Eli can retire, the EPA on Africa Gate

Stoat has arisen to contemplate the libel suit that Irene Meichsner brought (and won two out of three falls) from Stefan Rahmstorf. This showed up in a post on Klima Zwiebel, and, of course, at the non-innocent Roger Pielke's. Not innocent because Roger was deep into this thing early on.

It arises from some mischief that Eli's friends Jonathan Leake and Richard North had got up to, accusing the IPCC AR4 of making unjustified accusations about how climate change coule lead to decreased ag yields in Africa. IM, simply adopted their frame. Stoat makes the important point that no one is looking at whether SR was right or wrong on the science. The point he won is that the court agreed that his statement

Reading helps, if the author of the article, IM, herself had once looked in the IPCC report, she would have found out that the accusations were completely false.

was an allowable difference of opinion. But of course there is more

Turns out that the EPA and it's various friends in the denialsphere had already read the IPCC report AND the background information (this is long folks)
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Comment (2-10):
The Competitive Enterprise Institute, the Ohio Coal Association, Peabody Energy, and the Southeastern Legal Foundation take issue with a statement in Section 16(b) of the TSD that: “In some countries, yields from rain-fed agriculture could be reduced by up to 50% by 2020.” They claim the statement originated from gray literature in the IPCC AR4 and is therefore illegitimate. Southeastern Legal Foundation concludes: “The African Crop Yields claim stands as another example of the IPCC making a claim of imminent disaster that inappropriately relied on non-peer-reviewed literature…”

Response (2-10):
The IPCC statement cites a report by Dr. Ali Agoumi, a climate expert from Morocco (Agoumi, 2003) that was published by the International Institute for Sustainable Development (IISD) and funded by the government of Canada, the U.S. Agency for International Development, and other public and private institutions. Based on EPA’s review of the report, it appears that the 50% number was not obtained from the peer-reviewed literature but rather from “vulnerability studies on three North African countries (Algeria, Morocco and Tunisia) with respect to climatic changes.” These vulnerability studies were prepared under the U.N. Environment Programme Global Environment Fund and included in the National Communications of these three countries to the U.N. Framework Convention on Climate Change (Ministry of Territory Development and Environment, 2001, Kingdom of Morocco, 2001 and Republic of Tunisia, 2001).

In response to publicity regarding this purportedly unsubstantiated statement in the IPCC report, Dr. Coleen Vogel, a contributing lead author of the IPCC chapter on Africa impacts, described the context in which Dr. Agoumi’s research was used. She explained that Agoumi’s report received rigorous scrutiny by her fellow authors and was thoroughly discussed during development of the chapter (Kretzmann, 2010). She explained that the decision to include this (gray literature) study was based on the paucity of peer-reviewed material relating to some parts of the world, particularly Africa, and the desire of the authors of the report to provide balanced information. The process described by Dr. Vogel is consistent with the IPCC’s guidance on the use of gray literature, as previously described in Volume 1 of the RTC document and further discussed in Subsection 2.2.4.4 of this Response to Petitions (RTP) document.

Finally, we note that this statement relates to impacts outside the United States, and it did not materially impact the determination of endangerment of public health and welfare in the United States. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

Comment (2-11):




Referring to an analysis published by Ben Pile, co-editor of the blog climateresistance.org on the blog of Roger Pielke, Jr. (Pile, 2010), the Southeastern Legal Foundation states that the primary reference supporting the IPCC’s statement on African crop yields “Vulnerability of North African Countries to Climatic Changes” (Agoumi, 2003) was from IISD, an advocacy group.

Regarding the IISD reference, Peabody Energy states:

Thus, the EPA based its findings on the IPCC WGII report, which based its findings on a report [the IISD report] published by an organization with a declared political interest in climate change that based its findings from an assessment of other non-peer reviewed national studies. This is not the way EPA science should be carried out.

Response (2-11):
The implication that the credibility of IPCC’s statement on African crop yields is diminished because the IPCC’s source (Agoumi, 2003) for the statement was published by an advocacy organization or an organization with a “declared political interest in climate change” is unsupported. The organization in question is IISD, which describes itself as follows:

The International Institute for Sustainable Development contributes to sustainable development by advancing policy recommendations on international trade and investment, economic policy, climate change, measurement and indicators, and natural resource management. By using Internet communications, we report on international negotiations and broker knowledge gained through collaborative projects with global partners, resulting in more rigorous research, capacity building in developing countries and better dialogue between North and South.

