Editor's Note: David Schnare, the former EPA transition official who wrote this article, left the agency earlier this year over concerns about infighting among administration appointees and Administrator Scott Pruitt's alleged lack of engagement. In it, his first since departing the agency, he discusses his reasons for leaving and his views on EPA's upcoming climate science review. The views expressed here are his.
It is a high honor to be asked to serve on a presidential transition team -- an even higher one to be asked to go back into an agency into a major role. The Presidential Personnel Office, with the full support of Transition Team Leader and Senior White House Advisor, Don Benton, asked me to act as, and then become permanently appointed as the Assistant Deputy Administrator, a position Administrator Pruitt described as the Chief Operating Officer for the Agency. A few days before the White House officially made that assignment, I resigned. As a 34 year-veteran of EPA, a PhD environmental scientist and attorney who retired from the Agency in 2011, President Trump’s team asked me to go into the agency in a leadership role implementing the EPA transition plan. Based on discussions with the entire EPA transition team, I had drafted approximately 80% of the agency transition plan. Why resign and why explain why?
My commitment to the President and his agenda is ongoing, despite my resignation. Over 20 news organizations have asked me to spell out why I left, and previously I have not as I saw no value to President Trump in doing so. However, telling this brief tale deflates attention on my resignation and allows attention to go to an important issue that demands attention from within and outside the Agency -- specifically, how to address the highly controversial issue of climate and the human influence on climate.
In simple terms, Mr. Pruitt and I simply never meshed.
Every agency or departmental transition team confronted two challenges: rapid implementation of the President’s agenda and team-building with the career managers. The EPA transition team faced extreme antagonism by some lower level employees within the Agency and open hostility from the initial Pruitt appointments. My job was to form a working bridge between the Pruitt team and the career professionals while ensuring the President’s transition plan moved forward. In the final call, I was unable achieve this mission.
Bill Ruckelshaus, the Agency’s first and fifth Administrator, recently discussed why senior government officials resign, something he did twice. He explained that it comes down to a question of fundamental principles. Where the appointee is being forced to compromise his core principles, he has no choice but to resign. In my case, Mr. Pruitt and I had basic irreconcilable differences in management approach and professional ethics.
Because, in the opening weeks of his tenure, Mr. Pruitt chose not to engage closely with the senior career managers, my function was to bring time- and policy-sensitive issues to his attention and brief him on those issues. Each time, I suggested he meet with the appropriate career managers so as to ensure he had detailed answers to any questions he might have. He rarely did so, relying instead on the extremely short briefs I provided at his morning staff meetings.
This problem came to a head at a meeting in which I gave him notice that a delegated EPA authority was going to be used by a career manager on a sensitive issue, an action required by law. I advised him on the Agency’s options and he rejected them all. Mr. Pruitt then ordered a different course of action, one I firmly believe is not permitted under law. He left it to me or his chief of staff to direct the career staff to implement the action. In my view, this violated our oaths of office and placed the career staff in an untenable position -- one from which I could not extract them, whether I stayed or resigned. The next week I was ordered to no longer meet with Mr. Pruitt on policy issues, having already been directed to not participate in either personnel or budget matters. Thus, I could not do the job the President asked me to do. Under those conditions, there was but one choice and I made it.
Revisiting Climate Science
In my commitment to President Trump’s agenda, I have identified a structural problem that does not seem to be understood by EPA appointees or White House policy staff. I came to Inside EPA to highlight this problem as it is the loudest megaphone into the Agency and within the environmental policy community. It needs to be raised now and strongly, or the President will lose the opportunity to carry out one of his key election promises: reexamination of climate science and how that science informs policy-making that has vast economic and political implications.
There are three problems involving climate science that many others within the Administration do not understand: (i) The law does not assign responsibility for assessing the significance of greenhouse gas emissions to EPA; (ii) the law does not permit the federal government to assume the science is settled; and, (iii) the Red team -- Blue team concept simply does not apply within the scientific community. I opt for the Red, White and Blue team approach, with a heavy dash of Karl Popper thrown in.
Who is responsible for assessing climate science?
The Subcommittee on Global Change Research (GCRC) of the Committee on Environment, Natural Resources, and Sustainability of the National Science and Technology Council was established to plan and coordinate the U.S. Global Change Research Program (USGCRP), as described in the Global Change Research Act of 1990 (P.L. 101-606). The USGCRP provides for development and coordination of a comprehensive and integrated research program, which assesses, predicts and responds to human-induced and natural processes of global change.1 Among its eleven functions is the duty to conduct a periodic scientific assessment which addresses the following:
(1) integrates, evaluates, and interprets the findings of the Program and discusses the scientific uncertainties associated with such findings;
(2) analyzes the effects of global change on the natural environment, agriculture, energy production and use, land and water resources, transportation, human health and welfare, human social systems, and biological diversity; and
(3) analyzes current trends in global change, both human-induced and natural, and projects major trends for the subsequent 25 to 100 years.
The staff at the Office of Science and Technology Policy are currently engaged in writing the statutorily mandated 2017 “National Climate Assessment.” This is a legacy of the Obama administration, one being done as quickly and quietly as possible by the Obama holdovers ensconced at OSTP. The Assessment draws on the science as discussed in another statutorily mandated report, the “Research Plan.” Both the Assessment (currently in draft) and the Research Plan parrot an alarmist view of the “settled” science. The Research Plan was published days before President Trump took office. Both the Research Plan and the Assessment need to go back to ground zero and be redone, and a properly appointed OSTP leadership and staff have all the authority and tools needed to reexamine the science.
