Regulating Geoengineering: Principles and Recommendations, Summaries of English Literature

The need for regulation of geoengineering techniques to mitigate climate change, comparing the cost and environmental impact of solar radiation management (srm) methods. It emphasizes the importance of public participation in decision-making and international cooperation. The document also suggests principles to guide research and the potential creation of international norms and legislation.

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HC 221
Published on 18 March 2010
by authority of the House of Commons
London: The Stationery Office Limited
£0.00
House of Commons
Science and Technology
Committee
The Regulation of
Geoengineering
Fifth Report of Session 2009–10
Report, together with formal minutes, oral and
written evidence
Ordered by the House of Commons
to be printed 10 March 2010
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HC 221 Published on 18 March 2010 by authority of the House of Commons London: The Stationery Office Limited £0.

House of Commons

Science and Technology

Committee

The Regulation of

Geoengineering

Fifth Report of Session 2009–

Report, together with formal minutes, oral and

written evidence

Ordered by the House of Commons to be printed 10 March 2010

The Science and Technology Committee

The Science and Technology Committee is appointed by the House of Commons to examine the expenditure, administration and policy of the Government Office for Science. Under arrangements agreed by the House on 25 June 2009 the Science and Technology Committee was established on 1 October 2009 with the same membership and Chairman as the former Innovation, Universities, Science and Skills Committee and its proceedings were deemed to have been in respect of the Science and Technology Committee.

Current membership

Mr Phil Willis (Liberal Democrat, Harrogate and Knaresborough)(Chair) Dr Roberta Blackman-Woods (Labour, City of Durham) Mr Tim Boswell (Conservative, Daventry) Mr Ian Cawsey (Labour, Brigg & Goole) Mrs Nadine Dorries (Conservative, Mid Bedfordshire) Dr Evan Harris (Liberal Democrat, Oxford West & Abingdon) Dr Brian Iddon (Labour, Bolton South East) Mr Gordon Marsden (Labour, Blackpool South) Dr Doug Naysmith (Labour, Bristol North West) Dr Bob Spink (Independent, Castle Point) Ian Stewart (Labour, Eccles) Graham Stringer (Labour, Manchester, Blackley) Dr Desmond Turner (Labour, Brighton Kemptown) Mr Rob Wilson (Conservative, Reading East)

Powers

The Committee is one of the departmental Select Committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No.152. These are available on the Internet via www.parliament.uk

Publications

The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the Internet at http://www.parliament.uk/science A list of reports from the Committee in this Parliament is included at the back of this volume.

Committee staff

The current staff of the Committee are: Glenn McKee (Clerk); Richard Ward (Second Clerk); Dr Christopher Tyler (Committee Specialist); Xameerah Malik (Committee Specialist); Andy Boyd (Senior Committee Assistant); Camilla Brace (Committee Assistant); Dilys Tonge (Committee Assistant); Melanie Lee (Committee Assistant); Jim Hudson (Committee Support Assistant); and Becky Jones (Media Officer).

Contacts

All correspondence should be addressed to the Clerk of the Science and Technology Committee, Committee Office, 7 Millbank, London SW1P 3JA. The telephone number for general inquiries is: 020 7219 2793; the Committee’s e- mail address is: [email protected].

