems with the Superfund law can
16
greatly improve the efficiency and success of our projects, as well as
reducing the costs associated with cleanups.
The proposals I have outlined, which address standardized cleanup levels,
future land use planning/remedy selection, community involvement, and
technology innovation, can go a long way in making the Environmental
Management program less costly and more productive.
There is much that the Department can do on its own to increase efficiency and
cut the costs of doing business. But we cannot get to where we need to be
without a team effort with regulators and Congress to address the systemic
roots of our problems. Furthermore, these problems need to be addressed
quickly. The necessary legislative changes are needed this year in order for
the Department to be able to meet its legal commitments and effectively pro-
tect public health and safety given our declining resources.
In closing, I would like to make clear that we would like to work with this
Committee to find common ground so that we can move ahead and cooperatively
address the problems the Department and the Nation, face.
Mr. Chairman, thank you for this opportunity to address this Committee on some
changes we would like to see in any Superfund reform legislation and the
effect(s) such reforms would have on the Environmental Management Program. I
would be happy to answer any questions you might have at this time.
17
Statement of Thomas P. Grumbly
Assistant Secretary for
Environmental Management
U.S. Department of Energy
before
the Committee on Armed Services
U.S. Senate
April 25, 1995
Mr. Chairman, and Members of the Committee, I appreciate this opportunity to
appear before you to discuss the Department of Energy's Fiscal Year 1996
budget request for the Department of Energy's Environmental Management (EM)
program. This program manages the human health and safety and environmental
contamination consequences of the nation's fifty year nuclear weapons
research, production, and testing program.
In my testimony, I will:
Begin with some background of the Environmental Management program and
describe the progress we have made, the challenges we face, and what we
are doing and propose to do about them;
Present an analysis of the budget requests for each program area,
explaining the major activities, accomplishments, and commitments for
each program; and
Discuss some of the new program initiatives and progress being made
toward achieving our strategic goals.
I. INTRODUCTION
Last year the Department submitted a budget request for the Environmental
Management program that was essentially flat, halting the trend of increasing
budget requests that had occurred since the program was established in 1989.
This year, I can report that this trend is being reversed with our FY 1996
budget request, which represents a reduction from last year given a comparable
work scope. We have made substantial progress in changing the way we do
business and have achieved increased cost savings through efficiency gains and
2
productivity improvements. This effort translates into safer working
conditions, better protection of public health and safety, and a cleaner
environment. All at less cost to the taxpayer.
The Environmental Management program is playing a significant role in
contributing to a leaner federal government and deficit reduction as part of
the President's proposed FY 1996 budget. The entire Departmental budget is
being reduced by $10.4 billion over the next five years. The Environmental
Management program budget request will account for a large portion of this
reduction. For fiscal years 1997 through 2000 our request is being reduced by
$4.4 billion in outlays, which translates into a $5.5 billion reduction in
requested budget authority over the same period, from the previous budget
targets established by the Administration. I believe these are very
aggressive, but, ultimately achievable reductions.
Our FY 1996 request reflects a continued commitment to solving environmental
and safety problems as well as a continued commitment to improve the way the
Department does business. Our request includes funding for major added
responsibilities previously in the Defense Programs budget. The new scope
includes management of the Savannah River site in South Carolina, the Mound
site in Ohio, and the Pinellas Plant in Florida and 18 high risk facilities
and 16 supporting facilities. Without the additional transferred scope of
work, the Environmental Management base budget request for activities in waste
management, environmental restoration, nuclear materials and facilities
3
stabilization, and technology development is actually four percent less than
the amount appropriated in FY 1995.
The Environmental Management program is committed to doing more with less now
and into the foreseeable future. The aforementioned reductions in outyear
budgets will take place over a five-year period to allow us to ramp down in a
controlled fashion. More extreme budget cuts beginning in FY 1996 would
likely have negative consequences.
First, a drastic drop in our resources could diminish our ability to protect
human health and safety at our sites. We have focussed significant attention
on the most urgent risks at our sites. But, we cannot afford to defer
indefinitely the lower priority efforts. Deferring problems only increases
costs later and saddles future generations with the problems, and may, in some
cases, cause the cleanup to be more expensive and more dangerous as conditions
deteriorate.
Second, extreme budget cuts could also cause the Department to be out of
compliance with its environmental requirements. Roughly 65 percent of our
budget is driven by enforceable agreements. Without the needed time to
renegotiate and reconfigure these agreements, where appropriate, to account
for funding constraints and other factors, we may be unable to comply with
them. This could result in the Department being subject to administrative or
judicial enforcement orders and fines and penalties.
4
The Environmental Management program has many responsibilities, one of which
is storing securely more than 25 metric tons of plutonium to prevent theft,
sabotage, or diversion. We take our traditional environmental and waste
management responsibilities very seriously. But, certain nuclear materials we
handle have the potential for much greater harm. A mistake in safeguarding
this nuclear material could result in incalculable calamity on a global scale.
Nonetheless, nearly fifty years of nuclear weapons production have left us
with a massive environmental legacy which we have a moral and legal obligation
to address.
BACKGROUND ON THE ENVIRONMENTAL MANAGEMENT
The Department's Office of Environmental Management manages the largest
environmental stewardship program in the world -- with over 130 sites and
facilities in over 30 states and one territory. When it was established in
1989, the program was called environmental restoration and waste management.
Since then, however, the importance of other missions, such as nuclear
materials and facilities stabilization and technology development have grown
significantly. The number of sites and facilities under our management has
also grown as more buildings are determined to be surplus. The nuclear
weapons production complex alone is spread over thousands of square miles in
13 states. Nuclear weapons production operations were shut down in the late
1980's, leaving a legacy of thousands of contaminated areas and buildings,
huge waste volumes, and a large amount of hazardous nuclear materials still in
the pipeline of their production processes. The Environmental Management
program's responsibility is to address the most immediate, urgent risks to
5
human health and the environment as well as manage the long-term contamination
and safety threats.
The task of Environmental Management is a significant one. To illustrate the
extent of this task here is a short list of the wide variety of threats and
risks facing the Department:
hundreds of large, underground high-level radioactive waste tanks, many
of which have leaked, and some of which may pose danger of an explosion;
thousands of metric tons of highly radioactive spent nuclear fuel in
various types of storage, some corroding; and
thousands of radioactively contaminated buildings that must be
stabilized and eventually decontaminated.
contaminated drinking water, soils, and surface water;
worker exposure to radiation and chemicals;
theft or diversion of nuclear weapons material (e.g., plutonium and
highly enriched uranium);
industrial and transportation accidents;
We simultaneously satisfy a wide variety of demands:
compliance with state and federal laws and regulations;
compliance with negotiated agreements stemming from those regulations or
court orders;
International Atomic Energy Agency nuclear nonproliferation safeguards
requirements;
Defense Nuclear Facilities Safety Board "Recommendations";
Worker safety and health protection expectations derived from OSHA,
nuclear industry, and Departmental practices;
Short- and long-term technology development needs; and
Worker and community development needs (e.g., training and land reuse);
The task ahead remains formidable. Yet, we are taking some tangible steps now
to identify and mitigate the environmental and health risks at our sites.
In March the Department completed the 1995 Baseline Environmental Management
Report which provides life-cycle cost estimates for completing the DOE
environmental management mission. The Baseline Report, which was required by
6
the FY 1994 National Defense Authorization Act, includes descriptions of
projects, activities, remedies, schedules, and estimated costs for addressing
the environmental problems at DOE sites. In addition to a "Base Case" program
estimate, alternative scenarios were developed by modifying the following
variables: future land use, funding, technology development, and waste
management complex configuration.
The "Base Case" total program cost ranges from $200 billion to $350 billion
(constant 1995 dollars) depending on productivity assumptions. The Baseline
Report analysis assumes program activities through the year 2070; however,
ninety percent (90%) of estimated costs would be incurred during the first
forty years. The Mid-Range Base Case estimate is $230 billion, assuming 20%
productivity improvement through 2000 and 1 percent annual improvement
thereafter. This is the productivity goal we are working for in our current
program planning, although, we need to achieve it long before the year 2000.
The first question the Baseline Report was designed to help address is, "What
do we as a Nation want to buy?" Considering this question, the Baseline
Report is a tool to help us make better informed policy decisions with
increasingly scarce federal resources and competing requirements. The
alternative cases developed and estimated in the Baseline Report begin to shed
light on what those alternatives would mean in terms of future policy
decisions and estimated costs. The results of this year's Baseline Report
indicate that future land use and development of new technologies will have
the greatest long-term impact on costs.
7
We have other efforts underway, in addition to the Baseline Report, to support
making more informed policy decisions, as well as improve the productivity of
the Environmental Management program. For example, our current technology
development efforts help us to better understand, in a more cost-effective
manner, the type and extent of the environmental and safety risks at our
sites. This information is a necessary first step in the process of
remediating problems, such as dealing with plutonium in various forms and
spent nuclear fuel rods. Technology development also addresses the major
ongoing concerns and lessons learned from the past five years of Environmental
Management program activities and from experience in the implementation of
Superfund. These types of problems include the lack or inadequacy of existing
technologies to remedy fully many of our complex environmental problems, the
significant cost of some of these technologies, the lack of data available to
characterize fully the risks; and the lack of consensus on standards for
remediation.
The Environmental Management program is a prominent part of the nation's
science and technology development effort. As I mentioned, one of the
challenges we face is the lack of available technologies for many of our
contamination and/or waste management problems -- a "technology/application"
gap, if you will. The Department's National Laboratory system is a critical
tool in developing newer, more effective, and cheaper environmental
technologies to allow us to efficiently carry out our environmental projects.
The Task Force on Alternative Futures for the Department of Energy National
Laboratories released its report earlier this year, and I am happy that Bob
8
Galvin and Henry Kendall are joining us today to discuss the task force's
work. We agree with many of its findings and recommendations and have already
begun to implement some of them. We have and will continue to use the
laboratory system to the extent it can compete in producing useful results in
a cost-effective manner, compared to other sources of research and technology.
MAKING PROGRESS
I would now like to highlight some of the Environmental Management program's
accomplishments. These results not only demonstrate significant progress, but
also reflect a new way of doing business by addressing urgent risks first
while simultaneously managing the long-term contamination and health risks
present at our sites. For example, in the last year we have addressed urgent
risks in the following areas:
Completed safety improvements to a building and begun to stabilize
inventories of pyrophoric plutonium contained inside it at the Rocky
Flats Plant in Colorado in FY 1995. This material poses a fire hazard
since, under certain conditions, plutonium ignites in air;
Safely transferred 199 spent nuclear fuel elements to safer storage
facilities in Idaho; and
Returned 153 spent nuclear fuel elements containing weapons-grade
uranium of United States origin from foreign research reactors.
Accepting these fuel elements helps support the Nation's nuclear
nonproliferation policy because they contain weapons-usable highly-
enriched uranium;
Began routine operation of a pump that has virtually eliminated the
threat of explosion in a high-level waste tank at our Hanford site.
Since 1989, we have also reduced the backlog of accumulated waste and long-
term contamination problems across the country. The Department's
accomplishments include the following:
9
Decommissioned approximately 100 facilities across the complex;
Cleaned up 18 former nuclear weapons and industrial sites and 14 sites
associated with uranium mining and milling;
Remediated over nearly 5,000 public and private properties contaminated
with uranium tailings;
Treated 2.4 billion gallons of ground water and 1.8 billion gallons of
surface water;
Recycled 16 million pounds of scrap metal;
Safely transported roughly one million tons of hazardous materials in
140,000 shipments; and
CHANGING THE WAY WE DO BUSINESS
These achievements demonstrate real progress in meeting our legal and moral
obligations. However, inefficiencies still exist in our system, and there is
room for more improvement. Given the downward trend in funding for the
Department's Environmental Management program, we cannot afford to become
complacent. To make up for this year's real budget reductions, and to
continue to seize opportunities for increasing productivity, we must continue
to be smarter about the way we operate through increasing efficiency and
eliminating wasteful spending by hiring experienced federal project managers,
streamlining our contractor workforce, reducing indirect and overhead labor
costs, and reforming our contracts. For example:
We have hired 1,200 experienced project managers, cost estimators,
safety and health professionals, and environmental engineers to provide
greater accountability and oversight at our sites. In return for
additional staff, field office managers have committed to specific
productivity savings.
10
We are reducing the number of contractor employees by a total of about
17,500 -- about 34 percent -- from FY 1994 to FY 1996. We are
downsizing our workforce in accordance with Section 3161 of the Defense
Authorization Act of 1993 to mitigate adverse effects of such layoffs.
The Rocky Flats Plant in Colorado and the Idaho National Engineering
Laboratory are taking about 35 and 30 percent reductions of their total
workforce, respectively; the Hanford Site in Washington and the Savannah
River Site in South Carolina are reducing their workforce by 26 and 22
percent, respectively.
We are recompeting and renegotiating our contracts to include greater
incentives for outstanding performance and to ensure that the
contractors -- not the taxpayers -- take on a larger share of the risks
associated with doing business with the Department. A recently
completed consolidation of our Idaho contract is projected to save $500
million over the next five years.
By instituting these changes, we believe that our program will be able to meet
its legal commitments during FY 1996, with a few exceptions. In cases where
legal problems may occur we have already begun working with State regulators
to resolve them within the FY 1996 request level.
Our program will continue to be driven by a results-oriented, risk-based
approach that seeks to address the most urgent public health and safety
problems first. However, after this fiscal year, even with the continued
productivity savings that are expected, there will be a gap between available
resources and requirements in the future. In order to continue to meet our
obligations, we will need to address these outyear challenges with new
analytical tools, renegotiation of some of our compliance agreements, and
statutory changes.
11
To help shape a smarter, more productive program, we are responding to several
Congressional requirements by developing analytical and informational tools:
As already described, the Baseline Environmental Management Report was
submitted to Congress on March 30, 1995. This is the Department's first
attempt since 1988 to estimate the total life-cycle costs and schedules
to complete its Environmental Management missions. It also examines the
potential impacts on cost of several factors, including future land use,
residual contamination standards, and technology development.
A Risk Report requested by the Committees on Appropriations in DOE's FY
1994 Energy and Water Development appropriation will be submitted to
Congress in June. Although the Environmental Management program is
making progress we realize a better understanding of the risks and how
those risks are reflected in our compliance agreements is needed. This
report presents an evaluation of the risks to the environment, workers
and the public posed by Departmental facilities that are currently
subject to compliance agreements.
The Environmental Management Annual Cost and Variance Report submitted
to Congress in March describes progress by the program across the
country at our sites, including cost and schedule performance
information.
With these tools we expect to improve our ability to plan the long-term future
of the program.
COOPERATIVE EFFORTS TO INCREASE SUCCESS ARE NEEDED
The managerial initiatives are both bold and necessary to increase
productivity, and the analytical tools we are developing and using to plan for
a better future will reduce costs. But even these initiatives are not
sufficient to ensure success. We still face a real reduction in budget
relative to scope of work this year, and even deeper reductions in later
years. Therefore, another way in which we are ensuring that we continue to
meet our legal obligations is by working with regulators to make appropriate
changes to compliance agreements and asking for appropriate changes in
12
requirements that apply to the Department such as the Comprehensive
Environmental Response, Compensation, and Liability Act or "Superfund" law.
Let me emphasize that the Department is committed to complying with the laws
that apply to its sites and operations. If Congress appropriates the
President's budget request the Environmental Management program will be in
substantial compliance with its legal commitments in FY 1996. Indeed, we have
made real improvement in meeting our legal milestones in the past two years.
In FY 1993 75% of Environmental Management milestones were completed. For FY
1994 and FY 1995 we are on track to complete 88% of our milestones, and in FY
1996 we are projecting completing 95% -97% of our milestone commitments.
Notwithstanding that improvement many of our compliance agreements were signed
during a fiscal climate much different from the one we have today. Some of
the future milestones and schedules for completion are currently unworkable.
Recognizing this, it is a reasonable, and indeed sensible, thing to do to work
cooperatively with the States, stakeholders, and EPA to renegotiate those
agreements as appropriate to align them more with current fiscal reality.
Also, our goal in renegotiating these agreements is to ensure that they will
achieve the greatest risk reduction and risk prevention per dollar spent.
Compliance Agreement Changes
Changes are needed in our compliance agreements with regulators to address the
systemic conditions that continue to hinder greater progress in the
Environmental Management program. Given our future budget profile, it will be
13
necessary to renegotiate some of the milestones in our current agreements.
The Department will seek to accomplish the following in any new or
renegotiated compliance agreements:
Establish realistic timelines for milestones that are challenging
but doable;
Establish ultimate end-point target dates, with appropriate inter-
mediate objectives;
--
Limit the enforceable milestones included in the agreement to a
maximum of a three year timeframe to reflect sound technical
planning assumptions, but allow for annual appropriations
adjustments; and
--
Provide that any and all penalties for noncompliance would fund
further risk reduction.
We will continue to seek appropriate changes to our compliance agreements to
better reflect budget realities and be able to address changing conditions at
the sites. The Hanford Tri-Party Agreement was the first agreement renegoti-
ated by the Clinton Administration, resulting in more than $1 billion in
savings. A second portion of the agreement is now being renegotiated to focus
appropriate efforts on those risks of greatest concern to our stakeholders and
make the cleanup more cost-effective. We are working with the states to
effectively renegotiate our compliance agreements where necessary. We
anticipate that by the end of June we will have a better idea whether this
process will work.
14
In addition, changes in our budget cycle and the methods for setting
enforceable milestones may be needed. In discussions with states we have
proposed would allow for shorter-term milestones in our compliance agreements
based on the lessons-learned after operating for several years under the
current regime of multi-year milestone schedules. I would like to see compli-
ance agreements with three-year milestone time frames, subject to annual
appropriations changes, with longer-term milestones included as guidelines
rather than enforceable actions. We hope to be able to accomplish this
approach without the need for legislation. However, legislation that allowed
a three-year budgeting cycle that parallelled the agreements would be
desirable to provide more budget predictability to site and project managers.
Legislative Changes
We currently recommend four areas of legislative change which we believe are
vital this year in order to rationalize cleanups. First, the Superfund law
needs changes to future take land use into consideration in cleanup actions
and to establish universal standards for cleanup -- standards based on
sensible levels of risk given different future land uses.
Second, we support many elements of recently proposed risk legislation, and
are working with the Congress to develop a sound and effective approach for
such a risk analysis program. The Department also supports the inclusion of
risks to workers as part of this legislation. The Department defined and
published a set of principles for using risk analysis in January 1995. The
principles are designed to be a first cut for the Department at defining risk
15
analysis, its purposes, and the principles to be followed if it is to be done
well and credibly.
Third, changes are needed to address the way budgets are allocated among our
sites. For example, legislation to allow for site-based budgeting would help
improve integration of operations at our sites, and allow them more
flexibility in responding to changing environmental conditions and priorities.
It would also allow a more tailored approach to risk reduction, letting the
site managers and stakeholders determine what the greatest risks are at the
individual site and how to prioritize activities based on cost-benefit analy-
ses. We have proposed such a system on a pilot basis in our FY 1996 budget
request at the Rocky Flats site.
Finally, we should take another look at whether Federal officials should be
exposed to the risk of criminal liability if a violation of environmental
requirements occurs because of funding constraints where a good faith effort
has been made to comply with the law.
The outlook for the Environmental Management program depends on many things.
I have described the managerial changes we are implementing to address the
challenges we face given declining resources. I have also outlined the focus
on urgent risk reduction in prioritizing a results-oriented program. However,
the scope of the Environmental Management program demands a national debate to
16
help set priorities and directions for the future. Some of the issues that I
believe we need to work on together include the following:
We need to reconsider the pace and long-term schedule for the
Environmental Management program: In 1989, the Administration committed
to a 30-year program. Now, preliminary analysis indicates that such a
schedule is neither feasible nor wise. We need to consider carefully
how to pace different aspects of the program. Our near-term goals need
to address our urgent risks such as the Hanford waste tanks, spent
nuclear fuel, and stabilizing nuclear materials and facilities to reduce
maintenance costs. In addition, we need to invest in new technologies
so that we have more effective and less costly remedies in the future.
We need to think carefully about the risks and benefits of each
alternative before selecting a particular course. In fact, the decision
will not be a single one, but will be thousands of individual decisions
based on the best information we can obtain on risks, costs, and
schedules.
We lack a rational and timely process to allocate funds in the event of
a shortfall. I know that the Federal Facilities Environmental
Restoration Dialogue Committee -- the "Keystone" group in which the
Department participated -- recommended in 1993 that a pro rata
allocation be made among compliance-related budget areas for
environmental restoration and related activities. First, environmental
restoration activities are only one part of our budget and other
activities such as waste management and facility stabilization need to
be considered in the allocation of cuts. Also, although this process is
appealingly simple, it does not take into consideration differences
between sites such as efficiency, risk or opportunities to make
progress.
