Peter,
As usual, this is a distortion of the statement of others, including most
notably here, the conclusions in the NASEM CDR study, for which myself and
others on this list served as reviewers. The NASEM study did not conclude
“there are no actual legal barriers to ocean iron fertilization.” Rather, it
indicated that uncertainties, and gaps in regulatory frameworks, necessitated
development of additional regulatory standards for research, and POTENTIALLY
deployment in the future. The clear message of NASEM is that there is not clear
authority for proceeding at this point, certainly with deployment (ditto from a
scientific perspective, see below). Here’s the key section:
Notwithstanding the lack of international and domestic law specifically
governing ocean CDR research and deployment, projects could be subject to a
variety of general environmental and other laws. Because those laws were
developed to regulate other activities, there is often uncertainty as to how
they will apply to ocean CDR research and deployment. Further research is
needed both to resolve unanswered questions about the application of existing
law to ocean CDR projects and to develop new model governance frameworks for
such projects.
Developing a clear and consistent legal framework for ocean CDR is essential to
facilitate research and (if deemed appropriate) full-scale deployment, while
also ensuring that projects are conducted in a safe and environmentally sound
manner. Having appropriate legal safeguards in place is vital to minimize the
risk of negative environmental and other outcomes and should help to promote
greater confidence in ocean CDR among investors, policy makers, and other
stakeholders. It is, however, important to avoid imposing inappropriate or
overly strict requirements that could unnecessarily hinder ocean CDR research
and deployment. Having clearly defined requirements should simplify the
permitting of projects and reduce uncertainties and risks for project
developers.
***
Establishing a robust legal framework for ocean CDR is essential to ensure that
research and (if deemed appropriate) deployment is conducted in a safe and
responsible manner that minimizes the risk of negative environmental and other
outcomes. There is currently no single, comprehensive legal framework for ocean
CDR research or deployment, either internationally or in the United States. At
the international level, while steps have been taken to regulate certain ocean
CDR techniques—most notably, ocean fertilization—under existing international
agreements, significant A Research Strategy for Ocean-based Carbon Dioxide
Removal and Sequestration Copyright National Academy of Sciences. All rights
reserved. CROSSCUTTING CONSIDERATIONS ON OCEAN-BASED CDR R&D 55 uncertainty and
gaps remain. Domestically, in the United States, initial studies suggest that a
range of general environmental and other laws could apply to ocean CDR research
and deployment. Those laws were, however, developed to regulate other
activities and may be poorly suited to ocean CDR. Further study is needed to
evaluate the full range of U.S. laws that could apply to different ocean CDR
techniques and explore possible reforms to strengthen the legal framework to
ensure that it appropriately balances the need for further research to improve
understanding of ocean CDR techniques against the potential risks of such
research, and put in place appropriate safeguards to prevent or minimize
negative environmental and other outcomes.
Moreover, at least two international treaty regimes, the London
Convention/Protocol and the CBD have passed resolutions limiting OIF to
small-scale experiments, with no commercial component, subject to risk
assessment, with the LC Parties developing such a framework in 2010. Ken
Buesseler at Woods Hole, who drafted much of the NASEM section on OIF, has
acknowledged that these provisions would guide any research program that he
might develop for OIF in the future. Thus, it’s incorrect to conclude there are
no barriers at this point to a full-scale deployment of OIF.
I also think it’s incorrect to say that there’s no one opposed to OIF, at least
if you mean full-scale deployment. Again, Ken Buesseler in the NASEM study made
it clear that only RESEARCH should ensue at this point given a number of
questions of effectiveness, and potential risks of this approach, including
nutrient robbing. Here’s some topline conclusions:
While OF, and OIF in particular, has a longer history of scientific study than
all other ocean CDR approaches, these studies were not intended as a test of
the feasibility and cost of OIF for large-scale CDR and climate mitigation, or
to fully assess environmental impacts at deployment scales. Modeling studies,
on the other hand, often focused on the sequestration potential, environmental
impacts, and, sometimes, cost estimates of large-scale deployment. Efforts to
bridge local experimental scales and global modeling scales (e.g., Aumont and
Bopp, 2006) should be encouraged to help maximize the information gained. The
earlier OIF studies do serve as a pilot[1]scale work that can be used to pose
several key questions that would be answered with additional laboratory, field,
and modeling studies as part of a portfolio of ocean CDR research activities.
These research questions can be grouped broadly by the ones on “will it work”
related to C sequestration effectiveness and “what are the intended and
unintended consequences” related to changes to ocean ecosystems that are an
intended part of responsible ocean CDR of any type.
These pilot studies taught us that aOIF experiments would need to be
significantly longer and larger than earlier ones that used 0.3–4 tons of iron
(II) sulfate (FeSO4) and covered 25–300 km2 with ship-based observations
lasting 10–40 days. A demonstration-scale aOIF field study might need to add up
to 100–1,000 tons of iron (using planes, or autonomous surface vehicles), cover
up to 1 million km2 (1 percent of HNLC waters), and last for at least an entire
growth season with multiyear follow-up. This would be a scale similar to the
Kasatochi volcanic eruption in the Gulf of Alaska (see Fisheries) that caused
no permanent harm, but was of a size that it could be readily tracked and pH
and CO2 impacts could be measured, and it provided a regional C loss out of the
surface of 0.01–0.1 Gt C (0.04–0.4 Gt CO2) (Hamme et al., 2010; Longman et al.,
2020).