  • Summary Report Page
  • 1 Introduction - Previous scrutiny of geoengineering - Committee Coordinated working with US House of Representatives Science and Technology - The inquiry - Structure of this Report
  • 2 Categories of geoengineering - Introduction - Definition of geoengineering - Carbon Dioxide Removal (CDR) - Solar Radiation Management (SRM) - Differences between CDR and SRM - Weather modification techniques - Conclusions on definition - Conclusions on grading for the purposes of regulation
  • 3 Need for regulation of geoengineering - Geoengineering techniques currently subject to regulation - Geoengineering techniques currently not subject to regulation - Urgency - Geoengineering is too unpredictable - Conclusions on the need for the regulation of geoengineering - Public attitudes
  • 4 Future regulatory arrangements - The formulation of a regulatory regime - Principles to be applied to geoengineering research - Research - Research: climate impact testing - Research: international confidence and cooperation - Formulating international regulatory arrangements for geoengineering - Role of the UK
  • 5 Collaborative working with the US Congress - Introduction - Arrangements for collaborative working - Review of procedural arrangements - Conclusion on collaborative working
  • 6 Conclusion
    • Conclusions and recommendations
    • Coordination on Geoengineering Annex: Joint Statement of the U.K. and U.S. Committees on Collaboration and
      • Introduction
      • Background
      • Geoengineering
      • The U.S. inquiry
      • The U.K. inquiry
      • Committee co-ordination
  • Formal Minutes
  • Witnesses
  • List of written evidence
  • List of Reports from the Committee during the current Parliament

Summary

Geoengineering describes activities specifically and deliberately designed to effect a change in the global climate with the aim of minimising or reversing anthropogenic (that is human caused) climate change. Geoengineering covers many techniques and technologies but splits into two broad categories: those that remove carbon dioxide from the atmosphere such as sequestering and locking carbon dioxide in geological formations; and those that reflect solar radiation. Techniques in this category include the injection of sulphate aerosols into the stratosphere to mimic the cooling effect caused by large volcanic eruptions.

The technologies and techniques vary so much that any regulatory framework for geoengineering cannot be uniform. Instead, those techniques, particularly carbon removal, that are closely related to familiar existing technologies, could be regulated by developing the international regulation of the existing regimes to encompass geoengineering. For other technologies, especially solar refection, new regulatory arrangements will have to be developed.

There are three reasons why, we believe, regulation is needed. First, in the future some geoengineering techniques may allow a single country unilaterally to affect the climate. Second, some—albeit very small scale—geoengineering testing is already underway. Third, we may need geoengineering as a “Plan B” if, in the event of the failure of “Plan A”—the reduction of greenhouse gases—we are faced with highly disruptive climate change. If we start work now it will provide the opportunity to explore fully the technological, environmental, political and regulatory issues.

We are not calling for an international treaty but for the groundwork for regulatory arrangements to begin. Geoengineering techniques should be graded with consideration to factors such as trans-boundary effect, the dispersal of potentially hazardous materials in the environment and the direct effect on ecosystems. The regulatory regimes for geoengineering should then be tailored accordingly. The controls should be based on a set of principles that command widespread agreement—for example, the disclosure of geoengineering research and open publication of results and the development of governance arrangements before the deployment of geoengineering techniques.

The UN is the route by which, eventually, we envisage the regulatory framework operating but first the UK and other governments need to push geoengineering up the international agenda and get processes moving.

This inquiry was innovative in that we worked collaboratively with the US House of Representatives Science and Technology Committee, the first international joint working of this kind for a House of Commons select committee. We found the experience constructive and rewarding and, we hope, successful. We are enthusiastic supporters of collaborative working between national legislatures on topics such as geoengineering with international reach. Our Report covering the regulation of geoengineering will now dovetail into a wider inquiry that the House of Representatives Committee is carrying out on geoengineering. Science, technology and engineering are key to solving global challenges and we commend to our successor committee international collaboration as an innovative way to meet these challenges.

1 Introduction

  1. There were two spurs to this Report. First, in what we believe was a first for scrutiny by a legislature we examined geoengineering as one of the case studies in our Report, Engineering: turning ideas into reality.^1 We wished to follow-up that earlier work. Second, during our visit to the USA in April 2009 we met the Chairman of the House of Representatives Science and Technology Committee, Representative Bart Gordon, who suggested that the committees might find it beneficial to coordinate their scrutiny on a subject. Later in the year we agreed that geoengineering was an area where we could pool our efforts and complement each other’s work, particularly as it has a significant internal dimension—a large geoengineering test could have global repercussions, deployment certainly would.