IISD’s vision is better living for all—sustainably; its mission is to champion innovation, enabling societies to live sustainably. IISD receives operating grant support from the Government of Canada, provided through the Canadian International Development Agency (CIDA) and Environment Canada, and from the Province of Manitoba. The institute receives project funding from the Government of Canada, the Province of Manitoba, other national governments, United Nations agencies, foundations and the private sector. IISD is registered as a charitable organization in Canada and has 501(c)(3) status in the United States.

We find no reason to question the credibility and legitimacy of information produced by this organization on the basis of either its mission or funding sources. Moreover, neither the Southeastern Legal Foundation nor Peabody Energy provide any support for the implication that work by an organization such as IISD is automatically suspect or flawed.

Finally, Peabody Energy’s statement that EPA’s findings are based on this material is incorrect. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

We discuss the legitimacy of the science and underlying references for the African crop yields statement in Response 2-12.

Comment (2-12):
The Southeastern Legal Foundation alleges that EPA uncritically adopted the IPCC’s “faulty conclusion” with respect to crop yields. It refers to a blog by writer/commentator Richard North (North, 2010) to conclude the Agoumi (2003) reference cited by the IPCC on the issue of rain-fed agricultural yields in Africa relies on studies that “do not support the proposition for which they are cited.”

Relying on Richard North’s blog, the Southeastern Legal Foundation summarizes the vulnerability studies cited by Agoumi (2003) from the National Communications of Morocco, Tunisia, and Algeria. The Southeastern Legal Foundation notes that the Morocco National Communication “lends some support [to the Agoumi reference], saying that by 2020 during drought conditions cereal yields would decline up to 50%” but that “the data apply to cereal yields only, not crops in general as is implied by the IPCC.” The Southeastern Legal Foundation further states that “Algeria’s report said their yields would double, and be trimmed only slightly by ‘climate change’” and “Tunisia’s submission concluded the picture was mixed, but they could have an increase in rain and agricultural production.”

Response (2-12):
The IPCC’s statement on rain-fed agriculture in Northern Africa is not “faulty” and the Southeastern Legal Foundation presents no evidence that it was included uncritically in EPA’s TSD. Furthermore, the Southeastern Legal Foundation’s portrayal of findings on climate and crop yields from the National Communications of Morocco, Tunisia, and Algeria derived from Richard North’s blog is not complete. When all of the information in these National Communications is considered, we find there is broad support for Agoumi’s (2003) statements on North African rain-fed agriculture, which are:

• “Some of the key statistics regarding water, soil, urban areas and coastal zones are outlined below. . . . Decreasing rain-based agricultural yields with grain yields reduced by up to 50 percent in periods of drought.”
• “Studies on the future of vital agriculture in the region have shown the following risks, which are linked to climate change: . . . deficient yields from rain-based agriculture of up to 50 percent during the 2000–2020 period.”

PBL, in its report Assessing an IPCC Assessment (PBL, 2010a), makes the following important point with respect to IPCC’s statement on rain-fed agriculture in Africa:

This statement is not directly a statement on climate change, but on climate variability: in individual years, droughts can cause up to 50% in yield reductions. The implicit message here is that when droughts would become more frequent due to climate change, more years with up to 50% in yield reductions would occur. The statement could easily mislead readers into thinking that average annual yields could be reduced by up to 50% due to climate change. In the Summary for Policymakers of the Working Group II Report, the paragraph that contains this statement starts with a sentence introducing the notion of climate variability, which puts the statement more into context.

It is possible that petitioners misinterpreted the IPCC’s statement as suggesting that the IPCC’s projection was on the basis of climate change alone, given the Southeastern Legal Foundation’s assertion, for example, that IPCC was projecting “imminent disaster.” While we agree with PBL that the IPCC’s statement could easily mislead readers without the proper context, we note that, before quoting the IPCC’s projection on rain-fed agriculture, EPA’s TSD includes the statement “Agricultural production, including access to food, in many African countries and regions is projected to be severely compromised by climate variability [emphasis added] and change.” Therefore, EPA provided the proper context for the IPCC’s conclusion.

With respect to the basis for the conclusion itself, the following excerpts from the three countries’ National Communication reports on the issues of climate variability and change, precipitation, and crop yields provide broad support for the Agoumi (2003) statements along with accompanying discussion:

• The National Communication of Morocco states (Kingdom of Morocco, 2001):

The development of climate scenarios for Morocco according to IPCC methodology reveals the following results: . . .

• A trend towards a decrease in average annual rainfall volume by about 4% in 2020 compared to 2000 levels. . . .
• An increase in the frequency and intensity of droughts in the south and the east of the country.

The first quantitative estimate of possible CC [climate change] impacts on water resources in 2020 points to the fact that there would be an average and general decrease in water resources (in the order of 10 to 15 %...).