[cid:image001.jpg@01D943B5.AD46A510] <http://twitter.com/>
WIL BURNS
Co-Director, Institute for Carbon Removal Law & Policy
American University
Visiting Professor, Environmental Policy & Culture Program, Northwestern
University
Email: wil.bu...@northwestern.edu<mailto:wil.bu...@northwestern.edu>
Mobile: 312.550.3079
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From: carbondioxideremo...@googlegroups.com
<carbondioxideremo...@googlegroups.com> On Behalf Of Peter Fiekowsky
Sent: Saturday, February 18, 2023 3:57 PM
To: Metta W Spencer <mspen...@web.net>
Cc: Clive Elsworth <cl...@endorphinsoftware.co.uk>; Michael Hayes
<electrogeoc...@gmail.com>; rob...@rtulip.net; Planetary Restoration
<planetary-restorat...@googlegroups.com>; healthy-planet-action-coalition
<healthy-planet-action-coalit...@googlegroups.com>; NOAC
<noac-meeti...@googlegroups.com>; Healthy Climate Alliance
<healthy-climate-allia...@googlegroups.com>;
carbondioxideremo...@googlegroups.com <carbondioxideremo...@googlegroups.com>
<carbondioxideremo...@googlegroups.com>; geoengineering
<geoengineering@googlegroups.com>
Subject: Re: [CDR] [HCA-list] Iron Salt Aerosol: Article in MIT Technology
Review
Metta-
Excellent question about the legal standing of adding iron to the ocean.
The NAS report from Dec 2021: Ocean Carbon Dioxide
Removal<https://nap.nationalacademies.org/catalog/26278/a-research-strategy-for-ocean-based-carbon-dioxide-removal-and-sequestration>
says there are no actual legal barriers to ocean iron fertilization (OIF).
Iron salt aerosol (ISA) is essentially a variation on that theme.
I have looked high and low for a specific person who opposes either OIF or ISA
and have not found one in the last few years. Nevertheless many people share
your (perhaps unfounded) belief that somewhere there are people actually
opposed to this. I am working with several indigenous peoples' alliances, and
they are now committed to restoring the climate, saying "We don't have a
choice."
There are people opposed to slowing down the clean energy transition (you may
be included), and most people agree that the carbon offset system allows large
GHG emitters to delay or defer their transition to clean energy. Some OIF
ideas are built on the idea of selling carbon offsets--so there is some
opposition to the concept of selling carbon offsets from OIF. The ETC Group
discusses that on their site, stated not quite elegantly.
If you come across an actual OIF opponent, please let me know and send them to
me.
Peter
On Sat, Feb 18, 2023 at 11:03 AM Metta W Spencer
<mspen...@web.net<mailto:mspen...@web.net>> wrote:
I should probably know this but don’t. Can someone tell me whether there is
really a legally binding international agreement NOT to do this? I am aware
that there would be plenty of opposition, but is there anything to actually
keep Canada from doing something like this over Hudson Bay, which is entirely
inside Canada?
Metta Spencer
mspen...@web.net<mailto:mspen...@web.net> 1-416-789-2294
On Feb 18, 2023, at 1:29 PM, Clive Elsworth
<cl...@endorphinsoftware.co.uk<mailto:cl...@endorphinsoftware.co.uk>> wrote:
Michael
We calculate that potentially tens of Gt of CO2 per year could be safely
removed by iron salt aerosol dispersal over remote iron poor ocean areas at low
cost, if allowed. Of course this would need to be incrementally scaled, with
lots of measurement, analysis.
Clive
On 18/02/2023 18:11 GMT Michael Hayes
<electrogeoc...@gmail.com<mailto:electrogeoc...@gmail.com>> wrote:
Clive, I'm aware of the chemistry, yet this is a CDR list not a CH4 mitigation
list. Removing CO2 has little involvement with CH4 mitigation. Use of iron salt
is not a CDR method, and it has little if any relation to CDR policy or
economics.
The many CCed groups often welcome any comment on any subject under the Sun.
This list, however, is focused on removing CO2, not second or third order
indirect subjects that can be tacked onto CO2 removal.
Getting things done requires maintaining focus, and the GE list along with many
others like it simply can not maintain focus and thus are of little use and
even less importance. Converting this list to a CC of the GE list is not
needed, yet there seems to be a core group interested in either taking the
moderators' post to do so or simply overrunning the CDR list with non CDR posts
and making the CDR list a defacto non focused GE list. I object to the petty
politics and to the non CDR posts.
