GAO 

United States Government Accountability Office

Report to the Chairman, Committee on 

Science and Technology, House of 

Representatives 

CLIMATE CHANGE

A Coordinated 

Strategy Could Focus 

Federal 

Geoengineering 

Research and Inform 

Governance Efforts 

September 2010 

GAO-10-903 
 United States Government Accountability Office 

Accountability • Integrity • Reliability 

Highlights of GAO-10-903, a report to the 

Chairman, Committee on Science and 

Technology, House of Representatives 

September 2010 

CLIMATE CHANGE 

A Coordinated Strategy Could Focus Federal 

Geoengineering Research and Inform Governance 

Efforts 

Why GAO Did This Study 

Policymakers have raised questions 

about geoengineering—large-scale 

deliberate interventions in the earth’s 

climate system to diminish climate 

change or its impacts—and its role in 

a broader strategy of mitigating and 

adapting to climate change. Most 

geoengineering proposals fall into 

two categories: carbon dioxide 

removal (CDR), which would remove 

carbon dioxide (CO2

) from the 

atmosphere, and solar radiation 

management (SRM), which would 

offset temperature increases by 

reflecting sunlight back into space. 

GAO was asked to examine (1) the 

state of geoengineering science, (2) 

federal involvement in geoengineering, 

and (3) the views of experts and 

federal officials about the extent to 

which federal laws and international 

agreements apply to geoengineering, 

and any governance challenges. GAO 

examined relevant scientific and policy 

studies, relevant domestic laws and 

international agreements, analyzed 

agency data describing relevant 

research for fiscal years 2009 and 2010, 

and interviewed federal officials and 

selected recognized experts in the field. 

What GAO Recommends 

GAO recommends that within the 

Executive Office of the President, the 

appropriate entities, such as the 

Office of Science and Technology 

Policy (OSTP), establish a clear 

strategy for geoengineering research 

in the context of the federal response 

to climate change to ensure a 

coordinated federal approach. OSTP 

neither agreed nor disagreed with our 

recommendation, but provided 

technical comments. 

What GAO Found 

Few geoengineering experiments or modeling studies have been conducted, 

and major uncertainties remain on the efficacy and potential consequences of 

geoengineering approaches. GAO’s review of relevant studies and discussions 

with selected experts indicated that relatively more laboratory and field 

research relevant to certain CDR approaches exists, although most of this 

research was not designed to apply to geoengineering. In contrast, few 

modeling studies or field experiments have focused on SRM approaches, 

according to experts and recent studies. Experts identified only one SRM field 

experiment with published results—a 2009 Russian experiment that injected 

aerosols into the middle troposphere to measure their reflectivity. Experts, as 

well as relevant studies, identified several major uncertainties in need of 

further investigation for CDR and SRM. 

Federal agencies identified 52 research activities, totaling about $100.9 

million, relevant to geoengineering during fiscal years 2009 and 2010. GAO’s 

analysis found that 43 activities, totaling about $99 million, focused either on 

mitigation strategies or basic science. Most of the research focused on 

mitigation efforts, such as geological sequestration of CO2, which were 

identified as relevant to CDR approaches but not designed to address them 

directly. GAO found that nine activities, totaling about $1.9 million, directly 

investigated SRM or less conventional CDR approaches. Officials from 

interagency bodies coordinating federal responses to climate change indicated 

that their offices have not developed a coordinated strategy, and believe that, 

due to limited federal investment, it is premature to coordinate 

geoengineering activities. However, federal officials also noted that a large 

share of existing federal climate science research could be relevant to 

geoengineering. Agencies requested roughly $2 billion for such activities in 

fiscal year 2010. Without a coordinated federal strategy for geoengineering, it 

is difficult for agencies to determine the extent of relevant research, and 

policymakers may lack key information to inform subsequent decisions on 

geoengineering and existing climate science efforts. 

According to legal experts and federal officials, the extent to which federal 

laws and international agreements apply to geoengineering is unclear. The 

Environmental Protection Agency (EPA) has taken steps to regulate one CDR 

approach and has determined that it has sufficient authority to regulate two 

other approaches. EPA officials said EPA has not assessed the applicability of 

other laws because geoengineering research is in its initial stages. Similarly, 

legal experts and Department of State officials said that, except for three 

instances, parties to international agreements have not addressed their 

agreements’ applicability to geoengineering, largely due to limited 

geoengineering activity and awareness of the issue. Legal experts’ and 

officials’ views differed on the best approach for international governance, but 

generally agreed that the federal government should take a coordinated, 

interagency approach on domestic regulation. Experts and officials also 

identified governance challenges, such as the need to address liability. 

View GAO-10-903 or key components.

For more information, contact Frank Rusco at 

(202) 512-3841 or ruscof@gao.gov, or John 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 
Page i GAO-10-903 

Contents 

Letter 1

Background 6 

Geoengineering Is an Emerging Field with Major Uncertainties, 

Including Potential Effects 13 

Federal Agencies Are Sponsoring Research Relevant to 

Geoengineering, but There Is No Coordinated Federal Strategy, 

Making It Difficult to Determine the Extent of Relevant 

Research 18 

The Extent to Which Existing Federal Laws and International 

Agreements Apply to Geoengineering Is Unclear, and Experts 

and Officials Identified Governance Challenges 26 

Conclusions 38 

Recommendation 39 

Agency Comments and Our Evaluation 39 

Appendix I Scope and Methodology 42 

Appendix II Geoengineering Experts Selected for This Review 46 

Appendix III Geoengineering Description Provided To USGCRP 

Agencies 47 

Appendix IV Data from USGCRP Agencies on GeoengineeringRelated Activities 51 

Appendix V GAO Contacts and Staff Acknowledgments 64 

Tables 

Table 1: Summary of Reported Research Activities Relevant to 

Geoengineering at USGCRP Agencies, Combined Fiscal 

Years 2009 and 2010 19 

Table 2: Summary of Reported Mitigation-Related Research and 

Fundamental Scientific Research Relevant to 

 Climate Change 
Geoengineering, by USGCRP Agency, Combined Fiscal 

Years 2009 and 2010 20 

Table 3: Summary of Reported Direct Geoengineering Research, by 

USGCRP Agency, Combined Fiscal Years 2009 and 2010 21 

Table 4: Examples of International Agreements Potentially 

Applicable to Geoengineering, as Identified by Legal 

Experts and Relevant Studies 31 

Table 5: Reported Mitigation-Related Research Relevant to 

Geoengineering, by USGCRP Agency and Related 

Geoengineering Approach, Fiscal Years 2009 and 2010 51 

Table 6: Reported Fundamental Scientific Research Activities 

Relevant to Geoengineering, by USGCRP Agency and 

Related Geoengineering Approach, Fiscal Years 2009 and 

2010 58 

Table 7: Reported Direct Geoengineering Research by USGCRP 

Agency and Related Geoengineering Approach, Fiscal 

Years 2009 and 2010 62 

Figures 

Figure 1: Examples of CDR Approaches 9 

Figure 2: Examples of SRM Approaches 11 

Page ii GAO-10-903 Climate Change
Abbreviations 

BECS biomass energy with carbon dioxide capture and 

sequestration 

CCS carbon capture and storage 

CDR carbon dioxide removal 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 

CO2 carbon dioxide 

Commerce Department of Commerce 

DOD Department of Defense 

DOE Department of Energy 

EOP Executive Office of the President 

EPA Environmental Protection Agency 

IEA International Energy Agency 

Interior Department of the Interior 

London Convention Convention on the Prevention of Marine Pollution 

by Dumping of Wastes and Other Matter 

London Protocol 1996 Protocol to the London Convention 

NASA National Aeronautics and Space Administration 

NEPA National Environmental Policy Act of 1969 

NIAC NASA Institute for Advanced Concepts 

NOAA National Oceanic and Atmospheric Administration 

NRC National Research Council 

NSF National Science Foundation 

OSTP Office of Science and Technology Policy 

RCRA Resource Conservation and Recovery Act of 1976 

SRM solar radiation management 

State Department of State 

UNFCCC United Nations Framework Convention on Climate 

Change 

USDA U.S. Department of Agriculture 

USGCRP U.S. Global Change Research Program 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page iii GAO-10-903 Climate Change
Page 1 GAO-10-903 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 23, 2010 

The Honorable Bart Gordon 

Chairman 

Committee on Science and Technology 

House of Representatives 

Dear Mr. Chairman: 

Changes in the earth’s climate attributable to increased concentrations of 

greenhouse gases may have significant environmental and economic 

effects within the United States and internationally. These effects are 

expected to vary across regions, countries, and economic sectors. In its 

recent study Advancing the Science of Climate Change, the National 

Research Council (NRC)1

 stated that temperature increases related to 

rising greenhouse gas levels are closely associated with a broad spectrum 

of climate impacts, such as changes in rainfall and widespread ocean 

acidification.2

 These impacts pose significant risks for—and in many cases 

are already affecting—a wide range of human and environmental systems, 

including freshwater resources, the coastal environment, agriculture, 

fisheries, human health, ecosystems, and national security, according to 

the study. Furthermore, NRC previously reported that human alterations 

of the climate system may increase the possibility of large and abrupt 

regional or global climatic events. NRC also found that because abrupt 

climate changes of the past have not yet been fully explained, future 

abrupt changes cannot be predicted, and climate surprises are to be 

expected.3

Key scientific assessments have underscored the urgency of reducing 

emissions of carbon dioxide (CO2), the most prevalent greenhouse gas 

produced by human activity, as a risk-management strategy to help reduce 

1

NRC is the principal operating agency of both the National Academy of Sciences and the 

National Academy of Engineering. 

2

Ocean acidification is defined by the Royal Society as a decrease in the pH of sea water 

due to the uptake of carbon dioxide produced as a result of human activity. 

3

According to NRC, historical climate records indicate that the climate system can 

experience abrupt changes in as little as a decade. As discussed in the background, these 

changes may be linked to “tipping points” in the earth’s climate system. 

 Climate Change 
 

or limit the negative effects of climate change—also known as mitigation.4

However, many countries with significant greenhouse gas emissions, 

including the United States, China, and India, have not committed to 

binding limits on CO2 emissions, and atmospheric CO2 levels continue to 

rise. Another strategy for responding to climate change is adaptation. We 

have reported that policies to prepare for and adapt to the potential 

adverse effects of climate change could help reduce the vulnerability of 

countries and regions and, in conjunction with emissions reductions, may 

be viewed as part of a risk-management strategy for responding to climate 

change.5

 In particular, we reported that federal entities such as the 

President’s Council on Environmental Quality (CEQ), the Office of Science 

and Technology Policy (OSTP), and the U.S. Global Change Research 

Program (USGCRP) had begun to develop governmentwide strategies to 

address adaptation and reduce the nation’s vulnerability to adverse 

impacts from climate change. We recommended that the appropriate 

entities within the Executive Office of the President (EOP), such as CEQ 

and OSTP, develop a national strategic plan to guide the nation’s efforts to 

adapt to a changing climate. Furthermore, we recommended that the plan, 

among other things, define federal priorities related to adaptation and 

build on and integrate ongoing federal efforts related to adaptation.6

Recently, policymakers and scientific organizations have begun to raise 

questions about a third possible risk-management strategy for climate 

change—geoengineering. The Royal Society,7

 the United Kingdom’s 

 

4

There are six primary greenhouse gases that are generally monitored and reported by 

countries: CO2 , methane, and nitrous oxide, as well as three synthetic gases: 

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 CO2 over a fixed period. This provides 

a way to convert emissions of various greenhouse gases into a common measure, called the 

CO2 equivalent. 

5

GAO, Climate Change Adaptation: Strategic Federal Planning Could Help Government 

Officials Make More Informed Decisions, GAO-10-113 (Washington, D.C.: Oct. 7, 2009). 

6

CEQ and OSTP, together with the National Oceanic and Atmospheric Administration 

(NOAA), are co-chairing an Interagency Climate Change Adaptation Task Force to develop 

recommendations for adapting to climate change impacts both domestically and 

internationally. The task force released an interim progress report on March 16, 2010, 

which can be accessed at: 

http://www.whitehouse.gov/sites/default/files/microsites/ceq/20100315-interagencyadaptation-progress-report.pdf. 

7

The Royal Society, Geoengineering and the climate: Science, governance and 

uncertainty (London: September 2009). 

Page 2 GAO-10-903 Climate Change
 

national academy of sciences, provided the definition of geoengineering 

that we use in this report: deliberate large-scale interventions in the earth’s 

climate system to diminish climate change or its impacts.8

 At the same 

time, some scientists and nongovernmental organizations have raised 

concerns that exploration of geoengineering as a policy option could 

further decrease incentives to reduce greenhouse gas emissions. 

A September 2009 study from the Royal Society divided most 

geoengineering proposals into two main categories: carbon dioxide 

removal (CDR) and solar radiation management (SRM). CDR addresses 

what scientists currently view as the root cause of climate change by 

removing CO2 from the atmosphere.9

 For example, one approach to CDR 

would be to enhance the biological processes for removal and storage of 

CO2 by microorganisms in the ocean. In contrast, SRM offsets temperature 

increases by reflecting a small percentage of the sun’s light back into 

space. For example, one SRM approach would be to add reflective 

particles to the upper atmosphere to reflect incoming sunlight back into 

space. More recently, NRC addressed geoengineering in a series of studies 

requested by Congress, collectively titled America’s Climate Choices.

10 In 

addressing the subject of geoengineering, NRC utilized the Royal Society’s 

definition and categorization of geoengineering approaches, but noted that 

there is no consensus regarding the extent to which the term 

geoengineering should be applied to various widely accepted practices 

that remove CO2 from the atmosphere, such as reforestation.11

 

8

Geoengineering is also referred to as climate engineering, or climate remediation and 

climate intervention. 

9

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. 

10The suite of studies for America’s Climate Choices examines issues associated with 

global climate change, including the science and technology challenges involved, and 

provides advice on actions and strategies the United States can take to respond. The four 

studies issued to date are: Limiting the Magnitude of Future Climate Change, Advancing 

the Science of Climate Change, Adapting to the Impacts of Climate Change, and 

Informing an Effective Response to Climate Change. These studies can be accessed at: 

http://americasclimatechoices.org/ 

11Questions about how to define geoengineering and what approaches should be included 

were also part of the discussion at the March 2010 Asilomar Conference on Climate 

Intervention Technologies, which classified geoengineering approaches into climate 

intervention technologies (equivalent to SRM) and climate remediation technologies 

(equivalent to CDR). 

Page 3 GAO-10-903 Climate Change
 

According to the Royal Society, CDR would work more slowly than SRM 

to reduce global temperatures but, with some exceptions, would involve 

fewer potential environmental risks. This is because CDR is intended to 

return the climate closer to its preindustrial state by reducing atmospheric 

concentrations of CO2. In contrast, the study reported that SRM would 

begin to reduce temperatures more quickly than CDR, but would create an 

artificial and approximate balance between increased atmospheric 

greenhouse gas concentrations and reduced sunlight. This artificial state 

would introduce additional environmental risks and require long-term 

maintenance. Additionally, SRM approaches generally have greater 

potential to cause uneven environmental impacts beyond national or 

regional boundaries. This creates social, ethical, legal, and political 

implications that should be addressed before many of the SRM 

technologies are implemented on a large scale, according to the Royal 

Society. 