With respect to the last point, we plan to take a step toward a more efficient
budget allocation process this year. As stated in brief earlier, we proposed
a pilot project at Rocky Flats to implement a site-based budget, rather than
allocating funds through the traditional program organizational elements. The
goal of this initiative is to provide sufficient flexibility to the site to
ensure that funds are allocated to the highest priorities after the
appropriation process is completed to address urgent risks or to make
investments to reduce long-term maintenance costs. Site managers will be
better able to work cooperatively with their local regulators and stakeholders
17
to develop priorities that make sense for the site. These changes allow site
managers to be more responsive to changing needs or site conditions, and
avoids the cumbersome budget reprogramming process currently used. If this
pilot proposal is approved and successful in FY 1996 at Rocky Flats, I plan to
expand this budget technique to all sites for FY 1997.
In addition, we are exploring other options with respect to budgeting and
priority setting that could help reduce total program costs and better focus
technical expertise. These options are at the early stages of development,
but could have the potential to dramatically change and improve how we conduct
business, how much it costs, and how long it takes.
II. ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT BUDGET BY PROGRAM AREA
The FY 1996 budget request is being proposed under three separate
appropriations accounts: the Energy Supply and Research Development
appropriation (roughly 10 percent of the budget request); the Defense
Environmental Restoration and Waste Management appropriation portion of the
Atomic Energy Defense Activities account (roughly 87 percent of the budget
request); and the Uranium Enrichment Decontamination and Decommissioning (D&D)
Fund appropriation (roughly 3 percent of the budget request).
The Department's FY 1996 budget request for the Environmental Management
program totals $6,591,741,000. This includes $843,000,000 for new
responsibilities primarily at three sites -- Mound, Pinellas, and Savannah
River -- transferred to the Environmental Management account from the Defense
18
Programs account. Management responsibility for the Savannah River Site,
Mound, and Pinellas was transferred to Environmental Management in January,
1995. Given a comparable work scope, this request represents a reduction of 4
percent from the FY 1995 baseline appropriation. The information on the FY
1996 budget request follows in Table 1.
19
TABLE 1
ENVIRONMENTAL MANAGEMENT
Fund Summary (in $ Millions)
Percent
FY 1995
FY 1996
Change
Waste Management
Defense
2,673.1
2,501.6
-6.4
Non-Defense
243.0
206.1
-15.2
Total
2,916.1
2,707.7
-7.1
Corrective Activities
Defense
$
0.5
3.4
+580.0
Non-Defense
26.7
5.4
-79.8
Total
27.2
8.8
-67.6
Environmental Restoration
Defense
1,379.9
1,576.0*
+14.2
Non-Defense
388.6
417.8
+7.5
Total
1,768.5
1,993.8
+12.7
Uranium D&D Fund
Non-Defense
301.3
288.8
-4.1
Nuclear Material and
Facility Stabilization
Defense
765.5
1,596.0
+108.5
Non-Defense
73.4
83.7
+14.0
Total
838.9
1,679.7
+100.2
Technology Development
Defense
417. 4
390.5
-6.4
Transportation Management
Defense
20.7
16.1
-22.2
Compliance and Program
Coordination
81.3
+100.0
Defense
0
Analysis Education and Risk
Management
84.9
157.0
+84.9
Defense
Use of Prior Year Balances
and Other Adjustments
Defense
- 249.3
-313.9
+25.9
Non-Defense
- 8.2
-23.1
+730.5
Total
- 257.5
-337.0
+48.3
Transfer Government
Contribution to Uranium
Enrichment D&D from
ER Defense/Foreign Fees
-133.7
-395.0
+161.8
20
FY 1995
FY 1996
Percent
Change
APPROPRIATION BREAKDOWN
Defense
5,092.7
6,008.0
+18.0
Energy Supply
723.5
689.9
-4.6
Uranium D&D Fund
167.6
-106.2
-163.4
TOTAL**
5,983.8
6,591.7
+10.2
*
Includes $350 million for Government contributions to the Uranium Enrichment D&D Fund.
Actual change from 1995 to 1996 for the Defense budget is -2%.
** This includes $843 million for newly transferred responsibilities. The
base budget request without these new responsibilities is $5.748 billion,
a 4 percent reduction from last year's enacted amount.
The Environmental Management program's budget is broken down into four primary
activity areas. These are the first four shown in Table 1. The program also
has Transportation Management, Compliance and Program Coordination, and
Analysis, Education and Risk programs. The Transportation Management program,
comprising less than 1 percent of the total Environmental Management budget,
is responsible for the safe, secure, and cost-effective transport of
Departmental materials, including hazardous and radioactive substances. The
program also assures that all Department shipments comply with applicable
regulations and operating procedures and guidelines. The Office of Compliance
and Program Coordination, which accounts for about 1 percent of the total
program budget, provides independent monitoring and appraisal, programmatic
guidance, integrated performance analysis and technical assistance for the
Environmental Management program's environment, safety, and health,
engineering, cost evaluation, technical operations, transportation management,
emergency management and other functions. The program-wide perspective of
this office provides line organizations with an understanding of their
implementation of applicable regulatory and technical requirements. The
Analysis, Education and Risk Management part of the budget, approximately 2
percent of the total program, includes transfers of some former Office of
21
Technology Development programs. Although a very small portion of the budget
request, Analysis, Education and Risk Management supports essential activities
such as analyzing current and long-term costs; formulating risk assessment and
risk integration activities; developing policy; administering, formulating and
executing the budget; conducting strategic, long-range planning; monitoring
and evaluating contractor performance; conducting employee and public
education programs; and providing links between the Department and other
agencies, Congress, environmental and other stakeholder groups, and the
private sector.
As we take on greater responsibility from other Departmental elements, we are
requesting more funding for our Nuclear Materials and Facilities Stabilization
program (formerly Facility Transition) which includes thousands of former
Defense Program (DP) facilities that are no longer needed for nuclear weapons
production. Significant funding is required to safely stabilize and maintain
surplus nuclear weapons facilities while they await decontamination and
decommissioning. Detailed breakouts of each of the four primary program areas
appear below.
WASTE MANAGEMENT
BUDGET REQUEST: $2,716,551,000
37.0% of the total program budget
Major Activities
Waste management activities of the Environmental Management program comprise
the largest portion -- over a third -- of the total budget request. (See
Tables 2 and 3 for a breakdown of the Waste Management budget.) The program's
activities include managing the treatment, storage and disposal of wastes, and
working to minimize the amount of new wastes generated. The Department is
faced with a variety of wastes, including high-level radioactive waste (such
as the waste found in the Hanford tanks), transuranic waste, low-level
22
radioactive waste, hazardous waste, and mixed waste (both radioactive and
hazardous). The Waste Management program is also responsible for managing the
Department's spent nuclear fuel. Some 2,700 metric tons of highly radioactive
spent fuel is stored at various sites around the country. Some of the fuel is
corroding, and some has been in storage for as long as thirty years -- far
longer than the planned storage time for this material.
In addition to maintaining safe storage the Department continues to operate
treatment and disposal facilities while developing badly needed additional
treatment and disposal capabilities. Examples of these projects include the
Tank Waste Remediation System at Hanford, Washington; the Defense Waste
Processing Facility and related high-level waste tank farm operations at the
Savannah River Site, South Carolina; the West Valley Demonstration Project in
New York; and the development of Site Treatment Plans with the 22 States where
the Department stores or generates mixed waste.
Part of the waste management budget is funding for "corrective activities." In
1989, approximately 175 active and standby facilities were identified as being
out of compliance with applicable local, state and federal regulations.
Corrective activities are conducted to bring these facilities into compliance
as rapidly as possible. This portion of the budget has declined dramatically
since 1991, when the appropriation was nearly $200 million, to this year's
request of roughly $9 million. This declining budget reflects the success of
this program in bringing the Department's facilities into compliance with
applicable environmental regulations. For FY 1996, only three projects under
the Corrective Activities budget require funding for completion: the Hazardous
Waste Treatment Facility at the Los Alamos National Laboratory, and two
construction projects related to low-level radioactive waste at the Oak Ridge
National Laboratory. Some of the environmental laws that the Department must
23
comply with include the Resource Conservation and Recovery Act, the Clean Air
Act, the Safe Drinking Water Act, and the Toxic Substances Control Act. These
are the same laws that the government expects private industries to comply
with to protect human health and the environment. Unless and until Congress
amends these laws, the Department has a legal and moral obligation to comply
with these laws and to request adequate funding to do so. This basic
principle is codified in Executive Order 12088.
24
TABLE 2
WASTE MANAGEMENT AND CORRECTIVE ACTIVITIES
Defense Funding Summary
(Dollars in Thousands)
Activity
FY 1995
FY 1996
Program Management
$ 184,113
$ 141,778
Facility Operations and Maintenance
1,236,258
1,178,891
Former Defense Program Facilities
62,060
171,085
New Facilities
708,786
566,040
Defense Waste Processing Facility
234,648
178,651
Hanford Waste Vitrification Plant
442
0
Waste Isolation Pilot Plant
174,323
172,700
Program Direction
72,417
92,451
TOTAL, Waste Management-Defense
2,673,047
2,501,596
CORRECTIVE ACTIVITIES
TOTAL, Corrective Activities-Defense
$ 512
$ 3,406
TOTAL, Corrective Activities/Waste Management - Defense
$2,673,559
$2,505,002
TABLE 3
WASTE MANAGEMENT AND CORRECTIVE ACTIVITIES
Non-Defense Funding Summary
(Dollars in Thousands)
Activity
FY 1995
FY 1996
Program Management
$ 4,242
$ 4,193
Facility Operations and Maintenance
71,191
63,290
New Facilities.
34,979
10,562
West Valley Demonstration Project
125,127
122,100
Low-Level Waste
7,477
6,000
TOTAL, Waste Management-Non-Defense
$243,016
$206,145
TOTAL, Corrective Activities, Non-Defense
$ 26,700
$ 5,404
TOTAL, Corrective Activities and Waste Management, Non-
Defense
$269,716
$211,549
GRAND TOTAL, Waste Management
$2,943,275
$2,716,551
25
Selected Accomplishments in Waste Management FY 1994
In Idaho:
Treated 700,000 gallons of liquid high-level waste to convert into
a more stable, dry calcine form at the New Waste Calcining
:
Facility.
In Nevada:
--
Began shipments of low-level waste from Rocky Flats to the Nevada
Test Site for disposal. Low-level waste has been accumulating at
Rocky Flats since 1990 when the last shipments were made.
In New Mexico:
--
Began the retrieval of bermed transuranic waste at Los Alamos
National Laboratory to place in a compliant above-ground
configuration;
In Washington:
--
Reduced the volume of high-level waste in tanks at Hanford by 5.2
million gallons after treatment with the 242-A Evaporator system;
and
Completed the construction and began operating the Treated
Effluent Disposal Facility at the Hanford site. This facility
provides continuous treatment and disposal of liquid effluent from
the 300 Area. All discharges of effluent to the 300 Area Process
Trenches has ceased.
In New York:
--
Completed the transfer and neutralization of acid high-level waste
at the West Valley site in preparation of vitrification.
In Tennessee:
--
At the Oak Ridge Reservation, we treated over 5 million pounds of
mixed waste (both radioactive and hazardous) in 1994 at the Toxic
Substances Control Act (TSCA) Incinerator, exceeding both the
requirements of the Oak Ridge Federal Facilities Compliance
Agreement and the performance in 1993 which was 3.6 million
pounds. These wastes originated from operations at our sites in
Oak Ridge, Tennessee; Portsmouth, Ohio; and Paducah, Kentucky.
Also at Oak Ridge, we treated 40 million gallons of wastewater at
the K-25 Gaseous Diffusion plant's Central Neutralization
Facility. This facility treats wastewater from the TSCA
incinerator that contains radioactive and/or hazardous
constituents in accordance with the National Pollution
26
In South Carolina:
--
At the Savannah River site, newly constructed low-level
radioactive waste vaults began accepting waste. These
vaults provide improved containment and protection of the area's
relatively shallow water table, and represent the evolution of
low-level disposal away from engineered trenches;
--
: After the restart of an evaporator system at Savannah River,
over 1 million gallons of high-level waste was processed to
reduce volume and create additional storage space; and
--
Commenced radioactive operations of the In-Tank Precipitation
facility and completed washing of Sludge Batch #1 at the Extended
Sludge Processing Facility to prepare feed for the DWPF.
Priorities and Challenges for FY 1996 in Waste Management
Begin operations at the Defense Waste Processing Facility at Savannah
River and at the West Valley vitrification facility.
Finalize the EPA compliance plan for the Waste Isolation Pilot Plant in
New Mexico.
Continue to safely manage and treat approximately 61 million gallons of
high-level radioactive waste stored in 177 underground tanks at the
Hanford Site in Washington.
Continue to improve management and storage of all DOE spent nuclear fuel
while implementing decisions of the complex-wide Spent Nuclear Fuel
Environmental Impact Statement.
Implement Site Treatment Plans for mixed waste under the Federal
Facility Compliance Act, and plan for the storage and disposal of
treated mixed low-level waste.
ENVIRONMENTAL RESTORATION
BUDGET REQUEST: $1,993,731,000
27% of the total program budget
Major Activities
The Office of Environmental Restoration is responsible for the assessment and
remediation of facilities and land no longer used for nuclear weapons
production, as well as other inactive sites. These sites range from
contaminated buildings to abandoned or inactive waste disposal sites. It is
27
this portion of the overall Environmental Management program that is often
described as the "cleanup" program.
Remedial action requirements are derived primarily from the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) and the
Resource Conservation and Recovery Act (RCRA), and are carried out in
compliance with the National Environmental Policy Act (NEPA).
The Formerly Utilized Sites Remedial Action Program (FUSRAP) and the Uranium
Mill Tailings Remedial Action program (UMTRA) are also managed under the
Environmental Restoration program.
We are continuing to move away from doing studies to engaging in actual
cleanup. Almost 40 percent of the Environmental Restoration budget request
for FY 1996 will fund remediation -- groundwater and soil restoration, and
decontamination and decommissioning of facilities. A little over 15 percent
of the budget request is for the Government Contribution to the Uranium
Enrichment Decommissioning and Decontamination Fund, and a smaller portion is
allocated for surveillance and maintenance activities, and landlord functions
at the Fernald site and the Oak Ridge, Tennessee K-25 site. Most of the
remaining budget is allocated to characterization and assessment of the nature
and extent of environmental problems at our sites. In the coming years we
will continue to devote even greater resources to environmental risk reduction
and fewer resources to environmental assessments. (Information on the
breakdown of the Environmental Restoration budget follows in Table 4.)
28
TABLE 4
ENVIRONMENTAL RESTORATION
Funding Summary
(Dollars in Thousands)
SUBACTIVITY
FY 1995
FY 1996
DEFENSE
Facilities and Sites
$1,379,924
$1,575,973
Subtotal, Defense
$1,379,924
$1,575,973
NON-DEFENSE
Facilities and Sites
219,380
244,758
Formerly Utilized Sites Remedial
Action Project
74,100
85,200
Uranium Mill Tailings Remedial
Action Project
88,117
80,000
Uranium Mill Tailings Groundwater
Restoration Project
7,000
7,800
Subtotal, Non-Defense
$ 388,597
$ 417,758
Uranium Enrichment D&D Fund
$ 301,327
$ 288,807
TOTAL, ENVIRONMENTAL RESTORATION*
$2,069,848
$2,282,538
*This total includes $288.8 million for the Uranium Enrichment D&D Fund.
The total for Environmental Restoration programs without this fund is
$1,993,731,000.
By the end of FY 1996, we expect to have completed the remediation of almost
99 percent of the Uranium Mill Tailing Remedial Action (UMTRA) program's
vicinity properties. As of now, we have cleaned up over 4,700 UMTRA vicinity
properties, removing in excess of 2,400,000 cubic yards of contaminated
materials.
The major activities of the Environmental Restoration program are as follows:
At over 30 major DOE installations, safe management and remediation of
contaminated sites, characterization, remedial action, decontamination
and decommissioning, and closure activities.
Formerly Utilized Sites Remedial Action Project (FUSRAP), which
currently includes 41 former Manhattan Project or Atomic Energy
Commission sites and five other sites added by Congress.
29
Uranium Mill Tailings Remedial Action (UMTRA) Project, which conducts
remediation of 24 inactive uranium mill tailings sites that provided
uranium for past Manhattan Project and Atomic Energy Commission
activities, as well as more than 5,000 associated vicinity properties.
Uranium Mill Tailings Groundwater Compliance Project, which will
restore; as necessary, the groundwater at the 24 UMTRA processing sites
to ensure compliance with EPA standards.
Uranium Enrichment Decontamination & Decommissioning (D&D) Fund, which
provides for D&D, remedial actions, site-wide landlord requirements, and
surveillance and maintenance efforts at the uranium enrichment
facilities at Portsmouth, Ohio, and Paducah, Kentucky, and the inactive
K-25 site at the Oak Ridge Reservation in Tennessee. This is also the
source of funds for reimbursing a portion of the remedial action costs
at active uranium and thorium mill sites as required by Title X of the
Energy Policy Act of 1992.
Selected Accomplishments in Environmental Restoration
18 out of 46 Formerly Utilized Site Remedial Action Program
(FUSRAP) sites (about 35%) have been cleaned up;
14 out of 24 Uranium Mill Tailings Remedial Action Program (UMTRA)
sites have been completed, nearly 60%. Over 27 million cubic
yards of mill tailings have been removed and disposed;
119 remedial action projects have been completed, with an
additional 111 underway;
16 million pounds of scrap metal have been recycled; and
2.4 billion gallons of ground water have been pumped and treated
and 1.8 billion gallons of surface water have been treated to
reduce contaminants.
Priorities and Challenges in Environmental Restoration
In FY 1996, the Environmental Restoration program will:
Complete 100 interim cleanup actions, such as early removals and
expedited responses;
Complete 20 remedial action projects;
Complete 12 interim decommissioning and decontamination actions;
Complete 6 UMTRA cleanups and begin cleanup at the final 2 sites;
and
Complete 2 FUSRAP cleanups.
30
NUCLEAR MATERIAL AND FACILITY STABILIZATION
BUDGET REQUEST: $1,679,711,000
23% of the total program budget
Major Activities
The mission of the Office of Nuclear Material and Facility Stabilization is to
reduce the high-risk conditions associated with unstable excess nuclear and
chemical materials left intact at former nuclear weapons production facilities
and reduce the maintenance costs associated with stabilizing buildings
awaiting decontamination or final disposition. More specifically, this
involves the protection of workers and environment from exposure and
contamination, stabilization of hazardous nuclear and chemical materials,
deactivation of facilities to attain the lowest surveillance and maintenance
costs, and disposition of facilities to the Office of Environmental
Restoration for decontamination and decommissioning.
With the end of the Cold War, a largè amount of extraordinarily hazardous
nuclear materials and a large number of facilities have become surplus and
require stabilization prior to decontamination and decommissioning. These
facilities typically require extensive surveillance and maintenance, as well
as associated "landlord" activities such as utilities and fire safety
functions. The Department will continue to incur costs for these activities
until the nuclear materials are stabilized and removed. Approximately 4500
facilities have already been transferred to the Environmental Management
program for stabilization. Another 1,200 are expected between now and FY
1999. Nuclear materials will require a variety of chemical processing
activities, repackaging operations, and performing surveillance, maintenance,
and safeguards activities. Surplus facilities, once stabilized, will require
decontamination and decommissioning (D&D).
31
In FY 1996, the Environmental Management program's responsibilities in the
Nuclear Material and Facility Stabilization program area will double as the
result of transferring the responsibility for Savannah River Site in South
Carolina, the Mound Site in Ohio, and the Pinellas site in Florida from
Defense Programs to the Environmental Management program, as well as
approximately 18 high-risk facilities and 16 buildings supporting them at
other sites in several states. These new responsibilities will include repair
and operation of some facilities, stabilizing nuclear materials that pose a
significant risk in their current form or location, producing radionuclides
for Departmental missions, and developing new ways of operating complex
facilities. This is the fastest growing program within the Office of
Environmental Management. The carrying costs for these facilities are
enormous and will continue to increase until the nuclear materials are
stabilized and/or removed. The landlord responsibilities -- including fire
safety, utilities, roadway maintenance, and security -- and surveillance and
maintenance costs, for which the Office of Nuclear Material and Facility
Stabilization is responsible, is in excess of $1 billion. Landlord
responsibilities represent about 70 percent of the Office's budget.
Our budget request for Nuclear Material and Facility Stabilization reflects
the overall strategy of the Environmental Management program to stabilize
nuclear materials and facilities, recognizing that we can not "cleanup" all of
our facilities at once. Let me emphasize that this is one area in which
inaction on our part could have serious near-term consequences on worker
health and safety and the quality of the environment. Significant funding is
needed to safely stabilize these facilities in order to reduce the cost and
risks of maintaining the surplus facilities awaiting decontamination.
