Climate Change: A Coordinated Strategy Could Focus Federal Geoengineering Research and Inform Governance Efforts
Published: 2010-09-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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) 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. 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.
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. or limit the negative effects of climate change—also known as mitigation.  However, many countries with significant greenhouse gas emissions,  including the United States, China, and India, have not committed to  binding limits on CO emissions, and atmospheric CO 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. , 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 CO equivalent. 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. 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 CO For example, one approach to CDR  would be to enhance the biological processes for removal and storage of  CO 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. 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 CO  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 CO. 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. 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.
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  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 peer- reviewed 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 USGCRP- participating agencies, and asked them to identify relevant federal  activities during fiscal years 2009 and 2010 that fit these descriptions.  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.  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. 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, 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.
subsections: section_title: Background
paragraphs: 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 CO 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  collapse of the West Antarctic Ice Sheet—which would lead to a large and  sudden contribution to sea level rise. 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 CO 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 CO-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 CO is transported to the deep ocean as detritus.
Enhanced removal by chemical processes. Ocean-based enhanced  weathering— accelerating chemical reactions between certain minerals  and CO to a nongaseous state. Methods  include adding chemically reactive alkaline minerals, such as limestone  or silicates, to the ocean to increase the ocean’s natural ability to  absorb and store COExamples of land-based CDR approaches include:    Physical removal by industrial processes. Direct air capture— technology-based processing of ambient air to remove CO from the  atmosphere. The resulting stream of pure CO  Biomass energy with CO 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 CO, which convert the CO into a geological formation of reactive minerals.
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 surfaces through activities such as painting roofs white,  planting more reflective crops or other vegetation, or covering desert  or ocean surfaces with reflective materials.
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 risk- free 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, ocean- based 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 CO could have substantial impacts on  regional precipitation—potentially leading to reductions that could create  droughts in some areas. 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  deployment of an SRM approach would need to be maintained over  decades and possibly centuries or longer.
section_title: Geoengineering Is an Emerging Field with Major Uncertainties, Including Potential Effects
paragraphs: 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.
subsections: section_title: More Relevant Modeling Studies and Experiments Have Focused on CDR than on SRM
paragraphs: : Update  and Recommendations (Paris: 2007). energy requirements, and scalability. 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 CO on a global scale is low.
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 CO 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. 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.
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. 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. 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.
section_title: Experts and Relevant Studies Identified Major Uncertainties that Merit Further Investigation
paragraphs: 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  CDR approaches, such as ocean fertilization and some land-based  methods, to significantly reduce atmospheric concentrations of CO on  a global scale, or sequester CO  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.
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.
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 global- scale 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 CO 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. Additionally, one expert raised  concerns over the potential economic costs associated with unintended  impacts from deploying SRM. 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.
section_title: 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
paragraphs: 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.
subsections: section_title: Most Federal Research Activities Focused on Mitigation or Basic Science, but a Few Specifically Addressed Geoengineering
paragraphs: 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. 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 CO, 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 CO 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  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 CO. 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.
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.
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 CO 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.
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.
section_title: Existing Federal Efforts Are Not Part of a Coordinated Geoengineering Research Strategy, Making It Difficult to Determine the Full Extent of Relevant Research
paragraphs: 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  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 CO  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 CO  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. 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. Similarly, several of the experts  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 adaptation and global food  security, 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 technology- based research. 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  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  CO into deep sub-seabed geological formations as part of a working group  for international regulation of the ocean, 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.
section_title: The Extent to Which Existing Federal Laws and International Agreements Apply to Geoengineering Is Unclear, and Experts and Officials Identified Governance Challenges
paragraphs: 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.  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  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.
subsections: section_title: EPA Officials Stated the Applicability of Existing Laws is Unclear and They Have Not Fully Assessed Their Applicability Because of Limited Geoengineering Activity
paragraphs: 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 CO  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 CO 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 CO 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  without a permit from EPA. EPA officials said that certain sub-seabed  geological sequestration of CO  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 CO and is currently considering a proposed rule to  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. 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 CO  streams could contain hazardous substances, thus subjecting the  parties injecting the CO 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  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.
section_title: Experts and Federal Officials Identified International Agreements That Could Apply to Geoengineering, but Their Applicability Is Largely Uncertain
paragraphs: 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, 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  countries that have become parties to the particular agreement.  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.
Almost all the legal experts and State officials we spoke with noted that, of  all the potential geoengineering approaches, sub-seabed geological  sequestration of CO  Ocean fertilization. The parties to the London Convention and the  London Protocol 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 Diversity  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, CO  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, CO stream consists  overwhelmingly of CO(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 CO streams for disposal  in certain circumstances. The parties are developing specific guidance  for these exports and issues related to the management of  transboundary movement of CO 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.
section_title: Experts and Federal Officials Identified Governance Challenges, but Their Views Varied on the Most Effective Governance Approach
paragraphs: 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,  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. 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  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  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  resulting from geoengineering activities. Moreover, some legal experts  were concerned about the ability of parties to enforce certain international  agreements related to geoengineering.
section_title: Conclusions
paragraphs: 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  international negotiations regarding other countries’ consideration of, or  actions related to, geoengineering research and deployment.
section_title: Recommendation
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
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 CO 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  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.
In addition to these comments, CEQ, OSTP, and the agencies provided  technical changes and corrections which we incorporated where  appropriate.
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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.
section_title: Appendix I: Scope and Methodology
paragraphs: 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 semi- structured 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, 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  Geoengineering and the climate: Science, governance and uncertainty.
The Royal Society is the United Kingdom’s national academy of sciences. provided. 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. , (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. 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. 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.
section_title: Appendix II: Geoengineering Experts Selected for This Review
paragraphs: 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.
subsections: section_title: Scientific and Policy Experts
section_title: Legal Experts
section_title: Appendix III: Geoengineering Description Provided To USGCRP Agencies
paragraphs: 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.
subsections: section_title: Definition of Geoengineering
section_title: Description of Geoengineering Approaches
paragraphs: 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.
section_title: Appendix IV: Data from USGCRP Agencies on Geoengineering-Related Activities
paragraphs: 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. 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.
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: 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.