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Before the Committee on Science and Technology, House of 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 12:00 p.m. EDT:
Thursday, March 18, 2010: 

Climate Change: 

Preliminary Observations on Geoengineering Science, Federal Efforts, 
and Governance Issues: 

Statement of Frank Rusco, Director:
Natural Resources and Environment: 


GAO Highlights: 

Highlights of GAO-10-546T, a testimony before the Committee on Science 
and Technology, House of Representatives. 

Why GAO Did This Study: 

Key scientific assessments have underscored the urgency of reducing 
emissions of carbon dioxide to help mitigate potentially negative 
effects of climate change; however, many countries with significant 
greenhouse gas emissions, including the United States, China, and 
India, have not committed to binding limits on emissions to date, and 
carbon dioxide levels continue to rise. 

Recently, some policymakers have raised questions about geoengineering—
large-scale deliberate interventions in the earth’s climate system to 
diminish climate change or its potential impacts—and its role in a 
broader strategy of mitigating and adapting to climate change. 

Most geoengineering proposals fall into two approaches: solar 
radiation management (SRM), which offset temperature increases by 
reflecting a small percentage of the sun’s light back into space, and 
carbon dioxide removal (CDR), which address the root cause of climate 
change by removing carbon dioxide from the atmosphere. 

Today’s testimony focuses on GAO’s preliminary observations on (1) the 
state of the science regarding geoengineering approaches and their 
effects, (2) federal involvement in geoengineering activities, and (3) 
the views of experts and federal officials about the extent to which 
federal laws and international agreements apply to geoengineering. To 
address these issues, GAO reviewed scientific literature and 
interviewed federal officials and scientific and legal experts. 

What GAO Found: 

Substantial uncertainties remain on the efficacy and potential 
environmental impacts of proposed geoengineering approaches, because 
geoengineering research and field experiments to date have been 
limited. GAO’s review of relevant studies and interviews with experts 
to date found that relatively few modeling studies for SRM approaches 
have been published, and only limited small-scale testing—primarily of 
carbon storage activities relevant to CDR approaches—have been 
performed. Consequently, the experts GAO spoke with stated that a 
sustained effort of coordinated and cooperative research would be 
needed to determine whether proposed geoengineering approaches would 
be effective at a scale necessary to reduce temperatures and to 
attempt to anticipate and respond to potential unintended consequences—
including the political, ethical, and economic issues surrounding the 
use of certain approaches. Specifically, just as the effects of 
climate change in general are expected to vary by region, so would the 
effects of certain large-scale geoengineering efforts, therefore, 
potentially creating relative winners and losers and thus sowing the 
seeds of future conflict. 

Federal agencies have funded some research and small demonstration 
projects of certain technologies related to proposed geoengineering 
approaches; but these efforts have been limited, fragmented, and not 
coordinated as part of a federal geoengineering strategy. Officials 
from interagency bodies coordinating the federal response to climate 
change stated that their offices (1) have not developed a coordinated 
research strategy, (2) do not have a position on geoengineering, and 
(3) do not believe is it necessary to coordinate efforts due to the 
limited federal investment to date. In the event that the federal 
government decides to expand geoengineering research, GAO’s interviews 
with experts suggest that transparency and international cooperation 
are key factors for any geoengineering research that poses a risk of 
environmental impacts beyond our borders. Further, GAO’s past work 
indicates that a comprehensive assessment of costs and benefits that 
includes all relevant risks and uncertainties is a key component in 
strategic planning for technology-based research. 

According to legal experts and federal agency officials, some existing 
federal laws and international agreements could apply to 
geoengineering research and deployment. However, some federal agencies 
have not yet assessed their authority to regulate geoengineering, and 
those that have done so have identified regulatory gaps. Although 
legal experts have identified some relevant international agreements 
and parties to two agreements have taken actions to address 
geoengineering, it is not certain whether and how other agreements 
would apply. Most scientific and legal experts GAO spoke with 
distinguished the governance of research from governance of deployment 
and noted that governance of geoengineering research with 
transboundary impacts, such as SRM approaches, should be addressed at 
the international level in a transparent manner and in consultation 
with the scientific community. However, the experts’ views on the 
details of governance varied. 