The study of CC [climate change] impacts on agriculture (dominated by cereal cultivation) in 2020 unfolds the following results: A decrease in cereal yields by 50% in dry years and 10% in normal years.

As the Southeastern Legal Foundation admits, the numbers from Morocco’s National Communication lend support to the statement in Agoumi (2003) that “studies on the future of vital agriculture in the region have shown the following risks, which are linked to climate change: . . . deficient yields from rain-based agriculture of up to 50 per cent during the 2000–2020 period.”

Richard North’s contention (North, 2010, as referred to by the Southeastern Legal Foundation) that “the data apply to cereal yields only, not crops in general as is implied by the IPCC” is arguable considering that Morocco’s National Communication indicates that agriculture is “dominated by cereal cultivation.” Thus, it is not unreasonable to use cereal cultivation as a proxy for all of agriculture in this cereal-crop-dominated region.

• The National Communication of Algeria (Ministry of Territory Development and Environment, 2001) states: ¹

Because of global warming, we must brace ourselves for chronic climate instability and greater frequency of droughts and floods. Droughts damage soils and floods destroy ground cover and contribute to the erosion of soils. With longer spans of time between dry and wet spells comes an even greater impact due to erosion. The southern regions of the country will be most directly impacted by increased temperatures and will be subject to the numerous consequences of accelerated desertification. The increased risk of drought presents the greatest challenge as a result of climate change. The Intergovernmental Panel on Climate Change (IPCC) expect that the desert regions will extend northward in the Maghreb.

The above text provides a clear qualitative description of the risks climate change pose to agriculture in Algeria. In addition, this information from the National Communication of Algeria provides quantitative output from a model known as CROPWAT, which estimates changes in crop yields using climate change projections obtained from two general circulation models. The National Communication of Algeria reports:

… one can consider an average reduction in the output cereal of about 5.5 to 6.8%, corresponding mainly to instances of climate change [in 2020]( Ministry of Territory Development and Environment, 2001)

When considering these quantitative cereal yield changes, it is very important to note that these percentages refer to changes in cereal yields resulting primarily from climate change alone and not climate variability and change combined. The climate and hence precipitation variability in northern Africa can be quite large. For example, in the report Assessing an IPCC Assessment (PBL, 2010a), PBL states “…the [IPCC] authors made plausible that, due to current climate variability, the yields in Algeria, Morocco and Tunisia have been varying annually, including yield reductions of nearly 70% in individual years, in the period between 2000 and 2006.”

In other words, if these yield reductions resulting from greenhouse gas–induced climate change were superimposed on the yield reductions that might occur during a particularly dry period arising from the region’s characteristic precipitation variability, they would be higher and comparable with the results from the Morocco National Communication.

Finally, the Southeastern Legal Foundation’s reference to the Algeria National Communication’s projections for net increases in cereal projections in 2020 (relative to prior decades) is irrelevant and misleading. These increases are related not to climate variability and change but to changing agricultural practices and technology. Algeria’s National Communication makes clear that the effect of climate change on cereal yields is projected to be negative.

• The National Communication of Tunisia states (Republic of Tunisia, 2001):

…Tunisia is in a hydrous stress situation close to a shortage, sharpened by a high anthropic pressure. So minor they be, the Climate Changes can so, result in harmful consequences on water resources, on ecosystems depending of water, and on the different economic activities that need large quantities of water such as agriculture and tourism.

By modifying the evaporation and precipitation rate, the global warming will probably affect the hydrous climate balance and therefore the Tunisian water resources. In this way, if the intensification of the evaporation can lead to a possible important increase of the rain falls, it might not be sufficient to offset the decrease of the sweet water resources. Moreover, due to the global warming, the rain situation can be characterized by a bigger frequency of rains resulting from torrential storms and downpours, disappearing generally in streaming waters rather than be absorbed by the soils.

This information in the Tunesian National Communication does not provide any quantitative estimates of climate variability and/or change on rain-fed agriculture, but the clear qualitative implication is that climate changes—both drought and heavy precipitation events—will stress agriculture in Tunisia. We, therefore, find that the Southeastern Legal Foundation’s statement that “Tunisia’s submission concluded the picture was mixed, but they could have an increase in rain and agricultural production” is an overly optimistic interpretation of clearly expressed negative impacts.

Overall, these three National Communications (Morocco, Algeria, and Tunisia) provide qualitative support for the fact the climate change will likely stress rain-fed agriculture in northern Africa, consistent with the portrayal of Agoumi (2003) and the IPCC. The National Communication of Morocco presents quantitative information consistent with what is reported by Agoumi (2003) and the IPCC (and hence the TSD), while the National Communication of Algeria provides quantitative information that is consistent with these sources when factoring in precipitation variability in addition to climate change. The National Communication of Tunisia does not provide quantitative information.