The House Committee on Science and Technology held hearings on 

geoengineering science and governance issues, and as part of those 

hearings, the committee asked expert witnesses to testify about the extent 

of existing geoengineering research and areas where additional study is 

needed to better understand geoengineering approaches and their 

potential impacts. In March 2010, we provided preliminary observations on 

our work to the committee as part of these hearings.12 Additionally, due to 

the interest of the committee and the strategic relevance of this topic, we 

have initiated a technology assessment on geoengineering. 

Internationally, the European Union has initiated a research program to 

study the scientific issues, as well as the policy implications of SRM 

geoengineering approaches. Furthermore, some nongovernmental 

organizations have begun to examine the scientific and policy issues 

surrounding geoengineering.13 

Within this context, you asked us to review geoengineering. Our objectives 

were to examine (1) the general state of the science regarding 

geoengineering approaches and their potential effects; (2) the extent to 

 

12GAO, Climate Change: Preliminary Observations on Geoengineering Science, Federal 

Efforts, and Governance Issues, GAO-10-546T (Washington, D.C.: Mar. 18, 2009). 

13For example, the American Physical Society and the National Commission for Energy 

Policy have undertaken studies to examine geoengineering. Additionally, the American 

Meteorological Society and American Geophysical Union have issued policy statements 

regarding geoengineering. 

Page 4 GAO-10-903 Climate Change
 

which the federal government is sponsoring or participating in 

geoengineering research or deployment; and (3) the views of legal experts 

and federal officials about the extent to which federal laws and 

international agreements apply to geoengineering activities, and 

associated challenges, if any, to geoengineering governance. 

To address these objectives, we reviewed relevant studies from peerreviewed journals, law reviews, scientific organizations, and 

nongovernmental organizations related to geoengineering. We also 

selected 10 knowledgeable scientific or policy experts and 8 legal experts 

to interview based on criteria, including participation in one of several 

expert panels related to geoengineering, the number of articles authored in 

peer-reviewed journals or law reviews, and recommendations from other 

recognized experts in their respective fields. To determine the extent to 

which the federal government is sponsoring or participating in 

geoengineering research or deployment, we provided a document defining 

geoengineering and describing proposed geoengineering approaches 

based on the Royal Society study to officials from the 13 USGCRPparticipating agencies, and asked them to identify relevant federal 

activities during fiscal years 2009 and 2010 that fit these descriptions.14

Because the federal government does not have a formal policy on 

geoengineering, we relied on agency officials’ professional judgment to 

identify relevant activities. We collected these data through July 2010. We 

analyzed the officials’ responses and removed 12 activities that did not 

appear related to geoengineering based on the definition we provided.15

We then categorized the remaining activities into three broad types: (

activities related to conventional carbon mitigation efforts that are directly 

applicable to a proposed geoengineering approach, although not 

1) 

 

14USGCRP-participating agencies are the Departments of Agriculture, Commerce, Defense, 

Energy, Interior, Health and Human Services, State, and Transportation; and the U.S. 

Agency for International Development, the Environmental Protection Agency, the National 

Aeronautics and Space Administration, the National Science Foundation, and the 

Smithsonian Institution. 

15These 12 activities were (1) investigating green roof behavior in dense urban 

environments, (2) developing membrane technology for hydrogen purification, (3) 

converting municipal solid wastes to liquid fuel, (4) developing technology for generating 

hydrocarbon fuels using solar energy and CO2 , (5) water desalinization project using solar 

energy, (6) internationally collaborating with China to foster emissions mitigation research, 

(7) developing technology to facilitate the conversion of methane gas to liquid fuel, and five 

activities to develop technologies related to biofuels. Based on their description, we 

determined that these 12 activities did not appear relevant to identified CDR or SRM 

approaches. 

Page 5 GAO-10-903 Climate Change
 

designated as such; (2) activities related to improving basic scientific 

understanding of earth systems, processes, or technologies that could be 

applied generally to geoengineering; and (3) activities designed specifically 

to address a proposed geoengineering approach that does not overlap with 

a conventional carbon mitigation strategy. In addition, we met with 

officials and staff from interagency bodies coordinating federal responses 

to climate change, including OSTP, CEQ, and USGCRP, as well as the 

Department of Energy (DOE), which coordinates the Climate Change 

Technology Program—a multiagency research and development program 

for climate change technology. We also reviewed federal laws and 

international agreements, interviewed 7 legal experts,16 and interviewed 

officials from the Environmental Protection Agency (EPA) and the 

Department of State (State) to identify potentially relevant federal laws 

and international agreements and discuss how these laws and 

international agreements might apply to future geoengineering efforts, and 

associated challenges, if any, to geoengineering governance. 

We conducted our work from December 2009 through September 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 objectives. 

Geoengineering proposals to deliberately alter the climate in response to 

the greenhouse effect have appeared in scientific advisory reports since at 

least the 1960s. Until recently, these proposals generally remained outside 

the mainstream discussions of climate policy, which focused either on 

strategies to reduce emissions or adapt to climate change impacts. 

However, there is growing concern among many scientists that the lack of 

progress on emissions reductions will lead to gradual increases in 

atmospheric concentrations of CO2 beyond a threshold that could prevent 

substantial impacts to human health and environmental systems. 

Furthermore, there is also concern about the existence of “tipping points,” 

where the earth’s climate system reaches a threshold that unexpectedly 

results in abrupt and severe changes. One example would be the rapid 

Background 

 

16One of the eight legal experts we selected did not respond to our request for an interview. 

See appendix II for more information on the legal experts we selected for this review. 

Page 6 GAO-10-903 Climate Change
 

collapse of the West Antarctic Ice Sheet—which would lead to a large and 

sudden contribution to sea level rise.17 These concerns have led to 

increased interest in geoengineering as a potential tool to help reduce the 

impacts of climate change, although the NRC study noted that few, if any, 

individuals are promoting geoengineering as a near-term alternative to 

emissions reductions. 

While both CDR and SRM are intended to reduce global temperatures, 

there are substantial differences in how CDR and SRM operate on the 

climate system, the timescales required for results, and their associated 

risks and trade-offs. Consequently, CDR and SRM are often discussed 

separately. The Royal Society identified several CDR approaches that 

would directly remove CO2 from the atmosphere, as shown in figure 1. 

Many of these methods are designed to enhance natural physical, 

biological, or chemical processes that capture and store CO2 in the ocean 

or on land. Examples of ocean-based CDR approaches include: 

• Enhanced removal by physical processes. Enhanced 

upwelling/downwelling—altering ocean circulation patterns to bring 

deep, nutrient rich water to the ocean’s surface (upwelling), to promote 

phytoplankton growth—which removes CO2 from the atmosphere, as 

described below—and accelerating the transfer of CO2-rich water from 

the surface of the ocean to the deep-sea (downwelling). 

• Enhanced removal by biological processes. Ocean fertilization—

introducing nutrients such as iron, phosphorus, or nitrogen to the 

ocean surface to promote phytoplankton growth. The phytoplankton 

remove CO2 from the atmosphere during photosynthesis, and some of 

the CO2 is transported to the deep ocean as detritus. 

• Enhanced removal by chemical processes. Ocean-based enhanced 

weathering— accelerating chemical reactions between certain minerals 

and CO2, which convert the CO2 to a nongaseous state. Methods 

include adding chemically reactive alkaline minerals, such as limest

or silicates, to the ocean to increase the ocean’s natural ability to 

absorb and store CO

one 

ure 1.) 

 

2. (Not shown in fig

17According to the NRC study Advancing the Science of Climate Change, the West 

Antarctic Ice Sheet stores an equivalent of 11 feet of sea level. While there is substantial 

uncertainty in sea level rise projections, the consequences of extreme and rapid sea level 

rise could be economically and socially devastating for highly built-up and densely 

populated coastal areas around the world, according to the study. 

Page 7 GAO-10-903 Climate Change
 

Examples of land-based CDR approaches include: 

• Physical removal by industrial processes. Direct air capture—

technology-based processing of ambient air to remove CO2 from the 

atmosphere. The resulting stream of pure CO2 can either be used or 

injected into geological formations for storage (geological 

sequestration). 

• Enhanced removal by biological processes.

18

• Biomass energy with CO2 capture and geological sequestration—

harvesting vegetation and using it as a fuel source with capture and 

storage of the resulting emissions in geological formations 

(geological sequestration). 

• Biomass for sequestration—harvesting of vegetation and 

sequestering it as organic material by burying trees or crop wastes, 

or as charcoal (biochar). 

• Afforestation and land-use management—the planting of trees on 

lands that historically have not been forested, or otherwise 

managing vegetation cover to maximize CO2 sequestration in soil or 

biomass. 

• Enhanced removal by chemical processes. Land-based enhanced 

weathering—accelerating chemical reactions between certain minerals 

and CO2, which convert the CO2 to a nongaseous state. Methods 

include mining reactive minerals such as silicates, and then exposing 

them to the air by spreading them on agricultural fields, or injecting a 

stream of CO2 into a geological formation of reactive minerals. 

 

18As previously noted, the NRC study indicated that there is no consensus regarding the 

extent to which the term geoengineering should be applied to various widely accepted 

practices that remove CO2 from the atmosphere. In commenting on this report, OSTP and 

U.S. Department of Agriculture officials recommended against including such land-based 

biological processes in an operational definition of geoengineering. For more information 

on their comments, see the Agency Comments and Our Evaluation section of this report. 

Page 8 GAO-10-903 Climate Change
 

Figure 1: Examples of CDR Approaches 

100 to 200 meters

7

1

2

3

4

5

6

Sources: Lawrence Livermore National Laboratory and GAO analysis of various sources.

1. Enhanced upwelling/downwelling

2. Ocean fertilization with nutrients to promote 

phytoplankton growth

3. Direct air capture with geological sequestration

4. Biomass for energy with CO2 capture and 

geological sequestration

5. Biomass for sequestration by burial or biochar

6. Afforestration and land-use management

7. Land-based enhanced weathering

Page 9 GAO-10-903 Climate Change
 

The Royal Society identified several SRM approaches that would reflect a 

small percentage of incoming sunlight back to space, as shown in figure 2. 

SRM approaches are generally discussed in terms of which sphere they 

would act upon—space, the atmosphere, or the earth’s surface. Examples 

of SRM approaches include: 

• Space-based methods. Reflecting or deflecting incoming solar 

radiation using space-based shielding materials, such as mirrors. 

• Atmosphere-based methods. 

• Stratospheric aerosol injection—injecting reflective aerosol 

particles into the stratosphere to scatter sunlight back into space. 

Although it is possible that a wide range of particles could serve this 

purpose, most attention has been on sulfur particles—partly 

because temporary global cooling has been produced in the past by 

volcanic eruptions. 

• Cloud-brightening—adding sea salt or other cloud condensation 

surfaces to low-level marine clouds to increase their ability to 

reflect sunlight before it reaches the earth’s surface. 

• Surface-based methods. Increasing the reflectivity of the earth’s land 

or ocean surfaces19 through activities such as painting roofs white, 

planting more reflective crops or other vegetation, or covering desert 

or ocean surfaces with reflective materials. 

 

19According to the Royal Society study, there appeared to be no peer-reviewed studies 

describing methods to increase the reflectivity of the ocean surface at the time of the 

study’s publication. However, two ideas that have been proposed are placing reflective 

disks on the ocean’s surface and creating microbubbles on the ocean surface, both of 

which would reduce the amount of sunlight absorbed by the ocean’s surface and converted 

into heat. 

Page 10 GAO-10-903 Climate Change
 

Climate Change

 

Page 11 GAO-10-903 

Figure 2: Examples of SRM Approaches 

3

4

2

1

5

6

Space

Stratosphere

Troposphere

Sources: Lawrence Livermore Laboratory and GAO analysis of various sources.

1. Space-based reflective mirrors

2. Stratospheric aerosol injection

3. Cloud-brightening

4. Painting roofs white

5. Planting more reflective crops

6. Covering desert surfaces with reflective material

Page 11 GAO-10-903 
 

According to the NRC and Royal Society studies, geoengineering is one of 

several potential tools to limit the impact and consequences of climate 

change. However, these studies state that geoengineering is a potential 

complement to, rather than a substitute for, sharp reductions in 

greenhouse gas emissions. For example, while geoengineering includes a 

range of approaches with varying degrees of potential effectiveness and 

consequences—no geoengineering approach can provide an easy or riskfree alternative solution to the problem of climate change, according to 

the Royal Society study. For example, compared to current CDR 

proposals, using SRM to divert incoming sunlight would relatively quickly 

produce a cooling effect to counteract the warming influence of increased 

atmospheric concentrations of greenhouse gases. However, SRM does not 

address the rising atmospheric concentration of greenhouse gases 

produced by human activity, and therefore would not reduce other serious 

climate change impacts such as ocean acidification. 

Furthermore, according to these studies, both CDR and SRM involve 

additional environmental risks or other trade-offs. For example, oceanbased CDR approaches, such as ocean fertilization, could have 

unanticipated negative impacts on ocean ecosystems. Additionally, the 

large-scale deployment of certain land-based CDR approaches, such as 

afforestation, land-use management for sequestration, and biomass for 

energy or burial, create trade-offs for land use. In general, the Royal 

Society study found that compared to CDR, most SRM approaches are 

associated with a higher risk of negative environmental effects, such as 

negative impacts on regional temperature or precipitation. For example, 

one study found that combining a reduction of incoming solar radiation 

with high levels of atmospheric CO2 could have substantial impacts on 

regional precipitation—potentially leading to reductions that could create 

droughts in some areas.20 Additionally, the Royal Society study said that 

increasing the reflectivity of desert or ocean surfaces could have major 

impacts on desert or ocean ecosystems. Moreover, this study indicated 

that the artificial balance between increased greenhouse gas 

concentrations and reduced solar radiation created by large-scale 

 

20Gabriele C. Hegerl and Susan Solomon, “Risks of Climate Engineering,” Science 325 

(2009): 955-956. 

Page 12 GAO-10-903 Climate Change
 

deployment of an SRM approach would need to be maintained over 

decades and possibly centuries or longer.21

Experts said that geoengineering is an emerging field, with relatively few 

experiments or other studies conducted and with major uncertainties 

remaining. We found that more is known about certain CDR approaches, 

since related laboratory and field experiments have been conducted, 

whereas there is limited understanding of other CDR approaches and 

SRM. Moreover, major uncertainties remain regarding the scientific, legal, 

political, economic, and ethical implications of researching or deploying 

geoengineering. 

Geoengineering Is an 

Emerging Field with 

Major Uncertainties, 

Including Potential 

Effects 

More Relevant Modeling 

Studies and Experiments 

Have Focused on CDR 

than on SRM 

We found that relatively more laboratory and field research relevant to 

certain CDR approaches exists, although most of this research was not 

designed to apply to geoengineering. For example, according to the 

International Energy Agency (IEA),22 there are several projects injecting 

CO2 into geological formations and monitoring it. The oldest of these is a 

private-sector project in Sleipner, Norway, that began in 1996, according to 

the IEA. 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 deployment of geological sequestration that 

would be required to significantly alter the climate through 

geoengineering. For direct air capture, one expert we selected said in a 

recent article that a system could be created using existing technologies, 

and that a handful of academic groups and small start-up companies have 

initiated direct air capture research projects. However, the NRC study, 

Advancing the Science of Climate Change, stated that major challenges 

remained in making direct air capture systems viable in terms of cost, 

 

21OSTP officials indicated that if greenhouse gas concentrations continued to rise, 

compensating SRM measures would also require a corresponding increase to maintain the 

balance between global heating and cooling. According to the Royal Society study, it is 

doubtful that such a balance would be sustainable for long periods of time if emissions 

were allowed to continue or increase, and any large-scale SRM deployment introduces 

additional risk. 