View [hyperlink,] or key 
components. For more information, contact Frank Rusco, at (202) 512-
3841 or 

[End of section] 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to participate in the committee's 
hearing on geoengineering. Changes in the earth's climate attributable 
to increased concentrations of greenhouse gases may have significant 
environmental and economic impacts in the United States and 
internationally. These impacts are expected to vary across regions, 
countries, and economic sectors. Among other potential impacts, 
climate change could threaten coastal areas with rising sea levels, 
alter agricultural productivity, and increase the intensity and 
frequency of floods and tropical storms. Furthermore, the National 
Academies of Science (NAS) has reported that human alterations of the 
climate system may increase the possibility of large and abrupt 
regional or global climatic events, and that because abrupt climate 
changes of the past have not yet been fully explained, future abrupt 
changes cannot be predicted with any confidence, and climate surprises 
are to be expected. 

Key scientific assessments have underscored the urgency of reducing 
emissions of carbon dioxide to help mitigate the negative effects of 
climate change; however, many countries with significant greenhouse 
gas emissions including the United States, China, and India, have not 
committed to binding limits on emissions to date, and carbon dioxide 
levels continue to rise.[Footnote 1] In addition to mitigation, we 
have reported that policies to adapt to climate change could help 
reduce the vulnerability of countries and regions to potentially 
adverse impacts and may be viewed as part of a risk-management 
strategy for responding to climate change.[Footnote 2] In particular, 
we reported that federal entities such as the President's Council on 
Environmental Quality (CEQ), the Office of Science and Technology 
Policy (OTSP), and the U.S. Global Change Research Program (USGCRP) 
had begun to develop governmentwide strategies to address climate 
change adaptation and reduce the nation's vulnerability to adverse 
impacts from climate change. Recently, some policymakers have begun to 
raise questions about geoengineering--deliberate large-scale 
interventions in the earth's climate system to diminish climate change 
or its impacts--and what role, if any, it could play in a broad risk-
management strategy for addressing climate change.[Footnote 3] 

A September 2009 study from the Royal Society[Footnote 4]--the United 
Kingdom's national academy of science--categorized most geoengineering 
proposals into two approaches: solar radiation management (SRM), which 
would offset temperature increases by reflecting a small percentage of 
the sun's light back into space, thus reducing the amount of heat 
absorbed by the earth's atmosphere and surface, and carbon dioxide 
removal (CDR), which would address what scientists currently view as 
the root cause of climate change by removing carbon dioxide--a 
greenhouse gas--from the atmosphere.[Footnote 5] 

Examples of SRM approaches in the study include the following: 

* increasing the reflectivity of the earth's surface through 
activities such as painting building roofs white, planting more 
reflective crops or biomass, or covering desert surfaces with 
reflective material; 

* increasing the reflectivity of the atmosphere by whitening clouds 
over the ocean or injecting reflective aerosol particles into the 
stratosphere to scatter sunlight; and: 

* space-based methods to use shielding materials to reflect or deflect 
incoming solar radiation. 

Examples of CDR approaches in the study include the following: 

* enhancing biological, physical, or chemical land-based carbon sinks 
to capture and store carbon in biomass or soil (carbon sequestration), 
or in chemically reactive minerals (land-based enhanced weathering); 

* enhancing biological, physical, or chemical ocean-based carbon sinks 
through the introduction of nutrients to promote phytoplankton growth 
(ocean fertilization), physically altering ocean circulation patterns 
to transfer atmospheric carbon to the deep sea, or adding chemically 
reactive minerals to increase ocean alkalinity (ocean-based enhanced 
weathering); and: 

* technology-based methods to remove carbon dioxide from the 
atmosphere (air capture) and then store the carbon dioxide--for 
example, in geological formations (geological sequestration). 

According to the Royal Society study, while both approaches are 
ultimately designed to decrease temperatures, the discussed SRM 
approaches, once deployed, would only take a few years to reduce 
temperatures, but would create an artificial and approximate balance 
between increased atmospheric greenhouse gas concentrations and 
reduced sunlight that would introduce additional environmental risks 
and require long-term maintenance. In contrast, the discussed CDR 
approaches would take many decades to reduce global temperatures but, 
with some exceptions, involve fewer potential environmental risks 
because they would return the climate closer to its pre-industrial 
state. Additionally, certain SRM approaches, such as atmospheric 
aerosol injection, are considered to be relatively inexpensive to 
implement and generally hold greater potential for causing uneven 
environmental impacts beyond national or regional boundaries, thus 
risking undesirable social, ethical, legal, and political implications 
that would need to be addressed before any of these technologies are 
implemented. For example, the European Union has initiated a research 
program to study the scientific issues, as well as the policy 
implications of SRM geoengineering approaches. Domestically, NAS will 
be including geoengineering as part of its pending report on America's 
Climate Choices for Congress,[Footnote 6] and some nongovernmental 
organizations, such as the American Physical Society, have also 
undertaken studies to examine these issues in further detail.[Footnote 