Previous scrutiny of geoengineering

  1. In our earlier Report, Engineering: turning ideas into reality, we carried out a wide examination of geoengineering. The Report provided us with an opportunity to consider the implications of a new engineering discipline for UK policy-making. The broad definition of geoengineering that we used in the earlier Report holds good: we use the term “geoengineering” to describe activities specifically and deliberately designed to effect a change in the global climate with the aim of minimising or reversing anthropogenic (that is, human made) climate change.^2 A more succinct definition was provided by one of the witnesses to the current inquiry, Professor Keith: the intentional large-scale manipulation of the environment.^3
  2. To set the scene for this inquiry it is worth recalling some of our earlier findings, conclusions and recommendations from the earlier inquiry which informed our approach to this inquiry.
    • We noted that unlike mitigation and adaptation to climate change, the UK had not developed any policies relating to geoengineering research or its potential role in mitigating against climate change.^4
    • We did not consider a narrow definition of geoengineering technologies to be helpful and took the view that technologies to reduce solar insolation^5 and to sequester carbon should both be considered as geoengineering options. 6

1 Innovation, Universities, Science and Skills Committee, Fourth Report of Session 2008–09, Engineering: turning ideas into reality , HC 50–I, chapter 4 2 HC (2008-09) 50–I, para 160 3 DW Keith, “Geoengineering the climate: history and prospect”, Annual Review of Energy and the Environment , (2000) 25:245– 4 HC (2008–09) 50–I, para 159 5 Insolation is the offsetting of greenhouse warming by reducing the incidence and absorption of incoming solar (short-wave) radiation. 6 HC (2008–09) 50–I, para 182

  • We were of the view that the Government should give the full range of policy options for managing climate change due consideration and that geoengineering technologies should be evaluated as part of a portfolio of responses to climate change, alongside mitigation and adaptation efforts.^7
  • The decision not to consider any initiative other than “Plan A”—mitigation— could be considered negligent, particularly since uncertainties in success of “Plan A—for example, climate sensitivity—could be greater than expected. Geoengineering should be considered “Plan B”.^8
  • In order to identify those geoengineering options it might be feasible to deploy safely in the future, it was essential that a detailed assessment of individual technologies was conducted. This assessment had to consider the costs and benefits of geoengineering options, including their full life-cycle environmental impact and whether they were reversible. We welcomed the efforts of the Royal Society to review the geoengineering sector.^9
  • We considered that support for detailed modelling studies would be essential for the development of future geoengineering options, and to the construction of a credible cost-benefit analysis of technological feasibility. We urged the UK Research Councils to support research in this area.^10
  • We recommended that the Government engage with organisations including the Tyndall Centre, Hadley Centre, Research Councils UK and the Carbon Trust to develop a publicly-funded programme of geoengineering research.^11
  • Before deploying any technology with the capacity to geo-engineer the climate, we considered that it was essential that a rational debate on the ethics of geoengineering was conducted. We urged the Department for Energy and Climate Change (DECC) to lead this debate, and to consult on the full range of geoengineering options.^12
  • We were of the view that it was essential that the Government support socio- economic research with regard to geoengineering technologies, in order that the UK could engage in informed, international discussions to develop a framework for any future legislation relating to technological deployment by nation states or industry.^13

7 HC (2008–09) 50–I, para 185 8 HC (2008–09) 50–I, para 187 9 HC (2008–09) 50–I, para 197 10 HC (2008–09) 50–I, para 203 11 HC (2008–09) 50–I, para 217 12 HC (2008–09) 50–I, para 226 13 HC (2008–09) 50–I, para 229

offered “no quick and easy solutions that should distract policy-makers from working toward a reduction of at least 50 percent in global carbon dioxide [...] emissions by 2050”.^21

