Memorandum submitted by Research Councils
UK (RCUK) (GEO 10)
1. Research Councils UK (RCUK) is a strategic
partnership set up to champion the research supported by the seven
UK Research Councils. RCUK was established in 2002 to enable
the Councils to work together more effectively to enhance the
overall impact and effectiveness of their research, training and
innovation activities, contributing to the delivery of the Government's
objectives for science and innovation. Further details are available
2. This evidence is submitted by RCUK on
behalf of the Economic and Social Research Council (ESRC) and
the Natural Environment Research Council (NERC) and represents
their independent views. It does not include or necessarily reflect
the views of the Department for Business, Innovation, and Skills.
3. The ESRC and the NERC have contributed
to the main text of this response. NERC input was provided by
Swindon Office staff, the Plymouth Marine Laboratory, and the
Oceans 2025 programme. In the preparation of this submission
it has been agreed that beyond the potential funding of high quality
research there are no conflicts of interest to declare.
4. While the term "geoengineering"
is useful to collectively refer to methods of large-scale intervention
in the global climate, it is worth noting that technologies fall
into two distinct categories; those which remove CO2 (or
other GHG) from the atmosphere (Carbon Dioxide Removal techniquesCDR);
and those that mediate the level of sunlight and heat that is
absorbed by the Earth (Solar Radiation Management techniquesSRM).
Different techniques offer different opportunities, have different
effects and carry different risks which raise different questions
about the regulation of geoengineering.
5. Given the limited geoengineering research
undertaken to date, the major social, environmental and technological
uncertainties associated with its developmental infancy, and the
specificity of the various techniques and technologies collectively
referred to as geoengineering, it is not yet appropriate to outline
a definitive framework for its regulation. Indeed, given the levels
of uncertainty it is essential that all mechanisms established
to regulate geoengineering are able to adapt to the evolving technological,
environmental, and socio-political context within which they operate.
6. Public confidence is an essential step
towards generating appropriate and effective geoengineering regulation.
Building knowledge amongst the public including regulators and
law makers is conducive to establishing a genuinely participatory
approach which must be sought if geoengineering is to be successfully
7. To better understand public views and
concerns, NERC is carrying out a public dialogue on geoengineering.
This will assess public opinion and concerns, which will inform
the direction, conduct and communication of future research in
geoengineering. This activity, which is due to deliver by April
2010, is in partnership with Sciencewise, which supports public
dialogue activities in government.
Is there a need for international regulation of
geoengineering and geoengineering research and if so, what international
regulatory mechanisms need to be developed?
8. Many, but not all, potential geoengineering
schemes involve winners and losers both nationally and internationally.
Given geoengineering will manipulate the climate at a global level,
all global citizens should in principle be considered stakeholders
in the development and implementation of geoengineering techniques
and their regulation. Nevertheless, the expertise and tools required
for the research and application of such techniques are likely
to be within the direct control of relatively few while the positive
and negative effects of geoengineering will be unevenly distributed,
both geographically and socially.
9. The need for explicit approval-based
regulatory mechanisms for geoengineering primarily arise when
the actions of one stakeholder have or could have consequences
for others. Where such action is not well-covered by existing
legal or regulatory arrangements an initial framework for joint
decision-making by all parties is required. This should be used
to establish that a net (global) advantage and equitable distribution
of those advantages from the geoengineering intervention can be
achieved prior to any interventions.
10. Careful consideration is required of
who is involved and consulted during the development of geoengineering
regulation in order that an equitable consensus can be reached.
Different countries and groups will have very different assessments
of the balance of risks of unchecked climate change and the application
of geoengineering, as well as the morality of intentional manipulation
of the climate system. Any geoengineering activity will therefore
bring a variety of ethical, legal and social, political and economic
questions into sharp focus.
11. Irrespective of the regulatory controls
implemented, geoengineering will entail costs (direct and potentially
indirect) as well as benefits. This raises significant research
questions about ownership of, and responsibility for, both negative
and positive effects of geoengineering action which have an international
impact. Approval-based mechanisms should, for example, include
protocols for the assessment of fair compensation; should adverse
impacts occur, who would meet the costs of such impactsthe
country or countries carrying out the geoengineering, or the companies
involved? In some cases it will be difficult to attribute climatic
impacts to particular acts of geoengineering and new, early-stage
research on how this should be done is essential. Such research
will have to address how to measure and attribute any changes
and how to value their impacts including, for example, effects
on health, crops and economic well-being. This research will help
inform judgements about impact and whether geographical areas
or social groups merit compensation.