Within this context, our testimony today is based on our preliminary 
observations for the committee addressing (1) the general state of the 
science regarding geoengineering approaches and their potential 
effects, (2) the extent to which the federal government has sponsored 
or participated in geoengineering research or deployment, and (3) the 
views of legal experts and federal officials concerning the extent to 
which federal laws and international agreements apply to 
geoengineering activities. We expect to provide the committee with the 
final results of this review in a report issued later this year. 
Additionally, due to the interest of the committee and the strategic 
relevance of this topic, GAO has initiated a technology assessment on 
this topic which is also scheduled to be issued later this year. 

To address these issues, we reviewed relevant studies from peer- 
reviewed literature, legal journals, and published policy studies 
related to geoengineering. We also identified a list of knowledgeable 
scientific, legal, and policy experts based on the following factors: 
participation on a geoengineering panel, the number of articles 
authored in peer-reviewed literature, and recommendations from other 
experts. From this list, we interviewed a sample of experts. Our 
interviews with other experts are ongoing. In addition, we met with 
officials and staff from interagency bodies coordinating the federal 
response to climate change, including OSTP, CEQ, and USGCRP, as well 
as the Department of Energy (DOE), which coordinates the Climate 
Change Technology Program (CCTP)--a multiagency research and 
development program for climate change technology. We also identified 
and reviewed federal laws and international agreements; interviewed 
international law experts; and interviewed officials from the 
Environmental Protection Agency's (EPA) Office of General Counsel, 
Marine Pollution Control Branch, and the Office of Water to discuss 
how federal laws are being or could be applied to activities related 
to geoengineering. Our work is ongoing, and we are continuing to 
collect and analyze information related to the objectives and findings 
presented in this testimony. We conducted our work on this testimony 
from December 2009 to March 2010 in accordance with generally accepted 
government auditing standards. Those standards require that we plan 
and perform the audit to obtain sufficient, appropriate evidence to 
provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 

Substantial Uncertainties Remain Regarding Geoengineering Approaches 
and Their Potential Effects: 

Substantial questions remain on the efficacy and potential 
environmental impacts of proposed geoengineering approaches, in part, 
because geoengineering research and field experiments to date have 
been limited. According to the experts we spoke with, research related 
to proposed SRM geoengineering approaches is sparse. According to 
recent studies, much of the research into SRM approaches to date has 
been limited to modeling studies to assess the effects of either 
injecting sulfur aerosols into the stratosphere or brightening clouds 
to reduce incoming solar radiation at the earth's surface and produce 
a cooling effect. For example, one study found that combining a 
reduction of incoming radiation with high levels of atmospheric carbon 
dioxide could have substantial impacts on regional precipitation--
potentially leading to reductions that could create drought in some 
areas.[Footnote 8] Based on our literature review and interviews with 
experts to date, only one study has been published for a field 
experiment related to SRM technologies--a Russian experiment that 
injected aerosols into the middle troposphere.[Footnote 9] 

For CDR approaches, our discussions with experts, as well as our 
initial examination of relevant studies, found that a greater amount 
of research and number of field trials related to geological 
sequestration and ocean fertilization has occurred; but, these efforts 
were not necessarily designed for the purpose of applying the concepts 
to geoengineering. For example, according to the International Energy 
Agency (IEA),[Footnote 10] several small-scale commercial applications 
of technology exist for injecting and monitoring the long-term storage 
of carbon dioxide in geologic formations. The IEA stated that the 
oldest of these started as a private-sector project in 1996 and now 
continues under funding from the European Commission. However, these 
projects are primarily associated with public and private initiatives 
to study, develop, and promote carbon capture and storage technologies 
as a greenhouse gas emissions reduction strategy, rather than the 
large scale that would be required to significantly alter the climate 
through geoengineering. Similarly, some ocean fertilization 
experiments using iron have been conducted as part of existing marine 
research studies or small-scale commercial operations. One expert 
familiar with these experiments noted that, while they improved 
scientific understanding of the role of iron in regulating ocean 
ecosystems and carbon dynamics, they were not specifically designed to 
determine the implications of ocean fertilization with iron as a 
geoengineering approach for large-scale removal of carbon dioxide from 
the atmosphere.[Footnote 11] 

