Introduction

Thank you Mr. Chairman and members of the Committee. I am Daniel Lashof, a senior scientist with the Natural Resources Defense Council (NRDC). Previously I was an Environmental Scientist at the Environmental Protection Agency, where I was the lead author of the Report to Congress Policy Options for Stabilizing Global Climate. I hold a doctorate in Energy and Resources from the University of California, Berkeley, where I specialized in the global carbon cycle. I appreciate the invitation to appear here today.

NRDC is a non-profit environmental protection organization, founded in 1970 and supported by 170,000 members. NRDC's Energy Program has more than ten years of experience in promoting energy efficiency and least-cost energy planning. In 1988 NRDC launched its Atmosphere Protection Initiative (API) to provide a coordinated response to the related threats to the integrity of the earth's atmosphere -global warming, ozone depletion, acid rain, and urban smog. This effort involves more than a dozen NRDC scientists, resource specialists, and attorneys expert in climate, energy efficiency, nuclear energy, forestry, agriculture, international environment, air pollution control, and coastal protection.

NRDC participated as an observer throughout the process of negotiating the United Nations Framework Convention on Climate Change as well as in the deliberations of the Intergovernmental Panel on Climate Change. NRDC is also an active participant in the Climate Action Network, an international coalition of non-governmental organizations working for climate protection. In today's testimony I will review the National Action Plan submitted last year by the Bush Administration in light of U.S. obligations under the Convention and the international scientific assessment of global warming. I will then make recommendations regarding preparation of an acceptable action plan.

The Basis for Taking Action

The U.N. Climate Convention was negotiated following a process of international scientific assessment conducted under the auspices of the Intergovernmental Panel on Climate Change (IPCC). The Bush Administration summarized this assessment in an accurate and

balanced manner:

"The following represents a consensus view of a broad range of scientists, including
most U.S. scientists, who have participated actively in the international effort to
understand the issue:

"Climate Change: While scientists cannot yet establish that a human-induced
warming has already occurred, best estimates indicate that increased concentrations
of greenhouse gases are likely to increase atmospheric and occan temperatures and
alter their associated circulation and weather patterns. However, the magnitude,
timing and regional details of these changes cannot be predicted with much
certainty. Climate models predict changes in the average temperature of the
globe's atmosphere as a consequence of a doubling of atmospheric concentrations
of carbon dioxide are unlikely to lie outside the range of 1.5° to 4.5°C (2.7 to

8.1°F), with a best estimate, based on model results and taking into account the
observed climate record, of 2.5°C (4.5°F). Associated sea-level rise has been
estimated to range between a few tens of centimeters and approximately 1 meter
(less than 1 foot to approximately three feet). In addition, observed warming in
recent years is of the same magnitude as that predicted by the models but also of
the same magnitude as natural variability. Thus, the observed increase could be
due predominately to natural variability or could be part of a larger warming offset
by other human factors. Potential impacts of climate change are likely to vary
considerably from region-to-region, with particular risks for drought-prone areas,
irrigated agriculture, water resources, coastal zones and natural ecosystems.

Precise evaluations of the impacts of climate change are not likely to be available
for a decade or more."

Responding to this scientific assessment, the parties to the climate convention adopted the following objective (Article 2):

"The ultimate objective of this Convention and any related legal instruments that
the Conference of the Parties may adopt is to achieve, in accordance with the
relevant provisions of the Convention, stabilization of greenhouse gas
concentrations in the atmosphere at a level that would prevent dangerous
anthropogenic interference with the climate system. such a level should be
achieved within a time frame sufficient to allow ecosystems to adapt naturally to
climate change, to ensure that food production is not threatened and to enable
economic development to proceed in a sustainable manner."

The Stockholm Environment Institute (SEI) in its report on Targets and Indicators of Climatic Change, has concluded that to ensure that this objective is met the rate of warming must be kept to less than 0.1°C (0.2°F) per decade, and the absolute warming to less than 1-2°C (2-4°F) compared with pre-industrial times. Warming greater than the lower limit of 1°C (2°F) "may clicit rapid, unpredictable, and non-lincar responses that could lead to extensive ecosystem damage," while beyond 2°C (4°F) "the risks of grave damage to ecosystems, and of non-linear responses, are expected to increase rapidly."

To prevent warming of more than 1°C (2°F) the SEI study estimates that the atmospheric concentration of greenhouse gases would have to be limited to the equivalent of 330-400 parts per million (ppm) of CO2 (this is called the CO2-cquivalent concentration). The concentration of CO, in the atmosphere is already over 350 ppm, and the CO2-equivalent concentration of all greenhouse gases exceeds 400 ppm, thus the world is most likely already committed to exceeding the 1°C (2°F) limit. To avoid exceeding even the upper limit SEI estimates that greenhouse gas concentrations would have to be limited to 400-560 ppm CO2-equivalent.2

1U.S. Views on Global Climate Change. U.S. Department of State, April 1992.

? This range

based on a climate sensitivity to doubling CO2 concentrations of 1.5-4.5°C, which

has been accepted by the Bush Administration, as quoted above.