32
Our budget request for FY 1996 includes funding for four principal sites:
Savannah River Site, South Carolina. As of January, 1995, the
Environmental Management program became the primary site manager, or
landlord, at Savannah River. The site budget request of $685 million in
FY 1996 is needed to safely conduct a range of operations. One urgent
risk to workers at the site is the presence of nuclear materials in
solution in the F-Canyon.
Rocky Flats Plant, Colorado. $393.8 million is allocated for the
program's operations, including the stabilization of 100 kilograms of
pyrophoric plutonium, thus reducing the risk of fire. Also, the
stabilization of about 375 gallons of acidic weapons-grade uranium
liquids is planned.
Hanford, Washington. Safe stabilization of plutonium with minimal
worker exposure at the Plutonium Finishing Plant is planned, as is the
removal of the remaining radioactive and hazardous chemicals from the
PUREX facility to place the facility in a safe and stable, low
maintenance condition, and to reduce out-year surveillance and
maintenance costs. The funding request for FY 1996 is $286.1 million.
Idaho National Engineering Laboratory. We are working to stabilize
uranium and liquid acidic solutions to significantly reduce out-year
maintenance costs and have requested $162.1 million for FY 1996.
Leakage from aging pipelines could result in unsafe and costly
contamination.
Additional Nuclear Material and Facility Stabilization site responsibilities
include high risk facilities at:
Los Alamos National Laboratory, NM; ETEC, CA; Oak Ridge, TN; Mound near
Dayton, OH; and Pinellas, FL.
Information on the Nuclear Material and Facility Stabilization budget follows
in Table 5.
33
TABLE 5
NUCLEAR MATERIAL and FACILITY STABILIZATION
Funding Summary
(Dollars in Thousands)
Activity
FY 1995
FY 1996
DEFENSE
(1) Program Integration
$ 29,590
$ 63,299
(2) Surveillance and Maintenance
268,010
542,733
(3) Deactivation/Compliance
124,868
208,719
(4) Landlord
232,335
539,294
(5) Program Management
53,940
144,681
(6) Program Direction
56,774
97,302
Total, Defense
765,517
$1,596,028
NON-DEFENSE
Program Integration
$ 1,200
$ 2,916
Surveillance and Maintenance
54,313
40,217
Deactivation/Compliance
17,823
40,550
Subtotal, Non-Defense
73,336
83,683
Total, Nuclear Materials/Fac. Stab.
$838,853
$1,679,711
(1)
Program Integration refers to planning, site characterization, and other
activities associated with assuming management responsibility for a
site.
(2)
Surveillance and Maintenance refers to periodic inspection of items such
as HEPA filters, tank levels, and waste drum conditions to ensure safe
operations of the facilities.
(3)
Deactivation/Compliance refers to activities associated with the removal
of hazardous and radioactive material, equipment, etc., to reduce the
hazard classification of the facility.
(4)
Landlord refers to activities that cut across an entire site, such as
medical and fire-fighting services, electricity, sewer, and water.
(5) Program Management refers to contract support directly related to
Nuclear Material and Facility Stabilization.
(6) Program Direction refers to salaries and other direct costs of Federal
employees.
34
Selected Accomplishments of the Nuclear Material and Facility Stabilization
Program
At Rocky Flats, Colorado:
Initiated shipment of low-level waste generated at Rocky Flats to the
Nevada Test Site and continued shipments to Hanford;
Completed renegotiation of interagency agreement with the State of
Colorado and the Environmental Protection Agency; and
Completed solidification of 375 bottles of dilute plutonium solutions.
At Richland, Washington:
Completed deactivation of the Uranium Tri-Oxide plant;
Reduced the contaminated area of PUREX by 420,000 square feet,
approximately 90 percent of the total area; and
Remediated the plutonium bearing ductwork in support facility at the
Plutonium Finishing Plant.
At Idaho National Engineering Laboratory, Idaho
Completed the uranium accountability at the Idaho Chemical Processing
Plant's Buildings 601 and 602, part of the facility's uranium recovery
line;
Completed the deactivation of the second and third cycle extraction
processes at the Idaho Chemical Processing Plant (ICPP); and
Completed the deactivation of the ICPP denitrator process stabilizing
12,000 liters of liquid uranium inventories.
Priorities and Challenges for Nuclear Material and Facility Stabilization
At Rocky Flats, Colorado:
Thermally stabilize 100 kilograms of pyrophoric plutonium oxides
to eliminate the risk of fire;
Convert 1,400 liters of nitrate solutions comprising 275 kilograms
of 93.2% highly enriched uranium to a solid form; and
Complete filtered venting of 2,000 drums containing plutonium
materials to prevent explosion and possible failure of
containment.
At Richland, Washington:
Complete 78% of the Plutonium-Uranium (PUREX) deactivation
project;
35
Disposition 947,000 liters of surplus uranium contaminated nitric
acid; and
Complete 75% defueling of the Fast Flux Test Facility (FFTF)
reactor.
At Idaho National Engineering Laboratory, Idaho:
:
Initiate deactivation of the Idaho Chemical Processing Plant dry
end process including removal of up to 150 kilograms of uranium in
graphite ash; and
Complete definitive design for deactivation of calcine cell within
the Old Waste Calcining Facility.
At Savannah River, South Carolina:
Complete stabilization of 300,000 liters of plutonium 239
solutions in F Canyon; and
Complete the stabilization of 1,600 liters of Pu-242 solutions and
16,000 corroding plutonium targets pending completion of the
Interim Management of Nuclear Materials Environmental Impact
Statement.
36
TECHNOLOGY DEVELOPMENT
BUDGET REQUEST: $390,510,000
5.3% of the total program budget
Major Activities
Developing new technologies to address the environmental challenges in the
former nuclear weapons complex is an integral part of the Environmental
Management program. This program also reflects our strategy of investing in
technology development to develop long-term effective methods for addressing
environmental challenges. The goals of our technology development program
include reducing risks to people and the environment, reducing cleanup costs,
and finding new technologies to environmental problems for which no solutions
currently exist. The Environmental Management Technology Development program
is an aggressive national program of applied research, development,
demonstration, testing, and evaluation for environmental cleanup, waste
management, and related technologies. Our strategy is to identify and develop
technologies that can clean up the nuclear weapons complex, and manage the
wastes more quickly, more safely and at a lower cost. In many cases,
developing new technologies presents the best hope for ensuring a real
reduction in risk to the environment and improved worker and public safety,
especially given competing national priorities and limited funds. (The
Technology Development budget follows in Table 6.)
37
TABLE 6
TECHNOLOGY DEVELOPMENT
Funding Summary
(Dollars in Thousands)
Subactivity
FY 1995
FY 1996
DEFENSE
Treatment and
Remediation
Technology
Systems
157,718
203,800
Innovative &
Crosscutting
Technology
Program
80,229
80,200
Industry Programs
43,200
41,200
Technology
Integration
9,789
17,040
Program Support
38,054
33,271
Program Direction
16,754
14,999
Education and
Integrated Risk
Management
Initiative
38,752
0
Infrastructure
Program
32,863
0
Total, Technology
Development
417,359*
390,510
*This includes Education and Risk Management Initiatives and
Infrastructure Programs. These programs have been transferred to other
Environmental Management organizations for FY 1996. The base budget
for FY 1995 is $336.5 million.
38
Selected Accomplishments in Technology Development
In Texas:
The Expedited Site Characterization methodology saved $3 million and 6
months in characterizing parts of the Pantex, Texas, site. It also
provided a more comprehensive site analysis than would have been
possible with baseline technologies.
Five new applications of technologies developed saved over $28 million
and, in one case, decades of treatment. (See California example below.)
Decisions have been signed with private industry for three remediation
projects using new technologies: Minimum Additive Waste Stabilization
(MAWS) at Fernald, Robotic Retrieval and Vitrification at Idaho, and
MAWS at Savannah River. These applications will save over $80 million
over baseline technologies. In total, over $115 million have been saved
through the use of new or improved technologies.
In Tennessee:
We demonstrated a Laser-Induced Fluorescence (LIF) sensor system for the
detection of uranium at the now closed K-25 gaseous diffusion uranium
enrichment plant at the Oak Ridge site. This real-time sensor is
capable of detecting uranium on surfaces through laser excitation of the
oxide. Uranium was detected on the surfaces of gaseous diffusion
chambers inside the building of K-25 as well as on the rooftops and vent
stacks. For decontamination and decommissioning activities, where alpha
particle detectors are currently being used to screen for uranium, the
LIF system offers the potential of reducing first-order screening time
to less than 10 percent of current requirements.
In California:
At Lawrence Livermore National Laboratory, we demonstrated the use of
dynamic underground stripping, a system for thermal remediation of an
underground gasoline spill. Underground imaging techniques were used to
verify remediation efficiency and to detect the presence of free
gasoline, if any. Over 30,280 liters of gasoline have been removed, at
an estimated cost of $65 per cubic meter, versus a typical pump and
treat cost of about $260 per cubic meter. The time for remediating with
a pump-and-treat system is in terms of several decades, while the
dynamic stripping is in terms of several months. The baseline
technology, pump and treat, costs $25 million and takes 30 years;
dynamic stripping costs $6 million and takes only 6 months -- saving $19
million and decades. The University of California is seeking
commercialization opportunities.
In South Carolina:
39
At the Savannah River Site, we successfully demonstrated in-situ air
stripping. This new technology, which involves injection of air through
underground horizontal wells to strip groundwater and soils of volatile
organic chemicals, will be transferred to the Environmental Restoration
program and to private industry for use.
Also at Savannah River, Fiber Optic Chemical sensors have been
used to allow on-the-spot monitoring of chlorine in waste streams
and groundwater. This allows real-time analysis rather than normal
week-long laboratory analysis. Non-exclusive licenses for
Trichloroethylene sensors have been issued with Purus and Burge
Instrument Company In New Mexico:
In New Mexico:
The Long Range Alpha Detector was implemented at the Los Alamos National
Laboratory. This instrument measures alpha radiation in air molecules
in real-time and on large surface areas. Preliminary costs estimates
indicate that LRAD saves from $10 to $20 thousand per site surveyed
compared to conventional technologies. Up to 30 sites can be monitored
in a day without disturbing soil or generating waste. This technology
was transferred from Los Alamos to TMA/Eberline via a Cooperative
Research and Development Agreement.
The Magnetometer Towed Array measures magnetic forces, allowing buried
hazardous wastes -- particularly ferrous metals -- to be located. Up to
15 acres a day can be surveyed, more than 7 times the capability of
conventional technologies. It also costs about $2000 per acre to use
versus $3500 to $5000 with conventional methods. Sandia National
Laboratory developed this technology, and transferred it to Geo-Centers,
Inc.
Priorities and Challenges in Technology Development
Some major priorities and challenges for Technology Development include:
Treat and dispose of mixed wastes. We are pursuing versatile treatment
methods such as plasma, vitrification, molten metal and non-thermal
techniques. These activities are being closely coordinated with the
Waste Management program to meet Federal Facility Compliance Act
requirements.
Retrieve and process tank waste. We are initiating full-scale
demonstrations on technology systems to safely retrieve and efficiently
process high-level tank waste for permanent disposal. Tank structural
analysis and waste content analysis methods are being developed.
Remediate contaminated soils and groundwater. We have initiated full-
scale demonstrations on technology systems to characterize, contain, and
remediate contaminated plumes in soils and groundwater. In-situ
treatment of Dense Non-Aqueous Phase Liquids (DNAPLs) is one example.
40
Stabilize landfills. Containment and in-situ treatment methods for
buried waste are being developed. In addition, the retrieval,
characterization and treatment of landfill wastes are being pursued.
Recycle materials from decontamination and decommissioning of
facilities. We will conduct a full-scale demonstration for the
development of facility decontamination and decommissioning technologies
with emphasis on the recycling of materials.
Transfer technologies to private industry. As part of the Secretary's
emphasis on measuring results, we have committed to making a minimum of
24 technologies available for transfer to private industry and to
federal facilities. By successfully transferring these technologies,
the nation can achieve a return on the investment in technology
development.
This concludes the description of our specific program areas. In the next
section, I will describe our program's strategic goals and highlight the
progress we have made.
41
III. STRATEGIC GOALS: INITIATIVES AND PROGRESS
Over the past year, the Department has made significant progress in fulfilling
its goals for improving the Environmental Management program. In 1993 I
established six strategic goals to guide our efforts.
(1) Manage and eliminate the urgent risks and threats in our system;
(2) Provide a safe workplace that is free from fatalities and accidents, and
that continuously reduces injuries and adverse health effects;
(3) Change the system so that it is under control managerially and
financially;
(4) Become more outcome oriented and get more results on the ground in a
timely fashion;
(5) Focus the technology development program on DOE's major environmental
management issues while involving the best talent in the DOE and the
national (public and private) science and engineering communities; and
(6) Develop strong partnerships between the Department and its stakeholders.
We are dedicated to meeting the strategic goals we have set for the
Environmental Management program, despite fiscal constraints. In fact,
focussing on these strategic goals and priorities is even more critical in the
face of funding constraints. However, we must all do our jobs more
efficiently and effectively to meet the increasing amount of work we face. I
would like to highlight some of our recent achievements in these six areas.
REDUCING URGENT RISKS
Two of our most urgent safety concerns have been addressed. A unique mixing
pump installed in the SY-101 high-level waste tank at Hanford has begun
routine operation after previous experimental use. This pump has virtually
eliminated the danger of an explosion in this tank. Also, the threat of fire
42
from unstable inventories of plutonium has been greatly reduced at Rocky Flats
since beginning stabilization processes there.
In addition to these high-priority risks, our spent nuclear fuel management
program continues to improve the storage conditions of this highly radioactive
material. Nearly 200 spent fuel elements were recently transferred to safer
storage conditions at our Idaho site, and we continue to upgrade the
facilities that store this highly radioactive material.
We are committed to continued risk reduction. The Department has hundreds of
high-level waste tanks, and some continue to pose some risk of explosion.
Though the installation of the mixing pump in our most troublesome tank has
been successful, we must continue to mitigate risks in the other storage
tanks. Also, we have only begun to stabilize the plutonium inventory at Rocky
Flats that poses a fire hazard. Some 100 additional kilograms need to be
stabilized to eliminate the risk of a plutonium fire. We are committed to
seeing this project through as quickly as possible. Furthermore, the
continued improvement of our spent nuclear fuel storage facilities is a
priority. We have made progress in this area, but more needs to be done. We
are determined to see that these materials are stored in a safe, secure manner
to enhance worker and public safety as well as support the Nation's
nonproliferation goals.
As noted earlier in my testimony, the Department has published and adopted a
series of risk principles to guide the setting of priorities for the
Environmental Management program. These principles, which were developed as a
result of efforts led by the Office of Science and Technology Policy, will be
used across the federal government, including applying sound risk analysis
43
procedures to regulatory decision-making. As a regulated agency, not a
regulator, the Department modified Administration's principles to apply more
specifically to its programs and procedures, to accommodate our citizens'
values, to address inter-generational issues, and to clarify the role of
prevention programs and social and economic considerations in risk management.
PROTECTING WORKER'S HEALTH AND SAFETY
Far too often, worker protection and safety have taken a back seat in the
Department's corporate culture. This is no longer the case. Our second
strategic goal helps ensure that the people who carry out the heart of the
work of our program are protected from the risks they may face. Through
continuing vigilance and close cooperation with our contractors, last year the
Department reduced the amount of work days lost due to injury by 12 percent.
We will continue to train thousands of workers through sponsorship of a
Hazardous Waste Operations and Emergency Response (HAZWOPER) program in
cooperation with the National Institute for Environmental Health Sciences.
This training is essential for the safe conduct of operations within
Departmental treatment, storage, and disposal facilities and hazardous waste
sites, and is required by the Occupational Safety and Health Administration
for workers who enter and work in these areas.
44
GAINING FINANCIAL AND MANAGERIAL CONTROL
Contract Reform
The Department's contracting system fulfilled the nation's Cold War priorities
of designing, building, and testing nuclear weapons secretly and quickly.
When production was the primary mission, one large contractor was responsible
for virtually all services at each site, and that contractor was protected
from most financial risks by the terms of the contract.
While appropriate for Cold War production, these types of contracts are not
the best way to reach the environmental quality objectives of the Department
today. We will require contractors involved in environmental management
activities to demonstrate sound business practices and assume greater
financial responsibility for activities within their control.
Contract reform initiatives emphasize competition and the development of
clear, objective performance criteria and measures. Performance-based
incentives are focused on the accomplishment of the Department's strategic
mission and reward contractors for fulfilling clear programmatic objectives.
The Department has also begun to reallocate the financial and legal risks
inherent in operating its sites in order to hold contractors more accountable.
Currently, nearly $30 billion worth of contracts are being renegotiated and
recompeted. A recent example of how the Department is changing its
contracting arrangements is the consolidation of contracts at the Idaho
National Engineering Laboratory. This consolidation is projected to save over
$500 million over the next five years. It is also notable in that the
contractor assumes a greater and more appropriate share of the financial risk
for inadequate performance.
45
This process is just getting underway, and will take time to complete.
However, it is well worth the effort to create a contract regime that is
better-suited to our mission and will save billions of dollars.
Improved Contract Management
Compared to other federal agencies, the Department of Energy has the highest
ratio of contractors to federal employees. We cannot gain managerial control
of this program until we have the personnel to help us do that. The
Department has been working closely with the Congress and the Office of
Management and Budget to allow for greater flexibility within the authorized
budget to hire more federal workers to shift this ratio. New cost estimators
and project managers have already been hired to improve the efficiency of
projects and quickly identify cost needs and opportunities for savings.
Overall, sixteen hundred new federal employees, including project managers and
cost estimators, have been authorized for the program since FY 1994 and 1200
will be hired by March 1995. These new managers will primarily be located at
our field sites, rather than in Washington, D.C.
As I mentioned before, we must downsize our contractor workforce substantially
to bring workforce structure and size in line with new missions and management
arrangements. These contractor workforce reductions are also necessary for
improved productivity and cost savings.
New Initiatives for Budget Allocation
There are opportunities to better manage our money and achieve savings. Given
the uncertainty of annual budgets, and the varying scope of work the program
is responsible for, flexibility in budget allocation is essential to meet our
program goals.
46
As I mentioned earlier, a new approach to budget allocation is proposed for
this year. In FY 1996, at the Rocky Flats site, we are proposing a pilot
budget process that will allocate funds to the site as a whole, rather than be
divided along Environmental Management programmatic lines (such as
environmental restoration, waste management, etc.). This will allow site
managers to more quickly and effectively direct funds to the most urgent risks
they face and to be responsive to changing conditions or new information about
risks at the sites rather than having to go through the cumbersome exercise of
reprogramming funds currently done at headquarters. Additionally, the site
manager will be better able to engage regulators and other stakeholders to
develop priorities that make sense for the site. It also increases the
accountability of site managers to National Program Managers, to Congress, and
to the regulators.
This pilot program holds much promise to reinvent budget allocation and
improve risk management. Though only a preliminary program this year, we plan
to expand the concept to all of our major sites in FY 1997 if it proves
successful.
DEMONSTRATING TANGIBLE RESULTS
The Environmental Management program is committed to showing tangible progress
in all of its activities. Already I have highlighted the achievements of the
program since its inception, at particular sites, and by program area. The
progress we have made is significant, but the challenges we face continue to
mount. Thus, we must continue to set goals for progress in order to guide our
efforts and address priorities. Let me share with you some of our immediate
plans for the coming year.
47
Some of the key outcomes of the Environmental Management program planned for
FY 1996 include:
Complete the stabilization of the current plutonium oxide inventories at
Rocky Flats, eliminating the risk of a plutonium fire;
Transfer over 500 additional spent fuel elements to safer storage
conditions in Idaho and Washington, thus protecting workers and the
public from these highly radioactive substances;
Demonstrate 50 new or improved environmental cleanup and/or
characterization technologies to help reduce costs and increase the
effectiveness of our work;
Complete 100 interim environmental restoration actions, 20 larger-scale
cleanups, 12 interim decommissioning and decontamination actions, and
complete 2 more Formerly Utilized Sites Remedial Action Program (FUSRAP)
projects;
Begin operation of the Defense Waste Processing Facility in South
Carolina and the vitrification plant at West Valley, New York, to
convert liquid high-level waste into stable glass logs; and
Finalize the Waste Isolation Pilot Plant compliance application for EPA
approval, an important milestone for the Department's transuranic waste
repository program.
It is my sincere hope and intention that, given adequate resources for our
program, I can report back to you next year, as I am this year, and tell you
that all of these things, and more, have been achieved.