22The 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: 

http://www.iea.org. International Energy Agency, Legal Aspects of Storing CO2 : Update 

and Recommendations (Paris: 2007). 

Page 13 GAO-10-903 Climate Change
 

energy requirements, and scalability.23 Similarly, the Royal Society study 

found that both land- and ocean-based enhanced weathering CDR 

approaches could potentially store a large amount of carbon, but face 

barriers to deployment such as scale, cost, and possible environmental 

consequences. This report also found that while some other land-based 

CDR approaches—such as afforestation, land-use management techniques, 

and biomass for energy or burial—can remove CO2 from the atmosphere, 

their relative potential to significantly reduce atmospheric concentrations 

of CO2 on a global scale is low.24

Other CDR approaches have been the focus of relatively few laboratory 

and field experiments, and fundamental questions remain about their 

potential efficacy. For example, according to the Royal Society and NRC 

studies, while ocean fertilization has received some sustained research 

activity, its potential to remove CO2 from the atmosphere and keep it 

sequestered remains unclear. Specifically, we found that several ocean 

fertilization experiments using iron have been conducted as part of 

existing marine research studies or small-scale commercial operations. 

However, one scientific researcher familiar with these experiments noted 

that they were designed to improve scientific understanding of the role of 

iron in ocean ecosystems and the carbon cycle, not to investigate 

geoengineering.25 For example, according to researchers who designed a 

2009 joint German and Indian iron fertilization experiment, their 

experiment was designed 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 biologically-generated 

elements, such as carbon and nitrogen.26 Furthermore, these researchers 

noted that future long-term experiments to study phytoplankton blooms 

and their effect on the deep ocean and underlying sediments would have 

to be much larger than experiments to date. 

 

23National Research Council, Advancing the Science of Climate Change (Washington, D.C.: 

2010). 

24The Royal Society, Geoengineering and the climate: Science, governance and 

uncertainty (London: September 2009). 

25In a 2008 report, Fertilizing the Ocean with Iron, the Woods Hole Oceanographic 

Institution said that previous research looking at ice-core records suggested that naturally 

occurring iron fertilization had repeatedly drawn carbon out of the atmosphere during past 

glacial periods. 

26The experiment was sponsored by the German Alfred Wegener Institute for Polar and 

Marine Research and the Indian National Institute of Oceanography. 

Page 14 GAO-10-903 Climate Change
 

According to our review of relevant studies and expert interviews, 

understanding of SRM is more limited than that of CDR because there 

have been few laboratory experiments, field experiments, or computer 

modeling efforts. Two of the most frequently discussed SRM approaches 

are stratospheric aerosol injection and cloud-brightening, according to 

many of the scientific experts we spoke with. For stratospheric aerosol 

injection, some of the experts said that research to date consisted 

primarily of a few modeling analyses. They also said that more work 

would need to be done to assess whether this approach could reduce 

incoming solar radiation without serious consequences. For example, one 

study identified the potential for regional impacts on precipitation—

potentially leading to drought in some areas.27 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 2009 

Russian experiment that injected aerosols into the middle troposphere to 

measure their reflectivity.28 Similarly, in the case of cloud-brightening, 

several experts said that there currently is not enough research to assess 

its effectiveness or impacts. According to the 2010 NRC study, other 

methods for SRM, including using space-based reflectors and increasing 

the solar reflectivity of buildings or plants, have limited potential, either 

due to the cost of deployment or the limited potential to affect the climate. 

Experts and Relevant 

Studies Identified Major 

Uncertainties that Merit 

Further Investigation 

Experts we interviewed and relevant studies identified several major 

uncertainties in the field of geoengineering that are in need of further 

investigation. These uncertainties ranged from important scientific 

questions for CDR and SRM, to political, ethical, and regulatory issues. 

Areas that merit further investigation include: 

• Technical feasibility and effectiveness of SRM and certain CDR 

approaches. Experts we interviewed and the Royal Society and NRC 

studies agreed that SRM approaches generally were not researched 

sufficiently to be considered well-understood or technically feasible. 

Additionally, questions remain regarding the effectiveness of certain 

 

27Gabriele C. Hegerl and Susan Solomon, “Risks of Climate Engineering,” Science 325 

(2009): 955-956. 

28 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. 

Page 15 GAO-10-903 Climate Change
 

CDR approaches, such as ocean fertilization and some land-based 

methods, to significantly reduce atmospheric concentrations of CO2 on 

a global scale, or sequester CO2 over the long term, according to 

relevant studies. 

• Unintended consequences. According to the NRC and Royal Society 

studies as well as some of the experts we interviewed, modeling 

studies indicate that stratospheric aerosol injection could change 

regional precipitation and that other unintended effects are possible.29

The Royal Society study also noted that large-scale deployment of CDR 

approaches, such as methods requiring substantial mineral 

extraction—including land- or ocean-based enhanced weathering—

may have unintended and significant impacts within and beyond 

national borders. For example, the study noted that impacts from 

enhanced weathering approaches could include localized 

environmental damage caused by increased mineral extraction activity, 

as well as changes to soil and ocean surface water pH that could affect 

vegetation and marine life. Several of the experts that we spoke with 

agreed that potential unintended consequences of geoengineering 

approaches require further study.30

• Better understanding of the climate and a way to determine 

when a “climate emergency” is reached. The NRC study 

recommended additional basic climate science research, including (1) 

improved detection and attribution of climate change to distinguish the 

effects of intentional intervention in the climate system from other 

causes of climate change, and (2) information on climate system 

thresholds, reversibility, and abrupt changes to inform societal debate 

and decision-making over what would constitute a “climate emergency” 

and whether deployment of a geoengineering approach would be 

merited. 

 

29According to a NOAA official, the idea of making up-front investments to evaluate risks 

(prior to any large investments in engineering or implementation) was successfully used to 

protect the ozone layer from unintended consequences of new chemicals that were 

proposed to replace ozone-depleting substances such as chlorofluorocarbons. This could 

serve as a potential model for risk evaluation for geoengineering approaches. 

30In commenting on this report, a NOAA official noted that the amount of research directed 

specifically towards understanding uncertainties surrounding geoengineering is minimal, 

and that such research is important to improve our understanding of the benefits and 

consequences of various geoengineering activities. This official recommended that such 

research be interdisciplinary and take an ecosystem perspective. 

Page 16 GAO-10-903 Climate Change
 

• How best to regulate geoengineering internationally. Several of 

the experts we interviewed as well as the NRC study emphasized the 

potential for international tension, distrust, or even conflict over 

geoengineering deployment. The NRC study also stated that globalscale geoengineering deployment creates the potential for uneven 

positive and negative regional outcomes, and this raises questions of 

decision-making and national security. Further research can help 

clarify what type of governance might be useful and when, both for 

deployment and for field experiments that may involve risks of 

negative consequences. 

• Political, economic, and ethical concerns. Some experts we 

interviewed and relevant studies said that geoengineering introduces 

important political, economic, and ethical questions. For example, 

several experts said that pursuing geoengineering research could 

unintentionally reduce interest in reducing CO2 emissions and that 

social science research would be needed to assess this potential effect. 

The NRC studies stated that major questions remain regarding the 

economic viability of certain CDR approaches, such as direct air 

capture and enhanced weathering.31 Additionally, one expert raised 

concerns over the potential economic costs associated with unintended 

impacts from deploying SRM.32 Furthermore, NRC reported that public 

involvement is critical to making decisions about whether to pursue 

testing and deployment of geoengineering and that research is needed 

to determine how best to involve the public in such a decision-making 

process. 

 

31National Research Council, Advancing the Science of Climate Change (Washington, D.C.: 

2010), and National Research Council, Limiting the Magnitude of Future Climate Change 

(Washington, D.C.: 2010). 

32DOE officials noted that any economic costs of geoengineering would also need to be 

weighed against the costs of damages from unmitigated climate change. 

Page 17 GAO-10-903 Climate Change
 

USGCRP agencies reported funding at least 52 research activities relevant 

to geoengineering in fiscal years 2009 and 2010. We found that, of these 52 

activities, 43 were either related to conventional mitigation strategies or 

were fundamental scientific research, whereas 9 directly investigated a 

particular geoengineering approach. We identified approximately $100.9 

million in geoengineering-related funding across USGCRP agencies in 

fiscal years 2009 and 2010, with about $1.9 million of this amount related 

to research directly investigating a particular geoengineering approach. 

The other roughly $99 million was related to research concerning 

conventional mitigation strategies that could be applied directly to a 

particular geoengineering approach or basic science that could be applied 

generally to geoengineering. However, there is no coordinated federal 

strategy or operational definition for geoengineering, so agencies and 

policymakers may not know the full extent of relevant federal research. 

Federal Agencies Are 

Sponsoring Research 

Relevant to 

Geoengineering, but 

There Is No 

Coordinated Federal 

Strategy, Making It 

Difficult to Determine 

the Extent of Relevant 

Research 

Most Federal Research 

Activities Focused on 

Mitigation or Basic 

Science, but a Few 

Specifically Addressed 

Geoengineering 

The 13 agencies participating in USGCRP identified 52 research activities 

relevant to geoengineering—accounting for approximately $100.9 million 

in federal funding for fiscal years 2009 and 2010.33 Twenty-eight of these 

activities—funded at approximately $54.4 million—were related to 

conventional mitigation strategies that are directly applicable to a 

particular CDR approach, such as enhancing land-based biological 

removal of CO2 or geological sequestration of CO2, according to our 

analysis. Fifteen of the reported activities—funded at approximately $44.6 

million—were fundamental scientific efforts that could be generally 

applied to geoengineering, such as modeling the interactions between the 

atmosphere and the climate and basic research into processes to separate 

gas streams into their individual components, such as CO2 or methane. 

The remaining nine activities—funded at approximately $1.9 million—

directly investigated a particular geoengineering approach, such as 

stratospheric aerosol injection that does not overlap with a convention

mitigation strategy. Table 1 summarizes the reported funding for the 52 

identified activities by each geoengineering approach and our 

categorization of the results. For more detailed information on rep

activities, see 

al 

orted 

appendix IV. 

 

33These activities were current as of July 2010. Accordingly, additional activities relevant to 

geoengineering may receive funding during fiscal year 2010. 

Page 18 GAO-10-903 Climate Change
 

Page 19 GAO-10-903 Climate Change 

Table 1: Summary of Reported Research Activities Relevant to Geoengineering at USGCRP Agencies, Combined Fiscal Years 

2009 and 2010 

(In thousands of dollars) 

Fundamental Mitigation-related 

research with general research with direct Direct geoengineering 

applicability applicability research Totala

Geoengineering Reported Reported Reported Reported 

approach Activities funding Activities funding Activities funding Activities funding

CDR 

Biological carbon 2 $26,308 10 $27,323 1 $474 13 $54,105

removal and 

sequestration 

Physical carbon 10 2,076 16 26,695 2 293 28 29,064

removal and 

sequestration 

Chemical carbon 2 334 2 334

removal and 

sequestration 

SRM 

Multiple 4 904 4 904

approaches 

Stratospheric 1 45 1 45

aerosol injection 

Other greenhouse 2 400 2 400

gas removal 

General 1 15,840 1 170 2 16,010

geoengineering 

Approximate 15 $44,624 28 $54,352 9 $1,886 52 $100,862

totalb

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. 

a

Reported funding totals for each approach may not add across tables 1, 2, and 3 due to rounding. 

b

We present an approximate total because agencies used different measures to report funding data. 

For example, while most agencies provided obligations data, EPA reported enacted budget authority. 

Additionally, the Department of the Interior (Interior) reported planned obligations for a grant that had 

not yet been awarded. 

Of the 43 activities related to fundamental research or mitigation efforts 

relevant to geoengineering but not designed to address it directly, the 

Department of Commerce (Commerce) reported the most funding—

approximately $41.6 million. This was largely due to the National Oceanic and 

Atmospheric Administration’s (NOAA) climate modeling and monitoring of 
 

Page 20 GAO-10-903 Climate Change 

biological emissions and absorption of greenhouse gases, which NOAA 

officials said could be relevant for assessing the impacts and efficacy of 

various geoengineering approaches. The U.S. Department of Agriculture 

(USDA), DOE, the Department of the Interior (Interior), and EPA reported 

similar levels of funding—from about $11.3 million to $13.9 million. These 

efforts were largely directed at measuring and monitoring carbon 

sequestration potential in soils and biomass and assessing the impacts and 

storage potential for geological sequestration of CO2. Although these activities 

are associated with efforts to reduce or offset emissions, agency officials 

identified them as relevant to certain CDR approaches—such as large-scale 

afforestation, and direct air capture—based on the working definition we 

provided. Table 2 summarizes the approximately $99 million in reported 

funding for the 43 relevant activities related to conventional mitigation efforts 

and fundamental scientific research, by agency. 

Table 2: Summary of Reported Mitigation-Related Research and Fundamental Scientific Research Relevant to 

Geoengineering, by USGCRP Agency, Combined Fiscal Years 2009 and 2010 

(In thousands of dollars) 

Geoengineering approach 

Reported funding Totalb

Commerce USDA Interior DOE EPA 

 

Othera Activities

Reported 

funding

CDR 

Biological carbon removal 

and sequestration 

$25,800 $13,900 $7,652 $5,078 $300 $900 12 $53,630

Physical carbon removal 

and sequestration 

 5,250 6,759 11,000 5,763 26 28,772

Chemical carbon removal 

and sequestration 

 334 2 334

Other greenhouse gas 

removal 

 400 2 400

General geoengineering 15,840 1 15,840

Approximate totalc

 $41,640 $13,900 $12,902 $11,837 $11,300 $7,397 43 $98,976

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. a

Other represents the eight other agencies participating in the USGCRP. b

Reported funding totals for each approach may not add across tables 1, 2, and 3 due to rounding. 

c

We present an approximate total because agencies used different measures to report funding data. 

For example, while most agencies provided obligations data, EPA reported enacted budget authority. 

Additionally, Interior reported planned obligations for a grant that had not yet been awarded. 

The National Science Foundation (NSF), DOE, and Commerce were the 

only agencies that reported funding for activities directly supporting 

geoengineering research during fiscal years 2009 and 2010. Of these 
 

agencies, NSF reported the most funding—approximately $1.1 million—

directed to three research activities: a study on the potential impacts of 

ocean iron fertilization, a study to examine the moral challenges 

associated with SRM, and a modeling effort investigating stratospheric 

aerosol injection and space-based SRM approaches. DOE reported funding 

research—approximately $700,000—for two studies about direct air 

capture technologies, a modeling activity for stratospheric aerosol 

injection and cloud-brightening, as well as a study investigating the 

unintended consequences of climate change responses, including CDR and 

SRM approaches. Commerce reported funding two relevant research 

efforts—for about $70,000—examining the unintended impacts of SRM 

approaches, with one study focused on climate-related impacts and the 

other study exploring potential effects on solar electricity generation. 

