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: *
>
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>
>
>
> [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: *
>
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>
>
>
> [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
>
>
>
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> <https://groups.google.com/d/msgid/CarbonDioxideRemoval/CAEr4H2m2NBUsb_BLFYFv3XT_yTUUZmk3gx%2B3vmigoUbugHUdPQ%40mail.gmail.com?utm_medium=email&utm_source=footer>
> .
>
>

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