DEVELOPING MORE EFFECTIVE TECHNOLOGIES
Beginning in 1993, the Environmental Management program established the goal
of "focusing" technology development efforts on our most critical needs to
assist in the missions of environmental quality. Five "focus areas" were
created in 1994 to guide this effort. This "focusing" has been achieved and
we are now engaged in developing and implementing new technologies and methods
of environmental characterization and remediation to get results. Considering
initial analysis that points to the Environmental Management program requiring
several decades -- or more -- to complete its work, the need for basic
research is also clear.
48
The five focus areas, and some examples of progress, include the following:
Mixed waste characterization, treatment, and disposal. Our Idaho
National Engineering Laboratory leads the programs to address treatment,
destruction, and disposal of mixed wastes. Two of these, vitrification
of mixed waste sludge and the encapsulation of nitrate salt waste in
polyethylene, have been demonstrated in pilot projects. These
activities will be closely coordinated with the Office of Waste
Management to meet Federal Facility Compliance Act requirements.
Radioactive tank waste remediation. Led by our Richland, Washington
office, this program addresses the urgent problems associated with the
storage of millions of gallons of high-level radioactive waste.
Characterization, leak detection, retrieval and processing of the tank
wastes for final disposition are key areas of this effort. By June of
1997, the goal is to demonstrate the ability to retrieve and treat
liquid tank waste to comply with the Hanford Tri-Party Agreement.
Contaminant plume containment and remediation. Over 600 billion gallons
of ground water and 200 million cubic yards of soil are contaminated
with radioactive and hazardous materials. Our Savannah River Site in
South Carolina heads up this focus area. The goal of this focus area is
to prevent further spread of contaminants and remediate the ground water
and soil contamination.
Landfill stabilization. Also coordinated by the Savannah River Site,
this focus area is aimed at remediating landfills and contaminated soils
associated with over 3 million cubic meters of radioactive and hazardous
buried waste, and other types of landfilled waste.
Facility transitioning, decommissioning final disposition. The
Department is responsible for deactivating and dispositioning 1200
facilities across the nation. The vast majority of surplused facilities
are expected to be transferred to the Environmental Management program.
The Morgantown Environmental Technology Center in West Virginia leads in
the development of methods to decontaminate structures at lower cost to
the taxpayer.
For FY 1996, our Technology Development program plans to demonstrate 50 new or
improved environmental technologies. Furthermore, 24 technologies will be
transferred or made available for transfer to our operating programs, other
federal facilities, and the private sector.
Last year, we announced a new approach to managing our environmental research
and technology development activities. The goal of this new approach is to
49
conduct a research and technology development program that involves the best
talent in the Department and the national science communities to focus on
developing environmental surveillance and remediation technologies to
efficiently clean up our sites.
Key features of this new approach include teaming up with our Waste
Management, Environmental Restoration, and Nuclear Materials and Facilities
Stabilization programs to identify, develop and field test needed technologies
for these programs; continuing to use a life-cycle approach to technology
development; involving high-level management across the Department; focusing
technology development activities on solutions to major environmental
management problems; focusing all available resources in national laboratories
more effectively; involving industry in developing and implementing solutions
including both technology transfer into the Department and technology transfer
from DOE to the private sector; strengthening basic research by involving
academia and other research organizations to stimulate technological
breakthroughs; enhancing mechanisms for regulator and stakeholder involvement;
and applying business principles such as avoiding unnecessary costs, getting a
return on investment, and quickly transferring technologies to the
marketplace.
We are involved in a number of efforts to develop new technologies. First, of
course, are the variety of efforts at the national laboratories. These
institutions have some of the best technical talent and facilities in the
world, and are now available for conversion from their previous defense
missions. However, we will continue to seek the most cost-effective source of
research and development rather than rely solely on an internal, Departmental
system. Second, we are participating on a Federal Advisory Committee to
50
Develop On-Site Innovative Technologies (DOIT) with several western governors,
senior representatives from the Department of Defense and Interior, the
Environmental Protection Agency, and ex-officio members of the Western
Governors Association and the Office of Management and Budget.
PUBLIC PARTICIPATION AND ACCOUNTABILITY
Our nation's nuclear weapons operations were conducted in secrecy over a
period of fifty years, which while necessary during the Cold War, resulted in
distrust of the Department's ability to restore, stabilize, and clean up the
environmental legacy left behind. Secretary O'Leary's openness initiative
beginning in December 1993 recognized the credibility problems the Department
faced and its impact on our ability to do our job. We have learned that
building trust is essential to the success of the Environmental Management
program -- for negotiating agreements, obtaining permits, and achieving public
consensus. Following the Secretary's initiatives on openness and involving
the public in our decision-making, I established the Office of Public
Accountability in 1993. This office is responsible for ensuring that all
Environmental Management offices conduct substantive, cooperative planning
with all our stakeholders in the development and implementation of budgets and
policies. This mechanism allows the people who live and work in and around
our sites to understand what we are doing and why, and affords them the
opportunity to engage in the process. Our personnel in the field are
receiving training on public participation, and in a short time, this office
has taken major strides to actively involve the public in meaningful ways:
We are continuing with an aggressive schedule that follows the
recommendations of the Keystone process to involve stakeholders in key
decisions through site-specific advisory boards (SSABs) at our major
sites. We currently have SSABs in place at Fernald, Hanford, Rocky
Flats, Idaho, Nevada, and the Savannah River Site. Three additional
SSABs are in the final stages of forming.
51
Through the State and Tribal. Government Working Group (STGWG), the
Department provides a forum for six tribes and 17 states to share their
concerns with us and provide input to the various sites around the
country.
The Environmental Management Advisory Board (EMAB) involves
representatives from labor, the U.S. Environmental Protection Agency,
tribes, states, and citizen groups in a variety of issues facing the
Environmental Management program. The EMAB was recently reconstituted,
and now has 28 members.
We are also committed, in accordance with Executive Order 12898 on
environmental justice, to working with those individuals and groups
around our sites who may consider themselves to be disenfranchised. For
example, we are working to ensure that the Native American communities
around our sites are responsibly included in all of our regulatory
negotiations.
IV. CONCLUSION -- REMAINING CHALLENGES BEFORE US
The Department of Energy has undergone significant changes and faced difficult
challenges over the past few years. Since the end of the Cold War, the
Department's primary mission has changed from that of producing nuclear
weapons to addressing the consequences of a half-century of nuclear weapons
production, testing, and research. We are applying our technical and
scientific expertise on other endeavors to expand our knowledge and support
the national economy. The Secretary has led the momentous effort in making
our Department more open to facilitate meaningful public awareness and
participation in national policy decisions. These institutional and
fundamental cultural changes within the Department cannot happen overnight.
We believe that we are on the right track and have been effective in making
fundamental changes in the way the Department does business.
The Environmental Management program has been integrally involved with these
Departmental changes. Openness, focus on a new mission, new motivations, and
accountability are characteristics that the Environmental Management program
52
has attempted to develop, and will continue to nurture. Coupled with our
strategic goals, the Environmental Management program is dedicated to meeting
its responsibilities in reducing risks, creating a safe work environment, and
protecting public safety.
Our proposed FY 1996 budget for the Environmental Management Program is a
declining budget given an equal work scope but it will still allow us to
fulfill legal and moral commitments while simultaneously streamlining our
program. This streamlining, however, has limits beyond which further cuts in
funding will trade off savings against safety. We are engaged in a daunting
effort to redirect the national commitment from production of nuclear weapons
for our national security strategy to resolving the resulting widespread
environmental and safety problems at thousands of contaminated sites across
the country. We have an obligation to do no less and we are dedicated to
producing meaningful results.
Thank you.
53
John Michael sto A. Toman (TOMAN_M)
Two 6/20/95 1.30p
Environ - Climate
From:
Char 88
To:
STIGLITZ J
Date:
Monday, June 19, 1995 8:17 pm
Subject: climate change deputies mtg
McGinty, Gibbons, Wirth, Cutter, Claussen are meeting tomorrow
(Tues) at 1.30 to go over a number ofissues from a broader
policy/politics/message prespective: CarTalk, New CAFE standards
for trucks, the "gap" in meeting the existing 2000 goals for
emission stabilization, budget, and the longer-term (post Berlin)
issues. I would say that the last issue is the most important,
though you may have some thoughts on the others. My
understanding is that your schedule is pretty tough tomorrow PM.
What do you want to do? If you don't want to go, do you want me
to cover? What role should Sally play? I will leave some info
with Lisa re: the meeting.
CC:
BRANCH_L
06/19/95
13:46
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NAT SEC COUNCIL
001/005
CCMI
NATIONAL SECURITY COUNCIL
Global Environmental Affairs Directorate
Phone: (202) 456-9141
Fax:
(202) 456-9140
TO:
Jack Gibbon
Tim Wirth
Katie McGinty
Bo Cutter
Joe Stiglitz
FROM:
Eileen Claussen
DATE:
June 19, 1995
No. of Pages 5 (including cover sheet)
MESSAGE: For our meeting tomorrow.
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STATE UE37
CLIMATE CHANGE: NEXT STEPS NEGOTIATIONS
ISSUE:
What posture should the United States adopt with regard to
forthcoming negotiations of a protocol under the climate
convention?
ESSENTIAL FACTORS:
The United States agreed in Berlin to a negotiating process
that will lead to a protocol/another legal instrument in 1997.
Since then, a number of items have become clearer. First,
the gap between our commitment to return U.S. greenhouse gas
emissions to 1990 levels by 2000 and results under current
programs is about as large as the initial gap we faced two
years ago when the action plan was developed (i.e., plus or
minus 100 million metric tons), while our ability to close the
gap has significantly diminished. Second, the 104th Congress
has slashed FY 95 funding for our voluntary programs and will
likely dismantle them altogether in FY 96. This could put us
further behind by as much as 60-70 MMT. Third, the 104th
Congress is likely to cut the Administration's funding request E
for the Global Environment Facility by more than 50 percent and
our ability to support developing country efforts to deal with
climate change will be seriously retarded in other areas
well. Fourth, the 104th Congress is threatening to e
funding for many global change research programs as well
funding for various U.N. activities related to climate change.
including funding for the climate convention.
Under these circumstances, the Administration will be hard
pressed to deliver on existing commitments, much less enter
into a new round of negotiations aimed at further commitments
in the post 2000 period.
Before embarking on these negotiations, we must consider
carefully the options before us.
OPTION #1 - Withdraw
Indicate to our Annex I partners that we are not prepared
to enter into negotiations on next steps at this time since we
have no way of delivering on the kinds of commitments they will
seek; lay the blame clearly on Congress.
OPTION #2 - Advance
Engage actively in negotiations of next steps because the
threat to the global environment from climate change is simply
too serious to ignore; be prepared to consider approaches such
as caps/trading and coordinated fiscal instruments (e.g.
06/19/95
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-2-
carbon/energy taxes), recognizing from the outset that Congress
and many parts of industry will howl; either forward such a
protocol to Congress for it to reject or defer transmitting it
until a more receptive Congress emerges.
OPTION #3 - Muddle Through
Engage in negotiations but reject far-reaching commitments;
seek to argue the Europeans back to reality and cajole the
Congress/industry to support a modest result.
PROS AND CONS
Option #1
Pro:
Accurately reflects current domestic situation in
which Congress will not deliver on Administration
commitments
Avoids having the Administration slammed from left and
right for the next two years
Avoids downstream accusations of bad faith
Lays blame for inaction where it belongs and could
ultimately force a change in Congressional attitudes
Con:
Totally inconsistent with Administration belief in the
need for action to counter the serious climate change
threat
Allows Congress to dictate Administration policy
Administration, not the Congress, might be blamed by
U.S. NGOs and other governments
Would destroy momentum of Berlin Mandate and cripple
international efforts to deal with climate change
Option #2
Pro:
Buys important time if the threat of climate change
ultimately materializes as many fear and sends a clear
signal to U.S. industry and the rest of the world
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--- NAT SEC COUNCIL
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Takes the moral "high road," clearly signalling the
Administration's belief in the problem and resolve to
deal with it seriously
Would be warmly endorsed by environmental NGOs and
other governments
Would lay blame for any failure to act on the protocol
negotiated clearly on Congress
Con:
Would assure "holy war" between the Administration and
Congress and invite further Congressional efforts to
cut funding/programs. and otherwise make political hay
out of the climate issue
Would likely alienate a large segment of the U.S.
private sector
Would open the Administration to charges of
environmental extremism that might resonate with voters
Could backfire on Administration if public chose to
blame Admistration for going too far rather than
Congress for not going far enough
Option #3
Pro:
Avoids extreme decisions on climate change with their
potential for serious political fallout
Could take advantage of the known fears of some
foreign governments and their private sectors with
far-reaching actions and might avoid having the United
States shoulder the entire blame for modest results
Could enlist support from Congressional and industry
moderates for important, but modest results
Would be perceived as a sober approach and avoid
public backlash against the Administration
Con:
Would likely do little to advance meaningful solutions
to the threat of climate change
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Risks criticism from the left (environmental NGOs and
advanced European countries) for not doing enough and
from the right (Congressional and industry
conservatives) for going too far
Provides no guarantee that ultimate agreements reached
will reflect U.S. concerns and avoid anti-competitive
results nor that Congress or the U.S. private sector
will ultimately endorse the results
Potentially subjects the Administration to two years
of difficult negotiations and bad press when the
Administration's ability to deliver is essentially
controlled by Congress
Withdrawal/Redaction Marker
Clinton Library
DOCUMENT NO.
SUBJECT/TITLE
DATE
RESTRICTION
AND TYPE
001. memo
To Joseph Stiglitz from John Shlaes, re: Meeting with representatives
09/21/1994
b(6)
of the Global Climate Coalition [PII] [partial] (1 page)
COLLECTION:
Clinton Presidential Records
Council of Economic Advisers
Stiglitz, Joseph
OA/Box Number: 9554
FOLDER TITLE:
Environment - Climate Change [Folder I]
2017-1095-F
bg241
RESTRICTION CODES
Presidential Records Act - |44 U.S.C. 2204(a)]
Freedom of Information Act - 15 U.S.C. 552(b)|
PI National Security Classified Information [(a)(1) of the PRA|
b(1) National security classified information [(b)(1) of the FOIA]
P2 Relating to the appointment to Federal office [(a)(2) of the PRAJ
b(2) Release would disclose internal personnel rules and practices of
P3 Release would violate a Federal statute [(a)(3) of the PRA|
an agency |(b)(2) of the FOIA]
P4 Release would disclose trade secrets or confidential commercial or
b(3) Release would violate a Federal statute [(b)(3) of the FOIA]
financial information |(a)(4) of the PRA|
b(4) Release would disclose trade secrets or confidential or financial
P5 Release would disclose confidential advice between the President
information ((b)(4) of the FOIA]
and his advisors, or between such advisors [a)(5) of the PRAJ
b(6) Release would constitute a clearly unwarranted invasion of
P6 Release would constitute a clearly unwarranted invasion of
personal privacy [(b)(6) of the FOIA]
personal privacy |(a)(6) of the PRA|
b(7) Release would disclose information compiled for law enforcement
purposes [(b)(7) of the FOIA]
C. Closed in accordance with restrictions contained in donor's deed
b(8) Release would disclose information concerning the regulation of
of gift.
financial institutions [(b)(8) of the FOIA]
PRM. Personal record misfile defined in accordance with 44 U.S.C.
b(9) Release would disclose geological or geophysical information
2201(3).
concerning wells [(b)(9) of the FOIA]
RR. Document will be reviewed upon request.
Wed, 9/21/94, 3Pm
GLOBAL CLIMATE COALITION
GROWTH GLOBAL )
CC:AR
IN
A
SK
MT
MEMORANDUM
DATE:
September 21, 1994
TO:
Joseph Stiglitz
FROM:
John Shlaes
SUBJECT:
Meeting with representatives of the Global Climate Coalition
Following is a list of GCC representatives who will be attending the meeting at 3:00 p.m. today
in Room 324, Old Executive Office Building:
Name
Company
Birth Date
John Shlaes
Global Climate Coalition
Richard Briggs
Association of American Railroads
Raymond Harry
Southern Company
Russel Jones
American Petroleum Institute
[001]
Robert McFadden
American Automobile Manufacturers
(b)(6)
Association
Paul Cicio
Dow Chemical
Harry Foster
General Motors
Constance Holmes
National Coal Association
If you require any further information, please do not hesitate to contact us.
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
SENT BY:GCC
; 8- 8-94 :11:34AM ;
GCC-
202 395 6958;# 1
Wed, 9/21/94,3-48
GLOBAL CLIMATE COALITION R.324
ENVIRONMENT
W/AK,Toman
GROWTH IN A GLOBAL
CC: SK
August 8, 1994
Member
would like to meet appou.
Per alan, GIC reps
Mr. Joseph Stiglitz
Council of Economic Advisors
He recommends that you
Room 3145
Old Executive Office Building
do. should I net up a
Washington, D.C. 20500
mts? GRE would like to
Dear Joseph:
meet ASAP. No
Yes- NO_
As you know, the climate issue and implementation of the climate convention is critical to U.S.
industry.
The Global Climate Coalition has been actively involved in deliberations on this issue for the
last several years both here at home and overseas. We recognize it is an important issue to the
future of U.S. competitiveness, and that the U.S. will be involved in continuing negotiations on
the Climate Convention for some years to come.
As the U.S. and other countries approach the upcoming August meetings in Geneva, and are
confronted with March's Conference of Parties, we feel that a meeting could be quite useful to
members of the Coalition and will give us the opportunity to exchange views on an important
issue to industry. We would intend to bring with us senior Board Members of the Global 5 00
Climate Coalition.
We look forward to the opportunity to meet with you.
down
Sincerely,
Jon John Executive Shlaes Aplues Director
pain
637-3164
CC:
Allen Krupnick
9/1 resewed dinf in
viaLiz
1331 Pennsylvania Avenue, NW
Suite 1500 . North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202)638-1043
Fax: (202) 838-1032
SENT BY:GCC
; 8- 8-94 :11:34AM ;
GCC->
202 395 6958;# 2
GLOBAL CLIMATE COALITION
PRESS OFFICE: (202) 628-3622
CROMITH
BACKGROUNDER
IN
1331 PENNSYLVANIA AVE. NW
SUITE 1500 - NORTH TOWER
WASHINGTON, DC 20004-1703
Global Climate Coalition
An Overview
What It Is:
The Global Climate Coalition (GCC) is an organization of business trade associations and
private companies established in 1989 to coordinate business participation in the scientific and
policy debate on the global climate change issue.
GCC is dedicated to: 1) promoting scientific research on global climate change, 2) analyzing
economic and social impacts of policy options, 3) creating an understanding of the global
dimensions of the issue to ensure that solutions are addressed equitably by all nations, 4)
encouraging transfer of technology to developing nations, and 5) promoting a voluntary
commitment among members to "Guiding Principles for Business" that benefit the
environment, are consistent with good business practices and are technically and economically
feasible.
What it Does:
GCC is the leading voice for industry on the global climate change issue, and represents its
members before government agencies, Congress, the media and the general public. The
coalition contributes to a balanced debate on global climate change by sponsoring independent
research and studies that examine the potential impacts of proposed global climate change
policies on the economy. Through educational materials and programs. GCC supports an
informed press and public, and an open scientific dialogue.
Where does GCC Stand?
GCC does not disagree with the presumption that there is a natural "greenhouse effect" which
protects the Earth from the freezing rigors of space. In addition, GCC agrees that the amount
of so-called greenhouse gases in the Earth's atmosphere are increasing. It is an open question
however, whether manmade contributions of greenhouse gases have contributed, or will ever
contribute to an "enhanced greenhouse effect," which could result in a potentially harmful
increase in global surface air temperatures.
There is considerable uncertainty within the scientific community about fundamental questions
relating to this issue. Predictions about anthropogenic global warming are based on computer
models designed to simulate atmospheric chemistry. GCC agrees with a growing number of
scientists who point out that these climate models (which have been used to frame the debate)
can neither confirm that global warming is occurring now or predict future climate changes.
While some minor climate changes have suggested, it has yet to be determined whether these
are the result of natural forces (like solar flares). human activity, natural long-term climate
cycles or a combination of all of these factors.
SENT-BY:QCC
; 8- 8-94 :11:35AM ;
GCC->
202 395 6958:# 3
GCC supports a coordinated international research program, the continuation of U.S. climate
research efforts ($1.4 billion requested for FY 1993), in addition to independent and industry
sponsored research. GCC also supports activities to reduce greenhouse gas emissions that
make sense in their own right, thus continuing sound business practices that will lead to more
efficient use of energy.
GCC believes that there are trade-offs associated with many of the regulatory schemes to
control greenhouse gas emissions. Some of these proposals would impose a direct tax on
businesses and consumers through energy or environmental fees while other proposals would
impose a hidden tax through other indirect, control measures. These trade-offs would include
higher energy and product costs to American consumers, higher operating costs for industry
and a potential negative impact on employment. Importantly, many of these proposals would
create a competitive advantage for our international trading partners at the expense of U.S. jobs
and economic growth.