Table 3 summarizes the approximately $1.9 million in reported funding for 

the nine relevant activities directly supporting geoengineering research, by 

agency. 

Table 3: Summary of Reported Direct Geoengineering Research, by USGCRP Agency, Combined Fiscal Years 2009 and 2010 

(In thousands of dollars) 

Reported funding Totala

Geoengineering approach Commerce DOE NSF Activities

Reported 

funding

CDR

Biological carbon removal and sequestration $474 1 $474

Physical carbon removal and sequestration $293 2 293

SRM

Multiple approaches $25 266 613 4 904

Stratospheric aerosol injection 45 1 45

General geoengineering 170 1 170

Approximate totalb$70 $729 $1,087 9 $1,886

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. 

a

Reported funding totals for each approach may not add across tables 1, 2, and 3 due to rounding. 

b

We present an approximate total because agencies used different measures to report funding data. 

For example, while most agencies provided obligations data, EPA reported enacted budget authority. 

Additionally, Interior reported planned obligations for a grant that had not yet been awarded. 

Page 21 GAO-10-903 Climate Change
 

During our review, we also found examples of other relevant activities 

sponsored by USGCRP agencies that were outside the scope of our data 

request, mostly because they occurred prior to 2009. These activities 

included: 

• DOE sponsored studies on ocean-based carbon sequestration 

approaches, such as ocean fertilization and direct injection of CO2 into 

deep ocean sediments, from 2000 to 2006. From 2007 to 2008, DOE also 

sponsored research investigating the potential application of porous 

glass materials for SRM approaches. 

• From 2006 to 2007, the 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.34 Additionally, scientists at NASA’s Ames Research Center 

held a conference on SRM approaches in 2006, in conjunction with the 

Carnegie Institution of Washington. NASA also funded atmospheric 

modeling studies, which were used by independent researchers, in part, 

to assess the potential impact of stratospheric aerosols on the ozone 

layer. 

• In 2008, NSF sponsored studies examining the long-term carbon 

storage potential of soils and the impact of increased nitrogen on 

biological carbon sequestration. 

• A Department of Defense (DOD) advisory group sponsored a 1-day 

workshop at Stanford University on geoengineering in 2009; however, 

DOD officials said that no funded research projects resulted from this 

workshop. 

• In 2007, EPA funded research relevant to the economic implications of 

SRM approaches through its National Center for Environmental 

Economics. 

 

34According 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 opensolicitation and peer-reviewed competition, which was managed by the Universities Space 

Research Association, a private, nonprofit organization. 

Page 22 GAO-10-903 Climate Change
 

Furthermore, federal officials also 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, federal 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. Similarly, 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. 

Existing Federal Efforts 

Are Not Part of a 

Coordinated 

Geoengineering Research 

Strategy, Making It 

Difficult to Determine the 

Full Extent of Relevant 

Research 

We found that it was difficult to determine the full extent of federal 

geoengineering research activities because there is no coordinated federal 

strategy for geoengineering, including guidance on how to define federal 

geoengineering activities or efforts to identify and track federal funding 

related to geoengineering. Officials from federal offices coordinating 

federal responses to climate change—CEQ, OSTP, and USGCRP—stated 

that they do not currently have a coordinated geoengineering strategy or 

position. For example, a USGCRP official stated that there is no group 

coordinating federal geoengineering research and that such a group is not 

currently necessary because of the small amount of federal funding 

involved. However, while USGCRP agencies reported about $1.9 million in 

funding for activities directly investigating geoengineering, federal officials 

also told us that a large fraction of the existing federal research and 

observations on basic climate change and earth science could be relevant 

to understanding geoengineering. According to the USGCRP’s most recent 

report to Congress, USGCRP agencies requested roughly $2 billion in 

budget authority for climate change and earth science activities in fiscal 

year 2010. Consequently, the actual funding for research that could be 

applied either generally or directly to understanding geoengineering 

approaches is likely greater than the roughly $100.9 million reported in 

response to our data request. 

However, without the guidance of an operational definition for what 

constitutes geoengineering or a strategy to capitalize on existing research 

efforts, federal agencies may not recognize or be able to report the full 

extent of potentially relevant research activities. For example, some 

agency officials indicated that, without a clear governmentwide definition, 

in their determination of which federal research activities were relevant to 

geoengineering, our data request was subject to different interpretations—

particularly for CDR approaches, since there is extensive overlap with 

Page 23 GAO-10-903 Climate Change
 

existing mitigation efforts. In particular, EPA and USDA officials said that 

there is a large body of research regarding biological sequestration but 

that these officials would not consider it to be geoengineering. However, 

officials from other agencies, such as Interior and DOE, included certain 

research on biological sequestration as relevant to geoengineering based 

on the definition we provided. Similarly, we found that from NSF officials’ 

perspectives, the distinction between existing efforts to develop carbon 

capture and storage technologies, such as membranes to separate CO2

from other gases, and geoengineering direct air capture technologies is 

also not well-defined. This definitional issue is not unique to these 

agencies. In its recent study Advancing the Science of Climate Change, 

NRC acknowledged the lack of consensus regarding what constitutes 

geoengineering in relation to widely accepted practices that remove CO2

from the atmosphere.35

The NRC study included other findings about the nation’s climate change 

science efforts that may be relevant to a potential federal geoengineering 

strategy. The study emphasized the importance of providing decision 

makers with scientific information on a range of available options, 

including geoengineering, to limit future climate change and its impacts. 

According to this study, this information would help policymakers use 

adaptive risk management to update response strategies as new 

information on climate change risks and response strategies becomes 

available.36 NRC recommended an integrative, interdisciplinary research 

effort to improve understanding of available response options, as well as 

of climate change and its impacts. The study indicated that this effort 

should be led by a single coordinating body, and NRC identified USGCRP’s 

capacity to play a role in such an effort.37 Similarly, several of the experts 

 

35National Research Council, Advancing the Science of Climate Change (Washington, D.C.: 

2010). 

36We have also reported on the advantages of applying such an adaptive approach to riskmanagement when making decisions under substantial uncertainty. See GAO, Highway 

Safety: Foresight Issues Challenge DOT’s Efforts to Assess and Respond to New 

Technology-Based Trends, GAO-09-56 (Washington, D.C.: Oct. 3, 2008). 

37While recognizing USGCRP’s capacity to lead a coordinated climate change science 

research effort, NRC also identified areas where further improvements are needed for 

USGCRP to implement NRC’s recommendations. For example, NRC stated that USGCRP 

will need to establish improved mechanisms for identifying and addressing weaknesses and 

gaps in research and decision support activities. NRC also recommended that USGCRP will 

need expanded budget oversight and authority to coordinate and prioritize research across 

agencies. 

Page 24 GAO-10-903 Climate Change
 

we interviewed recommended that federal geoengineering research should 

be an interdisciplinary effort across multiple agencies and led by a 

coordinating body, such as OSTP or USGCRP. 

Our recent work offers insights on key considerations for establishing 

governmentwide strategies, which could be relevant to a future 

geoengineering strategy. Specifically, our review of federal efforts related 

to crosscutting issues, such as climate change adaptation38 and global food 

security,39 highlighted key practices for enhancing collaboration across 

agencies. These practices include establishing a commonly accepted 

operational definition for relevant activities; leveraging existing resources 

to support common outcomes and address identified needs; and 

developing mechanisms to monitor, evaluate, and report on results. 

Furthermore, our review of DOE’s FutureGen project—a program to help 

build the world’s first coal-fired, zero-emissions power plant—identified 

important factors to consider when developing a strategy for technologybased research.40 Specifically, we found that it is important to 

comprehensively assess the costs, benefits, and risks of each technological 

option and to identify potential overlap between proposed and existing 

programs. For example, the NRC study acknowledged the importance of 

improving understanding of SRM and its consequences, without replacing 

or reducing existing research on climate change science or other 

approaches to limiting climate change or adapting to its impacts. As the 

study noted, much of the research needed to advance scientific 

understanding of SRM, such as studying the climate effects of aerosols and 

cloud physics, is also necessary to advance understanding of the climate 

system, and could therefore contribute more broadly to climate change 

science. Similarly, an OSTP official said that ongoing fundamental 

research to investigate the relationship of cloud/aerosol interactions could 

also be applied to improve understanding of certain SRM approaches. 

In the absence of a coordinated federal strategy for geoengineering, 

decisions about whether a particular research activity is relevant to 

 

38GAO-10-113. 

39GAO, Global Food Security: U.S. Agencies Progressing on Governmentwide Strategy, 

but Approach Faces Several Vulnerabilities, GAO-10-352 (Washington, D.C.: Mar. 11, 

2010). 

40GAO, Clean Coal: DOE’s Decision to Restructure FutureGen Should Be Based on a 

Comprehensive Analysis of Costs, Benefits, and Risks, GAO-09-248 (Washington, D.C.: 

Feb. 13, 2009). 

Page 25 GAO-10-903 Climate Change
 

geoengineering may not necessarily be consistent across the federal 

government. In addition, agencies generally do not collect and share 

information on such research activities in the context of geoengineering. 

While EPA officials told us that certain agencies, such as EPA, State, and 

NOAA, share information about ocean fertilization and direct injection of 

CO2 into deep sub-seabed geological formations as part of a working group 

for international regulation of the ocean,41 a USGCRP official said there is 

no working group to share information or coordinate geoengineering 

research more broadly, because such an action would require a decision 

from the administration to pursue geoengineering research on a larger 

scale. However, without a coordinated effort to identify relevant research 

and share information across agencies, policymakers and agency officials 

may lack key information needed to inform their decisions on 

geoengineering research. For example, if policymakers and officials do not 

know the full extent of the relevant federally funded research that is under 

way, they may not have sufficient information to leverage existing 

research on climate change science to also improve understanding of 

geoengineering. 

Legal experts we interviewed and EPA and Department of State (State) 

officials said that the extent to which existing laws and international 

agreements apply to geoengineering is unclear, largely because detailed 

information on geoengineering approaches and effects is not available.42

EPA has taken steps to regulate one CDR approach and has determined 

that an existing law provides sufficient authority to regulate two other 

approaches. EPA officials provided their preliminary thoughts on how 

other laws might apply to geoengineering activities. However, according to 

EPA officials, they have not fully assessed (1) whether the agency has the 

authority to regulate or (2) how to regulate most geoengineering 

approaches, because the research is still in its initial stages. Similarly, legal 

experts and State officials stated that many international agreements 

could apply to geoengineering; however, most agreements’ applicability is 

unclear because they were not intended to address geoengineering and 

parties to the agreements have not determined whether or how the 

agreements should apply to relevant geoengineering activities. This 

uncertainty and inaction is due, in part, to the limited general 

The Extent to Which 

Existing Federal Laws 

and International 

Agreements Apply to 

Geoengineering Is 

Unclear, and Experts 

and Officials 

Identified Governance 

Challenges 

 

41An EPA official also noted that DOE, Interior, and EPA have been informally coordinating 

for several years on issues related to geological sequestration. 

42The term “legal experts” refers to nongovernmental legal experts, as listed in appendix II 

Page 26 GAO-10-903 Climate Change
 

understanding of geoengineering and a lack of geoengineering activity. 

Legal experts and federal officials identified challenges for establishing 

governance of geoengineering, such as the potential for unintended and 

uneven impacts, although their views differed on the most effective 

governance approach. 

EPA Officials Stated the 

Applicability of Existing 

Laws is Unclear and They 

Have Not Fully Assessed 

Their Applicability 

Because of Limited 

Geoengineering Activity 

EPA officials stated that the extent to which existing federal 

environmental laws apply to geoengineering is unclear, largely because 

detailed information on most geoengineering approaches and effects is not 

available. However, EPA officials said that there is relatively more 

information available about geological sequestration of CO2—a 

conventional mitigation strategy—which could be relevant to certain CDR 

approaches that capture CO2 from the air and sequester it underground or 

in the sub-seabed. EPA has taken steps to regulate geological 

sequestration under the Safe Drinking Water Act, and EPA officials said 

that the Marine Protection, Research, and Sanctuaries Act of 1972 provides 

the agency with authority to regulate (1) certain sub-seabed geological 

sequestration activities, and (2) ocean fertilization activities. Specifically: 

• 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 to govern the underground injection of CO2

for geological sequestration. Although the rule’s preamble discusses 

geological sequestration as the process of injecting CO2 captured from 

an emission source, such as a power plant or industrial facility, the 

rule’s definition of geological sequestration is broad enough to include 

long-term sequestration of CO2 captured directly from the air. The 

proposed rule was published in July 2008, and EPA officials told us the 

final rule is scheduled to be promulgated in late 2010. In addition, EPA 

also issued a proposed rule in 2010 that would require monitoring and 

reporting of CO2 injection and geological sequestration, which is 

scheduled to be finalized in the fall of 2010. 

• 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 

Page 27 GAO-10-903 Climate Change
 

without a permit from EPA.43 EPA officials said that certain sub-seabed 

geological sequestration of CO2 and ocean fertilization activities would 

require a permit pursuant to this act. In addition, they said some 

atmospheric-based geoengineering approaches may also require a 

permit if the aerosol particles eventually could be deposited into the 

ocean. 

For most other laws and geoengineering approaches, EPA officials said 

that the agency has not considered the applicability of existing laws 

because the technologies have not reached a sufficient level of 

development. In particular, EPA officials stated that they would need 

detailed information on the activity itself, including the materials used and 

the delivery mechanism, as well as information on potential effects from 

the activity, to perform a regulatory risk assessment of environmental and 

human health impacts under existing laws. However, such information is 

not available for most geoengineering approaches. Furthermore, EPA 

officials noted that they have difficulty determining whether a particular 

activity is considered geoengineering because there is no standard 

definition for geoengineering. For example, EPA officials said that there is 

a substantial body of knowledge related to terrestrial biological 

sequestration and to programs that offset greenhouse gas emissions, but 

EPA would not necessarily label these activities as geoengineering. 

Although EPA officials had not formally assessed how existing laws would 

apply to geoengineering, they shared their preliminary thoughts on the 

applicability of the following laws, including how additional laws could 

apply to geological sequestration44 and ocean fertilization: 

• Resource Conservation and Recovery Act of 1976 (RCRA). RCRA 

regulates the management of hazardous waste from generation of the 

waste to its disposal. An EPA official stated that EPA has been 

examining questions of RCRA’s applicability to geological 

sequestration of CO2 and is currently considering a proposed rule to 

 

43The law is limited to disposition of materials by vessels or aircraft registered in the United 

States, vessels or aircraft departing from the United States, federal agencies, or disposition 

of materials conducted in U.S. territorial waters, which extend 12 miles from the shoreline 

or coastal baseline. 

44For an in-depth discussion of how existing laws apply to the capture, transport, and 

geological sequestration of CO2, see the Report of the Interagency Task Force on Carbon 

Capture and Storage, available at: 

http://fossil.energy.gov/programs/sequestration/ccs_task_force.html. 

Page 28 GAO-10-903 Climate Change
 

clarify how RCRA hazardous waste requirements apply in that context. 

This official also noted that RCRA’s applicability to other 

geoengineering approaches where materials are applied to the land or 

oceans would depend on whether there was intent to discard the 

materials and whether the materials are a hazardous waste. 