  1. We welcomed both the Government’s response to our Report—albeit we consider some parts to be too cautious—and the Royal Society’s report. Both are constructive and show that further work needs to be done. We considered therefore what part we could play in moving geoengineering policy on in the limited time left in this Parliament. One of the recommendations in the Royal Society’s report was that:

The governance challenges posed by geoengineering should be explored in more detail, and policy processes established to resolve them.^22

The report explained:

A review of existing international and regional mechanisms relevant to the activities and impacts of [geoengineering] methods proposed to date would be helpful for identifying where mechanisms already exist that could be used to regulate geoengineering (either directly or with some modification), and where there are gaps.^23

We considered that the national and international regulation of geoengineering was an issue we could examine in more detail by means of a short inquiry.

Coordinated working with US House of Representatives Science and

Technology Committee

  1. When the Innovation, Universities, Science and Skills Committee, as we were until October 2009, visited the USA in April 2009 we met Representative Bart Gordon, Chairman of the House Science and Technology Committee. Representative Gordon suggested that the two Committees might wish to identify a subject on which they could work together. The Commons Committee (now the Science and Technology Committee) discussed the proposal after its return from the USA and explored possible topics and arrangements for coordinating work. During the summer geoengineering emerged as an attractive subject, particularly as geoengineering has a large international dimension. In addition, the two Committees were at different stages in examination of the subject with the Commons Committee having, as we have noted, already produced a report and the House Committee about to embark on its first examination of the subject. This meant that each could cover different ground and complement each other’s work.
  2. In October 2009 the Committees agreed a timetable and working arrangements within the procedural rules of their respective legislatures. The text of a joint statement agreed between the Committees is the Annex to this Report.
  3. The House Committee began its examination of geoengineering with a hearing in Washington DC on 5 November 2009, in which testimony was provided by a panel of

21 Ev 51, para 2 22 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, rec 6. 23 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 5.

expert witnesses that included Professor John Shepherd, who chaired the working group that produced the Royal Society’s report, and leading US climate scientist Professor Ken Caldeira, Carnegie Institution, from whom we took evidence in our earlier inquiry. That session assessed the implications of large-scale climate intervention. On 4 February 2010 the House Committee took evidence on the scientific basis and engineering challenges from Professor Klaus Lackner, Columbia University, from whom we took evidence for our earlier inquiry, and from Professor David Keith, who gave evidence to this inquiry. The third hearing is planned for 18 March 2010 and will cover issues of governance.^24 It is planned that our Chairman will give testimony to that session. Ultimately, the hearings may lead to the formation of legislation authorising US government agencies to undertake certain geoengineering research activities and establish intergovernmental research agreements with other nations.

  1. It is our intention that this report will assist members of the House Committee in their deliberations on the regulation of geoengineering. We also see our work on geoengineering as a pilot for future collaborative scrutiny between select committees of the House of Commons and the committees of other national legislatures, which is an issue we examine further in this Report.

The inquiry

  1. In our call for evidence on 5 November 2009 we stated that the inquiry would focus on the regulation of geoengineering, particularly international regulation and regulation within the UK. The following were the terms of reference of our inquiry.
    • Is there a need for international regulation of geoengineering and geoengineering research and if so, what international regulatory mechanisms need to be developed?
    • How should international regulations be developed collaboratively?
    • 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
  2. We received 13 written submissions (excluding supplementary memoranda) in response to our call for submissions, which we accepted as evidence to the inquiry and which are appended to this Report. We are grateful to all those who submitted written memoranda. We are especially pleased that with the international dimension to this Report we received submissions from across the world.
  3. On 13 January 2010 we took oral evidence from three panels consisting of:

a) Dr Jason J Blackstock, Centre for International Governance Innovation, Canada, Professor David Keith, Director, ISEEE Energy and Environmental Systems Group,

24 “Subcommittee Examines Geoengineering Strategies and Hazards”, US House of Representatives Science and Technology Committee, Press Release, 4 February 2010 25 “The regulation of geoengineering”, Science and Technology Committee press release 2008–09 no. 10, 5 November 2009