Who are GCC Members?
The current membership of GCC represents a broad cross-section of U.S. business
organizations and companies representing a range of industrial sectors, including: oil, coal,
paper, automobile manufacturing, railroads, chemical manufacturing, and utilities.
How is GCC Structured?
The GCC Board of Directors serves as the organization's governing body. The Operating
Committee oversees the functional implementation of GCC activites, and John Shlaes,
Executive Director, has oversight of day-to-day operations. To address specific aspects of the
global climate change issue and to evaluate policy options. GCC utilizes twelve committees,
including Science and Technology, Technology Cooperation, Economic Analysis, Industry
Initiatives, and International, to name a few.
For More Information:
Global Climate Coalition
Press Office
1331 Pennsylvania Ave., NW
Phone: (202) 628-3622/Fax:(202) 639-8685
Suite 1500 - North Lobby
Executive Director
Washington, DC 20004
Phone: (202) 637-3158/ Fax:(202) 638-1043
Doc 2913
SENT-BY:GCC
; 8- 8-94 ;11:35AM ;
GCC->
202 395 6958;# 4
GLOBAL CLIMATE COALITION
ENVIRONMENT
GROWTH
IN
A
GLOBAL
GCC BOARD OF DIRECTORS
Aluminum Association, Inc.
Dave Parker
American Automobile Manufacturers Association
Andrew Card
American Electric Power Service
Dale Heydlauff
American Forest & Paper Institute
Red Cavaney
American Iron & Steel Institute
Andrew Sharkey
American Mining Congress
Jack A. Knebel
American Petroleum Institute
Charles DiBona
American Portland Cement Alliance
Richard Creighton
Association of American Railroads
Richard Briggs
Atlantic Richfield Company
William Leake
Chemical Manufacturers Association
Fred Webber
Chevron
R.L. Hartung
Cincinnati Gas & Electric
Thomas Chaney
Council of Industrial Boiler Owners
William B. Marx
CSX Corporation
Woodruff M. Price
Dow Chemical USA
R.W. Jewell
Drummond Company, Inc.
Bruce Windham
Duke Power
Roy Hamme
Edison Electric Institute
Thomas Kuhn
ELCON
John Hughes
Exxon
Gerald Graves
Illinois Power
Jesse Price
Kaiser Aluminum & Chemical Corporation
Robert E. Cole
Mobil Corporation
James Taylor
National Association of Manufacturers
Jerry Jasinowski
National Coal Association
Richard Lawson
National Lime Association
Tom Potter
NRECA
Robert Bergland
Phillips Petroleum Company
J. Bryan Whitworth
Process Gas Consumers
Glen Howard
Southern Company Services
John Richardson
Texaco, Inc.
J. Donald Annett
U.S. Chamber of Commerce
Jeffrey Joseph
Union Electric Company
Joseph Burke
GCC Executive Director
John Shlaes
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
From:
Sally M. Kane (KANE_S)
To:
BRANCH L
Date:
Tuesday, September 6, 1994 5:49 pm
Subject: JES Mtg w/GCC Reps on 9/21 -Reply
yes, I am interested.
From:
Lisa D. Branch (BRANCH_L)
To:
kane S
-
Date:
Thursday, September 1, 1994 5:01 pm
Subject:
JES Mtg w/GCC Reps on 9/21
Joe is meeting with senior Board members (5 or 6) of the Global
Climate Coalition on Wed, 9/21, fm 3-4, in his ofc. Alan K. and
Mike Toman will also attend this mtg. Are you're interested in
sitting in on the mtg? Topic: climate issue & the implementation
of the climate convention.
Let me know ASAP. (I may move the mtg to the conference rm
later, if gets too big.)
of sent 01222
GLOBAL CLIMATE COALITION
ENVIRONMENT
GROWTH IN A GLOBAL
Thursday, August 11, 1994
Joe Peninder PL
Mr. Joseph Stiglitz
she Jy of meet of
I lan, this aroup
Member
Council of Economic Advisors
w/you (ree 67
O.E.O.B.
8/60/19 01. 11ay want set
Room 3145
Washington DC, 20500
to meet ASHP.
Dear Mr. Stiglitz:
No
As you know, the Global Climate Coalition and its members continue to follow closely initiatives
by the U.S. and other countries on climate change issues. We feel it is important to provide
industry's views on these matters. We were pleased to have the opportunity yesterday to submit
to the State Department our comments on the U.S. Climate Action Report Draft of August 3,
1994, a copy of which you will find attached. Additionally, we are providing you with the GCC's
views on Joint Implementation and Additionality and several key issues to be considered at INC-
10, which we hope you will consider as the U.S. develops its climate policy and its positions in
the international climate negotiations.
If you have any questions, please do not hesitate to contact us.
Codulas John Shlaes
Sincerely
KD
Executive Director
should we do
Attachments:
- Recommendations of The Global Climate Coalition on The U.S. Climate Action Report
- GCC Comments on The Issues of Joint Implementation & Adequacy
- GCC Comments on Additional Issues for Consideration at INC-10:
- Comments on the Report on Implementation (AC/AC237/48)
- Comments on the Rules of Procedure (AC/AC237/58)
- Comments on the First Review of Commitments (AC/AC237/63)
- Comments on Subsidiary Bodies (AC/AC237/64)
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
SENT BY:GCC
; 8- 8-94 :11:34AM ;
GCC->
202 395 6958;# 1
WK018/22
GLOBAL CLIMATE COALITION
GROWTH GLOBAL )
IN
A
CC: SK
August 8, 1994
Per alan, GIC repo2
Mr. Joseph Stiglitz
Member
would like tomeet after
Council of Economic Advisors
He recommends that you
Room 3145
Old Executive Office Building
do. Should Inct up to K
Washington, D.C. 20500
mts? GDC would like
meet ASAP. it
Dear Joseph:
Yes- no_
As you know, the climate issue and implementation of the climate convention is critical to U.S.
industry.
The Global Climate Coalition has been actively involved in deliberations on this issue for the
last several years both here at home and overseas. We recognize it is an important issue to the
future of U.S. competitiveness, and that the U.S. will be involved in continuing negotiations on
the Climate Convention for some years to come.
As the U.S. and other countries approach the upcoming August meetings in Geneva, and are
confronted with March's Conference of Parties, we feel that a meeting could be quite useful to
members of the Coalition and will give us the opportunity to exchange views on an important
issue to industry. We would intend to bring with us senior Board Members of the Global
Climate Coalition.
We look forward to the opportunity to meet with you.
Sincerely,
Jon John Executive Shlaes Aplues Director
CC: Allen Krupnick
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
SENT BY:GCC
; 8- 8-94 :11:34AM ;
GCC-
202 395 6958;# 2
GLOBAL CLIMATE COALITION
PRESS OFFICE: (202) 628-3622
CROMITH
BACKGROUNDER
INA
1331 PENNSYLVANIA AVE. NW
SUITE 1500 - NORTH TOWER
WASHINGTON, DC 20004-1703
Global Climate Coalition
An Overview
What It Is:
The Global Climate Coalition (GCC) is an organization of business trade associations and
private companies established in 1989 to coordinate business participation in the scientific and
policy debate on the global climate change issue.
GCC is dedicated to: 1) promoting scientific research on global climate change, 2) analyzing
economic and social impacts of policy options, 3) creating an understanding of the global
dimensions of the issue to ensure that solutions are addressed equitably by all nations, 4)
encouraging transfer of technology to developing nations, and 5) promoting a voluntary
commitment among members to "Guiding Principles for Business" that benefit the
environment, are consistent with good business practices and are technically and economically
feasible.
What it Does:
GCC is the leading voice for industry on the global climate change issue, and represents its
members before government agencies, Congress, the media and the general public. The
coalition contributes to a balanced debate on global climate change by sponsoring independent
research and studies that examine the potential impacts of proposed global climate change
policies on the economy. Through educational materials and programs, GCC supports an
informed press and public, and an open scientific dialogue.
Where does GCC Stand?
GCC does not disagree with the presumption that there is a natural "greenhouse effect" which
protects the Earth from the freezing rigors of space. In addition, GCC agrees that the amount
of so-called greenhouse gases in the Earth's atmosphere are increasing. It is an open question
however, whether manmade contributions of greenhouse gases have contributed, or will ever
contribute to an "enhanced greenhouse effect," which could result in a potentially harmful
increase in global surface air temperatures.
There is considerable uncertainty within the scientific community about fundamental questions
relating to this issue. Predictions about anthropogenic global warming are based on computer
models designed to simulate atmospheric chemistry. GCC agrees with a growing number of
scientists who point out that these climate models (which have been used to frame the debate)
can neither confirm that global warming is occurring now or predict future climate changes.
While some minor climate changes have suggested, it has yet to be determined whether these
are the result of natural forces (like solar flares). human activity, natural long-term climate
cycles or a combination of all of these factors.
SENT BY GCC
:8- 8-94 :11:35AM
GCC->
202 395 6958;# 3
GCC supports a coordinated international research program, the continuation of U.S. climate
research efforts ($1.4 billion requested for FY 1993), in addition to independent and industry
sponsored research. GCC also supports activities to reduce greenhouse gas emissions that
make sense in their own right, thus continuing sound business practices that will lead to more
efficient use of energy.
GCC believes that there are trade-offs associated with many of the regulatory schemes to
control greenhouse gas emissions. Some of these proposals would impose a direct tax on
businesses and consumers through energy or environmental fees while other proposals would
impose a hidden tax through other indirect, control measures. These trade-offs would include
higher energy and product costs to American consumers, higher operating costs for industry
and a potential negative impact on employment. Importantly, many of these proposals would
create a competitive advantage for our international trading partners at the expense of U.S. jobs
and economic growth.
Who are GCC Members?
The current membership of GCC represents a broad cross-section of U.S. business
organizations and companies representing a range of industrial sectors, including: oil, coal,
paper, automobile manufacturing, railroads, chemical manufacturing, and utilities.
How is GCC Structured?
The GCC Board of Directors serves as the organization's governing body. The Operating
Committee oversees the functional implementation of GCC activites, and John Shlaes,
Executive Director, has oversight of day-to-day operations. To address specific aspects of the
global climate change issue and to evaluate policy options, GCC utilizes twelve committees,
including Science and Technology, Technology Cooperation, Economic Analysis, Industry
Initiatives, and International, to name a few.
For More Information:
Global Climate Coalition
Press Office
1331 Pennsylvania Ave., NW
Phone: (202) 628-3622/Fax:(202) 639-8685
Suite 1500 - North Lobby
Executive Director
Washington, DC 20004
Phone: (202) 637-3158/ Fax:(202) 638-1043
Doc 2913
SENT BY:GCC
; 8- 8-94 :11:35AM ;
GCC-
202 395 6958;# 4
GLOBAL CLIMATE COALITION
ENVIRONMENT
GROWTH
IN
A
GLOBAL
GCC BOARD OF DIRECTORS
Aluminum Association, Inc.
Dave Parker
American Automobile Manufacturers Association
Andrew Card
American Electric Power Service
Dale Heydlauff
American Forest & Paper Institute
Red Cavaney
American Iron & Steel Institute
Andrew Sharkey
American Mining Congress
Jack A. Knebel
American Petroleum Institute
Charles DiBona
American Portland Cement Alliance
Richard Creighton
Association of American Railroads
Richard Briggs
Atlantic Richfield Company
William Leake
Chemical Manufacturers Association
Fred Webber
Chevron
R.L. Hartung
Cincinnati Gas & Electric
Thomas Chaney
Council of Industrial Boiler Owners
William B. Marx
CSX Corporation
Woodruff M. Price
Dow Chemical USA
R.W. Jewell
Drummond Company, Inc.
Bruce Windham
Duke Power
Roy Hamme
Edison Electric Institute
Thomas Kuhn
ELCON
John Hughes
Exxon
Gerald Graves
Illinois Power
Jesse Price
Kaiser Aluminum & Chemical Corporation
Robert E. Cole
Mobil Corporation
James Taylor
National Association of Manufacturers
Jerry Jasinowski
National Coal Association
Richard Lawson
National Lime Association
Tom Potter
NRECA
Robert Bergland
Phillips Petroleum Company
J. Bryan Whitworth
Process Gas Consumers
Glen Howard
Southern Company Services
John Richardson
Texaco, Inc.
J. Donald Annett
U.S. Chamber of Commerce
Jeffrey Joseph
Union Electric Company
Joseph Burke
GCC Executive Director
John Shlaes
1331 Pennsylvania Avenue, NW
Suite 1500 . North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
GLOBAL CLIMATE COALITION
Comments on:
*
The Draft U.S. Climate Action Report (August 10, 1994)
*
Issues of Joint Implementation & Additionality (August 11, 1994)
*
Additional Issues For Consideration at INC-10 (August 11, 1994):
- The Report on Implementation (A/AC237/48)
- The Rules of Procedure (A/AC237/58)
- The First Review of Commitments (A/AC237/63)
- Subsidiary Bodies (A/AC237/64)
August 12, 1994
GLOBAL CLIMATE COALITION
ENVIRONMENT
GROWTH IN A GLOBAL
Thursday, August 11, 1994
Mr. Joseph Stiglitz
Member
Council of Economic Advisors
O.E.O.B.
Room 3145
Washington DC, 20500
Dear Mr. Stiglitz:
As you know, the Global Climate Coalition and its members continue to follow closely initiatives
by the U.S. and other countries on climate change issues. We feel it is important to provide
industry's views on these matters. We were pleased to have the opportunity yesterday to submit
to the State Department our comments on the U.S. Climate Action Report Draft of August 3,
1994, a copy of which you will find attached. Additionally, we are providing you with the GCC's
views on Joint Implementation and Additionality and several key issues to be considered at INC-
10, which we hope you will consider as the U.S. develops its climate policy and its positions in
the international climate negotiations.
If you have any questions, please do not hesitate to contact us.
Executive Codulas Director
Sincerely
John Shlaes
Attachments:
- Recommendations of The Global Climate Coalition on The U.S. Climate Action Report
- GCC Comments on The Issues of Joint Implementation & Adequacy
- GCC Comments on Additional Issues for Consideration at INC-10:
- Comments on the Report on Implementation (AC/AC237/48)
- Comments on the Rules of Procedure (AC/AC237/58)
- Comments on the First Review of Commitments (AC/AC237/63)
- Comments on Subsidiary Bodies (AC/AC237/64)
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
GROWTHINA GROWTH GLOBAL GL INA CLIMATE GLOBAL ENVIRONMENT COALITION
RECOMMENDATIONS OF THE
GLOBAL CLIMATE COALITION
on the
U.S. CLIMATE ACTION REPORT
August 10, 1994
GLOBAL CLIMATE COALITION
POSITION STATEMENT ON DRAFT U.S. CLIMATE ACTION REPORT
INTRODUCTION
The Global Climate Coalition appreciates the opportunity to comment on portions of the draft
U.S. Climate Action Report. We assume that given the short review period, additional more
complete drafts will be provided for public review before the final versions are submitted to the
INC. The following comments reflect the GCC's response to the draft given the seven-day lead
time. We look forward to commenting on the next draft, including the missing Introduction and
Executive Summary.
In March of 1993 the Global Climate Coalition provided the Administration with a detailed
comprehensive analysis of the Administration's proposed U.S. Climate Action Report. (Ref.
3) The issues raised in that submission still reflect the basis for the Global Climate Coalition's
position. We are pleased that the Administration has adopted voluntary actions as the basis and
core of the U.S. Plan. However, we still have a number of concerns which are reflected in the
following comments.
It is becoming more and more apparent that developing countries will play a key role in the
climate change issue. Four-fifths of the world's people live in developing countries and most
of the population, economic and energy demand growth-and the resulting emissions-are
projected to occur there. Furthermore, these countries now emit the largest share of global
greenhouse gas emissions, and according to the 1992 supplementary report of the
Intergovernmental Panel on Climate Change, their share of emissions will rise to 68 percent of
the total energy related co² emissions by 2025. For this reason, to the extent that actions may
be required, measures to facilitate developing country participation in climate change activities
will become a growing necessity. The Global Climate Coalition is convinced that technology
development, technology transfer and joint implementation which focus on promoting
collaboration with developing countries and countries whose economies are in transition are
central to achieving the Framework Convention's goal of stabilizing greenhouse gas emission.
The U.S. and others should make every effort to expand the number of developing countries that
are parties to the Convention.
The business and industrial community is ideally placed to provide the technologies and
management practices required to enable these countries to enlarge and diversity less polluting
energy sources, as well as acquire energy efficiency technologies for more efficient power
plants, transportation systems, lighting, refrigeration, air conditioning, building design, and the
GCC/August 1994
1
like. The Global Climate Coalition believes that by providing essential technologies and creating
job opportunities, technology transfer programs can be extremely helpful in addressing
environmental challenges and meeting the economic needs of developing countries and those
countries with economies in transition. And because it will open additional markets for U.S.
goods and services abroad, these programs will also benefit the United States.
The Global Climate Coalition believes the United States must promote efforts to implement the
many provisions outlined in the Framework Convention on Climate Change before
recommending additional mandates beyond those now in the Convention. The current
knowledge of climate change science and our understanding of its effects, which will require
years of additional research before we can more fully understand the impact of man-made
emissions on the climate, do not justify new commitments at this time. Therefore, a sensible
and cost-effective approach for the U.S. to promote global action, as detailed in the Convention,
would be to encourage technology transfer and voluntary business/government partnerships.
EXECUTIVE SUMMARY
Post-2000 Actions:
Additional post-2000 commitments should not be made because the state of the science does not
justify them and because current actions will have substantial post-2000 effects.
The discussion of the inadequacy of the U.S. actions to meet the ultimate
objectives of the Framework Convention in the post-2000 period is not required
or appropriate in the initial submission to the Conference of the Parties, is highly
inaccurate and should be deleted. The actions described in the draft report,
including mitigation, adaptations, scientific research and technology development
and transfer will have substantial impact in the post-2000 period. The fact that
many of the impacts cannot be forecast at this time should not be used as a basis
for stating that they are non-existent or inadequate. Many of the measures in the
Plan were developed only within the past 18 months, and have not yet been
substantially implemented. The state of the science does not justify adopting any
additional commitments or actions at this time. The science remains highly
uncertain; the next scientific assessment of the IPCC will not be available until
1995.
The implementation and success of the mitigation, research, and technology
cooperation actions already underway will need to be evaluated and then to serve
as the basis of later decisions. Thus new actions are not now justified, and there
is even less justification for seeking new commitments at this time.
GCC/August 1994
2
1990 Baseline:
The 1990 greenhouse gas emissions baseline should not now be changed by using the new and
unvalidated data. Furthermore it will take time to gauge the impacts of current and additional
actions being undertaken by industry, government and others.
Since it is the position of the Administration that Articles 4.2 (a) and (b) of the
Convention do not address adequately the objective of the Convention because it
does not address post-2000 action, the Climate Action Report would logically and
appropriately discuss action put into place prior to 2000. The discussion of post-
2000 commitments should be left to other fora. As noted in the transmittal letter
to the draft Report, there is a serious internal inconsistency in the greenhouse gas
emissions data for 1990. The data in the inventory chapter are new and have not
previously been available for public review and validation. The presentation of
the data in the inventory chapter does not provide adequate supporting detail to
permit a careful evaluation. If the new inventory data are adopted, with no other
corresponding changes in the modelling and forecasts contained in the mitigation
chapter, it would imply that the draft plan falls short of the goal established by
the President for bringing projected emissions in the year 2000 to 1990 levels.
This is a serious issue to be bringing to the attention of the interested parties at
this late stage of the process for completing the U.S. Climate Action Report.
Until the proposed new data can be subjected to a peer review, it should not be
included in the U.S. Climate Action Plan. This action can be taken without
prejudice to the ultimate outcome, because the Framework Convention provides
ample flexibility for the Annex I Countries to revise and update their submissions
to the Contractual Parties.
International Actions and Joint Implementation:
Joint Implementation, the private sector role in foreign investments and expanding the
participation of developing countries in the Convention are all vital to U.S. progress and
leadership.
The United States needs to adopt more of a leadership role in seeking
international action on climate change. Developing countries will account for an
increasing share of global greenhouse gas emissions (as much as 70% by 2025).
The draft Report should address this issue in greater depth.
U.S. policies to promote market reforms will encourage more efficient economic
development with greater sensitivity to environmental concerns. U.S. private
industry has played and will continue to play a major role in investments in
environmentally-oriented economic development. Yet U.S. private sector efforts
are not discussed in any degree in the Report. The Administration's proposals
for Joint Implementation are only a first step and can and should be expanded.
GCC/August 1994
3
National Circumstances and Historical Trends:
U.S. is and has been a leader in improving energy efficiencies and thereby reducing greenhouse
gas emissions substantially below levels they would otherwise reach. This progress occurred
even though U.S. resources, industry, climate, geography and other circumstances are markedly
different than other countries.