• Comprehensive Environmental Response, Compensation, and 

Liability Act of 1980 (CERCLA). CERCLA authorizes EPA to clean 

up hazardous substance releases at contaminated sites and then seek 

reimbursement from the parties responsible for contaminating them or 

compel the responsible parties to clean up these sites.45 Responsible 

parties include current and former site owners and operators, as well 

as those who transport or arrange for the disposal of the hazardous 

substances. Although a stream of pure CO2 is not a hazardous 

substance under CERCLA, an EPA official noted that injected CO2

streams could contain hazardous substances, thus subjecting the 

parties injecting the CO2 to liability for any release that did not qualify 

as federally-permitted release. In addition, if CO2 enters groundwater, it 

might also cause hazardous substances, such as some metals, to be 

dissolved by the groundwater from enclosing strata. If that constitutes 

a release of hazardous substances from a “facility,” such as the strata, 

then the owner of that facility could be liable for any cleanup costs 

caused by that release. This official was not aware of CERCLA’s 

applicability to any other geoengineering activity. 

• Clean Air Act. This law authorizes EPA to regulate emissions of 

certain air pollutants from mobile and stationary sources into the 

ambient air, including those that destroy the stratospheric ozone layer. 

EPA officials said that the act could apply to geoengineering activities 

that emitted air pollutants into the atmosphere—either as the purpose 

of the activity or as a side effect—depending on where the pollutant 

was released and the delivery mechanism. Officials also noted that 

although the act regulates emissions into the ambient air, substances 

injected into the upper atmosphere that eventually cycle down to 

ground level could also be subject to regulation, depending on the 

definition of ambient air. EPA officials stated that they would require 

 

45CERCLA defines hazardous substances as substances which may present substantial 

danger to the public health, welfare, or environment when released, including all hazardous 

wastes subject to RCRA. 

Page 29 GAO-10-903 Climate Change
 

further information on the specific technology and activity to 

determine exactly how the law might apply. 

In addition, EPA and DOE officials noted that geoengineering activities 

undertaken, funded, or authorized by federal agencies would be subject to 

the National Environmental Policy Act of 1969 (NEPA), the Endangered 

Species Act, and the conformity provision of the Clean Air Act. NEPA 

requires federal agencies to evaluate the likely environmental effects of 

certain major federal actions using an environmental assessment or, if the 

projects likely would significantly affect the environment, a more detailed 

environmental impact statement. Under the Endangered Species Act, 

geoengineering activities taken or authorized by federal agencies would 

require consultation among federal agencies, including the Fish and 

Wildlife Service and NOAA, to ensure that the activity is not likely to 

jeopardize the continued existence of any endangered or threatened 

species or adversely modify habitat critical for the species. Under the 

Clean Air Act’s conformity provision, no federal agency may approve or 

provide financial assistance for any activity that does not conform with a 

state implementation plan, which is a plan required by the act to ensure 

that national ambient air quality standards are met. 

Experts and Federal 

Officials Identified 

International Agreements 

That Could Apply to 

Geoengineering, but Their 

Applicability Is Largely 

Uncertain 

Acknowledging the lack of an existing international agreement that 

comprehensively addresses geoengineering, State officials and legal 

experts we interviewed said that many agreements could perhaps apply to 

a geoengineering activity and its impacts, depending on the activity’s 

nature, location, and actors. For example, some international agreements 

with broad scopes, such as the United Nations Framework Convention on 

Climate Change,46 could apply generally to geoengineering activities, 

whereas other agreements specifically addressing the atmosphere, oceans, 

and space could apply only if the activity occurred in or impacted that 

particular area. However, international agreements legally bind only those 

 

46In 1992, the United States and most other nations of the world negotiated the convention, 

whose objective is to stabilize greenhouse gas concentrations in the atmosphere at a level 

that would prevent dangerous man-made interference with the climate system within a 

time frame sufficient to allow ecosystems to adapt naturally to climate change, to ensure 

that food production is not threatened, and to enable economic development to proceed in 

a sustainable manner. 

Page 30 GAO-10-903 Climate Change
 

countries that have become parties to the particular agreement.47

Therefore, the number of parties to a particular agreement determines, in 

part, where the agreement applies, and countries that are not parties are 

not legally bound to abide by the agreement. Table 4 summarizes certain 

agreements identified by legal experts and relevant studies as potentially 

applicable to geoengineering and the number of parties to a particular 

agreement.48

Table 4: Examples of International Agreements Potentially Applicable to Geoengineering, as Identified by Legal Experts and 

Relevant Studies 

International agreement Number of parties U.S. participationa

 Applicable to a variety of approaches 

Convention on the Prohibition of Military or Any Other Hostile Use of 

Environmental Modification Techniques 

73 Party 

Convention on Environmental Impact Assessment in a Transboundary 

Context 

44 Signatory but not party 

Protocol on Strategic Environmental Assessment to the Convention on 

Environmental Impact Assessment in a Transboundary Contextb

18 Neither a signatory nor 

party 

United Nations Framework Convention on Climate Change (UNFCCC) 195 Party 

Kyoto Protocol to the UNFCCC 192 Signatory but not party 

Convention on Biological Diversityc193 Signatory but not party 

Ocean-based approaches 

Convention on the Prevention of Marine Pollution by Dumping of Wastes and 

Other Matter (London Convention)c

85 Party 

 1996 Protocol to the London Convention (London Protocol)c 38 Signatory but not party 

United Nations Convention on the Law of the Sea 160 Neither a signatory nor 

party 

Atmosphere-based approaches 

Vienna Convention for the Protection of the Ozone Layer 196 Party 

 

47Parties to an international agreement are those countries that have consented to be bound 

by the treaty and for which the treaty is in force. Generally, countries express their consent 

to be bound by a treaty by ratifying, accepting, approving or acceding to it. Countries that 

have signed the treaty but not consented to be bound to it are obliged to refrain from acts 

which would defeat the object and purpose of a treaty until the country’s intention not to 

become a party to the treaty is made clear. 

48The Royal Society noted that in addition to formal agreements between nations, there are a 

number of customary law and general principles that might also apply to geoengineering 

activities. For example, the Royal Society noted that the duty not to cause significant 

transboundary harm is recognized in several treaties and that states are expected to exercise 

due diligence in regulating activities under their jurisdiction and control. 

Page 31 GAO-10-903 Climate Change
 

International agreement Number of parties U.S. participationa

 1987 Montreal Protocol on Substances that Deplete the Ozone Layer 196 Party 

Convention on Long-Range Transboundary Air Pollution 51 Party 

Space-based approaches 

Treaty on Principles Governing the Activities of States in the Exploration and 

Use of Outer Space 

100 Party 

Convention on International Liability for Damage Caused by Space Objects 88 Party 

Approaches in Antarctic 

The Antarctic Treaty of 1959 28dParty 

 1991 Protocol on Environmental Protection to the Antarctic Treaty 28dParty 

Convention for the Conservation of Antarctic Marine Living Resources 27dParty 

Source: GAO analysis of expert interviews, relevant studies, and United Nations’ data on party status. 

Note: Because few formal analyses of existing international agreements’ applicability to 

geoengineering have been published and geoengineering science continues to evolve, this list may 

not include all agreements potentially applicable to geoengineering approaches. 

a

Countries that have signed an international agreement but have not consented to be bound by the 

treaty are referred to as signatories. 

b

This agreement is not yet in force. 

c

The parties to this agreement have issued a decision related to geoengineering. 

d

This is the number of parties entitled to participate in consultative meetings during such time as the 

party demonstrates its interest in Antarctica by conducting substantial research activity there. 

Almost all the legal experts and State officials we spoke with noted that, of 

all the potential geoengineering approaches, sub-seabed geological 

sequestration of CO2 and ocean fertilization had received the most 

international attention to date, and that parties to international agreements 

had issued decisions regarding the application of the agreements to ocean 

fertilization and amended an agreement to include sub-seabed geological 

sequestration in certain circumstances. In particular: 

Page 32 GAO-10-903 Climate Change
 

• Ocean fertilization. The parties to the London Convention and the 

London Protocol49 have decided that the scope of these agreements 

includes ocean fertilization activities for legitimate scientific research 

and that ocean fertilization activity other than legitimate scientific 

research should be considered contrary to the aims of the agreements 

and should not be allowed. The treaties’ scientific bodies are 

developing an assessment framework for countries to use in evaluating 

whether research proposals are legitimate scientific research. 

Additionally, the parties to the Convention on Biological Diversity50

issued a decision in 2009 urging countries to 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 them and a global, transparent, and 

effective control and regulatory mechanism in place. The parties to the 

London Convention and London Protocol are considering an additional 

resolution or amendment concerning ocean fertilization, and the 

parties to the Convention on Biological Diversity continue to discuss 

the issue. 

• Geological sequestration. In 2006, the parties to the London Protocol 

agreed to amend the protocol to include, in certain circumstances, CO2

streams for sequestration in sub-seabed geological formations in the 

protocol’s list of wastes and other matter that could be dumped. Under 

the amendment, CO2 streams from capture processes for sequestration 

can be considered for dumping if they satisfy three criteria: (1) disposal 

is into a sub-seabed geological formation, (2) the CO2 stream consists 

overwhelmingly of CO2 and only incidental associated substances, and 

 

49The Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other 

Matter (London Convention) entered into force on August 30, 1975. The London 

Convention requires parties to promote the effective control of all sources of pollution of 

the marine environment and take all practicable steps to prevent the pollution of the sea by 

the dumping of wastes and other matter. In 1996, the parties to the London Convention 

developed a protocol— the 1996 Protocol to the Convention on the Prevention of Marine 

Pollution by Dumping of Wastes and Other Matter (London Protocol)—that generally 

prohibits the dumping of wastes or other matter into the ocean except for those listed in 

the protocol for which a party to the agreement has issued a dumping permit that meets the 

protocol’s permitting requirements. As parties to the London Convention become parties to 

the London Protocol, the latter supersedes the former, but the convention remains in force 

for those parties to the convention, like the United States, that have not become parties to 

the protocol. 

50The Convention on Biological Diversity entered into force on December 29, 1993. The 

convention’s objectives are the conservation of biological diversity and the sustainable use 

of its components, among other things. 

Page 33 GAO-10-903 Climate Change
 

(3) no wastes or other matter are added for the purpose of disposing of 

those wastes or other matter. The parties also developed specific 

guidelines for countries to use when assessing whether applications for 

disposal of streams into sub-seabed geological formations is consistent 

with the protocol. In late 2009, the parties to the London Protocol 

adopted an amendment to allow the export of CO2 streams for disposal 

in certain circumstances.51 The parties are developing specific guidance 

for these exports and issues related to the management of 

transboundary movement of CO2 after injection. The parties have also 

discussed, but agreed not to develop, procedures regarding liability for 

CO2 sequestration in sub-seabed geological formations. 

However, legal experts and State officials stated that although parties to 

three agreements have taken action to clarify the agreements’ applicability 

to particular geoengineering approaches, most agreements’ applicability is 

unclear because they were not intended to address geoengineering and the 

parties had not yet addressed the issue. In addition, legal experts and 

federal officials generally said that more detailed information on 

geoengineering approaches and their effects would be needed for officials 

to develop a regulatory and governance framework. For example, aside 

from ocean fertilization and other marine-focused geoengineering 

approaches, State officials said that many of the ideas remain too 

theoretical and distant from implementation to consider addressing them 

through international law. 

Experts and Federal 

Officials Identified 

Governance Challenges, 

but Their Views Varied on 

the Most Effective 

Governance Approach 

Legal experts and EPA and State officials identified various challenges to 

establishing domestic and international governance of geoengineering. For 

example, the legal experts and EPA and State officials we interviewed 

generally agreed that there needs to be further research on most 

geoengineering approaches and their potential effects to inform—and in 

federal officials’ views to warrant—discussions regarding regulation. 

Similarly, some of these experts and federal officials said that a general 

lack of significant efforts to pursue geoengineering is a contributing factor 

to why geoengineering governance has not been pursued further to date. 

For example, a State official noted that geoengineering has not received 

much attention within international negotiations related to climate change, 

 

51The amendment will enter into force for those parties that have accepted it 60 days after 

two-thirds of the parties to the protocol have accepted, ratified, or approved the 

amendment. 

Page 34 GAO-10-903 Climate Change
 

and there isn’t enough geoengineering-related activity to drive interest in 

expanding international governance at this time. 

Legal experts and State officials had differing views about an international 

governance framework for geoengineering.52 Specifically, several legal 

experts recommended including all geoengineering activities with 

transboundary impacts in a single comprehensive agreement. Some of 

these experts said an existing comprehensive international agreement 

could be adapted to address geoengineering. Some of them specifically 

identified the United Nations Framework Convention on Climate Change 

as an appropriate agreement because it addresses climate change and 

geoengineering is intended to diminish climate change or its impacts. 

Other legal experts said a new international agreement was needed 

because of the difficulty reaching consensus within the United Nations 

Framework Convention on Climate Change. Experts in favor of a single 

comprehensive agreement said that it would be preferable to the 

patchwork of existing agreements, which were not designed to address 

geoengineering, because these agreements do not create comprehensive 

governance frameworks that could be used to address geoengineering. 

Additionally, some experts said that certain existing agreements rely on 

the parties to regulate activities under their jurisdiction without the 

international community’s participation in decision-making, which may 

not be the best structure for regulating geoengineering research or 

deployment. 

State officials we interviewed said that it would be better to rely on 

existing treaties to the extent they are adequate and appropriate and 

consider developing new international instruments if needed, since there 

is limited knowledge and practice of geoengineering. State officials said 

this approach would enable greater rigor and flexibility than trying to 

address all geoengineering activities within a single comprehensive 

agreement. They cited the London Convention and London Protocol as 

examples. While these agreements might not have addressed ocean 

fertilization several years ago, the parties took action when ocean 

fertilization reached a state of development where an agreed approach to 

regulation was considered necessary, and the agreements now 

unquestionably address it. In contrast, State officials said that parties to 

 

52In commenting on this report, a NOAA official noted that it would be important to have a 

coordinated strategy for addressing international oversight and regulation of 

geoengineering. For more information on agency comments, see the Agency Comments 

and Our Evaluation section of this report. 

Page 35 GAO-10-903 Climate Change
 

other agreements have not addressed other geoengineering approaches 

because they have not reached a similar stage of development. State 

officials said it was hard to imagine a single agreement appropriately 

covering geoengineering activities with all potential transboundary effects. 

State officials also said that while some countries have called for a broader 

inquiry into marine geoengineering more generally under the London 

Convention and the London Protocol, the parties deemed those calls 

premature at best. 

Legal experts and EPA officials we interviewed generally agreed that the 

federal government should take a coordinated, interagency approach to 

domestic geoengineering regulation. For example, the legal experts who 

spoke about domestic regulation generally agreed that the federal 

government should play a role in governing geoengineering research—

either by developing research norms and guidelines or applying existing 

regulations and guidelines. One expert noted that it was important that 

regulators stay abreast of research on the most mature technologies so 

that the regulatory framework would be in place prior to field 

experiments. Some experts and EPA officials also agreed that because 

there is a wide variety of geoengineering activities, research and regulation 

would fall under multiple agencies’ purview and expertise. For example, 

one expert said that there should be a coordinated interagency effort led 

by OSTP or USGCRP. Another said that the federal government should 

focus on a comprehensive policy for climate change, including 

geoengineering, and that that policy would determine what new 

regulations would be necessary to guide and govern research. EPA and 

State officials both said that agencies such as NOAA, NASA, and DOE 

should be involved in regulatory discussions due to their jurisdictional or 

scientific expertise. As an example, EPA officials noted that the 

Interagency Task Force on Carbon Capture and Storage, co-chaired by 

DOE and EPA, was created to propose a plan to overcome the barriers to 

widespread deployment of these technologies, which include geologic 

sequestration. The plan addresses, among other issues, how to coordinate 

existing administrative authorities and programs, legal barriers to 

deployment, and identifies areas where additional statutory authority may 

be necessary. 