2 Categories of geoengineering

Introduction

  1. This chapter examines what technologies and techniques could be classed as geoengineering and what can and should be regulated. As we explained in the previous chapter, we use the term “geoengineering” to describe activities specifically and deliberately designed to effect a change in the global climate with the aim of minimising or reversing anthropogenic climate change.^27 We are examining geoengineering exclusively in relation to climate change. Our starting point is again our earlier Report, Engineering: turning ideas into reality^28 along with the Royal Society’s report, Geoengineering the climate: science, governance and uncertainty.^29

Definition of geoengineering

  1. Geoengineering is not, however, a monolithic subject.^30 Geoengineering methods are “diverse and vary greatly in terms of their technological characteristics and possible consequences”.^31 They can be—and were by those who submitted evidence to us— classified into two main groups: Carbon Dioxide Removal (CDR) techniques; and Solar Radiation Management (SRM) techniques.

Carbon Dioxide Removal (CDR)

  1. CDR techniques remove carbon dioxide from the atmosphere. Proposals in this category include:

a) techniques for enhancing natural carbon sinks (the oceans, the forests, rocks and soils); and

b) sequestration of carbon dioxide from the atmosphere (“atmospheric scrubbing”) by chemical means, with the captured carbon deposited in the deep ocean or in geological structures.

Examples of CDR techniques Bioenergy with carbon dioxide capture and sequestration (BECS) Biomass may be harvested and used as fuel, with capture and sequestration of the resulting carbon dioxide; for example, the use of biomass to make hydrogen or electricity and sequester the resulting carbon dioxide in geological formations.^32 Biomass and biochar As vegetation grows it removes large quantities of carbon from the atmosphere during photosynthesis. When the organisms die and decompose, most of the carbon

27 HC (2008–09) 50–I, para 160 28 HC (2008–09) 50–I, paras 163– 29 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 1. 30 Q 8 [Dr Blackstock] 31 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 1. 32 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 2.2.

they stored is returned to the atmosphere. There are several ways in which the growth of biomass may be harnessed to slow the increase in atmospheric carbon dioxide—for instance, Biomass may be harvested and sequestered as organic material, for example, by burying trees or crop wastes, or as charcoal (“biochar”).^33 Enhanced weathering (land and ocean-based methods) Carbon dioxide is naturally removed from the atmosphere over many thousands of years by processes involving the weathering (dissolution) of carbonate and silicate rocks. Silicate minerals form the most common rocks on Earth, and they react with carbon dioxide to form carbonates (thereby consuming carbon dioxide).^34 Ocean fertilisation Phytoplankton take up carbon dioxide and fix it as biomass. When the organisms die, a small fraction of this “captured” carbon sinks into the deep ocean. Proponents of ocean fertilisation schemes have argued that by fertilising the ocean it may be possible to increase phytoplankton growth and associated carbon “removal”. Ocean fertilisation schemes involve the addition of nutrients to the ocean (soluble iron, for example), or the redistribution of nutrients extant in the deeper ocean to increase productivity (such as through ocean pipes).^35 Ocean N and P fertilisation Over the majority of the open oceans the “limiting nutrient” is thought to be nitrogen. One suggestion therefore has been to add a source of fixed nitrogen (N) such as urea as an ocean fertiliser. Phosphate (P) is also close to limiting over much of the ocean.^36

  1. The table below, which draws from the Royal Society’s report, compares the cost and environmental impact of CDR methods.^37

Technique Cost Impact of anticipated environmental effects

Risk of unanticipated environmental effects

Land use and afforestation Low Low Low Biomass with carbon sequestration (BECS)

Medium Medium Medium

Biomass and biochar Medium Medium Medium

Enhanced weathering on land Medium Medium Low Enhanced weathering—increasing ocean alkalinity

Medium Medium Medium

Chemical air capture and carbon sequestration

High Low Low

Ocean fertilisation Low Medium High Ocean N and P fertilisation Medium Medium High

33 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 2.2. 34 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 2.2. 35 HC (2008–09) 50–I, para 174 36 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, para 2.3. 37 The Royal Society, Geoengineering the climate Science, governance and uncertainty , September 2009, table 2.