How do we know a redux is needed? The National Academy of Science (well known to lean toward climate alarmism), said so.2 Among many recommendations, the Academy stated a need for “expanding the discussion of specific topic areas, to better reflect the full breadth of literature and understanding of the subject” and “Wherever possible, figures depicting observed trends should indicate the statistical significance of those trends, or confidence intervals.” A close reading of the NAS review indicates the GCRC effort reeks of failure to employ the basics of science as encapsulated in the Information Quality Act (IQA) guidelines that apply to federal agencies, including the White House offices.
EPA provides but one of fourteen members to GCRC and its representative is not currently the chairman of the committee nor does it provide the executive director. OSTP and its GCRC have the authority and resources to conduct a reexamination of the science. EPA can play, but it isn’t in charge and doesn’t have the authority under the Global Change Research Act of 1990 to unilaterally undertake this effort.
Red Team -- Blue Team Silliness.
The latest riff on climate has been the suggestion of using a Red team -- Blue team approach. As eminent a scientist as Steven Koonin, a theoretical physicist who served as Obama’s undersecretary for science at the Energy Department, has endorsed the idea. He has been accused of setting up a strawman argument regarding whether climate science is “settled.”3 Mr. Pruitt has indicated he wants Dr. Koonin to be the lead in a Red Team -- Blue Team effort. I can understand that an attorney like Mr. Pruitt might be comfortable with an adversarial process; or that legislators (read politicians) would think this an idea worthy of use. It’s an idea that grows out of ignorance of the scientific process or science itself.
Red teaming is a practice coming out of the national security community. According to them, it is the practice of viewing a problem from an adversary or competitor’s perspective. Those of us who have served in the military understand the value of having one’s strategic and tactical approaches challenged by opposing forces. That, however, is not how science works. Science is supposed to be done by individuals “disinterested” in the outcome of their observations. It is not supposed to be a political blood sport.
Science consists of making observations and attempting to “falsify” hypotheses based on observation. Where there are conflicting hypotheses, scientists test each. Often, each is falsified and each hypothesis has to be tossed. Lately, “science” has foundered on the rocks of academic imperialism. There is less of a division between “alarmists” and “skeptics” than between those whose future (read funding) is risked by climate skepticism (the alarmists) and those who need not worry about such support (the skeptics). The risk of loss of funding, and consequently loss of academic promotion and standing, is real and imposing.
Non-transparency in academic science has exacerbated this problem. When the public, and especially the technologically and scientifically literate public, can’t look deeply into the practices of scientists, there is no pressure to maintain the ethics of science.
What is needed is the convening of a scientific reevaluation of climate science, done in the most public fashion. As I discussed with senior EPA leadership before I left, webcasting a detailed discussion of critical issues, with the opportunity for viewers to pose appropriate technical questions during the discussion, would allow for the transparency and the depth needed to ensure a full rendering of our understanding of greenhouse gases on climate. It would also educate the 90 percent of U.S. citizens who admit they don’t know enough about climate change to have a view on the subject.
One additional element would be needed. All points of view and kinds of expertise need to be at the table. In the climate community, this has been nearly impossible to achieve, the animosity and professional fear within the community being what it is. A simple solution is to require any federal grantee or grant applicant to agree to participate in these sessions. You want to feed at the federal trough, you have to be willing to engage with the federal government processes, including these kinds of scientific enterprises.
What about Mr. Pruitt’s idea of televising a climate debate? It’s an extension of failure to understand how science works. Structured debates are too limiting. If televised, they are too short. If a continuing loop of “Red Team argument,” then “Blue Team argument,” it is inefficient. The depth needed to be examined cannot be reached in a televised debate. It will in a scientific conclave specifically intended to reach such depths and provide for discussion rather than antagonistic debate.
Finally, the fundamental questions that require reconsideration in light of evolving scientific observations include the following and should be the starting point for a full redraft of the Climate Science Special Report:
What empirical data (a) characterize climate conditions, changes in those conditions and normal variability in those conditions; and, (b) meet IQA criteria for quality, objectivity, utility and integrity?
What do IQA-qualified data tell us about how the climate has changed?
Using only IQA-qualified empirical data, (a) how sensitive is climate to GHGs, (b) how much of that sensitivity is attributable to human activity, and (c) what is the utility of these data as the basis for policy-making?
What methods for prediction of changes in climate conditions meet criteria necessary to allow policy reliance on such forecasting, criteria such as those mandated in financial forecasting?
What IQA-qualified empirical data characterize the beneficial and harmful consequences to human health and welfare of qualified climate change forecasts?
If EPA has a role to play, it is as a member of the GCRC. On climate issues, Mr. Pruitt will best serve this nation in following the law, implementing the climate statute and relying on competent scientists to follow fundamental scientific principles. Recognizing the challenges of a very large government with many departments and agencies, now is the time for leadership from the top. The President needs to appoint a head of OSTP and he or she needs to reorganize and recommit to a proper examination of climate science. -- David Schnare
2 See, “Review of the Draft Climate Science Special Report” at http://dels.nas.edu/Report/Review-Draft-Climate-Science/24712.