Wil- You speak for yourself, not for Ken Buesseler or for the Sabin Center for Climate Change Law, unless you have an agreement to do so--in which case you should tell us. Your point is made. Let's stop here.
Peter On Sat, Feb 18, 2023 at 3:17 PM Wil Burns <w...@feronia.org> wrote: > Hi Peter, > > > > First of all, thank you for acknowledging that the NASEM report did not > say what you said it did about either the law or science of OIF, and that > no less than the lead author of the OIF section doesn’t support deployment > at this point. That’s a good starting point. Moreover, you’re not > “supporting” Dr. Buesseler’s work if you’re plumping for deployment at this > point. He’s made that clear in both the NASEM report, and his current > efforts to develop a sound framework for RESEARCH and RESEARCH only; your > full-throated advocacy of deployment actually contravenes his intent. > > As to the Columbia report, that’s a bit of a distortion also. What the > authors conclude is that while there’s not a treaty that SPECIFICALLY > prohibits OIF, there’s a number of agreements, including UNCLOS, that could > be invoked to circumscribe research or deployment. It’s a bit blithe to say > that you could proceed tomorrow without challenge. Moreover, while the > resolutions of the London Convention and CBD are not legally binding on the > parties to said treaties, they provide strong guidance to the parties, and > countries generally conform. That’s why, again, Ken Buesseler, who you > claim to “support” says that the LC resolution would be in play, and it > clearly limits current OIF activities to small-scale scientific research. > Again, not what you claim is permissible. > > > > wil > > > > > > > > > > <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 > > Mobile: 312.550.3079 > > https://www.american.edu/sis/centers/carbon-removal/ > > > > *Want to schedule a call? Click on one of the following scheduling links: * > > - 60-minute phone call: https://calendly.com/wil_burns/phone-call > - 30-minute phone call: https://calendly.com/wil_burns/30min > - 15-minute phone call: https://calendly.com/wil_burns/15min > - 60-minute conference call: > https://calendly.com/wil_burns/60-minute-conference-call > - 30-minute conference call: > https://calendly.com/wil_burns/30-minute-group > - 60-minute Zoom call: https://calendly.com/wil_burns/60min > - 30-minute Zoom call: > https://calendly.com/wil_burns/30-minute-zoom-call > > > > Follow us: > > > <https://www.facebook.com/Institute-for-Carbon-Removal-Law-and-Policy-336916007065063/> > > <https://twitter.com/CarbonRemovalAU> > > > > [image: Title: line art] > > > > > > *From:* Peter Fiekowsky <pfi...@gmail.com> > *Sent:* Saturday, February 18, 2023 5:08 PM > *To:* Wil Burns <w...@feronia.org> > *Cc:* Metta W Spencer <mspen...@web.net>; 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 > > > > Wil- > > > > I stand corrected. Let's use the Columbia Law School's report > <https://scholarship.law.columbia.edu/faculty_scholarship/3637/>in > 2022 instead. They say, more succinctly: “There are currently no legally > binding international treaties dealing specifically with ocean > fertilization.” They add that operations might require EPA permits. But > there probably are no OIF projects that could be done within the EPA > jurisdiction. > > > > I wouldn't qualify Ken Buesseler as opposing OIF--he is working to advance > it, doing it safely, legally and ethically. And I am supporting him and his > work. > > > > Peter > > > > > > > > On Sat, Feb 18, 2023 at 2:42 PM Wil Burns <w...@feronia.org> wrote: > > 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).