Due to the limited amount of geoengineering research conducted to 
date, the experts we interviewed stated that a sustained program of 
additional research would be needed to address the significant 
uncertainties regarding the effectiveness and potential impacts of 
geoengineering approaches. Additionally, these experts noted that for 
certain approaches where transboundary impacts would be likely during 
field experiments, international cooperation for research would be 
necessary. Specifically, recent studies highlight the limitations of 
current models to accurately predict the environmental impact of SRM 
technologies at a regional scale--which would be necessary to 
accurately gauge potential impacts that might interfere with 
agricultural production for certain regions. Furthermore, studies 
indicate that, even for the most tested methods applicable to 
geoengineering, such as geological sequestration and ocean 
fertilization with iron, uncertainties remain surrounding the 
potential cost, effectiveness, and impacts of pursuing these 
approaches at a scale sufficient to reduce the amount of carbon in the 

Due to the potential for disparities in environmental outcomes from 
using these technologies--similar to the expected regional variation 
in climate change impacts--experts that we spoke with said that the 
political, ethical, legal, and economic issues surrounding the 
potential impacts of geoengineering technologies warranted close 
examination. These experts generally agreed that the policy 
implications for SRM and CDR approaches were very different. For 
example, certain SRM approaches, such as atmospheric aerosol 
injection, are generally perceived as being less costly to implement 
and would act more quickly to reduce temperatures than CDR approaches. 
However, these approaches are also associated with a greater risk of 
environmental impacts that cross national boundaries--which would have 
political, ethical, legal, and economic ramifications. Furthermore, 
according to several of these experts, the policy implications of SRM 
approaches are complicated by the fact that there are likely to be 
both positive and negative outcomes for nations or regions, and that 
one nation, group, or individual could conceivably take unilateral 
action to deploy one of these technologies. Experts emphasized that it 
is important to begin studying how the United States and the 
international community might address the ramifications of unilateral 
deployment of an SRM approach that would result in gains for some 
nations and losses for others. In contrast, with the exception of 
ocean fertilization, two of the experts we interviewed stated that 
most CDR approaches, such as air capture, would have limited impacts 
across national boundaries and could, therefore, mostly involve 
discussions with domestic stakeholders about societal, economic, and 
political impacts similar to those of existing climate change 
mitigation strategies. However, the Royal Society study noted that 
large-scale deployment of CDR approaches such as widespread 
afforestation--planting of forests on lands that historically have not 
been forested--or methods requiring substantial mineral extraction-- 
including land or ocean-based enhanced weathering--may have unintended 
and significant impacts within and beyond national borders.[Footnote 

Federal Agencies Have Sponsored Some Research Activities, but These 
Activities Are Not Part of a Coordinated Federal Geoengineering 
Research Strategy: 

Our observations to date indicate that federal agencies such as DOE, 
National Science Foundation (NSF), U.S. Department of Agriculture 
(USDA), and others have funded some research and small-scale 
technology testing relevant to proposed geoengineering approaches on 
an ad-hoc basis. Some examples are as follows: 

* For SRM approaches, DOE, through its Sandia National Laboratories, 
has sponsored a study investigating the potential unintended 
consequences and economic impacts of sulfur aerosol injection. 
Additionally, DOE has contributed a small amount of funding for 
modeling studies related to cloud-brightening and stratospheric 
aerosol SRM approaches at its Pacific Northwest National Laboratory--
an effort that is primarily funded by the University of Calgary. For 
CDR approaches, DOE has sponsored research in both land-based and 
ocean-based carbon storage, including small-scale demonstration 
projects of geological sequestration as part of its Regional Carbon 
Sequestration Partnerships. In conjunction with other partners, DOE 
also provided funding for a study on carbon dioxide air capture 

* NSF has funded projects relevant to both SRM and CDR approaches. For 
SRM approaches, NSF has sponsored some modeling studies for 
stratospheric aerosol injection and for a space-based SRM approach. 
NSF has also funded research investigating the ethical issues related 
to SRM approaches. For CDR approaches, NSF is supporting projects 
related to carbon storage in geological formations, saline aquifers, 
and biomass. 