Our view of the literature behind Agoumi (2003) provides considerable evidence that the scientific basis for the IPCC’s conclusion is legitimate. The PBL assessment of the IPCC notes that “…additional explanations could have provided further foundations for the statement, had they been included in [IPCC’s Working Group II] Chapter 9.” We concur, but the Southeastern Legal Foundation conclusion that “…there is no support for the IPCC’s dramatic pronouncement on African crop yields” is significantly overstated.

Comment (2-13):
The Southeastern Legal Foundation provides the following reaction to the African rain-fed agriculture projection, which appeared in the Sunday Times (Leake, 2010a) and comes from former IPCC chair Robert Watson: “Any such projection [pertaining to African crop yields] should be based on peer-reviewed literature from computer modeling of how agricultural yields would respond to climate change. I can see no such data supporting the IPCC report.”

Response (2-13):
Watson may not have appreciated that peer-reviewed modeling studies of climate change impacts on agriculture in parts of Africa are limited. As the IPCC’s AR4 WGI report states (Christensen et al., 2007): “Several climate change projections based on RCM (regional climate model) simulations are available for southern Africa, but are much scarcer for other regions.” Accordingly, as we discuss in Subsection 2.2.4.4 of this RTP document, the IPCC references gray literature in these circumstances. We also note in Response 2-10 that these studies are not central to the TSD or the Endangerment Finding. Finally, though we discuss some additional modeling studies pertinent to Africa in RTP 2-15, those modeling studies (Parry et al., 2005 and Hulme et al., 2001) were conducted at the global and continental scales and contain limited results pertinent to northern Africa specifically.

Comment (2-14):
The Southeastern Legal Foundation states that EPA ignored contrary peer-reviewed literature and submits literature that the Sahel is greening (from National Geographic and several studies) in contrast to “IPCC horror stories” (projecting reductions in rain-fed agriculture).

Response (2-14):
EPA is aware of the literature cited by the petitioner that suggests greening in parts of the Sahara and Sahel (e.g., Seaquisti, et al., 2009; Anyamba, and Tucker, 2005; Hutchinson et al., 2005; Olsson et al., 2005). The issue raised by petitioners is not new and was raised and responded to through the public comment process (see Response 2-73 in Volume 2 of the RTC document). Thus, these objections do not meet the test in Clean Air Act (CAA) Section 307(d)(7)(B) that it be impracticable to raise the objection during the public comment period or the reasons for the objection arose between June 24, 2009, and February 16, 2010. Nonetheless, we have reviewed these arguments and respond once again.

The fact that precipitation has increased recently in this region, as we note in our TSD in Section 4(d), does not mean that a combination of climate variability and change could not substantially reduce rain-fed agriculture in the future. The climate in this region is highly variable and while it has been relatively wet over the past decade or so, severe drought impacted the region for several decades from the 1960s to the 1990s and dry patterns could return to the region. As one of the studies (Nicholson, 2005) cited by the petitioner states: “The fluctuations between ‘wet’ and ‘dry’ in the Sahel/Soudan zones are extreme even on decadal and multi-decadal time scales.” Therefore, if the current wet period reverses to a dry period, the impacts of rain-fed agriculture on the region could be profound, especially when considering the potential enhancement of the drying from human-induced warming (i.e., climate change).

Finally, we note that the literature presented relates to impacts outside the United States, and it did not materially impact the determination of endangerment of public health and welfare in the United States. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

Comment (2-15):
The Southeastern Legal Foundation suggests that the IPCC ignored literature that drew different conclusions on the issue of rain-fed agriculture projections in Africa, specifically referring to two studies: Parry et al., 2005 and Hulme et al., 2001. The Southeastern Legal Foundation states: “Both Parry’s own paper and Hulme’s paper were known to and available to Professor Parry [co-chair of IPCC Working Group II] in composing the WGII Report and the Synthesis Report. Yet, Parry’s WGII report ignored his own paper and that of Hulme, which did not predict disaster, and instead relied on one that did, the Agoumi paper, even though it did so incorrectly and improperly and was not peer-reviewed.” The Southeastern Legal Foundation further notes that Hulme et al. (2001) were careful to note uncertainties in understanding African climate change, and implies that the IPCC was not as careful.

