Memorandum submitted by The Royal Society
1. The Royal Society welcomes the opportunity
to respond to the Select Committee inquiry into the regulation
of geoengineering. We also welcome the collaboration with the
US Congressional Science and Technology Committee to which Professor
John Shepherd FRS gave evidence on 5 November 2009. This
submission has been prepared based on the Society's report "Geoengineering
the Climate: Science, governance and uncertainty" and
ongoing streams of work. A copy of the report has been enclosed
with this submission.
2. The Royal Society decided to undertake
a review of the feasibility and uncertainties of the various proposed
geoengineering technologies due to the increased public awareness
of, and interest in geoengineering. Under the chairmanship of
Professor John Shepherd FRS of Southampton University, we assembled
a group of 12 experts, drawn from environmental science,
oceanography, engineering, economics, law and social science.
The review took one year and the report was published in September
2009. Here we emphasise three main points:
First, the report emphasises the
geoengineering is not an alternative to greenhouse gas emission
reductions. Geoengineering may hold longer-term potential and
merits more research, but it offers no quick and easy solutions
that should distract policy-makers from working toward a reduction
of at least 50% in global carbon dioxide (CO2) emissions
Second, the report brings greater
clarity to the debate by defining and comparing the two basic
classes of geoengineering methods: Carbon Dioxide Removal (CDR)
techniques that remove CO2 from the atmosphere
and Solar Radiation Management (SRM) techniques that reflect a
small percentage of the sun's light and heat back into space.
Third, the report looks beyond
the science to highlight a broader set of issues that need to
be considered before geoengineering could proceed. The mix of
factors is complex, and it is desirable that both geoengineering
research, and any plans for implementation, be pursued within
robust frameworks of governance, accountability and public engagement.
3. The Royal Society is now planning to
develop a partnership with other science academies and governance
institutions to address the governance of geoengineering. The
early stages of such a process are already underway, and further
details are given in paragraph 23.
Is there a need for international regulation of
geoengineering and geoengineering research and if so, what international
regulatory mechanisms need to be developed?
(a) Fundamental issues
4. It is important to distinguish between
the need for regulation of research and the need for international
regulation of deployment. We are of the opinion that some geoengineering
techniques will likely require international regulation of some
forms of research, and most (but possibly not all) techniques
are likely to require international regulation of deployment.
There is a very wide range of geoengineering methods, with diverse
characteristics, methods of action and potential side effects;
consideration of governance requirements is therefore best done
with reference to specific techniques. We do not consider that
a blanket requirement for regulation of research is necessary
or desirable. Geoengineering techniques can be broadly split into
two categories ie Carbon Dioxide Removal (CDR) and Solar Radiation
Management (SRM) methods, with different features requiring a
5. Carbon Dioxide Removal (CDR) techniques
treat the cause of climate change by removing CO2 from
the atmosphere. This can potentially be achieved through a number
of different technologies, eg air capture ("artificial trees"),
ocean fertilisation, biochar/BECS, and enhanced weathering. Some
of these technologies are likely to have a low risk of unintended
consequences, but they will all only have a significant impact
on global temperatures if applied for many decades. The ecosystem
based methods, such as ocean fertilisation, have much greater
potential for negative and trans-boundary side effects. Research
on many of these techniques (such as air capture and biochar/BECS)
could however be adequately managed by national legislation as
their effects are not trans-boundary, other than via the removal
of greenhouse gases (GHGs) from the atmosphere. The same also
applies to deployment of these techniques, at least until the
levels of GHGs in the atmosphere have been stabilised. Thereafter,
international agreement on the levels to which they should be
reduced will be required, but this requirement is not imminent.
6. Solar Radiation Management (SRM) techniques
are those which reduce the net incoming short-wave solar radiation
received by deflecting sunlight, or by increasing the reflectivity
of the atmosphere, clouds or Earth's surface. These technologies
do not treat the root cause of climate change and would not help
to solve associated problems such as ocean acidification. If these
techniques were deployed they would need to be sustained for a
very long time (several centuries) unless and until atmospheric
concentrations of greenhouse gases were reduced. SRM technologies
would include space mirrors, aerosols (eg sulphates) in the stratosphere
and cloud brightening. The effects of most SRM techniques (other
than "white roofs") would occur on regional to global
scales and so would require international regulation.
7. We suggest that the fundamental criteria
in relation to governance are whether (and to what extent) the
trans-boundary effects (other than the
removal of GHGs from the atmosphere);
dispersal of potentially hazardous materials
in the environment; and
direct intervention in (or major direct
side-effects on) ecosystems.
