Dear Diana,

Thank you very much for reviewing our paper thoroughly.
We really appreciate it.  It is a working paper, and we
will make efforts to fully reflect on your points when
we revise it.

I agree with you that some people are using the mantra
of "we need more research" as a marketing tool.  This point
was probably not well represented in our paper.

Again many thanks for your comments.

Best,
Masa Sugiyama



(2010/12/08 5:14), Diana Bronson wrote:
The paper recently circulated by Sugiyama and Sugiyama of the Central Research
Institute of Electric Power Industry in Japan makes for interesting reading but
also warrants some points of clarification. While ETC Group agrees with some
points made the paper, and we welcome independent assessments of the CBD COP 10
geoengineering decision, we offer the following comments on assertions made in
the paper that we disagree with.

1. COP 10 delegates were not well informed about geoengineering and negotiations
were conducted in haste without proper scientific consideration (p. 1).

_Response_: It is true that this is a new area of negotiation for diplomats,
mainly because it is the first time substantial attention has been devoted to
geoengineering in a UN inter-governmental body. Geoengineering is a new topic
for most people. However, the topic did arise from the May 2010 meeting of the
scientific subsidiary body (SBSTTA) in Nairobi and given that the original
language went to the COP in bracketed from, states did have time (6 months) to
prepare their positions for the COP in Nagoya. In fact, Slovenia first raised
geoengineering as far back as the 2007 SBSTTA in Paris! The language that was
adopted at this COP was based on the debates and language on ocean fertilization
from 2008. So delegates certainly did have time to prepare and ample warning
that this was coming up.

The precautionary approach adopted by the COP on geoengineering is indeed
consistent with the need to reflect upon the topic in more depth before any
real-world experimentation (in uncontrolled settings) with potential
transboundary impacts or deployment can be contemplated. More in-depth
scientific consideration is surely needed (and will be forthcoming). This
decision simply ensures that geoengineering is not seen as a uniquely scientific
matter, but rather emphasizes questions of governance and social, environmental
and other impacts and inputs that ought to be considered.

2. Definition and CCS issues (pp. 3, 8, 13 )

_Response_: It is odd that the authors assert that no definition of
geoengineering was agreed to at COP 10 and that geoengineering was “treated as
though [it was] a single monolithic technology” when clearly a tentative
definition was adopted, was extensively debated and was agreed upon by the (193)
countries present and indeed is quoted on page 10. That definition in fact is
largely based on the Royal Society’s influentual conceptualization of
geoengineering as encompassing two broad categories: SRM and CDR technologies.
The compromise definition, adopted in the footnote (to 8 (w)), applies only for
this COP and may be revised subsequently.

The question of how to define geoengineering is a complex one, and is clearly
not yet settled practically, theoretically or legally. Some of the complexities
of this debate are highlighted in pages 4-7 of Geopiracy: The Case Against
Geoengineering <http://www.etcgroup.org/en/node/5217>. Obviously many other
things have been written as well. Whether or not what we normally understand as
CCS is included in CDR is open for debate -- and clearly concerned countries
like Norway and Canada with substantial investments in CCS. I think that it is
understood by all sides in this debate that geoengineering is an umbrella term
for a large number of very different technologies and of course there will be
some different governance considerations for different ones (as well as some
commonalities, like scale and intentionality for example).

Finally, the authors mischaracterize the position of Bolivia by stating "Bolivia
requested to clarify that excluding CCS cannot be interpreted as an acceptance
of geonegineering activities" (p. 8).In fact, what Bolivia sought to clarify,
was that “The exclusion of carbon capture and storage from this definition is
not to be interpreted as an endorsement of carbon capture and storage
technologies under this Convention, pending a full consideration by the
Conference of the Parties of its impacts on biodiversity in general.”

3. The paper states that environmental groups argue for ban including research
(p. 5)

_Response:_The authors argue that "some environmental groups... argue for a
blanket ban on geoengineering, including research". It is not clear to whom the
authors are referring as there is no footnote or evidence cited. ETC Group has
been very clear that our opposition is to experimentation, not to laboratory or
modelling research. Many people on this list disagree with that stance but we
have been clear, repeatedly, that we do seek a ban on research in any way, shape
or form. This statement needs to be nuanced or supported with precise
references. It is, however, clear that the mantra that "we need more research"
is being used not only by portions of the scientific community with rational
concerns about run-away climate change but also by commercial advocates as well
as those of the Bjorn Lomborg "Lets get on with it" “Cool it” persuasion. In
other words, "more research" is sometimes used a geoengineering marketing 
strategy.

4. There is a significant difference in the strength of LP and CBD decisions on
ocean fertilization in 2008, and that the COP 10 decision on geoengineering is
the weakest of all and does not in fact constitute a /de facto/ moratorium.

_Response:_The strength of an international decision cannot be assessed by
looking at wording alone. The CBD has been ratified by 193 countries whereas the
London Convention and Protocol have respectively 86 and 35 Parties. It was the
German chair of the 2008 CBD COP who called the ocean fertilization wording a
"/de facto/ moratorium" and ETC Group simply agreed with that formulation. The
2008 CBD wording is very similar to the COP 10 wording on geoengineering
although the breadth of the latter is much greater (requests Parties and urges
other governments to ensure that OIF activities VS Invites parties and other
governments to consider the following guidance....ensure that no climate-related
geoengineering activities....). Indeed the 2010 decision is explicitly IN LINE
AND CONSISTENT WITH the 2008 decision. The decision is more politically binding
than legally binding, a point which is made in our own evaluation of what the
moratorium means. ETC Group is certainly not the only organization to call this
decision a moratorium – Reuters, the Washington Post and several people who
disagree with almost everything we say, also reported it as such.

It is unfortunate that the authors did not contact ETC Group for our views about
the process or the outcome before circulating the paper, or consult our ownmore
detailed evaluation <http://www.etcgroup.org/en/node/5236> of what it means. We
hope that our comments can be considered in any subsequent evaluation alongside
the “anonymous” sources that appear to have been misleading in several respects.

There will be much more discussion about the meaning of the CBD moratorium in
the months and years to come and ETC Group welcomes this discussion. As we have
pointed out elsewhere, the CBD moratorium does not resolve the issue -- but it
does put it firmly on the UN agenda and issues a clear instruction to all
governments, directly bound or not by the Convention, against proceeding
unilaterally down this path.

Sincerely,

Diana Bronson

ETC Group

On 2-Dec-10, at 5:10 AM, geoengineering+nore...@googlegroups.com
<mailto:geoengineering+nore...@googlegroups.com> wrote:

Today's Topic Summary

Group: http://groups.google.com/group/geoengineering/topics

    * Paper on CBD COP10 decision <#group_thread_0> [1 Update]

Topic: Paper on CBD COP10 decision
<http://groups.google.com/group/geoengineering/t/1f92f5f00e9973b4>

      Josh Horton <joshuahorton...@gmail.com
      <mailto:joshuahorton...@gmail.com>> Dec 01 01:41PM -0800 ^ <#digest_top>

      Good discussion of the Decision. You note that "The most precarious
      part of the negotiation was that parties were not well informed of the
      science of geoengineering" (p. 13). Agreed, the ignorance on display
      was remarkable, although not all that surprising given the continuing
      influence of climate deniers. The Royal Society was on hand, but
      misleading and ridiculous claims by opponents of geoengineering
      received the most attention. However, I think ETC Group and others
      have experienced some blowback since the meeting.

      Josh Horton




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