Legal experts we interviewed generally agreed that governance for 

geoengineering research should be addressed separately from governance 

for deployment of geoengineering approaches. For example, experts said 

that discussions of governance of deployment were premature, and one 

expert cautioned that discussing deployment could raise the level of 

controversy surrounding the subject, leading to a general gridlock that 

Page 36 GAO-10-903 Climate Change
 

could disrupt discussions about research and lower interest in a 

coordinated and transparent approach. Both State and EPA officials cited 

the need for further research into geoengineering prior to engaging in 

discussions of domestic regulation or a governance framework at the 

international level. State officials said that, in practice, the United States 

and other countries have already effectively separated geoengineering 

research and deployment governance for ocean fertilization under the 

London Convention and London Protocol, because the parties decided 

that any ocean fertilization activities other than those for legitimate 

scientific research should not be allowed at this time. 

However, the legal experts we spoke with also agreed that some type of 

regulation of geoengineering field research was necessary in the near 

future, particularly for those approaches where large-scale experiments 

could have transboundary impacts. According to these experts, any 

framework governing research should include several elements, such as 

transparency, coordination, flexibility, a review process for experiments, 

the use of environmental risk thresholds, and an emphasis on modeling 

prior to field studies. A few legal experts said that these elements could 

start as voluntary norms and guidelines within the research community 

and then evolve into formal regulations prior to field trials. As one expert 

said, transparent decision-making and guidelines are necessary to ensure 

that research does not pose unacceptable risk to the environment. State 

officials said that, generally, the United States supports careful 

consideration of research implications rather than a full ban on research. 

In addition, they said that some geoengineering research could be fostered 

most effectively through international cooperation and coordination rather 

than governance, or that domestic regulation is more appropriate than 

international regulation. 

Legal experts and EPA and State officials cited other challenges related to 

geoengineering governance, particularly for those approaches with uneven 

or unintended environmental effects. For example, some legal experts said 

that controversy surrounding certain geoengineering approaches, as well 

as a lack of understanding and acceptance, could make domestic and 

international governance difficult. In addition, State officials said that if 

large-scale experiments or activities have unknown consequences or 

effects borne by nations other than the nation conducting the experiment 

or activity, this could risk undermining existing agreements on climate 

change strategies. Furthermore, legal experts and EPA officials agreed 

that liability for unintended consequences was an important issue that 

would need to be addressed. Specifically, one expert suggested that there 

should be a mechanism to compensate individuals or nations for damages 

Page 37 GAO-10-903 Climate Change
 

resulting from geoengineering activities. Moreover, some legal experts 

were concerned about the ability of parties to enforce certain international 

agreements related to geoengineering. 

Major scientific bodies such as the NRC and Royal Society have identified 

geoengineering as one of several potential tools to limit the impact and 

consequences of climate change. However, these bodies have stated that 

geoengineering is a potential complement to, rather than a substitute for, 

sharp reductions in greenhouse gas emissions. While the NRC and Royal 

Society have identified geoengineering as a potential tool, what role 

geoengineering might play in a domestic and international response 

strategy will likely be shaped by resolving unanswered scientific questions 

surrounding the technical feasibility, unintended consequences, 

effectiveness, cost, and risks associated with each approach. Answers to 

these questions will also inform the public debate concerning whether 

geoengineering is an acceptable response given the ethical and social 

implications of deliberate interventions in the earth’s climate system. The 

federal government is already engaging in research that could help address 

some of the uncertainties surrounding geoengineering and inform policy 

decisions about research priorities. While agencies identified about $100.9 

million in research funding relevant to geoengineering in fiscal years 2009 

and 2010, federal officials also said that a substantial portion of the 

existing federal climate change and earth science research could be 

relevant to understanding geoengineering—roughly $2 billion in requested 

budget authority for 2010 alone. However, because there is no coordinated 

federal geoengineering strategy, it is difficult to determine the extent of 

relevant research. At present, while some agencies are sharing information 

on two geoengineering approaches to inform negotiations relevant to 

international regulation of ocean dumping and address barriers to 

geological sequestration as a mitigation strategy, agencies generally are 

not collecting and sharing information more broadly on research relevant 

to other geoengineering approaches. Without a definition of 

geoengineering for agencies to use, and without coordination among 

agencies to identify the full extent of available research efforts relevant to 

geoengineering as well as to identify research priorities, policymakers and 

agency officials may lack sufficient information to leverage existing 

research resources to their full benefit. In turn, this lack of information 

may hinder policy decisions and governance at the domestic and 

international level. Even if policymakers decide that geoengineering 

should not be pursued domestically, knowledge of geoengineering 

approaches and their potential effects will be essential to inform 

Conclusions 

Page 38 GAO-10-903 Climate Change
 

international negotiations regarding other countries’ consideration of, or 

actions related to, geoengineering research and deployment. 

GAO recommends that the appropriate entities within the Executive Office 

of the President (EOP), such as the Office of Science and Technology 

Policy (OSTP), in consultation with relevant federal agencies, develop a 

clear, defined, and coordinated approach to geoengineering research in 

the context of a federal strategy to address climate change that (1) defines 

geoengineering for federal agencies; (2) leverages existing resources by 

having federal agencies collect information and coordinate federal 

research related to geoengineering in a transparent manner; and if the 

administration decides to establish a formal geoengineering research 

program, (3) sets clear research priorities to inform decision-making and 

future governance efforts. 

Recommendation 

We provided a draft of this report to the Office of Science and Technology 

Policy (OSTP) within the Executive Office of the President (EOP) for 

review and comment. OSTP also circulated the report to the 13 

participating USGCRP agencies. In response to the draft, OSTP, the 

Council on Environmental Quality, U.S. Department of Agriculture 

(USDA), Department of State (State), National Oceanic and Atmospheric 

Administration (NOAA), and National Science Foundation (NSF) neither 

agreed nor disagreed with our findings and recommendation; rather, they 

provided technical and other comments, which we incorporated as 

appropriate. General comments and our response are summarized below. 

Agency Comments 

and Our Evaluation 

In their comments, USDA, NSF, and OSTP raised various concerns about 

how geoengineering should be defined. For example, OSTP and USDA 

cited concerns that the definition used in this report is too broad because 

it overlaps with certain land-based practices, such as biological 

sequestration of CO2 in forests, that are considered to be emissions 

reduction practices—also referred to as mitigation. In particular, USDA 

commented that applying such a broad definition to USDA’s portfolio of 

research would lead to a great deal of confusion. In contrast, NSF raised 

concerns that the definition used in the report was not broad enough, and 

should include techniques that reduce CO2 emissions. For the purposes of 

this report, we used the Royal Society study’s definition and descriptions 

of geoengineering approaches because this study was the most 

comprehensive review of geoengineering science available at the time of 

our request. Other scientific organizations, such as the National Research 

Council (NRC), the American Meteorological Society, and the American 

Page 39 GAO-10-903 Climate Change
 

Geophysical Union have also either reported on or issued position 

statements regarding geoengineering, and used a similarly broad 

definition. However, as we note in the report, discussions about how to 

define geoengineering and what activities should be considered 

geoengineering remain active. Variations in agencies’ interpretation of our 

data request, as well as the comments noted above, support our 

recommendation that additional clarity and guidance regarding the federal 

approach to geoengineering is needed, and that further discussion of what 

types of activities should be included in a federal operational definition of 

geoengineering may be warranted. Accordingly, we recommended that the 

appropriate entities within the EOP consult with the relevant federal 

agencies to develop a clear, defined, and coordinated approach to 

geoengineering research in the context of a federal strategy to address 

climate change. 

Additionally, NOAA and NSF noted that because the global nature of 

climate change requires an international response, international 

coordination and collaboration would be important for geoengineering 

activities and oversight efforts. As we noted in our report, the applicability 

of international agreements to geoengineering remains unclear; however, 

parties to three agreements have issued decisions regarding the 

agreements’ applicability to ocean fertilization and sub-seabed geological 

sequestration. Furthermore, the legal experts we spoke with generally 

agreed that some type of regulation of geoengineering field research is 

necessary in the near future, particularly for those approaches where 

large-scale experiments could have transboundary impacts. According to 

these experts, any framework governing research should include several 

elements, such as transparency, coordination, flexibility, a review process 

for experiments, the use of environmental risk thresholds, and an 

emphasis on modeling prior to field studies. 

NOAA emphasized the importance of fully understanding unintended 

consequences and risks associated with geoengineering approaches. In 

particular, NOAA commented that sufficient resources should be directed 

specifically towards identifying possible unintended consequences and 

risks. As we note in the report, relevant studies indicate that there are 

additional environmental risks and trade-offs associated with both CDR 

and SRM approaches. Furthermore, our discussions with experts and 

review of relevant studies identified unintended consequences associated 

with geoengineering approaches as a key uncertainty requiring further 

study. 

Page 40 GAO-10-903 Climate Change
 

In addition to these comments, CEQ, OSTP, and the agencies provided 

technical changes and corrections which we incorporated where 

appropriate. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Office of Science and 

Technology Policy within the Executive Office of the President, and other 

interested parties. In addition, the report will be available at no charge on 

GAO’s Web site at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact Frank Rusco at (202) 512-3841 or ruscof@gao.gov, or John 

Stephenson at (202) 512-3841 or stephensonj@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in Appendix V. 

Sincerely yours, 

Frank Rusco 

Director, Natural Resources and Environment 

John B. Stephenson 

Director, Natural Resources and Environment 

Page 41 GAO-10-903 Climate Change
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

This report examines (1) the general state of the science regarding 

geoengineering approaches and their potential effects; (2) the extent to 

which the federal government is sponsoring or participating in 

geoengineering research or deployment; and (3) the views of legal experts 

and federal officials about the extent to which federal laws and 

international agreements apply to geoengineering activities, and 

associated challenges, if any, to geoengineering governance. 

To determine the general state of the science regarding geoengineering 

approaches and their potential effects, we summarized the results of semistructured interviews with scientific and policy experts as well as the 

findings from relevant literature. First, we identified 95 potential experts 

based on five criteria indicating recognition from their peers as 

geoengineering experts. These criteria included having (1) presented at 

the Asilomar International Conference on Climate Intervention 

Technologies, (2) presented at the geoengineering panels held at the 

American Association for the Advancement of Science 2010 Annual 

Meeting, (3) served as a witness at one of the three hearings on 

geoengineering held by the House Science and Technology Committee, (4) 

recommendations from other recognized experts that we had interviewed 

during our work for the March testimony for the committee,1

 and (5) 

participating in smaller panels or working groups that specifically focused 

on geoengineering. To identify the most active experts in the field, we 

scored the experts from the initial list based on their participation in the 

five previously noted activities. Based on this process, we selected the 10 

highest-scoring experts and contacted them for interviews. We selected 10 

experts to ensure we could collect a range of views from experts 

associated with academia, nongovernmental organizations, and 

government. To assess potential conflicts of interest, we asked the 10 

experts to submit a conflict of interest form. These forms included 

questions about potential financial or other interests that might bias an 

expert’s opinions related to the state of geoengineering science. We 

conducted a content analysis to summarize expert responses and grouped 

responses into overall themes. The views expressed by experts do not 

necessarily represent the views of GAO. Not all of the experts provided 

their views on all issues. In addition to gathering expert views, we selected 

and reviewed collaborative peer-reviewed studies that addressed 

geoengineering, such as the National Research Council’s Advancing the 

Science of Climate Change study as well as the Royal Society’s study 

 

1

GAO-10-546T

Page 42 GAO-10-903 Climate Change 
Appendix I: Scope and Methodology 

Geoengineering and the climate: Science, governance and uncertainty.

2

To corroborate the factual information provided to us by our experts, we 

utilized these collaborative reports as well as select articles from peerreviewed journals to support specific key details from the interviews. 

To determine the extent to which the federal government is sponsoring or 

participating in geoengineering research or deployment, we obtained and 

analyzed data on relevant activities from the 13 agencies participating in 

the U.S. Global Change Research Program (USGCRP) through July 2010.3

We selected these agencies because the USGCRP is the interagency entity 

that coordinates and integrates federal research on global environmental 

changes, such as climate change, and their implications for society. To 

help officials identify relevant activities, we provided them with a data 

collection instrument that defined geoengineering and described proposed 

geoengineering approaches, based on the Royal Society study (see 

appendix III). We used the Royal Society study definition and descriptions 

because it was the most comprehensive review of geoengineering science 

available at the time of our request. The data collection instrument also 

included some examples of potentially relevant activities based on our 

work for the March testimony for the committee. We then asked officials 

to identify federal activities during fiscal years 2009 and 2010 that were 

relevant to the definition and description we provided. Because the federal 

government does not have a formal policy on geoengineering that defines 

what activities constitute geoengineering or asks agencies to track this 

information, we relied on agency officials’ professional judgment to 

identify relevant activities. As part of their response, we requested 

information that included a description of the activity, the dates of the 

work, whether it was a grant or conducted within a government lab, and 

funds obligated. We analyzed the responses and removed 12 activities that 

did not appear related to geoengineering based on the definition we 

 

2

The Royal Society is the United Kingdom’s national academy of sciences. 

3

USGCRP-participating agencies are the Departments of Agriculture (USDA), Commerce, 

Defense (DOD), Energy (DOE), Interior, Health and Human Services, State, and 

Transportation; and the U.S. Agency for International Development, the Environmental 

Protection Agency (EPA), the National Aeronautics and Space Administration (NASA), the 

National Science Foundation (NSF), and the Smithsonian Institution. 

Page 43 GAO-10-903 Climate Change
Appendix I: Scope and Methodology 

provided.4 We then categorized the remaining activities into three broad 

types: (1) activities related to conventional carbon mitigation efforts that 

are directly applicable to a proposed geoengineering approach, although 

not designated as such; (2) activities related to improving basic scientific 

understanding of earth systems, processes, or technologies that could be 

applied generally to geoengineering; and (3) activities designed specifically 

to address a proposed geoengineering approach that does not overlap with 

a conventional carbon mitigation strategy. We sent the results of our 

analysis and categorization of agency-reported activities to each agency 

for their review and verification in July 2010. Specifically, we asked agency 

officials to ensure that the data were complete and accurate, and that our 

categorization of the data was appropriate. Each agency verified our 

analysis. In addition, we met with officials and staff from interagency 

bodies coordinating federal responses to climate change, including the 

Office of Science and Technology Policy (OSTP), Council on 

Environmental Quality (CEQ), and USGCRP, as well as the Department of 

Energy (DOE), which coordinates the Climate Change Technology 

Program—a multiagency research and development program for climate 

change technology. We assessed the reliability of the data and found the 

data to be sufficiently reliable for the purposes of this report. 