8. In designing regulatory frameworks the
potential for technical and structural reversibility of the technologies
should also be considered.
(b) Institutional issues
13. CDR technologies could mostly be adequately
controlled by existing national and international institutions
and legislation. Many of the technologies are closely related
to familiar existing technologies. Air capture technologies are
very similar to those of carbon capture and storage; and this
is likely to be one of the most environmentally benign technologies.
Ocean fertilisation techniques are currently being managed by
the London Convention on ocean dumping, under the London Protocol.
The Convention of Biological Diversity has also adopted a decision
on ocean fertilisation which is mostly consistent with that of
the London Convention. Biochar and BECS face similar regulatory
issues to that of biofuels including life cycle analysis, and
land use management. Ecosystem impacts of enhanced terrestrial
weathering would be contained within national boundaries. Methods
of enhanced weathering involving oceanic dispersion of the products
would have trans-boundary effects, but may also be able to be
managed under the London Convention.
14. For SRM technologies there are fewer
existing institutions that could manage research and development.
Land surface albedo modification could be managed under national
regulatory frameworks as there are unlikely to be major trans-boundary
issues. The oceanic cloud brightening technologies would not fall
under national jurisdiction and no existing international institutions
have a clear mandate, so modifications and extensions of existing
treaties (eg ENMOD) and institutions would be required. Existing
treaties governing the atmosphere and space (CLRTAP & OST)
would similarly not be adequate to regulate stratospheric aerosols
and space mirrors. There is a risk that these methods could be
applied by an individual nation or corporation which highlights
the need for international regulation for deployment (and in some
15. Governance mechanisms should be decided,
and where necessary, constructed for technologies that require
them, before they are needed in practice.
16. Our report proposed that the Royal Society,
along with other scientific institutions, should initially develop
a voluntary code of practice to govern scientific research for
both SRM and CDR technologies. We are now looking to take forward
this work with a number of other science academies and governance
institutions (see paragraph 23).
17. Governance mechanisms will be required
for some research. Theoretical (modelling) studies and small scale
experiments undertaken in the laboratory would not require regulation
but we would encourage maximum transparency and international
collaboration on such activities. Field tests that are below a
level that could have discernable negative consequences should
be permitted, but further consideration and international agreement
is required to determine how these de minimis levels should
be set. International co-operation and public engagement will
also be needed to maintain trust in the process. For research
where effects on the environment could potentially have discernable
negative consequences, it would be necessary to have governance
mechanisms in place to ensure they are undertaken responsibly.
18. An important characteristic of any international
mechanisms is that they should be flexible enough to deal with
new proposals, and to adapt as our understanding improves of the
technologies and their implications.
19. Eventual deployment of any geoengineering
technologies will necessarily require involvement of and coordination
within the UNFCCC.
How should international regulations be developed
20. Our report proposed that the Royal Society
along with other scientific institutions should initially develop
a voluntary code of practice to govern scientific research for
both SRM and CDR technologies, as necessary. We are now looking
to take forward this work with a number of other science academies
and governance institutions. We are also continuing to actively
engage other organisations in process to include governance specialists,
NGOs and participants from a range of geographic locations.
21. We also suggested that a suitable international
body (possibly the UN Commission for Sustainable Development)
should commission a review of existing international and regional
Consider the relevant roles of the following
bodies (and any others that we may have overlooked): UNCLOS, LC/LP,
CBD, CLRTAP, Montreal Protocol, Outer Space Treaty, Moon Treaty,
Identify existing mechanisms that could
be used to regulate geoengineering research and deployment activities
(if suitably extended as necessary).
Identify where regulatory gaps exist
in relation to geoengineering methods proposed to date, and establish
a process for the development of mechanisms to address these gaps.
22. It will be important that the development
of any regulatory framework be as open, transparent and inclusive
Ongoing Royal Society work on geoengineering
23. Following on from our report we are
now seeking to facilitate a process of international research
and discussion to address the governance of geoengineering in
partnership with other prominent scientific and policymaking organisations.
The early stages of such a process are already underway, the Royal
Society and the Centre for International Governance Innovation
(CIGI) jointly hosted a series of three side events on "The
Science, Research and International Governance of Geoengineering"
at the COP15 in Copenhagen. These events disseminated the
key messages and findings of the Royal Society report, and began
engaging a broader audience of international policy-makers and
stakeholders in discussions of geoengineering governance. SRM
techniques present the greatest potential for near-term political,
social and ethical challenges; therefore the envisioned process
will focus predominantly on the governance of these techniques.
16 All methods will of course involve indirect side-effects
on ecosystems via their effects on climate change. Back