* Relevant to CDR approaches, USDA has supported research that 
examined land-based carbon storage approaches, such as biochar 
[Footnote 13]--a way to draw carbon from the atmosphere and sequester 
it in charcoal created from biomass--through its Agricultural Research 
Service, and carbon sequestration in soil and biomass as part of its 
Economic Research Service. 

* National Aeronautics and Space Administration (NASA) funded a 
research study investigating the practicality of using a solar shield 
in space to deflect sunlight and reduce global temperatures as part of 
its former independent Institute for Advanced Concepts program. 
[Footnote 14] Additionally, scientists at NASA's Ames Research Center, 
independent of headquarters, held a conference on SRM approaches in 
2006, in conjunction with the Carnegie Institution of Washington. 

* EPA has also sponsored research related to the economic implications 
of SRM geoengineering approaches through its National Center for 
Environmental Economics. 

In addition to these efforts, federal officials noted that a large 
fraction of the existing federal research and observations on basic 
climate change and earth science could be relevant to improving 
understanding about proposed geoengineering approaches and their 
potential impacts. For instance, according to federal officials, 
ongoing research conducted by USGCRP agencies related to understanding 
atmospheric circulation and aerosol/cloud interactions could help 
improve understanding about the potential effectiveness and impacts of 
proposed SRM approaches. Similarly, these officials said that basic 
research conducted by USGCRP agencies into oceanic chemistry could 
help address uncertainty about the potential effectiveness and impacts 
of CDR approaches, such as ocean fertilization. 

Staff from federal offices coordinating the U.S. response to climate 
change--CEQ, OSTP, and USGCRP--stated that they do not currently have 
a geoengineering strategy or position. Additionally, a USGCRP official 
stated that, while the USGCRP could establish an interagency working 
group to coordinate a federal effort in geoengineering research, such 
a group is not currently necessary because of the small amount of 
federal funding specifically directed toward these activities. 

In the event that the federal government decides to fund a coordinated 
geoengineering research strategy, our review of relevant studies and 
interviews with experts to date identified some key factors for 
policymakers to consider when designing a federal strategy for 
geoengineering research. For example, the Royal Society study noted 
that when there is a likelihood of transboundary impacts, such as the 
discussed SRM approaches, as well as one discussed CDR approach, ocean 
fertilization, transparency and international cooperation are key 
factors for pursuing geoengineering research. This point was 
reiterated by several experts at a recent panel discussion at the 
American Advancement for Science annual meeting. However, a couple of 
experts we interviewed noted that federal research for geoengineering 
approaches without likely transboundary impacts could be conducted 
independently of other countries, as is the case with the majority of 
currently proposed CDR approaches, such as air capture. Additionally, 
due to the variety of geoengineering approaches, several of the 
experts we interviewed recommended that federal geoengineering 
research should be an interdisciplinary effort across multiple 
agencies, and should be led by a multiagency coordinating body, such 

Recent GAO work offers insights on key considerations for assessing 
risk and managing technology-based research programs. For example, we 
have reported on the advantages of using a formal risk-management 
approach and applying an anticipatory perspective when making 
decisions under substantial uncertainty.[Footnote 15] Specifically, we 
reported that outlining the various alternative policy responses and 
the risks and uncertainties associated with pursuing each alternative 
is particularly important when prospective interventions require long 
lead times, high-stakes outcomes would likely result, and a delayed 
intervention would make impacts difficult to contain or reverse-- 
conditions that could be considered relevant to the risks associated 
with climate change impacts. Furthermore, our review of DOE's 
FutureGen project--a program that partners with the electric power 
industry to design, build, and operate the world's first coal-fired, 
zero-emissions power plant--found that a comprehensive assessment of 
the costs, benefits, and risks of each technological option is an 
important factor when developing a strategic plan for technology-based 
research.[Footnote 16] 

Existing Federal Laws and International Agreements Could Apply to 
Certain Geoengineering Activities, but Regulatory Gaps Remain: 

Existing federal laws and international agreements were not enacted or 
negotiated with the purpose or intent to cover geoengineering 
activities, but according to legal experts and federal officials, 
several existing federal laws and international agreements could apply 
to geoengineering research and deployment, depending upon the type, 
location, and sponsor of the activity. Domestically, however, 
interviews with agency officials to date and our past work indicate 
that federal agencies have not yet assessed their statutory authority 
to regulate geoengineering activities, and those that have done so 
have identified regulatory gaps. Examples include the following: 