To be prudent in the face of uncertainty we should adopt a goal in the lower half of this range. Thus the objective of the Climate Treaty translates into a goal of limiting the atmospheric concentration of greenhouse gases to 475 ppm CO2-equivalent. Based on feasible limits for the concentrations of greenhouse gases other than CO2 I calculate that this target requires holding CO2 concentrations to about 400 ppm. Immediate action to reduce CO2 emissions is essential if this limit is not to be exceeded.

Industrialized countries, with 25% of the world's population, are responsible for 75% of current global emissions of CO2 from the energy sector. Reducing energy-related CO2 emissions from industrialized countries is the most important action needed to combat global warming, and is essential to achieve the global targets just discussed. In particular, a protocol to the climate treaty should be adopted that would require all industrialized countries to reduce energy-related CO2 emissions to at least 25% below 1990 levels by the year 2005.

Developing countries, with 75% of the world's population, are responsible for 25% of global energy-related CO2 emissions. These emissions are expected to grow to meet legitimate development needs. In order to remain within the global CO2 target of 400 ppm the aggregate increase in CO2 emissions from developing countries would have to be limited to no more than 50% over 1990 levels by 2005. As called for in the Convention, the incremental costs of achieving this target should be borne by the industrialized countries, in accordance with their responsibility for the preponderance of all past emissions that have elevated greenhouse gas concentrations to current levels.

Deeper cuts in CO2 emissions from all countries will be required after these dates in order to stabilize atmospheric greenhouse gas concentrations. Let me emphasize that stabilizing emissions of greenhouse gases at current levels will allow greenhouse gas concentrations to continue increasing at roughly current rates. The only way to stabilize atmospheric concentrations of CO2 is to cut emissions by 60% or more, according to the IPCC.

The Bush Administration's Action Plan

NRDC believes that the National Action Plan (NAP) released by the Bush Administration in 1992 fails to meet U.S. commitments under the Climate Convention in at least two key respects: First, the Bush Administration NAP does not demonstrate an aim of returning emissions of greenhouse gases to 1990 levels, as required by Article 4; Second, it was not prepared with public participation as required under Article 6.3

The U.S. is not technically in violation of the treaty because it is not legally required to submit its national plan under the treaty until six months after entry into force. (The treaty will enter into force after 50 ratifications, which could occur by the end of 1993.) However, the text of the NAP suggests that this document is intended to be a formal submission to the Secretariat of the Convention. As such is does not fulfill U.S. obligations under the treaty.

Article 4(2)(b) states, in part, "Partics shall communicate...detailed information on its policies and measures...as well as on its resulting projected anthropogenic emissions by sources and removals by sinks of greenhouse gases not controlled by the Montreal Protocol for the period (continued...)

Rather than providing a strategic plan for capping and then reducing U.S. emissions of greenhouse gases, the Bush Administration NAP is primarily a description of U.S. circumstances and existing programs. Where projected emission reductions from new programs are provided the document fails to provide an implementation plan to ensure that the projected reductions are realized.

The Bush Administration NAP places too much emphasis on describing the U.S. economy and government structure as well as on the possibilities for adapting to climate change. Furthermore, the emissions inventory presents obsolete data for 1988 using inconsistent units and sometimes inconsistent values compared with other sections of the report. Far from being a model for how an emissions inventory should be developed, neither the data sources nor methodology for deriving national estimates are presented. The document also fails to provide a clear presentation of baseline emission forecasts.

The most important failing of the Bush Administration NAP, however, is that the mitigation section does not provide a plan for capping and then reducing greenhouse gas emissions. Instead it provides a mixture of existing and planned programs, some of which include projected emission reductions while other do not. Glaringly absent are energy taxes and policies to reduce emissions from the transportation sector, in particular through automobile efficiency improvements. Morcover, there is no specific plan of actions that must be taken by government agencies and the private sector in order to achieve those emission reductions that are specified.

Toward a Real Action Plan

The Bush Administration NAP is flawed in so many respects that it must be completely rewritten in order to produce an acceptable plan. On the other hand, the existing document and particularly the public comments on it can provide some useful material for a new action plan. The U.S. Climate Action Network recommends that the Clinton Administration announce at the upcoming meeting of the Intergovernmental Negotiating Committee (INC) that it plans to thoroughly revise the U.S. NAP in time for the subsequent INC meeting and that the new NAP will demonstrate how the U.S. plans to cap emissions at 1990 levels by 2000. Drawing on the public comments the Administration should revise the NAP using the following general guidelines:

The NAP should detail a credible plan for capping emissions of carbon dioxide and other greenhouse gases not controlled by the Montreal Protocol at 1990 levels by the year 2000, with subsequent emission reductions of 25% by 2005.

3(...continued)

referred to in subparagraph (a), with the aim of returning individually or jointly to their 1990 levels these anthropogenic emissions of carbon dioxide and other greenhouse gases not controlled by the Montreal Protocol."

Article 6(a)(iii) requires "public participation in addressing climate change and its effects and developing adequate responses;".