Response (2-15):
We have reviewed these papers (Parry et al., 2005, and Hulme et al., 2001) and find that, while not directly comparable with Agoumi (2003), they do not contradict that source. We also find, contrary to the Southeastern Legal Foundation’s assertion, that both of these studies were in fact cited by the IPCC, although not always in the same section or context as Agoumi (2003).

The Parry et al. (2005) study reports the results of a series of research projects that aimed to evaluate the implications of climate change for food production and risk of hunger. The analysis in this study is performed at global and continental scales rather than the regional scale. This is likely why it is not discussed in Chapter 5 of Working Group II’s contribution to the AR4 (Easterling et al., 2007), where Agoumi (2003) is cited in a section focusing on regional impacts in Africa (specifically on Morocco, Algeria, and Tunisia). The Parry et al. (2005) study is cited multiple times in Chapter 5 of Working Group II’s contribution (“Food, Fiber, and Forest Products,” Easterling et al., 2007), which provides a global perspective. Therefore, Parry did not “ignore his own paper” as stated by the Southeastern Legal Foundation.

One of the primary conclusions of Parry et al. is that “the region of greatest risk [of losses in food production, and hunger due to climate change] is Africa.” Parry et al. (2005) provide specific cereal yield projections for the 2020s and 2080s resulting from different GHG emission scenarios. They state for the globe: “By the 2020s, small changes in cereal yield are evident in all scenarios, but these fluctuations are within historical variations.” For the 2080s, Parry et al. (2005) provide projections specific to Africa – but not northern Africa specifically, stating that climate change could reduce cereal yields by up to 30%. Importantly, the changes in cereal yield projected for the 2020s and 2080s are driven by GHG-induced climate change and likely do not fully capture interannual precipitation variability which can result in large yield reductions during dry periods, as the IPCC (Christensen et al., 2007) states: “…there is less confidence in the ability of the AOGCMs (atmosphere-ocean general circulation models) to generate interannual variability in the SSTs (sea surface temperatures) of the type known to affect African rainfall, as evidenced by the fact that very few AOGCMs produce droughts comparable in magnitude to the Sahel droughts of the 1970s and 1980s.” Given the different scopes of the two analyses, it is misleading to state that the Parry et al. projections are inconsistent with the Agoumi (2003) yield projections.

The Hulme et al. (2001) study, which reviews observed (1900–2000) and possible future (2000–2100) continent-wide changes in temperature and rainfall over Africa, is also not ignored by the IPCC, contrary to the assertion of the petitioner. In fact, it is cited twice in IPCC’s Working Group II Chapter 9 on Africa (Boko et al., 2007):

• Hulme et al. (2001) is cited in a statement about the complexity of African climatology: “Other factors that complicate African climatology include dust aerosol concentrations and sea-surface temperature anomalies, which are particularly important in the Sahel region (Hulme et al., 2001; Prospero and Lamb, 2003) and southern Africa (Reason, 2002), deforestation in the equatorial region (Semazzi and Song, 2001; Bounoua et al., 2002)…”
• Hulme et al. (2001) is also cited in a statement pertaining to uncertainties in precipitation projections in the western Sahel (Boko et al., 2007): “For the western Sahel (10 to 18°N, 17.5°W to 20°E), there are still discrepancies between the models: some projecting a significant drying (e.g., Hulme et al., 2001; Jenkins et al., 2005) and others simulating a progressive wetting with an expansion of vegetation into the Sahara (Brovkin, 2002; Maynard et al., 2002; Claussen et al., 2003; Wang et al., 2004; Haarsma et al., 2005; Kamga et al., 2005; Hoerling et al., 2006).”

These examples demonstrate that the IPCC both cited Hulme et al. (2001) and transparently discussed the complexity of Africa’s climate and the uncertainty in African climate projections. This treatment is appropriate and reasonable, contrary to the petitioner’s implication.

Even in light of the complexities and uncertainties, Hulme et al. (2001) state that a “warming climate will nevertheless place additional stresses on water resources [in Africa], whether or not future rainfall is significantly altered” and they project reduced precipitation over Tunisia. Hulme et al. (2001) do not, however, provide projections for changes in cereal yields (from changes in rain-fed agriculture), so their results cannot be compared directly with Agoumi (2003) or its supporting documents (discussed in Response 2-12).

Overall, the IPCC does not ignore either the Parry et al. (2005) or Hulme et al. (2001) studies. The findings of these studies, while not directly comparable with Agoumi (2003), are broadly consistent. Hulme et al. (2001) project increased drying over northern Africa while Parry et al. (2005) project an increased risk of reduced cereal yields over all of Africa. The petitioner’s claim that IPCC was not careful or acted inappropriately in this regard is not confirmed by careful review of the material.
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Eli can retire