* EPA has authority under the Safe Drinking Water Act to regulate 
underground injections of various substances and is using this 
authority to develop a rule that would govern the underground 
injection of carbon dioxide for geological sequestration, which could 
be relevant to future CDR approaches. EPA issued a proposed rule on 
geological sequestration in July 2008. EPA officials told us that the 
final rule is currently scheduled to be issued in the fall of 2010. 
However, as EPA officials noted, the rulemaking was not intended to 
resolve many questions concerning how other environmental statutes may 
apply to injected carbon dioxide, including the Comprehensive 
Environmental Response, Compensation and Liability Act of 1980 
(CERLCA) and the Resource Conservation and Recovery Act of 1976 
(RCRA), which apply to hazardous substances and wastes, respectively. 
[Footnote 17],[Footnote 18] The White House recently established an 
interagency task force on carbon capture and storage to propose a plan 
to overcome the barriers to widespread deployment of these 
technologies. The plan will address, among other issues, legal 
barriers to deployment and identify areas where additional statutory 
authority may be necessary. 

* Under the Marine Protection, Research and Sanctuaries Act of 1972, 
as amended, certain persons are generally prohibited from dumping 
material, including material for ocean fertilization, into the ocean 
without a permit from EPA.[Footnote 19] Although EPA officials told us 
that the law's ocean dumping permitting process is sufficient to 
regulate certain ocean fertilization activities, including research 
projects, they noted that the law was limited to disposition of 
materials for fertilization by vessels or aircraft registered in the 
United States, vessels or aircraft departing from the United States, 
federal agencies, or disposition of materials for fertilization 
conducted in U.S. territorial waters, which extend 12 miles from the 
shoreline or coastal baseline. Consequently, a domestic company could 
conduct ocean fertilization outside of EPA's regulatory jurisdiction 
and control if, for example, the company's fertilization activities 
took place outside U.S. territorial waters from a foreign-registered 
ship that embarked from a foreign port. 

Additionally, agency officials and legal experts noted that other laws 
such as the National Environmental Policy Act of 1969 (NEPA) could 
also apply to certain geoengineering activities.[Footnote 20] For 
example, NEPA requires federal agencies to evaluate the likely 
environmental effects of certain major federal actions by using an 
environmental assessment or, if the projects likely would 
significantly affect the environment, a more detailed environmental 
impact statement. A geoengineering activity could well constitute a 
major federal action requiring a NEPA analysis. 

Although some geoengineering approaches, such as geological 
sequestration of carbon dioxide in underground formations, would not 
involve international agreements because the activities and their 
effects would be confined to U.S. territory, other SRM and CDR 
approaches would. Legal experts we spoke with identified a number of 
existing international agreements that could apply to geoengineering 
activities but none directly address the issue of geoengineering. Our 
initial work indicates that parties to two international agreements 
have taken action to address geoengineering activities, but it is 
still uncertain whether and how other existing international 
agreements that legal experts have identified as potentially relevant 
could apply to geoengineering. 

In our work to date, legal experts have identified a number of 
existing international agreements, such as the 1985 Vienna Convention 
for the Protection of the Ozone Layer and the 1967 Treaty on 
Principles Governing the Activities of States in the Exploration and 
Use of Outer Space, that could be relevant for injection of sulfate 
aerosols into the stratosphere and placement in outer space of 
material to reflect sunlight, respectively. However, these agreements 
were not drafted with the purpose or intent of applying to 
geoengineering activities and the parties to those treaties have not 
determined whether or how the agreement should apply to relevant 
geoengineering activities. 

Moreover, once the parties make such determinations, they may have 
limited applicability because international agreements generally are 
only legally binding on countries that are parties to the agreement. 
For example, the 1996 Protocol to the Convention on the Prevention of 
Marine Pollution by Dumping of Wastes and Other Matter (also known as 
the London Protocol) generally prohibits the dumping of wastes or 
other matter into the ocean except for the wastes and matter listed in 
the London Protocol and for which a party to the agreement has issued 
a dumping permit that meets the Protocol's permitting requirements. In 
2006, the parties to the London Protocol agreed to amend the Protocol 
to include, in certain circumstances, geological sequestration of 
carbon dioxide in sub-seabed geological formations on the list of 
wastes and other matter that could be dumped. However, only the 37 
countries that are a party to the London Protocol and who have not 
objected to the amendment would be legally bound by it. 