12. Geoengineering development involves
several stages and regulatory frameworks must be flexible enough
to cover the full cycle (eg from research through implementation
through monitoring to evaluation). While knowledge of geoengineering
techniques and the development of relevant technologies remain
limited, interest is growing. It is therefore important at this
stage that appropriate mechanisms for the regulation of research
(as well as implementation) are established. Field-based research
(such as method testing and small-scale trials) would for instance
be expected to have much more limited impact than full-scale geoengineering
interventions. Nevertheless, even small-scale actions could generate
negative environmental, social and economic consequences if undertaken
without appropriate controls in place or a sufficient level of
expertise. For example, a field trial involving atmospheric SRM
manipulations might temporallybut perhaps coincidentallybe
linked to extreme weather events resulting in high economic consequences.
Some highly controversial techniques could be applied at relatively
low cost and with relative ease, opening up geoengineering as
a feasible unilateral activity to a wide range of actors with
different knowledge, skills and motivations. Such actions may
be linked to political as well as, or even instead of, environmental
concerns. This suggests regulation might be best monitored at
the level of supra-national governance structures such as the
13. An example highlighting the potential
issues arising from the regulation of research on geoengineering
is provided by ocean fertilization. Large-scale ocean fertilization
is not currently allowed under the Convention on Biological Diversity
(CBD). Research is also restricted by the CBD, until a regulatory
framework has been developed; this is in progress, via the London
Convention and London Protocol (LC/LP). During 2009, the scientific
basis for a framework to allow further research (via large-scale
experiments outside territorial waters) was agreed, through discussions
that involved a wide range of stakeholder interests. However,
whilst representatives of the international scientific community
were able to reach consensus relatively rapidly, eight different
legal options were developed, covering the range from "light
touch" to much more complex and demanding approval arrangements.
Different legal options were favoured by different countries;
overall agreement is needed for LC/LP decisions; and there is
no early prospect for resolution of this issue to be reached.
Thus it could be some time before a regulatory outcome is obtained
and, once produced, it will apply only to research, not geoengineering
14. In terms of research and the implementation
of geoengineering techniques, the development of new national
and international regulation mechanisms, and the feasibility of
doing so, is highly dependent on the technique under consideration.
This is shown in Table 1, Annex 1, grouping the need for new regulation
as high, medium or low for 13 techniques considered by the
recent Royal Society report.
This broadly shows that SRM techniques currently lack regulatory
control, in comparison to techniques involving CDR. However, a
more fundamental grouping relates to the different environmentsspace,
atmosphere, ocean and landin which the techniques are deployed,
a function of the different jurisdictions applicable to different
resource ownership arrangements.
15. The situation is most straightforward
for land-based activities, since although there is potential for
regional effects any adverse impacts are more likely to be experienced
by the country carrying out the action. For the lower atmosphere
above nationally-owned land and for territorial waters, any adverse
impacts of geoengineering may be predominantly local and "self-inflicted";
for the upper atmosphere and open ocean, much larger adverse impacts
are possible, potentially on a global scale (indeed, for geoengineering
global-scale impacts are the intended outcome). The ocean has,
however, been recognised by most countries as a global good requiring
international stewardship, with three legal instruments for potential
regulation of geoengineering in non-territorial waters: the UN
Convention on Law of the Sea (UNCLOS), LC/LP; and the CBD.
16. In the future, assuming geoengineering
occurs, its implementation and monitoring are also likely to require
a verification-based form of regulation. These stages are also
potentially problematic. Assuming that geoengineering techniques
are formally recognised as contributing to climate change mitigation
(ie as part of national commitments to international climate change
agreements), such techniques will need linking to emission trading
schemes or other mechanisms that may evolve. Such regulation is
essentially international standard-setting, to verify that the
amount of carbon dioxide (or other greenhouse gas) removed from
the atmosphere, or cooling achieved by other means, is as claimed.
This also raises the broader point that the development of geoengineering
techniques should only be considered as complementary to other
methods of climate change mitigation and adaptation, and that
the regulation of geoengineering should therefore ensure that
the aims of such methods are not compromised.