To determine the views of legal experts and federal officials about the 

extent to which federal laws and international agreements apply to 

geoengineering activities and identify governance challenges, if any, we 

summarized the results of our interviews with experts and federal officials 

as well as the findings from relevant literature. First, we identified 23 

potential experts based on three criteria indicating recognition from their 

peers as legal experts knowledgeable about geoengineering. These criteria 

included having (1) participated in panels or working groups that 

specifically focused on geoengineering, (2) recommendations from other 

experts that we had interviewed during our work for the March testimony 

for the committee, and (3) published one or more articles related to 

geoengineering. To identify the most active experts in the field, we scored 

 

4

These 12 activities were (1) investigating green roof behavior in dense urban 

environments, (2) developing membrane technology for hydrogen purification, (3) 

converting municipal solid wastes to liquid fuel, (4) developing technology for generating 

hydrocarbon fuels using solar energy and CO2 , (5) water desalinization project using solar 

energy, (6) internationally collaborating with China to foster emissions mitigation research, 

(7) developing technology to facilitate the conversion of methane gas to liquid fuel, and five 

activities to develop technologies related to biofuels. Based on their description, we 

determined that these 12 activities did not appear relevant to identified CDR or SRM 

approaches. 

Page 44 GAO-10-903 Climate Change
Appendix I: Scope and Methodology 

each expert from the initial list based on the three criteria noted above. 

Based on this process, we selected the 8 highest scoring experts and 

contacted them for interviews. We selected 8 experts because the scoring 

process created a natural break between the 8 highest scoring experts and 

the remaining experts. To assess potential conflicts of interest, we asked 

each expert to submit a conflict of interest form. These forms included 

questions about potential financial or other interests that might bias an 

expert’s opinions related to the applicability of federal laws and 

international agreements to geoengineering. We conducted a content 

analysis to summarize expert responses and grouped responses into 

overall themes. The views expressed by experts do not necessarily 

represent the views of GAO. Not all of the experts provided their views on 

all issues. We also met with federal officials from the Environmental 

Protection Agency (EPA) and the Department of State (State) to collect 

their views on the applicability of domestic laws and international 

agreements to geoengineering, and governance challenges, if any. In 

addition to gathering experts’ and federal officials’ views, we selected and 

reviewed collaborative reports that addressed geoengineering governance, 

such as the Royal Society’s study Geoengineering and the climate: 

Science, governance and uncertainty, and the United Kingdom House of 

Commons Science and Technology Committee report The Regulation of 

Geoengineering, among others.5

 To corroborate the legal information 

provided to us by our experts, we utilized these collaborative reports as 

well as select articles from relevant journals to support specific key details 

from the interviews. 

We conducted this performance audit from December 2009 through 

September 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 objectives. 

 

5

House of Commons Science and Technology Committee, The Regulation of 

Geoengineering: Fifth Report of Session 2009-10 (London, United Kingdom, Mar. 18, 

2010). 

Page 45 GAO-10-903 Climate Change
Appendix 

Selected

II: Geoengineering Experts 

 for This Review

Page 46 GAO-10-903 

Appendix II: Geoengineering Experts 

Selected for This Review 

We identified and selected scientific and policy experts to provide their 

views on the general state of the science regarding geoengineering 

approaches and their potential effects. We also identified and selected 

legal experts to provide their views on the applicability of federal laws and 

international agreements to geoengineering, and associated challenges, if 

any, to geoengineering governance. This appendix lists the experts we 

selected and contacted for interviews. In two cases, experts we contacted 

did not participate in our review, either due to schedule conflicts or 

because they did not respond to our request. 

Scientific and Policy 

Experts 

Scott Barrett, Columbia University 

Ken Caldeira, Carnegie Institution of Washington 

James Fleming, Colby College 

Michael MacCracken, Climate Institute 

Philip Rasch, Pacific Northwest National Laboratory, Department of 

Energy 

Alan Robock, Rutgers University 

John Shepherd, University of Southampton, United Kingdom (did not 

participate) 

David Keith, University of Calgary, Canada 

M. Granger Morgan, Carnegie Mellon University 

Margaret Leinen, Climate Response Fund 

Legal Experts Daniel Bodansky, Arizona State University 

Dale Jamieson, New York University 

Edward (Ted) Parson, University of Michigan (did not participate) 

David Victor, University of California-San Diego 

Catherine Redgwell, University College London, United Kingdom 

Albert Lin, University of California-Davis 

David Freestone, George Washington University 

Stephen Seidel, Pew Center on Global Climate Change 

 Climate Change 
Appendix III: Geoengineering Description Appendix III: Geoengineering Description Provided To USGCRP Agencies 

Provided To USGCRP Agencies 

To help federal officials identify relevant activities, we provided them with 

a data collection instrument that defined geoengineering and described 

proposed geoengineering approaches, as outlined below. The definition 

and descriptions were based on the Royal Society study—which was the 

most authoritative review of geoengineering at the time of our data 

request. This appendix reflects the language and more technical 

descriptions we provided to the agencies and, as such, will not be an exact 

match to the more generalized language used to describe these approaches 

in the background section of this report. We have provided additional 

explanations of some scientific terms in footnotes to the text. These 

footnotes were not part of the data collection instrument sent to the 

agencies. 

Definition of 

Geoengineering 

Deliberate, large-scale interventions in the earth’s climate system to 

diminish climate change or its impacts 

Description of 

Geoengineering 

Approaches 

Carbon dioxide removal approaches: 

1. Biological carbon removal / sequestration—enhancing the natural 

abilities of the earth’s biological systems to capture and sequester 

carbon 

Land-based examples: 

• Large-scale afforestation / reforestation / land-use changes to 

maximize carbon sequestration in soil or biomass 

• Biomass energy with carbon dioxide (CO2) capture and 

sequestration (BECS) 

• Biomass sequestration and burial / biochar 

Ocean-based examples: 

• Ocean fertilization with limiting nutrients, such as iron, to 

stimulate phytoplankton growth and increase CO2 removal from 

the atmosphere 

• Enhancing upwelling of nutrient-rich deep sea water to the 

surface to stimulate phytoplankton growth 

Page 47 GAO-10-903 Climate Change
Appendix III: Geoengineering Description 

Provided To USGCRP Agencies 

2. Physical carbon removal / sequestration—physically enhancing the 

natural abilities of the earth’s systems to capture and sequester carbon 

Land-based examples: 

• Capture of CO2 from ambient air (air capture) via industrial 

atmospheric CO2 scrubber devices and either using the 

captured CO2 or sequestering it in underground formations 

(Note: Although we are excluding funding for “carbon capture 

and storage” research and projects from this data call since it is 

an emissions reduction rather than geoengineering strategy, we 

are interested in capturing federal dollars directed towards 

research of the storage of CO2 in underground formations, 

because it is an important component of this particular 

geoengineering approach.) 

Ocean-based examples: 

• Altering ocean overturning circulation patterns to increase 

the rate that atmospheric CO2 is transferred to the deep sea 

3. Chemical carbon removal / sequestration—chemically enhancing the 

natural abilities of the earth’s systems to capture and sequester carbon 

Land-based examples: 

• Enhanced weathering of carbonate or silicate rocks to 

accelerate the absorption of CO2 on the earth’s surface or 

underground 

• Accelerating carbon sequestration in soils by spreading ground 

silicate minerals on fields 

• Pumping reactant CO2 gas into underground olivine and basalt 

formations to form carbonates in-situ 

Ocean-based examples: 

• Enhancing the alkalinity of the ocean by grinding, dispersing, 

and dissolving limestone, silicates, or calcium hydroxide 

Page 48 GAO-10-903 Climate Change
Appendix III: Geoengineering Description 

Provided To USGCRP Agencies 

Solar radiation management approaches: 

1. Increasing planet surface albedo1

—increasing the albedo of the planet 

by making the surface of the planet more reflective 

Examples: 

• Brightening buildings and painting roofs white 

• Planting lands with more reflective vegetation or engineering 

more reflective variants of existing vegetation 

• Increasing reflectivity of desert regions 

• Increasing reflectivity of oceanic regions 

2. Cloud albedo enhancement—increasing the planetary albedo by 

producing additional cloud cover and thickening clouds over oceanic 

regions 

Example: 

• Brightening marine clouds by spraying seawater to increase the 

number of cloud condensation nuclei2

 available 

3. Stratospheric aerosol injection—increasing the albedo of the planet by 

injecting reflective aerosol particles into the atmosphere 

Examples: 

• Injecting sulfate aerosols into the stratosphere to reflect 

incoming solar radiation 

 

1

Albedo is the fraction of solar radiation reflected by a surface or object, often expressed as 

a percentage. Snow-covered surfaces have a high albedo, the surface albedo of soils ranges 

from high to low, and vegetation-covered surfaces and oceans have a low albedo. The 

earth’s planetary albedo varies mainly through varying cloudiness, snow, ice, leaf area, and 

land cover changes. 

2

Cloud condensation nuclei are small particles in the air that become surfaces on which 

water vapor can condense and form cloud droplets. Sources of cloud condensation nuclei 

can be both natural and human-caused. Natural sources of cloud condensation nuclei 

include volcanic dust, sea spray salt, and bacteria. Humans also release unnatural 

chemicals into the air from the burning of fossil fuels and from industrial sources. 

Page 49 GAO-10-903 Climate Change
Appendix III: Geoengineering Description 

Provided To USGCRP Agencies 

• Injecting other reflective aerosols into the stratosphere to 

reflect incoming solar radiation 

4. Space-based techniques for reducing incoming solar radiation—

reducing the amount of solar radiation that reaches the planet or 

adjusting the nature of that radiation to a type that is less likely to be 

absorbed by the earth’s climate system 

Examples: 

• Placing a large refracting lens at the L1 orbit position3

• Launching trillions of small reflecting disks into near-earth orbit 

Other greenhouse gas removal approaches: 

5. Techniques to remove other greenhouse gases such as methane, 

nitrous oxide, chlorofluorocarbons, or others from the atmosphere 

 

3

The L1 orbit position is the point between the earth and sun where the gravitational 

attractions of the two bodies are equal. 

Page 50 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on Appendix IV: Data from USGCRP Agencies Geoengineering-Related Activities 

on Geoengineering-Related Activities 

In response to our data collection instrument, the 13 agencies participating 

in the USGCRP reported the following research activities relevant to 

geoengineering. Our request was limited to activities funded during fiscal 

years 2009 and 2010; however, in some cases, reported activities were 

initiated prior to fiscal year 2009 and continued beyond fiscal year 2010, as 

noted in the “Dates of research” column in tables 5, 6, and 7. To be 

consistent with the tables in the report, the activities are organized by 

agency and geoengineering approach. According to agency officials, none 

of the activities listed below received funding in the American Recovery 

and Reinvestment Act of 2009.1

 The Departments of Health and Human 

Services and State, as well as the U.S. Agency for International 

Development, the National Aeronautics and Space Administration, and the 

Smithsonian Institution, all reported no relevant activities during fiscal 

years 2009 and 2010. 

Table 5: Reported Mitigation-Related Research Relevant to Geoengineering, by USGCRP Agency and Related Geoengineering 

Approach, Fiscal Years 2009 and 2010 

(In dollars) 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

Department of 

Agriculture 

(USDA) 

Research to 

quantify the effects 

of amending soils 

with biochar on 

crop productivity, 

soil quality, carbon 

sequestration, and 

water quality 

2008-2011 Nonfunded 

cooperative 

agreement 

Agricultural 

Research Service 

$2,800,000 2010 CDR - biological 

carbon removal/ 

sequestration 

Research to 

evaluate soil 

carbon 

sequestration in 

existing and 

alternative 

agricultural 

systems 

2007-2010 In-house Agricultural 

Research Service 

11,100,000 2010 CDR - biological 

carbon removal/ 

sequestration 

Department of 

Energy (DOE) 

Study investigating 

large-scale 

biological removal/ 

sequestration of 

carbon dioxide 

2009-2010 In-house Oak Ridge 

National 

Laboratory 

350,000 2010 CDR - biological 

carbon removal/ 

sequestration 

 

1

Pub. L. No. 111-5 (2009). 

Page 51 GAO-10-903 Climate Change 
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

DOE Research to 

identify, 

understand, and 

predict the 

fundamental 

physical, chemical, 

biological, and 

genetic processes 

controlling carbon 

sequestration in 

terrestrial 

ecosystems 

2000-

present 

Mixed — grant 

and national 

laboratories 

Office of Science 

(Biological and 

Environmental 

Research) 

4,728,000 2010 CDR - biological 

carbon removal/ 

sequestration 

Advanced carbon 

sequestration 

systems 

2009 In-house Savannah River 

National 

Laboratory 

50,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Regional 

Partnership 

Program activities 

related to 

geological 

sequestration of 

carbon dioxide 

2010 Grant Work performed by 

Savannah River 

National 

Laboratory on 

behalf of the Office 

of Fossil Energy 

139,000 2010 CDR - physical 

carbon removal/ 

sequestration 

Regional 

Partnership 

Program activities 

related to 

geological 

sequestration of 

carbon dioxide 

2009-2010 In-house Los Alamos 

National 

Laboratory 

770,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Measurement and 900,000 2009

detection of carbon 

dioxide at 

geological 

sequestration sites 

2008-2010 In-house Los Alamos 

National 

Laboratory 900,000 2010

CDR - physical 

carbon removal/ 

sequestration 

Modeling of 2,000,000 2009

geological 

sequestration of 

carbon dioxide 

2008-2010 In-house Los Alamos 

National 

Laboratory 2,000,000 2010

CDR - physical 

carbon removal/ 

sequestration 

Page 52 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

Department of the 

Interior 

An assessment to 

compare existing 

biological 

sequestration 

resources to 

estimates of 

hypothetical 

biological 

sequestration in 

potential or 

historical 

vegetation and 

soils 

2010 In-house U.S. Geological 

Survey Office of 

Global Change 

Programs 

290,000 2010 CDR - biological 

carbon removal/ 

sequestration 

A range of projects 

related to carbon 

dioxide balance, 

sequestration, and 

fluxes in soils and 

ecosystems, 

including 

mechanistic 

understanding, 

regionalization of 

site data, and 

modeling 

2009-2012 In-house U.S. Geological 

Survey Office of 

Global Change 

Programs 

2,362,408 2010 CDR - biological 

carbon removal/ 

sequestration 

Methodology 

development for a 

national 

assessment of 

biological 

sequestration 

resources that 

remove and store 

carbon dioxide in 

vegetation, soils, 

and sediments 

2009-2012 In-house U.S. Geological 

Survey Office of 

Global Change 

Programs 

5,000,000 2010 CDR - biological 

carbon removal/ 

sequestration 

Development of 

best management 

practices for 

geologic 

sequestration of 

carbon dioxide in 

sub-seabed 

formations 

2010-2013 Broad agency 

announcement 

Bureau of Ocean 

Energy 

Management, 

Regulation, and 

Enforcement 

250,000 - 

500,000 

2010 CDR - physical 

carbon removal/ 

sequestration 

Page 53 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

Interior Methodology 

development for a 

national 

assessment of 

geological 

sequestration 

resources for 

storage of carbon 

dioxide in oil and 

gas reservoirs and 

saline formations 

2009-2012 In-house U.S. Geological 

Survey Office of 

Global Change 

Programs 

5,000,000 2010 CDR - physical 

carbon removal/ 

sequestration 

Department of 150,000 2009

Transportation 

Pilot program to 

determine 

economic and 

policy implications 

of biological carbon 

sequestration 

(carbon offsets) in 

highway right-ofway 

2008-2011 In-house Federal Highway 

Administration 100,000 2010

CDR - biological 

carbon removal/ 

sequestration 

Environmental 

Protection Agency 

(EPA) 