* > > > > > > > > > > <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 > > Mobile: 312.550.3079 > > https://www.american.edu/sis/centers/carbon-removal/ > > > > *Want to schedule a call? Click on one of the following scheduling links: * > > - 60-minute phone call: https://calendly.com/wil_burns/phone-call > - 30-minute phone call: https://calendly.com/wil_burns/30min > - 15-minute phone call: https://calendly.com/wil_burns/15min > - 60-minute conference call: > https://calendly.com/wil_burns/60-minute-conference-call > - 30-minute conference call: > https://calendly.com/wil_burns/30-minute-group > - 60-minute Zoom call: https://calendly.com/wil_burns/60min > - 30-minute Zoom call: > https://calendly.com/wil_burns/30-minute-zoom-call > > > > Follow us: > > > <https://www.facebook.com/Institute-for-Carbon-Removal-Law-and-Policy-336916007065063/> > > <https://twitter.com/CarbonRemovalAU> > > > > [image: Title: line art] > > > > > > *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> 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 1-416-789-2294 > > > > On Feb 18, 2023, at 1:29 PM, Clive Elsworth <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> 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> 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> 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> 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> 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 > > > > -- > You received this message because you are subscribed to the Google Groups > "Healthy Climate Alliance" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to healthy-climate-alliance+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/healthy-climate-alliance/2bc901d942cd%248ee19e60%24aca4db20%24%40rtulip.net > <https://groups.google.com/d/msgid/healthy-climate-alliance/2bc901d942cd%248ee19e60%24aca4db20%24%40rtulip.net?utm_medium=email&utm_source=footer>. > > > > > -- > You received this message because you are subscribed to the Google Groups > "Carbon Dioxide Removal" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to carbondioxideremoval+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/CarbonDioxideRemoval/CAEr4H2nDV%2BvPXnOFK3wJ5Kvn_hzZQwgLk%3DbJqMUXRXioygR%3DDQ%40mail.gmail.com > <https://groups.google.com/d/msgid/CarbonDioxideRemoval/CAEr4H2nDV%2BvPXnOFK3wJ5Kvn_hzZQwgLk%3DbJqMUXRXioygR%3DDQ%40mail.gmail.com?utm_medium=email&utm_source=footer>. > > > > > -- > You received this message because you are subscribed to the Google Groups > "Carbon Dioxide Removal" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to carbondioxideremoval+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/CarbonDioxideRemoval/CABjtO1cv0bwVvebOcv_js7-c7-WB8W0ht3xFjEVQGaz04xi3Yw%40mail.gmail.com > <https://groups.google.com/d/msgid/CarbonDioxideRemoval/CABjtO1cv0bwVvebOcv_js7-c7-WB8W0ht3xFjEVQGaz04xi3Yw%40mail.gmail.com?utm_medium=email&utm_source=footer>. > > > > > -- > You received this message because you are subscribed to the Google Groups > "Carbon Dioxide Removal" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to carbondioxideremoval+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/CarbonDioxideRemoval/352759944.1617469.1676735989223%40email.ionos.co.uk > <https://groups.google.com/d/msgid/CarbonDioxideRemoval/352759944.1617469.1676735989223%40email.ionos.co.uk?utm_medium=email&utm_source=footer>. > > > > > -- > You received this message because you are subscribed to the Google Groups > "NOAC Meetings" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to noac-meetings+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/noac-meetings/1082078125.1624832.1676744947167%40email.ionos.co.uk > <https://groups.google.com/d/msgid/noac-meetings/1082078125.1624832.1676744947167%40email.ionos.co.uk?utm_medium=email&utm_source=footer> > . > > > > -- > You received this message because you are subscribed to the Google Groups > "Carbon Dioxide Removal" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to carbondioxideremoval+unsubscr...@googlegroups.com. > To view this discussion on the web visit > https://groups.google.com/d/msgid/CarbonDioxideRemoval/CAEr4H2m2NBUsb_BLFYFv3XT_yTUUZmk3gx%2B3vmigoUbugHUdPQ%40mail.gmail.com > <https://groups.google.com/d/msgid/CarbonDioxideRemoval/CAEr4H2m2NBUsb_BLFYFv3XT_yTUUZmk3gx%2B3vmigoUbugHUdPQ%40mail.gmail.com?utm_medium=email&utm_source=footer> > . > > -- You received this message because you are subscribed to the Google Groups "geoengineering" group. 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