17. As noted above, it is essential that
mechanisms for the regulation of geoengineering are imbued with
a high level of flexibility. This will be necessary for a variety
of reasons. First, regulatory controls will need to adapt to the
evolution of environmental, scientific, technological, geo-political,
economic and social risks. Major uncertainties remain about geoengineering
and it is impossible to foresee how technologies will develop,
their public confidence, and the measures that will be needed
to shape and respond to such developments. In addition, environmental,
geo-political, economic and social factors that will influence
the development of geoengineering are also in a constant state
of flux and must therefore be accounted for through flexible regulatory
arrangements. For example, the low likelihood of being able to
create and maintain the decadal-to-century political stability
that will be required to manage some geoengineering projects on
a global scale would need to be guarded against through sufficient
flexibility of regulatory mechanisms. Research is required to
both establish the extent to which such instability has been successfully
incorporated into other regulatory frameworks and the degree of
instability that might reasonably be expected to occur in the
18. The potential effects of geoengineering
activity are transboundary in nature. Mechanisms must be flexible
enough to regulate activity carried out in a wide range of locations
and by a variety of people operating under different legislative,
social and cultural environments. As a channel through which to
trade in the carbon market, the private sector may become an important
force in the development of geoengineering in some regions. It
will therefore be vital that businesses are subject to the same
stringent controls that are applied to other bodies.
19. It will be paramount that regulatory
measures are able to respond rapidly, if necessary, following
the application of geoengineering techniques. A key criterion
for geoengineering to be taken forward is the ability for applications
to be withdrawn quickly in case of negative consequences (where
this action in itself does not entail further negative impact).
Rapid agreement on such decisions will be challenging for many
international bodies. A mechanism by which consensus could quickly
be reached, and action taken without unilateral counter-action
in response, would need to be incorporated into regulatory measures.
Research can help inform policy makers about the sort of mechanisms
and regulatory frameworks that have been able to successfully
respond in such rapid ways.
How should international regulations be developed
20. The international mechanisms currently
most applicable to the regulation of geoengineering activity have
not been developed for this purpose. However, through modification
and expansion, existing international governance mechanisms should
be used as much as possible, subject to rigorous evaluation of
their fit for purpose. IPCC could, for example, provide a framework
to establish whether there is sufficient scientific justification
for research on different techniques and, if so, where effort
ought to be focussed. The international global change programmes,
co-sponsored by International Council for Science (ICSU), (International
Geosphere-Biosphere Programme (IGBP); World Climate Research Programme
(WCRP); International Human Dimensions Programme on Global Environmental
Change (IHDP) and Diversitas; grouped under the Earth System Science
Partnership, (ESSP)) also have a role in coordinating relevant
research and providing independent international assessments which
could be adapted for the purposes of geoengineering research.
21. At the later stages of development,
implementation and monitoring, it is unclear whether the regulatory
measures and controls needed for geoengineering may be adequately
incorporated into existing international, regional, and national
regulatory structures and bodies. The Environmental Modification
Convention (passed by the UN in 1977) banned the use of weather
modification for hostile use and, on a broad conceptual level,
therefore offers one channel through which new regulatory mechanisms
may be enforced. Given the fundamental aim of geoengineering,
the United Nations Framework Convention on Climate Change (UNFCCC)
would also need to inform its development. Research of how these
legislative frameworks should be amended would be valuable.
22. More specifically, the regulation of
particular geoengineering techniques may logically fit into the
remits of other international treaties and bodies. Ocean fertilisation
for instance has direct relevance to the UNCLOS while the implementation
of "space mirrors" may be monitored through the United
Nations Outer Space Treaty. It has been suggested that the only
major geoengineering technique being discussed that could not
be managed within existing regulatory structures is the application
of stratospheric aerosols.
23. Polar regions are likely to be at the
forefront of future geoengineering debate, because of climatic
feedback risks (relating to albedo change and methane emissions)
and socio-economic risks (sea level rise due to ice-sheet loss).
If SRM geoengineering could (mostly) be confined to these regions,
its negative impacts with regard to crop production, natural productivity,
economic development and social well being would be minimised.
The Antarctic is, however, strongly protected through the Antarctic
Treaty System, including the Protocol on Environmental Protection
to the Antarctic Treaty (Antarctic-Environment Protocol), whilst
any geoengineering activities in the Arctic would be highly politically-sensitive,
particularly in the context of recent new claims to undersea resources
and the claims of indigenous peoples.
24. The cost, effectiveness, timeliness
and risk of putative geoengineering approaches vary substantially.
It is therefore important that international collaboration is
sought at an early stage. An international geoengineering advisory
group may well be an appropriate body to help address these challenges.
With representation from the scientific, policy, commercial, regulatory
and non-governmental communities, such a group would provide independent
oversight of evolving regulatory issues concerning geoengineering.
It would be tasked with the coordination of existing research,
and the identification of a new research agenda, as well as the
development of an effective and objective assessment framework
to inform the regulation of geoengineering. This would involve
making informed judgements about the weight of different environmental,
social and economic costs and benefits and striking an appropriate
balance between short-term and long-term effects.