SRM technique Possible side-effects Risk (at max likely level) Human Settlement Albedo Regional Climate Change L Grassland and Crop Albedo Regional Climate Change Reduction in Crop Yields

M L

Desert Surface Albedo Regional Climate Change Ecosystem impacts

H H Cloud Albedo^46 Termination effect^47 Regional Climate Change

H H Stratospheric Aerosols Termination effect Regional Climate Change Changes in Stratosphere Chemistry

H M M

Space-based Reflectors Termination effect Regional Climate Change Reduction in Crop Yields

H M L

Differences between CDR and SRM

  1. The fundamental difference between CDR and SRM is that carbon sequestration addresses the root issue—that is, the concentration of carbon dioxide—while solar reflection “treats the symptom”—that is, global warming.^48 The Sustainability Council of New Zealand pointed out that problems arising from this include:
    • reflection does not address the acidification of oceans that results from excess carbon dioxide in the atmosphere being absorbed by the sea;
    • schemes that inject particles into the atmosphere are likely to alter the distribution of rainfall and also cause some reduction in the global quantity of rainfall; and
    • many reflection techniques will need to be replenished constantly over their lifetime and, if this is not kept up, extremely rapid warming could ensue.^49
  2. The other difference is that some SRM techniques could substantially influence the climate within months but, as Dr Blackstock pointed out, with “much greater uncertainty about the net climatic effects”.^50 Natural experiments caused by volcanoes have demonstrated the rapid impact potential of SRM, and recent reviews have shown such schemes should be technically simple to deploy at low cost relative to mitigation. But, as Dr Blackstock noted, these reviews also stressed that SRM would “at best unevenly ameliorate

46 See Ev 37 [Alan Gadian], which challenged the assessment of risk in the Royal Society’s report. 47 “Termination effect” refers here to the consequences of a sudden halt or failure of the geoengineering system. For SRM approaches, which aim to offset increases in greenhouse gases by reductions in absorbed solar radiation, failure could lead to a relatively rapid warming which would be more difficult to adapt to than the climate change that would have occurred in the absence of geoengineering. SRM methods that produce the largest negative changes, and which rely on advanced technology, are considered higher risks in this respect. 48 Ev 45 49 As above 50 Ev 2 [Dr Blackstock], para 10

regional climatic change, and may generate serious unintended consequences. For example, SRM could produce droughts with severe implications for regional and global food production, and delay the recovery of the ozone layer by decades, while doing almost nothing to address ocean acidification.”^51

Weather modification techniques

  1. While there was a measure of debate that some—CDR, in particular—technologies fell within the definition of geoengineering, there was greater disagreement about weather modification techniques should be included. The Action Group on Erosion, Technology and Concentration (ETC Group) considered that geoengineering should also encompass weather modification techniques such as hurricane suppression and cloud seeding.^52 Cloud seeding causes precipitation by introducing substances into cumulus clouds that cause condensation. Most seeding uses silver iodide, but dry ice (that is, solid carbon dioxide), propane, and salt are also used.^53
  2. These techniques are in use to precipitate rain and to suppress precipitation and hail.^54 Dr James Lee, from the American University, Washington DC, pointed out in his memorandum that cloud seeding was first scientifically demonstrated in 1946^55 and “is a geoengineering tool that is widely used by more than 30 countries” and that with climate change, fresh water resources will be in decline in many parts of the world and one “result may be an increase in the use of cloud seeding”.^56 He cited the example of China, whose:

cloud seeding program is the largest in the world, using it to make rain, prevent hailstorms, contribute to firefighting, and to counteract dust storms. On New Year’s Day in 1997, cloud seeding made snow in Beijing, for probably no other reason than popular enjoyment. During the 2008 Olympics, China extensively used cloud seeding to improve air quality. China sees cloud seeding as part of a larger strategy to lower summer temperatures and save energy.^57