In two instances, the parties to international agreements have issued 
decisions but not amended the agreements regarding the agreement's 
application to ocean fertilization, including research projects. 
Generally these decisions by the parties are not considered to be 
legally binding, although they would aid in interpreting the 
international agreement. Specifically, the two instances are: 

* Over the course of the last 2 years, parties to the Convention on 
the Prevention of Marine Pollution by Dumping of Wastes and Other 
Matters and the London Protocol to the Convention have decided that 
the scope of these agreements include ocean fertilization activities 
for legitimate scientific research. Accordingly, they have asked the 
treaties' existing scientific bodies to develop an assessment 
framework for countries to use in evaluating whether research 
proposals are legitimate scientific research and, therefore, 
permissible under the agreements. In addition, the parties have agreed 
that ocean fertilization activities other than legitimate scientific 
research are contrary to the aims of the agreements and should not be 
allowed. Meanwhile, the parties are considering a potentially legally 
binding resolution or amendment to the London Protocol concerning 
ocean fertilization. 

* In 2009, the parties to the Convention on Biological Diversity 
issued a decision requesting that parties to the Convention ensure 
that ocean fertilization activities, except for certain small-scale 
scientific research within coastal waters, do not take place until 
there is an adequate scientific basis on which to justify such 
activities and a global, transparent, and effective control and 
regulatory mechanism is in place. The decision also urged the same 
from governments not party to the agreement. 

In our interviews with legal experts to date, they suggested that 
governance of geoengineering research should be separated from the 
governance of deployment because scientists and policymakers lack 
critical information about geoengineering that would inform governance 
of deployment. The legal experts we spoke with all agreed that some 
type of regulation of geoengineering field experiments was necessary, 
but had different views as to the structure of such regulation. For 
example, some suggested a comprehensive international governance 
regime for all geoengineering research with transboundary impacts, 
under the auspices of the United Nations Framework Convention on 
Climate Change or another entity, while others suggested that existing 
international agreements, such as the London Convention and Protocol, 
could be adapted and used to address the geoengineering approaches 
that fall within their purview. 

The scientific and policy experts we spoke with largely echoed the 
same themes and issues that the legal experts raised. Interviews with 
scientific experts to date suggest that governance issues related to 
geoengineering research with the potential for transboundary impacts 
should be addressed in a transparent, international manner in 
consultation with the scientific community. Some scientific and policy 
experts noted that the approach adopted by parties to the London 
Protocol engaged the scientific community about developing guidelines 
for assessing legitimate scientific research proposals that are not 
contrary to the treaties' aims, rather than prohibiting the scientific 
research necessary to determine the efficacy and impacts of ocean 
fertilization. Regarding geoengineering deployment, some scientific 
and policy experts noted that similar to the difficulties presented by 
achieving international consensus in carbon mitigation strategies-- 
where there are definite "winners and losers" in terms of economic and 
environmental benefits--establishing a governance regime over 
geoengineering deployment for certain approaches may be equally 
challenging due to questions about whether deployment is warranted, 
how to determine an appropriate new environmental equilibrium, and 
compensation for adverse impacts, among other issues. 

Mr. Chairman, this concludes my prepared statement. We look forward to 
helping this committee and Congress as a whole better understand this 
important issue. I would be pleased to respond to any questions that 
you or other members of the committee may have at this time. 

GAO Contacts and Staff Acknowledgments: 

For further information about this testimony, please contact Frank 
Rusco, Director, Natural Resources and Environment at (202) 512-3841, 
or Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
statement. Contributors to this testimony include: Tim Minelli, 
Assistant Director; Ana Ivelisse Aviles; Charles Bausell Jr.; 
Frederick Childers; Judith Droitcour; Lorraine Ettaro; Brian Friedman; 
Cindy Gilbert; Gloria Hernandezsaunders; Eric Larson; Eli Lewine; 
Madhav Panwar; Timothy Persons; Jeanette Soares; John Stephenson; Joe 
Thompson; and Lisa Van Arsdale. 