This provides an overview discussion of national circumstances that affect
greenhouse gas emissions and climate policies. However, more discussion is
needed about the capital stock of physical infrastructure, its normal cycles of
replacement, and the implications for climate change mitigation and adaptation
actions. As a related issue, more discussion should be added to the Report on the
actions that have been taken to date to curb greenhouse gas emissions through
improved energy efficiency and similar actions, especially in the two decades
before 1990. The U.S. has been the leader among the developed countries in a
number of areas of energy efficiency improvement. These actions should be
noted in the Report, in order to better represent the leadership position taken by
the U.S. In particular, U.S. industry has been a world leader in improving energy
efficiency and reducing greenhouse gas emissions, especially in energy intensive
industries. These improvements are independent of structural shifts in the U.S.
economy.
State of the Science:
There are substantial uncertainties in the science of global climate change which must be
resolved before any further commitments to "aims" occur.
The scientific understanding of global climate change is highly uncertain.
Nonetheless the draft Report includes a number of references to the potential
adverse impacts of global climate change that represent worst-case views and are
not properly qualified. Examples include: the discussions of sea level rise and
wetland migration and of forest migration. A number of specific instances are
discussed in the detailed comments.
Adaptation:
Adaptation strategies should be an important part of the overall U.S. approach to global climate
change.
The draft Report discusses the importance of actions and the need to begin plans
for and facilitate adaptation. It also notes that in many resource areas there
currently exist a variety of management problems to which possible climate
change may add, and where the U.S. is already quite experienced in management
efforts to respond to change. The discussion of impacts generally is biased
GCC/August 1994
4
toward the worst case outcomes. The Discussion should be changed to recognize
that cloud cover and precipitation may well increase, that plants will be
beneficially affected by CO2 fertilization, and that sea level change may be zero
or modest if snowfall increases ice accumulations in some regions. It should be
clearly stated that the assessment of impacts depends on general circulation
models which all acknowledge are rudimentary at best. The results can vary
drastically depending on such areas of uncertainty as how to specify cloud
behavior.
Research and Public Education:
Scientific research to resolve the substantial uncertainties regarding climate change;
dissemination of the results globally, energy technology development to facilitate reduced
emissions, and better understanding of the economic impacts of climate change are critical
elements of the U.S. Action Plan.
The plan describes a robust plan of scientific research to improve our
understanding of global climate change. In view of the current large
uncertainties, and the potentially significant consequences of both climate change
and mitigation and adaption efforts, such a research program is necessary and
should continue to be accorded a high priority. However, greater emphasis needs
to be placed upon economics research and technology development. Investments
in economics research will enable policymakers to fashion more cost-effective
strategies over time and to avoid seriously adverse effects on the U.S. and world
economy and their economic growth. The development of new technology
options is absolutely essential as a longer term component of strategy for the
Plan.
Long Term Approach and Technology Development:
The U.S. actions underway already will have substantial post-2000 impacts and we should
continue on the path of voluntary greenhouse gas emission reductions that make economic sense
in their own right. More industry access to and government coordination of the Administration's
recent technology initiatives would improve their potential for emissions reductions.
The U.S. Action Plan should be described as a comprehensive long-term
approach including immediate mitigation, scientific research, technology research,
technology transfer and cooperation, and adaptation. The Plan should not be seen
as a short-term effort to meet the year 2000 goal. Pending more definite
scientific information the Plan should consist of prudent cost-effective efforts to
limit the growth of greenhouse gas emissions and enhance greenhouse sinks and
reservoirs. Minimizing the discussion of technology development undercuts this
view and encourages people to focus on immediate, short-term considerations.
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5
Chapter 2. National Circumstances
General Comments:
Historical Improvements, in Particular Industrial Energy Efficiency Improvements, Have
Been Substantial. The draft discusses the national circumstances of the U.S. and how they affect
energy consumption. Historical trends in energy consumption and actions to save energy
especially during the two decades before 1990 are explained, except for industrial energy
efficiency improvements. Thus, the following points from recent studies (Refs. 1 and 2) should
be added:
In comparison with other industrialized countries, the U.S. uses energy
differently, not less efficiently.
Higher levels of manufacturing energy intensity appear to be due to differences
in industry structure, use of raw materials, lower levels of capital investment and
other factors. Limited data on unit energy efficiency, energy required per
physical unit of output, in manufacturing suggest that there may not be a
significant difference among countries in unit efficiency, relative to these other
factors.
Looking at historical trends, the U.S. generally has made a greater improvement
than other industrial nations in energy performance over the past two decades.
Capital Stock and Availability Constraints. The discussion of energy consumption would
be greatly improved if it added an explanation regarding constraints on existing capital
stock and limited availability of investment capital. These factors limit the Nation's
ability to quickly reduce energy use and emissions.
Much of the existing U.S. capital stock was developed in an environment of
cheap, abundant energy well before greenhouse gas emissions was raised as an
international issue.
Housing stock is very long-lived. Its location determines the need for
transportation services. The existing transportation infrastructure is also long-
lived and determines the modes of transportation which are available. Much of
the commercial and industrial capital stock is also long lived.
Turning over these stocks to reduce greenhouse gas emissions would take a
relatively long time, because any given year's availability of investment capital
S small relative to the size of the capital stocks. U.S. investment levels in terms
of percentage of GDP have been consistently lower than most of its industrial
competitors.
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Mandatory replacement of capital while it is still economically viable would
impose real costs on society, which could be very substantial.
Specific Comments:
Industrial Energy Efficiency Improvements. The discussion of industrial energy use is
overly focused on changes in energy intensity and structural shifts in the product mix. U.S.
industry has increased its output substantially over the period 1972-1991 without increasing
energy use. It has been able to achieve this with levels of investment to GDP that are lower
than its competitors, while meeting increasingly stringent environmental requirements. This has
been documented in several studies prepared for the GCC. (Refs. 1 and 2) Some industrial
sectors-such as the most energy-intensive industries-have made very substantial increases in
output while significantly reducing energy use. e.g.
The energy intensity of U.S. manufacturing, measured as energy consumed per
dollar of value-added, has declined by 50 percent from 1974 to 1988. By
comparison, Germany (the former Western Sector) declined by 33% and Japan
declined 49%.
When the data are adjusted to eliminate the effects of any structural shifts (e.g.,
shifts from energy intensive to light manufacturing), the U.S. and Japan were
about equal in energy intensity reductions. The U.S. achieved a 32 percent
reduction, while Germany declined by 23 percent and Japan declined by 34
percent.
High Energy Use Per Capita. [Page 2-6.] The relative energy use per capita of the U.S.
compared to Europe is attributed to lower urban population densities. In fact, per capita
energy use is affected by many factors. The sentence in the draft should read: "The
relatively low densities in the U.S. increase the use of energy for transportation."
Auto Fuel Efficiency. The transportation policy section indicates that large increases in
vehicle miles traveled have offset gains in fuel efficiency. Figure 2-12 shows that auto fuel
consumption declined from 1973 to 1990, with added passenger miles only partially offsetting
gains in MPG. The analysis by the EOP Group for the GGC (Ref. 2) shows that the U.S. has
made 100% improvement in new automobile fuel efficiency, more than the other major
industrialized countries.
Vehicle Emissions. Since laws, regulations and governmentally inspired programs exist
to reduce emissions of NOX and VOCs by automobiles and other sources, it is not
appropriate to state in the Government and Market Economy section that vehicle owners
bear only part of the costs of emissions while other society members and the environment
bear the rest. Vehicle owners bear the greatest percentage of costs associated with
emission reductions.
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Pollution Control Expenditures Do Not Move with the Economy. Because compliance
with environmental regulations is independent of the state of the economy and because
most environmental expenditures are not associated with the construction of new sources,
these expenditures do not "to a large extent move with the economy" and this portion
of the Composition and Growth section should be changed.
Chapter 3. Greenhouse Gas Emissions Inventory
General Comment:
The draft analyzes United States greenhouse gas emissions and their major sources. The
data which it presents is new and has not been available for public discussion. Its use
would change the whole tenor of the Report, showing that U.S. actions fall short of
meeting the year 2000 goal. The Report should be changed so that the Plan's actions do
meet the goal emissions by using the earlier estimates in Chapter 4 instead of new,
unvalidated estimates.
Specific Comments:
Pre-1990 Emissions Reductions Ignored. A more complete picture would be presented
if pre-1990 numbers were also given to establish trends and show that the United States
did not only begin efforts to reduce emissions in 1990, as the following demonstrates:
The average reduction in carbon dioxide emissions intensity for seven major
manufacturing industries was a total of 29.8 percent between 1974 and 1988.
These seven industries accounted for 36% of 1991 value added and 73% of
energy used in manufacturing. If the seven manufacturing industries had not both
improved their energy efficiency and reduced their carbon dioxide emissions
intensity, then total carbon dioxide emissions for the seven would have increased
by 96.3 million metric tons of carbon. Instead, the combined total of carbon
dioxide emissions for the seven manufacturing industries declined by 30.1 million
metric tons. (Ref. 1)
A Stable 1990 Estimate Is Needed. As introductory comments indicates the U.S. draft
includes contradictory 1990 base estimates for individual gases, and for total greenhouse
gas emissions, with one set in Chapter 3 and a differing set in Chapter 4: Mitigation: The
Action Plan. In order to avoid confusion, it is important that we make the best estimates
we can and then stick with them.
Pre-Industrial Concentration Levels Are Only Estimated. Several references are made
GCC/August 1994
8
This focus, however, does not reflect the long-term nature of the Convention's
commitment by developed nations to adopt policies and measures to limit man-made
emissions of greenhouse gases. The commitment does not stop in the year 2000. As a
result, the U.S. does not get the credit it should for its ongoing, comprehensive, long-
term programs to identify and develop new low-emission technologies and practices,
accelerate their domestic adoption, and adapt and transfer them to developing economies.
A revised description of the Plan would include the following elements:
Explicit description of the current status of implementation and expected future
results from actions such as the Energy Policy Act. Different parts of such
actions have different lead times and different rates at which results are achieved.
The United States will not get the credit which it should get for taking major
actions unless these timings and rates are understood in context.
Future reductions from current actions. For example, future emissions reductions
from the Climate Challenge and Climate Wise programs are not estimated and
projected. While they are characterized as major new initiatives, the U.S. gets
no credit because the focus is narrowed to 2000 only.
Government Funding and Coordination. Many of these actions are highly dependent on
adequacy of both government agency funding and coordination among the government agencies
involved. These factors should be explicitly recognized as sources of significant uncertainty.
Actions taken to avoid these problems should be described.
Specific Comments:
Use of Administration Baseline Minimizes U.S. Credit. The Plan's reductions in U.S.
emissions are counted from an Administration Baseline that includes the results of all
legislation already in effect and of all federal programs funded as of the date of Plan
issuance. This means that any results from recent legislation are not reflected as
achievements of the U.S. climate change effort even though they may have been enacted
as a part of that effort. The discussion should show those results so that credit is given.
There is no indication that the other Annex I countries are using a similar restrictive
approach. As a result, the U.S. Plan tends to underemphasize actions already underway
relative to the other Annex I countries.
Modify HFC and PFC Control Strategies. HFCs and PFCs should be decoupled because
they are completely different in source and effect. Voluntary partnership efforts should
be used in lieu of regulation.
Remove Reference to "Net" in Emissions Reductions. On June 1, 1994, the U.S. State
Department published in the Federal Register the guidelines for the U.S. Joint
Implementation Initiative. An important issue in the guidelines was not limiting the
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10
to percentage increases that "have" taken place since 1800. The text should state that
these are estimates since no actual measurement data is available.
Chapter 4. Mitigation - The Action Plan
General Comments:
This Chapter gives a clear and detailed account of the mitigation plan's approach, the
plan development process, the plan's actions both by greenhouse gas and by the source
sector of the emissions, and the estimated effects of the actions in the year 2000. The
intent of the following comments is to suggest further possible improvements including
increased emphasis on the advantages of the voluntary approach, reasons for diverse
actions; a need to characterize the plan as comprehensive and long-term; and the
importance of deleting "net" in reference to "emissions reductions" in the joint
implementation section.
Emphasize the Advantages of a Voluntary Approach. The text should, as it does, stress
the advantages of voluntary programs to facilitate rapid and significant action, building
on private sector initiatives already undertaken. Related points that should be added
include:
Cost-effectiveness. Voluntary actions are most cost-effective since they involve
low government costs; they provide information and technical assistance; and they
usually have a positive return to the participants.
Large Potential for Reductions. Studies suggest that the potential for energy
savings and emissions reductions may be very large and very widespread.
Avoid Regulatory Inefficiencies. Voluntary actions can be sought widely in a
wide range of U.S. economic activity without the loss of jobs, productivity, or
economic efficiency. Broad, mandated regulatory programs would curtail
economic activity.
Reasons for Many Diverse Actions. The draft also correctly emphasizes the portfolio
approach where actions that fall short are likely to be balanced by others that produce
more than expected. It should be added that diversified actions are needed because there
is no "magic bullet".
Plan Should Be Described as Comprehensive and Long-Term. The draft focuses
primarily on short-term (year 2000) results of the selected actions and includes, only
peripherally, current actions which may be productive in the long term (after 2000).
GCC/August 1994
9
concept to "net" emissions. (Ref. 4) This will allow a project to be evaluated on the
basis of greenhouse gases that it reduces, avoids or sequesters. The reference to "net"
as modifying "emissions reductions throughout the Joint Implementation section is
inappropriate. While net reductions of greenhouse gases are relevant as they relate to
a Party to the Convention, they are not appropriate for the entities conducting projects
in the pilot program. Each joint implementation project must be considered on its own
merits and not with regard to its relationship to the cumulative emissions of any parties
to the Convention. Since one of the principal benefits of a joint implementation project
is its potential for cost-effective emission reductions, the appropriate measure of a project
is the "savings" in emissions that it reduces, avoids or stores. The term "net" should be
removed where it appears in the Joint Implementation section.
Chapter 5. Impacts and Adaptation
General Comments:
Adaptation Actions Are Important. The draft is a good discussion of the importance of
adaptation actions and the need to begin thinking about how to plan for and facilitate
adaptation. It recognizes that natural ecosystems may be sensitive to certain potential
changes in climate and that we know little or nothing about how we might intervene in
response. It recognizes that while in many other resource areas there currently exists a
variety of management problems to which potential climate change may add, we are
already quite experienced in management efforts to cope with change.
Uncertainties Not Adequately Described. The draft has a tendency to describe the more
adverse potential changes without reminding the reader that due to the high uncertainties
associated with climate change, the actual outcome may be even positive or much less
adverse. The text needs to explicitly remind the reader that the major difficulty in trying
to plan and prepare for adaptation actions is the great uncertainty in the current state of
the science regarding possible global impacts.
Global Climate Change Will Increase Yields. U.S. agriculture vulnerabilities are
overstated and forest mitigation impacts are exaggerated. Recent studies confirm global
climate change will likely increase, not decrease, agricultural yields.
Discussion Is Biased Toward Worst Case Outcomes. The discussion of impacts stresses
the worst case outcomes without balancing them with more favorable outcomes that may
be just as likely. The draft should be revised to include recognition that:
Cloud cover and precipitation may increase;
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confirm that global climate change will likely increase, not decrease, agricultural yields.
Forest Migration Impacts Are Exaggerated. The draft raises the specter of massive
forestry losses by first assuming an extremely pessimistic temperature-rainfall outcome,
followed by a list of pessimistic forestry yields. Less pessimistic combinations are more
likely and the radical yield losses are far less likely to occur. Recent studies have shown
far greater adaptation and shifts in species rather than loss in total forestry yields as a
result of climate change. Finally, the Report ignores the widely recognized uncertainties
associated with the impacts of predicted shifts in forestry output because of seasonal and
diurnal changes in temperature range on forestry yields, which are maximized over a 50-
100-year period.
Impacts on Ecosystems of Climate Change Are Unknown. Since ecosystems are always
changing and the science of global climate change is still uncertain, this Report should
have more qualifications regarding the extent and possibility of adverse impacts on
ecosystems.
Chapter 6. Research and Public Education
General Comments:
Substantial Scientific Uncertainties Still Exist. All scientists do not agree that
"continuing emissions" are expected to lead to "significant global warming and rising sea
levels." Thus the U.S. should support research on the basic climate change science,
research and development of technologies to mitigate climate change, as well as more
analysis of the economic impacts of climate change on human activities.
Research in Basic Science Questions. The draft seems to reflect a broad discussion of
the U.S. Global Change Research Program. The U.S. should actively continue to carry
out its program of research into basic science questions about climate change, its likely
characteristics, and its potential impacts. The uncertainties about any important questions
in all three of these areas are very great. Sound decisions about policy and actions
cannot be made without a good understanding of what we know, the uncertainties
associated with what we know, and what we don't know.
Economics Relating to Climate Change Are not Given Adequate Attention. This area of
research has been greatly neglected in the U.S. government's efforts. Understanding the
economic impacts of climate change on human activities and on valued assets such as
natural systems is key to understanding the benefits from mitigation and adaptation
actions. Understanding the economics and cost-effectiveness of mitigation and adaptation
activities is key to understanding the implications from possible responses to climate
GCC/August 1994
13
Plant growth may increase due to co² fertilization;
Sea level may change very modestly or even decrease if increased precipitation
increases ice volume in Greenland and the Antarctic; and
Estimated impacts are the result of general circulation models that are still
considered primitive and that depend on specifications of often poorly understood
small-scale phenomenon that may or may not produce realistic results. Model
outputs, for example, are known to vary drastically depending on alternative
specifications of cloud behavior.
Specific Comments:
Chapter's First Sentence Should Not Go Beyond IPCC Assessments. Conclusions about
the science of climate change, particularly to the extent they rely on the use of global
circulation models which most experts agree have substantial uncertainties, should not
go beyond the IPCC assessments. The reference to the "bulk of scientific evidence"
suggests a level of certainty that does not yet exist and should be changed.
Probability of Increased Hurricanes Not Validated. The discussion of Coastal Systems
states that they would be highly vulnerable to "the increased occurance of hurricanes."
While some experts have suggested such an increase as a possible effect of climate
change, there does not seem to be general agreement that hurricanes are likely to
increase.
Relative Rates of Sea Level Rise and Wetlands Migration Are Not Known. The draft
provides that "the possible rate of sea level rise predicted by some climate models is
more rapid than the natural rate of wetland migration". What such a statement really
means is not clear. "Some climate models" is undefined. It would be more useful to
make a comparison using the IPPC consensus on likely sea level rise, with appropriate
characterization of the uncertainties surrounding that consensus level. It also seems clear
from later in the discussion that the natural ability of wetlands to migrate is not
understood satisfactorily, nor do we know much, if anything, about effects of potential
adaptation actions in response to sea level rise.
The Vulnerability of U.S. Agriculture Is Overstated. The discussion of agriculture
generally suggests that the net effect on American agriculture will be adverse. In fact,
agriculture will not be adversely impacted: it will most likely experience a net benefit.
Pursuant to the 1990 Farm Bill, Cornell University held a comprehensive program of
renowned agriculture and climate experts on the impacts of climate change on
agriculture. The results of that study are clear: agriculture would actually benefit,
economically and environmentally, from all but the most dire predictions of climate
change. These conclusions, as well as those of several other studies on agriculture,
GCC/August 1994
12
change. A greater share of the government's funding for climate change research should
go into these critical areas.
The Role of Technology Research and Development Needs to Be Expanded. The
discussion in the section Research on Mitigating Climate Change is inadequate in several
respects:
The United States supports a substantial volume of research in this area. Neither
this draft nor previous documents have adequately described the U.S. Plan as a
comprehensive, long-term effort.
That U.S. effort includes scientific research to understand climate change and
potential responses, immediate emissions reduction actions, research and
development to provide the technology and practices needed for the long term,
and cooperation with developing countries to adapt and transfer technology to
them.
Without vigorous technology research, the emissions from developing countries'
economic growth and population pressures will inevitably overwhelm any
emissions reduction actions of the industrial countries and, further, will make
these actions excessively expensive.
The U.S. does not give itself appropriate credit for its efforts, because it has not
adequately described those efforts as a comprehensive program designed to
address the long-term global nature of the climate change problem.
The U.S. encourages others to view climate change as a problem which must be
addressed by immediate, short-term mitigation actions. It neglects its own role
as pointed out clearly in this Plan of technology research as a necessary part of
any serious response to climate change. Short-term actions, beyond a certain
economic point, become increasingly costly and increase the risk that the
necessary long-term actions will not be undertaken within an appropriate time and
at an appropriate scale.