Best regards
On Sat, Feb 18, 2023, 7:59 AM Clive Elsworth
<cl...@endorphinsoftware.co.uk<mailto:cl...@endorphinsoftware.co.uk>> wrote:
Michael
Iron salt aerosol relates indirectly to CDR. Reduced warming from reduced
atmospheric methane would slow the temperature rise of the ocean surface,
curbing the accelerating loss of nutrient mixing owing to surface
stratification. Without nutrients, less phytoplankton are available to raise
ocean surface pH. A higher pH at the ocean surface lowers the partial pressure
of dissolved CO2, increasing the oceanic CO2 absorption rate.
Where there is chlorophyll in the ocean there tend to be marine clouds also,
which provide an additional cooling effect. Thus, a beneficial feedback cycle
is established, or at least the opposite destructive feedback cycle is curbed.
The addition of iron to the ocean surface is of course highly controversial,
even if it’s by aerosol delivery adding less than 1 mg/m² per day and with
natural fertilisation by desert dust doing the same thing. Huge areas of
abyssal ocean are very low in iron content, so this would also enable a
slightly higher phytoplankton productivity than otherwise - over vast areas. In
areas where iron is not the limiting nutrient, the addition of a tiny amount
more would make essentially no difference.
Clive
On 18/02/2023 14:45 GMT Michael Hayes
<electrogeoc...@gmail.com<mailto:electrogeoc...@gmail.com>> wrote:
Again, how does this relate to CDR?
CH4 is not CO2.
The many other groups that have been CCed in this thread are wide open to any
and all chatter about any and all subjects that can pop into people's minds.
This list is about Carbon Dioxide Removal.
How does your comment relate to CDR?
On Fri, Feb 17, 2023, 12:49 PM Peter Fiekowsky
<pfi...@gmail.com<mailto:pfi...@gmail.com>> wrote:
Robert-
Good point about the scientists uniformly calling for delaying implementation,
essentially indefinitely, since they don't offer any criteria for actually
starting to restore safe methane levels and protect against a methane burst.
Do you think this is an ethical issue? Doubling the methane oxidation rate
would result, in 5 years, in methane levels cut roughly in half--bringing
warming back to roughly 2002 levels. This would likely save a million lives a
year lost in the severe hurricanes, floods, wildfires and droughts we have now.
And if today's methane burst gets serious, it could also save a quarter, or
even all of humanity from the kind of extinction event that happened last time
our planet lost the Arctic sea ice.
Even if it's only a 1% chance that history repeats itself (warming is now
happening 10 times faster than during the previous methane burst called the
PETM), statistically that's 8 billion people divided by a 1/1000 probability,
or 8 million people we could save.
Is it ethical for climate scientists to make the same claims that health
scientists made for tobacco companies and later that oil company scientists
made about climate actions--that we need undefined "more research" before
acting?
Should we establish a climate ethics committee to discuss this issue publicly?
Peter
On Fri, Feb 17, 2023 at 4:44 AM <rob...@rtulip.net<mailto:rob...@rtulip.net>>
wrote:
This article by James Temple provides a professional overview of efforts to
commercialise Iron Salt Aerosol (ISA).
https://www.technologyreview.com/2023/02/15/1068495/these-startups-hope-to-spray-iron-particles-above-the-ocean-to-fight-climate-change/
It discusses cooling effects of ISA including methane removal, ocean iron
fertilization and marine cloud brightening. The article comments that a
marine cloud brightening effect “would muddy the line between greenhouse-gas
removal and the more controversial field of solar geoengineering.” My view is
that taking this as a criticism shows the incoherence in popular understanding
of climate science. If marine cloud brightening could be a fast, safe, cheap
and effective way to mitigate dangerous warming, field research of ISA could be
a great way to test this. Solar geoengineering is no more controversial than
ocean iron fertilization, given that both are under a de facto ban on field
research.
The article comments that “if it brightened marine clouds, it would likely draw
greater scrutiny given the sensitivity around geoengineering approaches that
aim to achieve cooling by reflecting away sunlight.” It may prove to be the
case that ISA could only be deployed by an intergovernmental planetary cooling
agreement of the scale of the Bretton Woods Agreement of 1944 to establish the
IMF and World Bank. In that governance scenario, the scrutiny placed on all
cooling technologies will be intense regardless of the balance of effects
between brightening and greenhouse gas removal.
I disagree with the scientists quoted in the article who oppose field tests.
That is a dangerous and complacent attitude, failing to give due weight to the
risks of sudden tipping points that can only be prevented by albedo enhancement
and GHG removal at scale. Learning by doing is the most safe and effective
strategy. If there are unexpected effects it is easy to stop the trials. The
only risk of well governed field tests is that they would provide information
to justify a slower transition from fossil fuels. On balance that is not a
serious risk, given that emissions are expected to continue regardless of
climate concerns. Cooling technologies are essential to balance the ongoing
heating, the sooner the better.
I was pleased that the article included my comment that our company decided not
to pursue our ISA field test proposal because the overall political governance
framework is not ready to support this form of geoengineering. This
illustrates that strategic discussion of ethics and governance will need to be
far more advanced before any geoengineering deployment is possible. I explored
these moral themes in a recent discussion
note<https://pdfhost.io/v/nn85Rgk.g_Moral_Perspectives_on_Climate_Policy>
published by the Healthy Planet Action Coalition.
Robert Tulip
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