What UK regulatory mechanisms apply to geoengineering
and geoengineering research and what changes will need to be made
for the purpose of regulating geoengineering?
25. UK-based terrestrial and atmospheric
geoengineering and geoengineering research could be covered by
existing national and regional planning and pollution control
regulation, and, in part, by research institutes, funders and
professional bodies, as well as civil society more generally.
However, it is recommended that an early stage testing of these
assumptions is undertaken by independent experts with a brief
to address public engagement. Marine activities within the UK
Exclusive Economic Zone should be covered by the newly-formed
Marine Management Organisation (created under the 2009 Marine
Act) and the equivalent body for Scotland Marine activities outside
UK waters are primarily covered by LC/LP, with Defra as the national
Table 1. Preliminary assessment of the need
for geoengineering regulation for specific techniques, based on
those identified in 2009 Royal Society report. Convention
on Biological Diversity (CBD); Carbon Capture and Storage (CCS);
Carbon Dioxide Removal (CDR); London Convention/London Protocol
(LC/LP); Solar Radiation Management (SRM); UN Convention to Combat
Desertification (UNCCD); UN Convention on Law of the Sea (UNCLOS);
UN Framework Convention on Climate Change (UNFCCC).
|Environment||CDR or SRM
||Existing regulatory framework, if any
|1. HIGH need for international regulation
|1. 1 Cloud albedo enhancement (via ocean spray)
||Lower atmosphere, upper ocean||SRM
||?||Potential effects on regional weather, ocean dynamics, marine productivity, food production, economic and social well being
|1.2 Stratospheric aerosols||Upper atmosphere
||SRM||Long-range Transboundary Air Pollution Convention? Antarctic-Environment Protocol?
||Global scale effectsbut not direct reversal of CO2 warming. Reduced insolation, crop and plant productivity, economic, social and cultural well being
|1.3 Space-based methods||Space
||SRM||Outer Space Treaty?
||Global scale effectsbut not direct reversal of CO2 warming. Reduced insolation, crop and plant productivity, economic, social and cultural well being
2. MEDIUM need for international regulation
|2.1 Biomass burial in deep ocean||Land and ocean
||CDR||LC/LP (potentially); UNCLOS; carbon trading
||Land-grown crops/timber would be ballasted and sunk to deep ocean, could locally affect food availability and price
|2.2 Enhanced weatheringocean||Land and ocean
||CDR||LC/LP (potentially); UNCLOS; carbon trading
||Land-mined silicate rocks added to ocean, or carbonates used instead to derive Ca(OH)2
|2.3 Ocean fertilization||Ocean
||CDR||LC/LP: regulation in prep for research (with CBD); also UNCLOS
||Could be based on adding iron, other nutrients or enhanced mixing
|2.4 Surface albedodeserts||Land
||SRM||UNCCD?||Might affect regional weather, crop production, economic, social and cultural well being
3. LOW need for international regulation
|3.1 Land use management, afforestation, reforestation & deforestation avoidance
||Land||CDR||Carbon trading under UNFCCC
||Not necessarily regarded as geoengineering
|3.2 Bio-energy with carbon sequestration (BECS)
||Land (ocean?)||CDR||Carbon trading; CCS regulation
||Not necessarily regarded as geoengineering. (Ocean?) relates both to potential use of algae and sub seafloor CCS reservoirs
|3.3 Biochar and terrestrial biomass burial
|3.4 Enhanced weatheringterrestrial
||Land-mined silicate rocks added to soil
|3.5 Carbon dioxide capture from ambient air
||Land , lower atmosphere (ocean)||CDR
||Carbon trading; CCS regulation||(Ocean) relates to CCS components
|3.6 Surface albedohuman settlement
||Limited effectiveness on global scale|
Whilst climate system modelling provides a "safe"
means of investigating the effectiveness of different engineering
approaches, it does not necessarily include all interactions and
effects that will occur in the real world. Further investment
in modelling techniques will enhance the accuracy of the models;
however, large-scale field testing will be an inevitable intermediate
step for any geoengineering techniques considered worthy of serious
attention. Because of natural variability in weather/climate and
biogeochemical processes, multiple studies are likely to be needed
for adequate replication to achieve unambiguous effects. For some
methods, large-scale field testing is likely to be an extremely
fraught and controversial step; research on the potential social,
economic and cultural effects, as well as how to mitigate these
in advance of implementation, is essential.
Royal Society (2009) Geoengineering the climate: science, governance
and uncertainty. RS Policy Document 10/09; Back