Specific Comments:
All Scientists Do Not Agree. [Page 6-5, first sentence.] This sentence is too broad,
especially since there is no definition of what is meant by "continuing emissions"
or
"significant global warming," and many experts do not agree that there will be a sea
level rise.
Only Ozone Depleting Gases Have Been Shown to Have Influenced Global Environment.
[Page 6-6, first sentence in Atmospheric Constituents section.] This sentence's reference
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to "observations of increasing concentration of all greenhouse gases" showing "that
human activities are significantly influencing the global environment" is a premature
conclusion except as to ozone depleting gases like CFCs.
Sea Levels May Not Rise. [Page 6-11, last paragraph, Regional Efforts section.] The
assertion that sea levels "could rise" needs to be balanced by recognition that there may
be no sea level rise due to increased snow fall at high latitudes causing more, not less,
Greenland and Antarctic ice, especially since most of the warming will be at night.
Chapter 7. International Activities
General Comments:
The Chapter's strong support for international cooperation and extensive detailing of U.S.
Government projects is recognized and positive. However it is strongly recommended
that joint implementation initiatives and overseas private sector development be
emphasized.
More Discussion of Joint Implementation Initiative Is Needed. This Chapter calls for a
more extensive discussion of the Joint Implementation Initiative. It is a critically
important factor in any U.S. Action Plan. Although the Mitigation Chapter has some
discussion about the Initiative, its importance justifies more discussion in this Chapter.
Provide More Private Sector Project Development. This Chapter fails to recognize and
emphasize the important role of the U.S. private sector in international activities. As
noted in Chapter 2, the U.S. is best characterized as a mixed economy. Yet Chapter 7
focuses only on government-sponsored activities. Thus the Chapter needs much more
discussion of the substantial number of projects that will improve energy demand and
supply efficiency being developed in other countries by U.S. private sector firms,
independent of the identified bilateral and multilateral programs discussed. These
projects range from ones without any U.S. Government or multilateral development bank
assistance, to those promoted during trade missions, to those which purchase insurance
from OPIC, to those which receive Ex-Im Bank financing, and still others. This point
is important because most energy related investment in developing countries will be made
by private investors, foreign and local, including multinational banks, insurance
companies and other sources of private capital.
More Recognition of the Importance of Market Reforms in Other Countries Is Desirable.
The Chapter needs to give greater recognition to the importance of local private
investment and use of market forces in developing countries and the need for a range of
actions which will encourage such investment. Aggressive U.S. investment is likely to
result in a more efficient energy demand and supply.
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Specific Comments:
Provide Additional Reference to Joint Implementation Initiative and Private Efforts.
[Page 7-3, International Activities.] Two new sentences should be added to the
conclusion of the first paragraph. "In addition, U.S. companies are currently developing
projects which employ the latest technology and new energy demand and supply projects.
The U.S. Initiative on Joint Implementation offers potential for expanding these
activities."
Eliminate Reference to "Sustainable Development." [Page 7-4, second paragraph, first
sentence.] "Sustainable development" has no commonly agreed upon definition. The
reference in Chapter 7 could be viewed as a limitation on the U.S. commitment to
facilitating the transfer of efficient technology. The last part of the sentence, "that can
help developing countries achieve sustainable development" should be deleted so that the
sentence will read, "The United States is committed to facilitating the commercial
transfer of energy-efficient and renewable-energy technologies." While the principle of
"sustainable development" is a good one, specific definitions of criteria need to be fully
developed before it can be effectively implemented.
Expand Discussion of Private Sector Efforts. [Page 7-5, first paragraph.] Either here,
or in a totally new section, there should be reference to the significant and useful U.S.
Government encouragement of private sector companies' efforts to develop efficient
energy demand and supply projects in foreign countries, independent of the private
company involvement in the bilateral and multilateral programs. This encouragement
ranges from special recognition and involvement of companies in Presidential or White
House initiatives; to promoting U.S. exports of energy efficient products or technologies
by U.S. Governmental agencies, trade missions and expositions; to providing insurance
through OPIC; to providing export financing through the Ex-Im Bank. Since most
energy related investment in developing countries will be made by private investors
(foreign and local), including by multinational banks, insurance companies and other
sources of private capital, and are likely to be efficient and to reduce emissions, U.S.
Government efforts should encourage private sector investment.
Add Joint Implementation Initiative and Privatization Discussion. [Page 7-5, first
paragraph.] Because of its unusual importance, a sentence should be added to reflect the
U.S. support for the Joint Implementation Initiative and privatization efforts in various
countries. "These efforts lay the foundation for the Joint Implementation Initiative by
demonstrating beneficial projects and results and encourage the continued efforts of
privatization of energy supply systems."
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Expand Joint Implementation Initiative Paragraph. [Page 7-7, Joint Implementation
paragraph.] Additional sentences should be added to the conclusion of the paragraph to
further support the importance of the Initiative. "Joint Implementation will create
additional examples of projects that create substantial emissions reductions. These
examples will serve as further models for projects not formally in the Initiative and thus
have a "multiplier effect" on the environment. This is a further reason that the U.S. will
be pressing at COP 1 for reasonable criteria applicable to joint implementation projects.
If the criteria are too stringent or costly, industry will not participate. This would not
be in the interest of the U.S. or developing countries nor would it serve to reduce
greenhouse gas emissions on a cost-effective basis."
Expand Trade Facilitation Introduction to Recognize Administration Efforts. [Page 7-
21.] The opening paragraphs, "Information Sharing and Trade Facilitation," do not
support the Administration's efforts to promote U.S. exports of efficient energy demand
and supply technologies. These paragraphs only refer to information sharing and omit
important efforts and initiatives. The following should be added after the third
paragraph: "The U.S. Government encourages private sector exports of efficient energy
demand and supply technologies, including renewable energy technologies, through many
means which include: special representation by U.S. Government officials, public
recognition, expositions, trade offices in foreign countries, insurance, export finance, and
direct finance. These programs are coordinated and expanded through interagency
committees promotion and support of exports."
Expand Substantially Discussion of For-Profit Sector Activities. [Page 7-29,
Nongovernmental Efforts.] This paragraph is inadequate to convey the significance of
NGO activities-environmental or industry. This paragraph should be expanded into
several paragraphs.
Information regarding scope and range of specific projects underway;
The role of lending institutions such as banks and insurance companies in
financing overseas projects; because of their long-term perspective they are likely
to insist on the use of energy efficient, and thus, emissions reducing,
technologies;
Overseas projects of U.S. private sector firms are likely to approximate energy
efficiencies of equivalent projects in the U.S. Most U.S. firms investing overseas
deploy technology that is consistent with U.S. standards in order to maintain
competitiveness and to avoid conflicts with host governments concerned about the
use of technology that is not current; and
Information about the scope and range of efforts by U.S. environmental
organizations and other not-for-profit organizations.
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17
Chapter 8. The Future
General Comments:
Post-2000 Actions Such as Establishment of "Aims" Need Not and Should Not Be
Addressed at This Time. Post 2000 commitments other than those already made need
not and should not be addressed in this current report or at the COP because so many
other issues involving the implementation of the Convention, the criteria for
establishment of joint implementation and the participation of developing countries,
should first be resolved. Furthermore, the next Intergovernmental Panel on Climate
Change (IPCC) regular assessment on the state of the science will not be completed until
the fourth quarter of 1995. This may reduce the uncertainty of key elements of the
science of climate change. Since the 1992 IPCC Special Assessment, much of the
scientific information and observations that have become available would not support
increased concern over the possibility of man-induced climate change nor would they
justify renegotiating the commitments of the developed country parties to the Convention.
Furthermore, no assessment has been done of the long term effects of current actions,
including actions of mitigation, technology research, and technology transfer.
It is Not Necessary or Desirable for the U.S. to Agree to or Propose Additional
Measures or "Aims." The implication that the U.S. will agree to or propose additional
measures such as mandatory targets and timetables or common regulatory or financial
measures to reduce emissions is inappropriate. Such measures cannot be justified on the
basis of (a) the current state of science; (b) the programs in the Action Plan which will
have enormous positive impact post 2000; or (c) the current inadequate participation in
the IPCC of the developing nations whose greenhouse gas emissions will far surpass
those from the U.S. and the rest of the developed world in the post-2000 time frame.
The Current U.S. Plan Already Includes Substantial Post-2000 Actions. The current Plan
already will have substantial post-2000 impacts. Some of these impacts, such as the
effects of current technology research programs, cannot be forecast at this time. Other
actions identified in the Plan that likely will continue into the post-2000 time frame
include: industry voluntary initiatives, efforts to better understand the basic science of
climate change; development of cost-effective joint implementation and technology
transfer projects to developing countries, which will help reduce these countries;'
greenhouse gas emissions.
Specific Comments:
Greater Recognition Needed for Efforts Underway. [Page 8-4, second column, first full
paragraph.] The very substantial efforts that have been initiated and are well underway
should be given greater recognition by changing the sentence to read "However, in spite
GCC/August 1994
18
of these very significant efforts, it is impossible, to predict precisely the future effect of
the U.S. programs."
Recognition of Efforts Underway and Uncertainties in Projections Needed. [Page 8-7,
Adjustment, first paragraph.] Further recognition of the substantial emission reduction
efforts underway and uncertainties in projections of emissions should be incorporated in
this paragraph by inserting the following sentence between the first and second sentences:
"In light of the initiatives begun in the last 12 months, the substantial progress of the
Plan, and the uncertainties in projections of emissions, it is premature to conclude the
Action Plan's initiatives will not be successful and that major policy or program changes
are required now for the United States."
It Is Premature to Assert Current Measures Unlikely to Be Sufficient. [Page 8-8, second
sentence.] It is premature to state that the current set of measures are "unlikely to be
sufficient in the longer term": the sentence should be modified to read "However, the
current set of measures are dependent on a wide range of factors and it is unclear at this
time what the long-term impacts will be..."
Justification Does Not Exist to Commit to Additional Measures. [Page 8-8, first
paragraph.] The sentence beginning "The United States recognizes....' should either be
eliminated because it is premature to commit to additional measures as stated above, or
the statement should be changed to emphasize "evaluation" rather than commitment to
new policies. Modified, the sentence would read: "The United States recognizes the
need to evaluate additional measures which may be needed to combat the longer trend
of rising emissions."
Premature to Promote Market Transition Away From Activities, Fuels and Technologies
Generating Large Emissions. [Page 8-8, first paragraph, penultimate sentence.] This
sentence promoting "market transition away from activities, fuels and technologies that
generates large emissions of greenhouse gases" is not justified by the state of the science.
Additional Reference to Technology Development regarding Coal and Petroleum Is
Necessary. [Page 8-8, last full paragraph.] To be comprehensive, the following
sentence should be added: "Continued development of technologies that will increase
efficiency in the combustion of coal and petroleum would also lead to reduced
emissions."
More Cost Benefit and Economic Analysis Should Be Supported. [Page 8-10,
penultimate sentence.] The use of cost benefit analysis by the long-run strategy working
group is desirable. However, before any recommendations are developed, the economic
impact of those recommendations on the U.S. economy, jobs, international trade and
competitiveness must be determined both for the economy as a whole and in its major
relevant sectors.
GCC/August 1994
19
Re: International Process. Although the U.S. has argued that actions called for by the
Convention are not adequate for the post-2000 period, the focus of the U.S. Government
at INC 10 and INC 11 leading up to COP 1 should be on the following issues: (a)
implementing actions rather than "aims": (b) preparation of a plan to implement the
Convention on a global basis; (c) the efficacy of actions being taken by the OECD
countries; (d) improvement of understanding of the science; (e) establishment of
reasonable criteria for joint implementation projects; and (f) detailed economic analyses
of the issue. Pursuit of these factors would involve measures outlined in the FCCC.
GCC/August 1994
20
References
1.
Global Climate Coalition. Energy Efficiency in U.S. Industry: Accomplishments and
Outlook. Prepared by the EOP Group, Inc. Washington: Global Climate Coalition,
October 1993.
2.
Global Climate Coalition. Leadership in Energy Efficiency: A Comparison of the U.S.
versus the Other Major Industrialized Countries. Prepared by the EOP Group, Inc.
Washington: Global Climate Coalition, March 1993.
3.
Global Climate Coalition. Position Statement and Recommendations on the U.S.
National Action Plan for Global Climate Change. Prepared by EOP Group, Inc.
Washington: Global Climate Coalition, March 1993.
4.
Global Climate Coalition. Comments, February 25, 1994, on Groundrule for U.S.
Initiative on Joint Implementation, 58 Fed. Reg. 66057-59, Dec. 17, 1993.
GCC/August 1994
21
United States Department of State
Washington, D.C. 20520
August 3, 1994
Dear Colleague:
Attached please find a copy of the draft U.S. Climate
Action Report. The revised, final version of this document
will constitute the U.S. national submission under the U.N.
Framework Convention on Climate Change. The United States is
required to make this submission by September 21, 1994.
Please note, this draft is still incomplete:
additional sections, specifically the introduction and
the executive summary, are being prepared;
some chapters will be significantly refined in the
revised, final version;
the data in the emissions inventory chapter and those in
the mitigation chapter differ and we are currently
reconciling them (the values in the mitigation chapter
were prepared using an emissions inventory developed
more than two years ago, while the material in the
inventory chapter itself is entirely new); and
final graphics and layout are still being completed.
Despite the extremely tight production schedule for this
document, we believe it vital to incorporate public review and
comment at this stage. For this reason we are providing copies
of this draft today, August 3, and request that any comments be
forwarded no later than August 10, 1994, to:
Daniel A. Reifsnyder, Director
Office of Global Change, Department of State, Room 4333
2201 C Street, Washington, D.C. 20520-7818
tel (202) 647-4069; fax (202) 647-0191
We anticipate that notice of availability of the final
document will be published in the Federal Register shortly
after it is submitted in September, with provision for a. formal
period of public review and comment thereafter.
Sincerely,
Rafe Pomerance
Deputy Assistant Secretary for
Environment and Development
GLOBAL CLIMATE COALITION COMMENTS
on the
ISSUES OF JOINT IMPLEMENTATION & ADEQUACY
August 11, 1994
Comments On
Joint Implementation and Additionality
The Clinton Administration has taken significant steps in defining the criteria that will
enable the private sector to support greenhouse gas reduction projects overseas. While these
steps are to be commended, questions remain.
The issue arises in the concept of "joint implementation," a phrase born in the
Framework Convention on Climate Change signed at the Rio Earth Summit and included in the
Administration's Climate Change Action Plan published last October. Simply stated, joint
implementation (JI) is a concept that would recognize a given party for actions taken to reduce
greenhouse gas emissions in another country. This could include everything from providing
more efficient technology to planting forests or introducing new energy-related management
techniques.
GCC Supports JI: The Global Climate Coalition enthusiastically supports JI. The
proposed program's approach of working through voluntary business/government partnerships
is fully responsive to the requirements of the Framework Convention and wholly consistent with
the way business and industry can work most effectively abroad.
Joint implementation programs focus on promoting collaboration with developing
countries and countries whose economies are in transition is central to achieving the Framework
Convention's goal of stabilizing greenhouse gas emissions. While developed countries emit the
largest share of greenhouse gas emissions today, the overall level of greenhouse gas emissions
from developing countries and countries whose economies are in transition is rising most rapidly.
They emit a far greater volume of greenhouse gases for each unit of their GDP than the United
States. Four-fifths of the world's people live in developing countries and most of the population,
economic and energy demand expansion--and the resulting emissions--are projected to occur
there, as their population is expected to represent 90 percent of the world's population growth
in the coming decades. The 1992 supplementary report of the Intergovernmental Panel on
Climate Change Indicated that 68 percent of the total energy related CO2 emissions will come
from non-OECD (Organization of Economic Cooperation and Development) countries by 2025.
The Department of Energy's Energy Information Agency reported recently in its publication
Energy Use and Carbon Emissions: Some International Comparisons that since 1970 CO₂
emissions have grown by 82% in developing countries compared to a 28% growth in developed
countries. For this reason, to the extent that actions may be required, measures to facilitate
developing country participation in climate change activities will become a growing necessity.
GCC/August 1994
Industry Can Contribute to JI: The Global Climate Coalition believes that by providing
essential technologies and creating job opportunities the Joint Implementation initiative can be
extremely helpful in addressing environmental challenges and meeting the economic needs of
developing countries and those countries with economies in transition. And because it will open
additional markets for U.S. goods and services abroad, the initiative will also benefit the United
States. The business and industrial community is ideally placed to provide the technologies and
management practices required to enable the developing countries and those countries with
economies in transition to enlarge and diversify less polluting energy sources. It is equally well
situated to help these countries acquire energy efficiency technologies for more efficient power
plants, transportation systems, lighting, refrigeration, air conditioning, building design, and the
like.
The business partnerships employed to shape this technology and management
cooperation would also develop a long-term relationship to help needy countries to adapt,
improve and upgrade technologies and introduce new management systems. It would employ
local people and train them; it would adapt and orient the technology and practices to meet local
conditions and the needs of the people and markets in these countries.
Promotion of JI is Essential: Because the mutual benefits of such cooperation is so
clear, the Global Climate Coalition believes the current effort to assess programs and procedures
for joint implementation through pilot programs will help define efficient, effective means to
implement the concept nationally and internationally. GCC strongly encourages the U.S.
Government to maintain its lead in this effort.
The Guidelines for Joint Implementation: On June 1, the U.S. State Department
published in the Federal Register the guidelines for the U.S. initiative on Joint Implementation
(USIJI) as contained in President Clinton's Climate Change Action Plan. The guidelines
essentially set out the groundrules for implementing USIJI, and they will surely have an
important influence on how the United States Government promotes the joint implementation
concept internationally. GCC and a number of its member organizations submitted extensive
comments last February after initial draft guidelines were published.
The State Department and other involved federal agencies worked hard to develop a
broad and comprehensive plan. A JI pilot program represents a new concept in international
structures and relationships; it is not a simple task. It would mark a substantially increased
involvement of private industry in helping to carry out an intergovernmental program.
The GCC is pleased to note that several key concerns were addressed in the guidelines
that appear to make the pilot program more workable, including the creation of a governmental
secretariat/special staff to help administer the USIJI and serve as a focal point to assist in
managing the program. Another important issue was not limiting the concept to "net"
emissions. This will allow projects to be evaluated on the basis of greenhouse gases that it
reduces, avoids or sequesters.
GCC/August 1994
GCC comments requesting more complete definitions or clarifications of procedures were
left for the Evaluation Panel to be set up under the USIJI program. How these procedures are
eventually defined could have an important impact on industry's ability to contribute to the
program.
Concerns About the New Criterion on Additionality: The GCC has strong concerns
about the concept of "additionality," which was added to the USIJI final groundrules and
therefore was not subject to public comment. The program criterion says that: "To be included
in the USIJI, the Evaluation Panel must find that a project submission involves specific measures
to reduce or sequester greenhouse gas emissions initiated as the result of the U.S. Initiative on
Joint Implementation, or in reasonable anticipation thereof." The State Department explained
that the criterion is designed to promote "additionality--that is, actions above and beyond those
that would have been taken otherwise."
In further clarification the State Department acknowledges that "most projects will be
implemented for multiple reasons", but less clearly it goes on to say, "At the same time, the
integrity of the pilot program would be undermined if participants were able simply to repackage
activities that would otherwise have been undertaken and submit them for inclusion under the
USIJI."
GCC is concerned with how this term will ultimately be defined and how it might affect
industry's ability to contribute to the USIJI program. Our initial fear is that overly stringent
application of the criteria would make it difficult for firms to take active part for it might unduly
restrict the number and types of projects and activities that would qualify for the program, and
it could introduce unnecessary subjective judgements on the reasons for the projects proposed.
As the Department acknowledges in its explanation of the guidelines, business firms and
others will undertake projects that reduce or sequester greenhouse gas emissions for a number
of reasons. Underlying each business venture will be the desire for profitability. Few will
initiate projects related to joint implementation purely for the purpose of reducing greenhouse
gas emissions, although this consideration could be sufficient to tilt the balance in favor of an
otherwise marginally economic venture.
GCC believes that joint implementation projects that achieve emission reductions should
be considered, approved and given appropriate "credit", and that seeking to establish whether
a proposed project would be undertaken purely in response to the U.S. Initiative on Joint
Implementation is much less relevant to achieving the goals of the program.
GCC understands the purpose of the program to be to encourage as many participants as
possible in their regular activities to join in reducing greenhouse gas emissions; subjective
debates over the grounds for undertaking a greenhouse gas reducing project can defeat the
purpose of this worthwhile purpose. GCC believes that projects which achieve emissions
reductions should be provided appropriate recognition regardless of the motivation for making
the investment.
GCC/August 1994
Multiple Values of JI: Joint implementation is encouragingly consistent with the
worldwide trend toward the use of free markets and market-oriented mechanisms for addressing
environmental concerns and promoting technology cooperation between developed and
developing worlds. Properly administered it can help potential partners to identify new markets
and strong overseas collaborators, promote the exchange of technology and information, reduce
costs, bring sound rates of return on investments and offer opportunities to diversify and obtain
other commercial benefits. At the same time, it can provide cost-effective greenhouse gas
emission reductions in other countries.