[End of section] 


[1] There are six primary greenhouse gases that are monitored and 
reported by countries in accordance with the United Nations Framework 
Convention on Climate Change: carbon dioxide, methane, and nitrous 
oxide, as well as three synthetic gases including hydrofluorocarbons, 
perfluorocarbons, and sulfur hexafluoride. Because greenhouse gases 
differ in their potential to contribute to global warming, each gas is 
assigned a unique weight based on its heat-absorbing ability relative 
to carbon dioxide over a fixed period. This provides a way to convert 
emissions of various greenhouse gases into a common measure, called 
the carbon dioxide equivalent. 

[2] GAO, Climate Change Adaptation: Strategic Federal Planning Could 
Help Government Officials Make More Informed Decisions, [hyperlink,] (Washington, D.C.: Oct. 7, 

[3] Geoengineering is also referred to as climate engineering or 
climate intervention. 

[4] The Royal Society, Geoengineering and the climate: science, 
governance and uncertainty (London: September 2009). 

[5] In addition to these two types of approaches, other large-scale 
interventions in the earth's climate system, such as removing other 
greenhouse gases from the atmosphere, have been considered as part of 
a potential response to reduce the impacts of climate change. 

[6] According to NAS, the final report for America's Climate Choices 
will examine issues associated with global climate change, including 
the science and technology challenges involved, and provide advice on 
actions and strategies the United States can take to respond. This 
report will be based on a series of workshop panels and other 
activities conducted in 2009. 

[7] According to its research proposal, the American Physical Society 
is currently conducting a study of the likely technological and 
economic potential of air capture technologies. Additionally, the 
National Commission for Energy Policy is also investigating the policy 
implications of geoengineering. 

[8] Gabriele C. Hegerl and Susan Solomon, "Risks of Climate 
Engineering," Science 325 (2009): 955-956. 

[9] Yu. A. Izrael, V. M. Zakharov, N. N. Petrov, A. G. Ryaboshapko, V. 
N. Ivanov, A. V. Savchenko, Yu. V. Andreev, V. G. Eran'kov, Yu. A. 
Puzov, B. G. Danilyan, V. P. Kulyapin, and V. A. Gulevskii, "Field 
Studies of a Geo-engineering Method of Maintaining a Modern Climate 
with Aerosol Particles," Russian Meteorology and Hydrology 34, no. 10 
(2009): 635-638. 

[10] The IEA is an intergovernmental organization that acts as energy 
policy advisor to 28 member countries. Additional information on the 
IEA can be found at their website: [hyperlink,]. 
International Energy Agency, Legal Aspects of Storing CO2: Update and 
Recommendations (Paris: 2007). 

[11] According to the German Alfred Wegener Institute for Polar and 
Marine Research (AWI) and the Indian National Institute of 
Oceanography (NIO), the purpose of their joint ocean fertilization 
experiment last year was "to test a range of scientific hypotheses 
pertaining to the structure and functioning of Southern Ocean 
ecosystems and their potential impact on global cycles of biogenic 
elements." However, they noted that longer term experiments studying 
phytoplankton bloom development, and their effect on the deep ocean 
and underlying sediments, will have to be much larger than previous 

[12] The Royal Society, Geoengineering and the climate: science, 
governance and uncertainty. 

[13] Biochar is one by-product of heating biomass such as crop residue 
or wood wastes, in the absence of oxygen, in a process known as 

[14] According to its final report, the NASA Institute for Advanced 
Concepts (NIAC) was formed to provide an independent source of 
revolutionary aeronautical and space concepts that could dramatically 
impact how NASA develops and conducts its missions. As part of the 
NIAC selection process, the study related to SRM was selected through 
an open-solicitation and peer-reviewed competition, which was managed 
by the Universities Space Research Association, a private, nonprofit 

[15] GAO, Highway Safety: Foresight Issues Challenge DOT's Efforts to 
Assess and Respond to New Technology-Based Trends, [hyperlink,] (Washington, D.C.: Oct. 3, 

[16] GAO, Clean Coal: DOE's Decision to Restructure FutureGen Should 
Be Based on a Comprehensive Analysis of Costs, Benefits, and Risks, 
[hyperlink,] (Washington, D.C.: 
Feb. 13, 2009). 

[17] Pub. L. No. 96-510 (1980), as amended, codified at 42 U.S.C. §§ 

[18] Pub. L. No. 94-580 (1976), as amended, codified at 42 U.S.C. §§ 

[19] Pub. L. No. 92-532 (1972), as amended, codified at 33 U.S.C. §§ 

[20] Pub. L. No. 91-190 (1970), as amended, codified at 42 U.S.C. §§ 

[End of section] 

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