I finally had a chance to take another look at the regulatory study.
I think this is an improvement compared to earlier versions, portions
of which came across as ideological and one-sided.  Maybe some of the
comments helped to restore some neutrality.  In any event, this is a
more balanced document than previous iterations.

I had a similar reaction to the section on the precautionary principle
(KM-8) flagged by Ken; here are the comments I submitted on that
point:

The first sentence of KM-8 states “the implications of its [the
precautionary principle] application to geo-engineering may be
unclear,” but should read “the implications of its application to geo-
engineering are unclear.”  Disagreement on these implications is well-
established and widely recognized, and using the words “may be”
unfairly biases the key message against the view that geoengineering
is warranted by the precautionary principle.

Similarly, the last sentence states “an interpretation in support of
geo-engineering or pursuing further geo-engineering research would not
be evidently contrary to the wording,” but should instead read “an
interpretation in support of geo-engineering or pursuing further geo-
engineering research is also consistent with the wording.”  The phrase
“would not be evidently contrary to” is inelegant and suggests that
geoengineering may be implicitly contrary to the wording, which again
clearly biases the key message against geoengineering.

The precautionary principle has two legitimate interpretations in this
context, neither one of which is objectively “true.”  This key message
and the broader study should remain neutral on this point.


Josh Horton
joshuahorton...@gmail.com
http://geoengineeringpolitics.blogspot.com/


On Jan 30, 3:59 am, Ken Caldeira <kcalde...@carnegie.stanford.edu>
wrote:
> It should be noted that the CBD is requesting input on two different
> documents, on on geoengineering impacts and one of regulatory
> framework.Documents and instructions are 
> here:http://www.cbd.int/climate/geoengineering/review/
>
> ---------
> *
> *My main issue with CBD statements on this matter (see 'regulatory
> framework' document, paragraph KM-8) is implications drawn from the
> following sentence:*
>
> **Under the CBD, the precautionary approach has been introduced recognizing
> that “where there is a threat of significant reduction or loss of
> biological diversity, lack of full scientific certainty should not be used
> as a reason for postponing measures to avoid or minimize such a threat”. *
>
> Many people believe that temperature increases resulting from greenhouse
> gas emissions pose a "threat of significant reduction or loss of biological
> diversity", perhaps most acutely for Arctic ecosystems.
>
> Various people have proposed deploying 'geoengineering' measures to avoid
> or minimize the threat that greenhouse gases pose to these ecosystems.
> Should the "lack of full scientific certainty" be used as a reason to
> postpone deploying these measures?
>
> Is the most cautious course of action self-evident? Which is being more
> cautious: artificially keeping the Arctic cool vs. letting the Arctic melt?
>
> "Lack of full scientific certainty" is a reason I would give for wanting to
> postpone such action.
>
> With respect to the threat that Arctic melting poses for Arctic
> biodiversity, some in the CBD are apparently arguing that we should be
> "postponing
> measures to avoid or minimize such a threat”, based on a statement about
> not postponing such measures.
>
> ------------
>
> In some readings, the 'precautionary approach' is encapsulated in the
> concept that if one cannot assure a positive outcome, one should not act.
> However, life is a gamble and every action (or inaction) entails risk. The
> best thing we as a society can do is to try to create bets where the odds
> are in our favor, and then bet sensibly.
>
> From my perspective, the odds offered by deployment aerosol-based
> geoengineering proposals do not yet look all that attractive. In the
> future, it is possible the odds may look different.
>
> _______________
> Ken Caldeira
>
> Carnegie Institution Dept of Global Ecology
> 260 Panama Street, Stanford, CA 94305 USA
> +1 650 704 7212 
> kcalde...@carnegie.stanford.eduhttp://dge.stanford.edu/labs/caldeiralab @kencaldeira
>
> *YouTube:*
> Crop yields in a geoengineered
> climate<http://www.youtube.com/watch?v=-0LCXNoIu-c>
> Influence of sea cucumbers on a coral reef CaCO3
> budget<http://www.youtube.com/watch?v=-FSd4zy8iMo>
>
>  draft-study-impacts-geoengineering-second-review-en.docx
> 3109KViewDownload
>
>  draft-study-regulatory-framework-geoengineering-second-review-en.docx
> 218KViewDownload
>
>  template-comments-geoeng-study-impacts-en.doc
> 58KViewDownload
>
>  template-comments-geoeng-study-regulatory-en.doc
> 73KViewDownload

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