GCC believes strongly that the Joint Implementation Program should be defined and
administered so as to encourage as many collaborative activities as possible that make economic
sense and reduce greenhouse gas emissions. This will benefit world business and industry and
help protect the global environment.
This, we believe, is the spirit of the President's Climate Change Action Plan, and a spirit
and vision American business and industry will support with enthusiasm.
GCC/August 1994
GLOBAL CLIMATE COALITION COMMENTS
on the
REPORT ON IMPLEMENTATION
A/AC237/48
August 11, 1994
Comments On
Report on Implementation
A/AC237/48
The Global Climate Coalition (GCC) believes the intent of Article 7.2(f) of the Framework
Convention can best be met by having the Subsidiary Body for Implementation (SBI) prepare
and issue a Report on Implementation (ROI) following the first meeting of the Conference of
Parties. National action plans, as well as efforts by other countries to implement the
Framework Convention, should make up the bulk of this largely technical report. Moreover,
the ROI should be a public document rather than a negotiated document for it should provide
all Convention parties, the general public and the media transparent access to information on
how each country is progressing in its efforts to implement the Framework Convention.
1.
The Report on Implementation should be prepared after COP-1--The
Global Climate Coalition agrees with the interim secretariat that Annex I
National Action Plans will contain the bulk of any information communicated
in the first Report on Implementation. While some of those plans will be
available later this year, the secretariat does not have the human resources or
time needed to prepare an effective report before COP-1. Moreover, a hastily
prepared document would not serve well the needs of COP-1. Given the
already crowded agenda for the first conference of parties, any draft report on
implementation would have to be substantially amended at COP-1 to reflect
decisions taken by conference members.
2.
The Subsidiary Body for Implementation should prepare the document-The
Subsidiary Body for Implementation (SBI) is best suited to prepare the Report
on Implementation. Once national action plans have been submitted and the
Conference of Parties has met, SBI members should work with in country
government officials and NGOs to prepare a factual summary of Annex I
national action plans and efforts by other parties to limit greenhouse gas
emissions.
3.
The Document should be public and transparent--The Report on
Implementation should be a public, not a negotiated, document. The first
review should be completed and released by late 1995. It should report each
country's emission goals, progress to date and the impact these voluntary
efforts are having on the various economic sectors. The biennial release of
similar data would provide the public, the media and other parties to the
Convention timely, transparent access to the data needed to measure the
progress of Convention implementation.
4.
Final recommendation to COP-1--The GCC encourages the Committee to
adopt the above steps at INC-10 as a final recommendation to COP-1.
GCC/August 1994
GLOBAL CLIMATE COALITION COMMENTS
on the
RULES OF PROCEDURE
A/AC237/58
August 11, 1994
Comments on
Draft Rules of Procedure on the Conference of the Parties and
on the Subsidiary Bodies Established by the Convention
A/AC.237/58 and A/AC.237/WG.II/L.8
Rule 27, paragraph 5(a) states that "In the case of a subsidiary body that is open-ended, one
quarter of the Parties shall constitute a quorum. "
Rule 27, paragraph 5(b) states, in brackets, that "Decisions of subsidiary bodies shall be taken
by a majority of the Parties present and voting
"
Comment: Taken together this would mean - % -hat it is possible that decisions by the
Subsidiary Bodies called out in the Convention could be made by 13.5% of the Parties.
This could place the U.S., and even all the OECD countries, at a disadvantage since they
are so outnumbered by the non-OECD countries. The quorum requirements should be
the same as for the Conference of Parties (COP) as spelled out in Rule 31 (one third of
the Parties to the Convention be present to open or permit debate and two thirds present
for any decision to be taken). Likewise decisions on matters of substance should be
taken by a two-thirds vote of the Parties present and voting as stated in Rule 42 for the
COP.
Rule 30, Paragraph 2 states that "Meetings of the subsidiary bodies shall be held in private
unless the Conference of the Parties decides otherwise."
Comment: The footnote to Rule 30 states that "private" meetings would be interpreted
as permitting duly accredited observers to participate. This should be added to the text
of paragraph 2 or paragraph 2 should be changed to mirror Rule 30, paragraph 1 which
states that meetings of the COP shall be held in "public". Nongovernmental bodies must
be allowed to participate in the meetings of the Subsidiary Bodies to the same extent as
allowed under Rule 7 for the COP.
Rule 42, Paragraph 1 states, in brackets, that decisions by COP shall be taken "in the case of
the adoption of a proposed protocol., by a three-fourths majority vote..."
Comment: This bracketed text should be supported.
Again, since the U.S and the
OECD will be so outnumbered by the non-OECD nations, this should be an exception
to the two thirds majority vote rule for other matters of substance in Rule 42. Protocols
may commit Parties to far reaching actions with the same force and effect as amendments
to a treaty, and therefore should be subject to the same three-fourths approval
requirement as set forth for amendments in Article 15 of the Convention.
GCC/August 1994
Rule 7, paragraphs 1 & 2 state that non-governmental bodies qualified in matters covered by the
Convention may be represented at a session of the COP as an observer unless one third of the
Parties present object [paragraph 1], and such observers may "upon invitation of the President,
participate without the right to vote," unless one third of the Parties present object [paragraph
2).
Comment: The clause "upon invitation of the President" should be deleted from
paragraph 2. This gives too much power to the President to arbitrarily pick and
choose among NGOs regarding participation, and it is unnecessary since by definition
in paragraph 1 they are "qualified in matters covered by the Convention" and their
participation can be rejected by one third of the Parties.
Rule 36 states that normally proposals and amendments shall be introduced in writing and
circulated to the delegations and that as a general rule "no proposal" shall be discussed or put
to a vote unless copies have been circulated not later than the day preceding the meeting.
However, the President may permit discussion and consideration of "amendments to
proposals" or procedural motions even though they have "not been circulated" or are
circulated only on the same day.
Comment: Amendments to proposals should receive the same "general rule" of day
before circulation as proposals since they can be just as critical to Parties interests as
the base proposals themselves. It is particularly important that "voting" on
amendments come only after introduction the preceding day. This can be easily done
by inserting the words "or amendments to proposals" in the second sentence in
between the words "proposal" and "shall" and deleting the words "and consideration"
in the third sentence. There should be a separate sentence allowing procedural
motions to be discussed and voted on the same day as introduced.
GCC/August 1994
GLOBAL CLIMATE COALITION COMMENTS
on the
FIRST REVIEW OF COMMITMENTS
A/AC237/63
August 11, 1994
Comments on
First Review of Communications
From Parties to the Framework Convention on Climate Change
on Commitments
A/AC.237/63 (15 July 1994 draft)
I. Convention Mandate
Article 4.2(b) states that each Annex I Party shall communicate, within six months of the
entry into force of the Convention for that Party, and periodically thereafter, detailed
information on its policies and measures on limiting greenhouse gas (GHG) emissions
and enhancing GHG sinks; and that such information shall be reviewed by the First
Conference of the Parties (CoP-1).
Article 4.2(d) states that the First Conference of the Parties shall review the adequacy
of Article 4.2 (a) and (b); and that a second review of adequacy shall occur not later than
31 December 1998.
Article 4.1(j) states that Parties shall communicate to the Conference of Parties
information related to implementation, in accordance with Article 12.
Article 12.2 (a) & (b) states that Annex I parties shall communicate information
concerning implementation of their commitments under 4.2 (a) & (b) and their projected
effects on GHG emissions during the period referred to in Article 4.2(a).
Article 10.2 empowers the Subsidiary Body on Implementation with the authority to
"consider" information communicated under Article 12.1 & 12.2
Article 9.2(b) empowers the Subsidiary Body on Scientific and Technological Advice to
prepare assessments on the effects of measures taken in implementation of the
Convention.
II. Current Status
The Convention officially came into force on March 21, 1994, six months after 50
nations had ratified it on December 21, 1993. By September 21, 1994, the first
communications of the following 16 of the total 36 Annex I parties are due: United
States, Canada, Australia, Japan, Iceland, Sweden, Norway, New Zealand, United
Kingdom, Germany, Switzerland, Netherlands, Denmark, Portugal, Spain, European
Union. During INC-9 in February, Canada and the U.K. submitted their official
communications.
Eleven of the 36 Annex I parties are countries-in-transition (CITs), i.e., former Soviet
Bloc; and one nation (Turkey) has not yet signed or ratified the Convention.
GCC/August 1994
III. U.S. Position
At INC-9, the U.S. intervention proposed that each Annex I communication be reviewed
by a team composed of technical experts from developed and developing country Parties,
the Secretariat, NGOS, consultants and private sector organizations; and that this review
include country visits to resolve uncertainties posed by the written document. These
reports would be submitted to the Subsidiary Body for Scientific and Technological
Assessment (SUBSTA) to "develop an evaluation of the Parties aggregate efforts to meet
their communication obligations."
Due to time constraints, a formal review by SUBSTA is not possible before Cop-1. The
U.S., therefore, proposed that an 'ad hoc' body be created to review the first national
communications for the purpose of providing input to CoP-1 in its review of adequacy
of commitments; and that the assessment of the "aggregate efforts" be deferred until the
first formal meeting of the SUBSTA, which should occur within a few months after CoP-
1; and, that shortly thereafter CoP-2 should be held "to aggressively develop next steps"
in implementing the Convention.
Only two other parties (New Zealand and Canada) have submitted comments on this
issue. Canada states that the first review of communications and the review of adequacy
are properly, in the first instance, the responsibility of the, respectively, the SUBIM and
the SUBSTA. Since these are not yet functioning special interim arrangement are needed
to prepare for CoP-1. Canada proposes as "proxies", INC Working Group 1 for
SUBSTA and INC Working Group 2 for SUBIM. Canada and New Zealand argue in
favor of the Secretariat performing a limited 'compilation and synthesis' type of review
as the "first review".
IV. INC Secretariat Proposal
The Secretariat says that it is not possible to do, in time for CoP-1, an expert review of
individual national communications or a full aggregate review of all communications, but
it is possible for it to do a "compilation and synthesis" review in time for INC-11 if
sufficient guidance setting the parameters of this review is given by INC-10. Draft
parameters and a budget are proposed.
V. OECD Proposal
In June, the OECD held workshops in Paris to develop a proposal to submit to INC-10
providing for an initial "synthesis" report of all communications received to be followed
by assessments of individual national communications after CoP-1. A proposal for
country visits was very controversial and was limited to a 'trial basis'.
GCC/August 1994
VI.
Comments and Recommendations
1.
It is recognized, by the Parties and the INC Secretariat alike, that it is not
possible to do the type of review of first communications called for in the
Convention in time for CoP-1.
2.
It is also agreed that the Convention makes the first review of communications
an integral and essential part of the review of the adequacy of commitments.
3.
The various "interim" proposals do not rise to the level of meeting the
requirements of the Convention with respect to the process necessary for an
adequate review of "first communications" or of "adequacy". The proposal to
use INC Working Groups is interim "proxies" for Subsidiary Bodies would be
inappropriate as the latter are to be composed of government "experts" which the
Working Groups are not.
4.
Moreover, even if there were adequate time and resources, communications from
many of the Annex I parties would likely still be missing.
5.
It is, therefore, essential that CoP-1 defer a decision on the review of adequacy
and instead establish a process that will include provision for an adequate first
review of communications.
6.
CoP-1 should establish the rules of procedure and other organizational mandates
and arrangements to permit the prompt activization of the Subsidiary Bodies, and
set a date for their first meeting at a time no later than six months after CoP-1.
This schedule would permit the review of first communications to command the
attention of CoP-2 in 1996 with much greater assurance of a credible and useful
outcome.
7.
CoP- 1 should also direct the Secretariat to coordinate the selection of technical
review panels to prepare reports on the national communications, individually and
in the aggregate, to be submitted to the appropriate Subsidiary Bodies in advance
of their first meeting. These technical panels should include governmental
experts from Annex I and non-Annex I parties and non-governmental experts
from the private sector (including environmentalist and business groups).
8.
The credibility, transparency and comparability of the data and information
contained in the communications of Parties is a critical element in the "review of
adequacy" process and the viability of the Convention. The launch of this effort
should not be abbreviated or short-changed and the quality of the effort put at risk
for the sake of appearing to meet arbitrary deadlines. If that were to be the case,
the true "momentum" of the Convention could be seriously jeopardized, and with
it the prospects for the participation of developing nations.
GCC/August 1994
GLOBAL CLIMATE COALITION COMMENTS
on
SUBSIDIARY BODIES
A/AC/237/64
August 11, 1994
Comments on
The Roles of Subsidiary Bodies Under the Framework Convention
A/AC237/64
A clear distinction must be made between the role of the IPCC and the role of the Subsidiary
Bodies, especially the Subsidiary Body for Scientific and Technical Advice (SUBSTA).
There should be no doubt that the IPCC will remain an independent scientific body even after
the completion of the 1995 Second Assessment on Climate Change.
The Intergovernmental Panel on Climate Change (IPCC) was established in 1988 and has
gained a depth of experience in the science of climate change. Over time, the IPCC has
implemented procedures which incorporate the broadest possible peer review and critique.
These rules are aimed at assuring objectivity, balance and transparency. Unless the SUBSTA
is prepared to adopt these rules, including the opportunity for peer review, the independent
IPCC should be maintained and its relationship with the SUBSTA (and in turn with the COP)
be clearly defined.
Further, the IPCC is an established scientific body whose members include representatives of
most nations within the United Nations. Conversely, "voting' membership in the subsidiary
bodies is limited to the parties of the convention. The two are not necessarily identical. The
work and analysis conducted by the IPCC may be representative of a much wider set of input
than the analysis completed by the SUBSTA.
The SUBSTA should not be put in a position of "choosing" or "recommending" preferred
technologies but rather should only prepare data bases on ALL technologies.
The Secretariats note mentions that the SUBSTA could "Lay the groundwork with initial
emphasis on identifying, promoting access to, and disseminating information on state of the
art technologies and know-how...' (Paragraph 14 (d). It should not be the role of the
SUBSTA - or an body under the convention - to "pick and choose" among the many
commercial technologies available or to limit access to information on these. The SUBSTA
cannot act in place of the market, or attempt to influence the commercial market for
technologies. The SUBSTA's role should be limited to preparing a data base of all known
technologies (possibly in conjunction with the IEA) and to make this data base available to all
parties to the convention.
The meetings of the subsidiary bodies should be held at a time and in locations to ensure the
broadest participation including the participation of NGO'S. Where appropriate the
subsidiary body should invite the participation of relevant non-government expertise.
GCC/August 1994
Financial resources will limit the attendance of many representatives of less wealthy countries
unless these meeting are 1) held on a limited basis and 2) on a coordinated time schedule that
would maximize participation in task forces, work groups, etc. The secretariat suggests
many "open ended' working groups. The secretariat also suggests that meetings be held
where Parties are represented by permanent missions. We suggest that both would be
counter productive. Many open ended group. would eliminate fullest participation from
experts from the less wealthy countries. Representatives of permanent missions seldom
would have the expertise to contribute constructively to the technical discussions of the
subsidiary bodies. The subsidiary bodies should meet in conjunction with the COP with
possibly one interim meeting each year.
The meetings of all subsidiary bodies should be open to participation of NGO's in a manner
similar to that allowed by the IPCC and the INC. Further, the subsidiary bodies should
invite, where appropriate, the active participation by experts from the non-government
sector.
GCC/August 1994
GLOBAL CLIMATE COALITION
PRESS OFFICE: (202) 628-3622
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BACKGROUNDER
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WASHINGTON, DC 20004-1703
Global Climate Coalition
An Overview
What It Is:
The Global Climate Coalition (GCC) is an organization of business trade associations and
private companies established in 1989 to coordinate business participation in the scientific and
policy debate on the global climate change issue.
GCC is dedicated to: 1) promoting scientific research on global climate change, 2) analyzing
economic and social impacts of policy options, 3) creating an understanding of the global
dimensions of the issue to ensure that solutions are addressed equitably by all nations, 4)
encouraging transfer of technology to developing nations, and 5) promoting a voluntary
commitment among members to "Guiding Principles for Business" that benefit the
environment, are consistent with good business practices and are technically and economically
feasible.
What it Does:
GCC is the leading voice for industry on the global climate change issue, and represents its
members before government agencies, Congress, the media and the general public. The
coalition contributes to a balanced debate on global climate change by sponsoring independent
research and studies that examine the potential impacts of proposed global climate change
policies on the economy. Through educational materials and programs, GCC supports an
informed press and public, and an open scientific dialogue.
Where does GCC Stand?
GCC does not disagree with the presumption that there is a natural "greenhouse effect" which
protects the Earth from the freezing rigors of space. In addition, GCC agrees that the amount
of so-called greenhouse gases in the Earth's atmosphere are increasing. It is an open question
however, whether manmade contributions of greenhouse gases have contributed, or will ever
contribute to an "enhanced greenhouse effect," which could result in a potentially harmful
increase in global surface air temperatures.
There is considerable uncertainty within the scientific community about fundamental questions
relating to this issue. Predictions about anthropogenic global warming are based on computer
models designed to simulate atmospheric chemistry. GCC agrees with a growing number of
scientists who point out that these climate models (which have been used to frame the debate)
can neither confirm that global warming is occurring now or predict future climate changes.
While some minor climate changes have suggested, it has yet to be determined whether these
are the result of natural forces (like solar flares), human activity, natural long-term climate
cycles or a combination of all of these factors.
GCC supports a coordinated international research program, the continuation of U.S. climate
research efforts ($1.4 billion requested for FY 1993), in addition to independent and industry
sponsored research. GCC also supports activities to reduce greenhouse gas emissions that
make sense in their own right, thus continuing sound business practices that will lead to more
efficient use of energy.
GCC believes that there are trade-offs associated with many of the regulatory schemes to
control greenhouse gas emissions. Some of these proposals would impose a direct tax on
businesses and consumers through energy or environmental fees while other proposals would
impose a hidden tax through other indirect, control measures. These trade-offs would include
higher energy and product costs to American consumers, higher operating costs for industry
and a potential negative impact on employment. Importantly, many of these proposals would
create a competitive advantage for our international trading partners at the expense of U.S. jobs
and economic growth.
Who are GCC Members?
The current membership of GCC represents a broad cross-section of U.S. business
organizations and companies representing a range of industrial sectors, including: oil, coal,
paper, automobile manufacturing, railroads, chemical manufacturing, and utilities.
How is GCC Structured?
The GCC Board of Directors serves as the organization's governing body. The Operating
Committee oversees the functional implementation of GCC activites, and John Shlaes,
Executive Director, has oversight of day-to-day operations. To address specific aspects of the
global climate change issue and to evaluate policy options, GCC utilizes twelve committees,
including Science and Technology, Technology Cooperation, Economic Analysis, Industry
Initiatives, and International, to name a few.
For More Information:
Global Climate Coalition
1331 Pennsylvania Ave., NW
Suite 1500 - North Lobby
Executive Director
Washington, DC 20004
Phone: (202) 637-3158/ Fax:(202) 638-1043
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GLOBAL CLIMATE COALITION
GROWTH A GLOBAL )
IN
GLOBAL CLIMATE COALITION MEMBERSHIP
Board Membership
General Membership
Aluminum Association, Inc.
American Commercial Barge Line Co.
American Automobile Manufacturers
Amoco Corporation
Association
Arizona Public Service Company
American Electric Power Service
Association of International Automobile
Corporation
Manufacturers
American Forest & Paper Institute
BP America, Inc.
American Iron & Steel Institute
Burlington Northern Railroad
American Mining Congress
CONRAIL
American Petroleum Institute
Consumers Power
American Portland Cement Alliance
Du Pont Company
Association of American Railroads
Duquesne Light Company
Atlantic Richfield Company
Eastman Kodak
Chemical Manufacturers Association
Goodyear Tire & Rubber Co.
Chevron
LTV Steel Company, Inc.
Cincinnati Gas & Electric Company
Norfolk Southern
Council of Industrial Boiler Owners
Northern Indiana Public Service Co.
CSX Transportation, Inc.
Ohio Edison
Dow Chemical Company
Pennsylvania Power & Light Company
Drummond Company
Railway Progess Institute
Duke Power Company
Shell Oil Company
Edison Electric Institute
Union Carbide
ELCON
Union Pacific Railroad
Exxon
Illinois Power Company
Kaiser Aluminum & Chemical Corp.
Mobil Corporation
National Association of Manufacturers
National Coal Association
National Lime Association
National Rural Electric Cooperative
Association
Phillips Petroleum Company
Process Gas Consumers
The Southern Company
Texaco, Inc.
U.S. Chamber of Commerce
Union Electric Company
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032