  1. Dr Lee drew a distinction between climate change and weather:

since cloud seeding is more likely to affect the latter. Weather is a state of the atmosphere over the short-term and more likely at specific points and places. Climate is a long-term phenomenon expressed as average weather patterns over a long period. Cloud seeding could affect climate when carried out over a long period. Key measures of weather and climate are precipitation and temperature.^58

51 Ev 2 [Dr Blackstock], para 10 52 Ev 50, para 4 53 Ev 33, section 3 54 As above 55 As above 56 Ev 32, summary para 1; and see also Ev 33, section 3 57 Ev 34, section 3 58 Ev 32, section 1

  1. Taking the CDR technologies as a whole, it is clear that the risk of a negative impact on the environment is less than those in the SRM category. But, as the Royal Society pointed out, ecosystem-based methods, such as ocean fertilisation—a CDR technology—carries the risk of having “much greater potential for negative and trans-boundary side effects”.^66 As Sir David King put it: “as soon as we move into capture from the oceans [...] we are dealing with an issue of long range pollution and impact problems, so cross-boundary problems”.^67 On the other hand, painting roofs white—an SRM technique—would have little adverse effect or consequences across national boundaries. In our view, geoengineering as currently defined covers such a range of Carbon Dioxide Removal (CDR) and Solar Radiation Management (SRM) technologies and techniques that any regulatory framework for geoengineering cannot be uniform. As the Government put it, to formulate an overarching governance framework covering all geoengineering research and deployment “will be challenging”.^68 In our view, it is neither practicable nor desirable.

Conclusions on grading for the purposes of regulation

  1. A system to differentiate and grade geoengineering techniques is required. As Dr Jason Blackstock put it:

When we think of developing regulatory structures for what we class as geoengineering, our primary concern should be about how large is the transboundary impact and how soon will that transboundary impact manifest.^69

In more detail the Royal Society suggested that the fundamental criterion in relation to governance of geoengineering was whether, and to what extent, the techniques involved:

a) trans-boundary effects—other than the removal of greenhouse gases from the atmosphere;

b) dispersal of potentially hazardous materials in the environment; and

c) direct intervention in (or major direct side-effects on) ecosystems.^70

  1. Professor Keith preferred an approach based on leverage, which we understand to be large effect on the climate for a relatively small amount of resources, and timescale.^71 Mr Virgoe added that as well as environmental risks there were risks of things going wrong or risks of unintended side effects and that there “is clearly a risk that the techniques do not work and there are also risks around things like legal issues and liability”.^72
  2. We consider that geoengineering as currently used is a useful portmanteau definition encompassing CDR and SMR techniques but cannot be used as the basis for a single

66 Ev 52, para 5 67 Q 39 68 Ev 21, para 6 69 Q 18 70 Ev 52, para 7 71 Q 20 72 Q 21

regulatory regime. In our view the criteria suggested by the Royal Society provide a sound basis for building a grading system for geoengineering techniques for the purposes of regulation. They are intelligible and likely to command support. Other criteria such as leverage and risk could be included, though we would be concerned if the criteria proliferated or were drawn so widely as to bring techniques unnecessarily within tight regulatory control. We conclude that geoengineering techniques should be graded according to factors such as trans-boundary effect, the dispersal of potentially hazardous materials in the environment and the direct effect on ecosystems. The regulatory regimes for geoengineering should then be tailored accordingly. Those techniques scoring low against the criteria should be subject to no additional regulation to that already in place, while those scoring high would be subject to additional controls. So for example, at the low end of the scale are artificial trees and at the high end is the release of large quantities of aerosols into the atmosphere.