Research, in 

coordination with 

USDA and other 

land management 

agencies, to 

address the 

environmental 

effects of biological 

sequestration 

(carbon offsets) 

2009-2011 In-house Office of Research 

and Development 

300,000c 2010 CDR - biological 

carbon removal/ 

sequestration 

Research to 

understand how 

various carbon 

dioxide capture 

technologies could 

impact pollution 

control systems 

and their effluent 

streams, which 

could improve 

understanding of 

how contaminants 

present could 

adversely impact 

transport, injection, 

and long-term 

storage of carbon 

dioxide 

2010-2011 In-house Office of Research 

and Development 

500,000c

2010 CDR - physical 

carbon removal/ 

sequestration 

Page 54 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

1,900,000c EPA Research to 2009

assess the risks of 

underground 

injection of carbon 

dioxide 

2009-2011 In-house Office of Research 

and Development 2,900,000c

2010

CDR - physical 

carbon removal/ 

sequestration 

4,700,000cGrants to research 2009

the design, 

modeling, and 

monitoring of the 

geological 

sequestration of 

carbon dioxide to 

safeguard sources 

of drinking water 

2009-2011 Grant Office of Research 

and Development 1,000,000c 2010

CDR - physical 

carbon removal/ 

sequestration 

National Science 71,385 2009

Foundation (NSF) 

Ten year regional 

field experiment to 

improve 

understanding of 

biological 

sequestration of 

carbon dioxide in 

northern 

hemisphere 

forests; the 

research will 

quantify the 

amounts of carbon 

stored in overstory 

trees, forest floor, 

and soil over the 

next decade 

2008-2012 Grant (only 2 of 5 

years funding 

shown) 

Division of 

Environmental 

Biology 70,790 2010

CDR - biological 

carbon removal/ 

sequestration 

Research to 

determine whether 

waste materials 

that contain 

significant amounts 

of alkaline minerals 

can safely and 

permanently store 

carbon dioxide via 

the carbonation 

process 

2009 Grant Directorate of 

Engineering 

33,793 2009 CDR - chemical 

carbon removal/ 

sequestration 

Page 55 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

NSF Research to 

develop safe and 

permanent 

sequestration of 

carbon dioxide 

using techniques 

that mimic natural 

rock weathering 

processes, such as 

carbonation 

2009-2011 Grant Directorate of 

Engineering 

300,033 2009 CDR - chemical 

carbon removal/ 

sequestration 

Research to evolve 99,738 2009

an economically 

viable coal and 

biomass fed 

energy plant that 

generates 

electricity while 

capturing a 

significant portion 

of carbon dioxide 

and coproduces 

hydrogen for future 

fuel cell 

applications 

2009-2010 Grant Directorate of 

Engineering 99,647 2010

CDR - physical 

carbon removal/ 

sequestration 

Numerical 

investigation into 

aquifer carbon 

sequestration 

efficiency and 

potential leakage 

subsequent to 

injection of carbon 

dioxide 

2009-2010 Grant Directorate of 

Geosciences 

262,416 2009 CDR - physical 

carbon removal/ 

sequestration 

Modeling project to 

evaluate the longterm sequestration 

of carbon dioxide 

in saline aquifers 

2008-2011 Grant Directorate of 

Mathematical and 

Physical Sciences 

350,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Research into 

methods to 

enhance geological 

sequestration of 

carbon dioxide 

using 

hydrofracturing 

techniques 

2010-2012 Grant (pending) Directorate of 

Geosciences 

374,600 2010 CDR - physical 

carbon removal/ 

sequestration 

Page 56 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research (grant 

or in-house)a

Sponsoring 

federal program 

or laboratory 

Reported 

fundingb

Fiscal 

year

Related 

geoengineering 

approach 

NSF Demonstration 

project of a novel 

low cost and low 

energy-consuming 

capture technology 

to remove carbon 

dioxide from flue 

gas of postcombustion coalfired power plants 

2009-2010 Grant Directorate of 

Engineering 

499,998 2009 CDR - physical 

carbon removal/ 

sequestration 

1,000,000dProject to develop 2009

a deep 

underground 

laboratory for 

carbon dioxide 

sequestration 

experimentation, 

as well as several 

modeling projects 

that are exploring 

issues such as the 

impacts of 

underground fluid 

injection and 

uncertainty in 

sequestration 

models 

2009 - 2012 A set of 

collaborative 

grants and an 

interagency 

transfer 

Directorate of 

Engineering 1,000,000d 2010

CDR - physical 

carbon removal/ 

sequestration 

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. 

a

For the purposes of this table, grant refers to an award provided to an external institution, and inhouse refers to work performed by the reporting agency. 

b

Unless otherwise noted, reported funding represents dollars obligated to the activity for the noted 

fiscal years as reported by federal agencies. 

c

Reported funding represents enacted budget authority rather than obligations. 

d

For this project, NSF reported funded obligations of $2,000,000 during fiscal years 2009 and 2010, 

with approximately $1,000,000 obligated during each of these years. 

Page 57 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Table 6: Reported Fundamental Scientific Research Activities Relevant to Geoengineering, by USGCRP Agency and Related 

Geoengineering Approach, Fiscal Years 2009 and 2010 

(In dollars) 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

Department of $12,900,000 2009 

Commerce 

(Commerce) 

Subcontinental 

scale detection of 

contributions of 

biological emissions 

and sequestration of 

greenhouse gases 

on atmospheric 

composition 

Global 

emphasis 

since 1968; 

North 

American 

focus 1990 - 

present 

Long-term 

monitoring — 

mainly inhouse; some 

grants 

National Oceanic 

and Atmospheric 

Administration’s 

(NOAA) Office of 

Atmospheric and 

Oceanic Research 

12,900,000 2010 

CDR - biological 

carbon removal/ 

sequestration 

Comprehensive 7,920,000 2009 

Earth System 

Modeling to support 

research on the 

carbon cycle, 

climate system 

processes, and 

interfaces between 

atmospheric 

chemistry and 

climate 

2000-

present 

In-house NOAA’s 

Geophysical Fluid 

Dynamics 

Laboratory 

7,920,000 2010 

CDR - general, SRM 

- general 

Department of 

Defense 

Seed grant to study 

methods of 

removing methane 

and nitrous oxide 

greenhouse gases 

from the 

atmosphere using 

enzymes 

2010 Grant Defense Advanced 

Research Projects 

Agency 

250,000 2010 Other greenhouse 

gas removal 

approaches 

National 

Science 

Foundation 

(NSF) 

Research to develop 

and commercialize a 

new catalyst to 

improve the process 

for removing tar from 

gasified biomass; 

this research will 

improve the 

efficiency and 

reduce cost 

associated with the 

production of energy, 

liquid fuels, or other 

chemicals from 

gasified biomass 

2009-2011 Grant Directorate of 

Engineering 

508,000 2009 CDR - biological 

carbon removal/ 

sequestration 

Page 58 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

NSF Research to 

examine a new 

porous material for 

use in separating 

carbon dioxide from 

mixtures with 

carbon monoxide 

and methane 

2010 Grant Directorate of 

Engineering 

75,381 2010 CDR - physical 

carbon removal/ 

sequestration 

Research to design 79,626 2009 

and synthesize 

next-generation 

multifunctional, 

porous materials for 

the separation of 

carbon dioxide and 

methane, among 

other applications 

2009-2013 Grant (2 of 5 

years funding 

shown) 

Directorate of 

Engineering 75,723 2010 

CDR - physical 

carbon removal/ 

sequestration 

Research to 85,485 2009 

improve gas 

separation 

membranes 

2009-2013 Grant (2 of 5 

years funding 

shown) 

Directorate of 

Engineering 78,285 2010 

CDR - physical 

carbon removal/ 

sequestration 

Research to test 

methods to 

electrochemically 

reduce oxygen and 

atmospheric carbon 

dioxide to carbonate 

for various 

applications, 

including carbon 

sequestration 

2010 Grant Directorate of 

Engineering 

97,721 2010 CDR - physical 

carbon removal/ 

sequestration 

Project to 

commercialize a 

new gas separation 

product that 

separates the 

components of air to 

increase its oxygen 

content for natural 

gas and carbon 

dioxide 

sequestration 

applications 

2009 Grant Directorate of 

Engineering 

149,996 2009 CDR - physical 

carbon removal/ 

sequestration 

Page 59 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

NSF A technology 

transfer project to 

test the feasibility of 

producing 

lightweight building 

materials from fly 

ash using water 

supersaturated with 

air and carbon 

dioxide, which will 

sequester carbon 

dioxide 

2009 Grant Directorate of 

Engineering 

150,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Research into 204,120 2009 

methane and 

carbon dioxide 

hydrate systems to 

study in part, the 

potential for gas 

storage in artificial 

hydrate form 

2009-2011 Grant (2 of 3

years funding 

shown) 

Directorate of 

Engineering 50,000 2010 

CDR - physical 

carbon removal/ 

sequestration 

Research to design, 

fabricate, and test 

mixed matrix 

membranes for gas 

separations, 

including carbon 

dioxide, methane, 

nitrogen, and 

oxygen 

2009-2011 Grant Directorate of 

Engineering 

299,999 2009 CDR - physical 

carbon removal/ 

sequestration 

Research into gas 

separation 

membranes for 

carbon dioxide and 

methane, for natural 

gas applications 

2009-2010 Grant Directorate of 

Engineering 

330,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Research to 

quantify different 

types of gas 

transport in 

materials made to 

separate gases, 

such as carbon 

dioxide, methane, 

and nitrogen 

2009-2013 Grant Directorate of 

Engineering 

400,000 2009 CDR - physical 

carbon removal/ 

sequestration 

Page 60 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency 

Activity 

description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

NSF Research into gas 

separation 

membranes for 

separating 

hydrocarbons from 

methane and 

hydrogen, for 

natural gas 

applications 

2010 Grant Directorate of 

Engineering 

150,000 2010 Other greenhouse 

gas removal 

approaches 

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. 

a

For the purposes of this table, grant refers to an award provided to an external institution, and inhouse refers to work performed by the reporting agency. 

b

Unless otherwise noted, reported funding represents dollars obligated to the activity for the noted 

fiscal years as reported by federal agencies. 

Page 61 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Table 7: Reported Direct Geoengineering Research by USGCRP Agency and Related Geoengineering Approach, Fiscal Years 

2009 and 2010 

(In dollars) 

Department/ 

Agency Activity description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal 

program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

Department of 

Commerce 

(Commerce) 

Research examining the 

possible implications of 

aerosol-based 

geoengineering 

proposals for the peak 

power output of large 

solar-power-generating 

plants 

2008-2009 In-house NOAA’s Earth 

System 

Research 

Laboratory, 

Chemical 

Sciences 

Division 

$45,000 2009 SRM - 

stratospheric 

aerosol injection 

Research examining the 

possible climate 

implications (beyond 

temperature) of 

geoengineering 

proposals that limit 

incoming solar radiation 

2008-2009 In-house NOAA’s Earth 

System 

Research 

Laboratory, 

Chemical 

Sciences 

Division 

25,000 2009 SRM - multiple 

approaches 

Department of 

Energy (DOE) 

Contribution to American 

Physical Society’s review 

of the status of 

technologies and 

concepts to physically 

remove carbon dioxide 

from the air (direct air 

capture) 

2009-2010 Grant Office of 

Policy, Climate 

Change 

Technology 

Program, and 

Office of Fossil 

Energy 

50,000 2009 CDR - physical 

carbon removal/

sequestration 

Study to perform systems 

analysis and cost 

estimates for large-scale, 

direct, physical capture of 

carbon dioxide from the 

air (direct air capture) 

2009 In-house Lawrence 

Livermore 

National 

Laboratory 

243,000 2009 CDR - physical 

carbon removal/

sequestration 

Study investigating the 100,000 2009 

unintended 

consequences of climate 

change response 

strategies, including 

geoengineering 

2009-2010 In-house Sandia 

National 

Laboratory 70,000 2010 

Multiple CDR 

and SRM 

approaches 

Page 62 GAO-10-903 Climate Change
Appendix IV: Data from USGCRP Agencies on 

Geoengineering-Related Activities 

Department/ 

Agency Activity description 

Dates of 

research 

Type of 

research 

(grant or inhouse)a

Sponsoring 

federal 

program or 

laboratory 

Reported 

fundingb

Fiscal 

year 

Related 

geoengineering 

approach 

DOE Modeling studies related 

to two types of SRM: 

cloud-brightening and 

stratospheric aerosol 

injection 

2009-2010 Grant Work 

performed by 

Pacific 

Northwest 

National 

Laboratory on 

behalf of 

University of 

Calgary, 

Canada 

266,000 Total 

funding 

2009 

and 

2010 

SRM - cloud 

albedo 

enhancement, 

stratospheric 

aerosols 

National 

Science 

Foundation 

(NSF) 

Research examining the 

effect of iron to carbon 

ratios in food on marine 

copepods, which will 

shed light on potential 

environmental impacts of 

ocean iron fertilization 

2010-2013 Grant Directorate of 

Geosciences 

473,904 2010 CDR - biological 

carbon removal/

sequestration 

Collaborative modeling 221,558 2009 

research project studying 

the impacts of plausible 

scenarios of 

stratospheric aerosol 

injection and a spacebased SRM method 

2008-2011 Grant Directorate of 

Geosciences 183,265 2010 

SRM - 

stratospheric 

aerosol 

injection, spacebased 

techniques 

Research investigating 

the moral challenges of 

solar radiation 

management 

2010-2011 Grant Directorate of 

Social, 

Behavioral, 

and Economic 

Sciences 

208,551 2010 SRM - multiple 

approaches 

Source: GAO analysis of the agencies’ responses to our data collection instrument, which provided a definition and description of 

geoengineering to officials. The data collection instrument also included some examples of potentially relevant activities based on our 

work for our March testimony on geoengineering. 

Note: We collected data on agency activities through July 2010. Accordingly, additional activities 

relevant to geoengineering may receive funding during fiscal year 2010. 

a

For the purposes of this table, grant refers to an award provided to an external institution, and inhouse refers to work performed by the reporting agency. 

b

Unless otherwise noted, reported funding represents dollars obligated to the activity for the noted 

fiscal years as reported by federal agencies. 

Page 63 GAO-10-903 Climate Change
A

A

ppendix V: GAO Contacts and Staff

cknowledgments 

Page 64 GAO-10-903 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

Frank Rusco at (202) 512-3841 or ruscof@gao.gov, and John Stephenson at 

(202) 512-3841 or stephensonj@gao.gov

In addition to the contacts named above, Tim Minelli (Assistant Director), 

Ana Ivelisse Aviles, Judith Droitcour, Lorraine Ettaro, Cindy Gilbert, Eli 

Lewine, Madhav Panwar, Timothy Persons, Katherine Raheb, Benjamin 

Shouse, Jeanette Soares, Ardith Spence, Kiki Theodoropoulos, J. D. 

Thompson, and Lisa Van Arsdale made key contributions to this report. 

 Climate Change 

GAO Contacts 

Staff 

Acknowledgments 

(361158) 
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