Climate Change: Preliminary Observations on Geoengineering Science, Federal Efforts, and Governance Issues
Published: 2010-03-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Key scientific assessments have underscored the urgency of reducing emissions of carbon dioxide to help mitigate potentially negative effects of climate change; however, many countries with significant greenhouse gas emissions, including the United States, China, and India, have not committed to binding limits on emissions to date, and carbon dioxide levels continue to rise. Recently, some policymakers have raised questions about geoengineering--large-scale deliberate interventions in the earth's climate system to diminish climate change or its potential impacts--and its role in a broader strategy of mitigating and adapting to climate change. Most geoengineering proposals fall into two approaches: solar radiation management (SRM), which offset temperature increases by reflecting a small percentage of the sun's light back into space, and carbon dioxide removal (CDR), which address the root cause of climate change by removing carbon dioxide from the atmosphere. Today's testimony focuses on GAO's preliminary observations on (1) the state of the science regarding geoengineering approaches and their effects, (2) federal involvement in geoengineering activities, and (3) the views of experts and federal officials about the extent to which federal laws and international agreements apply to geoengineering. To address these issues, GAO reviewed scientific literature and interviewed federal officials and scientific and legal experts.
section_title: What GAO Found
paragraphs: Substantial uncertainties remain on the efficacy and potential environmental impacts of proposed geoengineering approaches, because geoengineering research and field experiments to date have been limited. GAO's review of relevant studies and interviews with experts to date found that relatively few modeling studies for SRM approaches have been published, and only limited small-scale testing--primarily of carbon storage activities relevant to CDR approaches--have been performed. Consequently, the experts GAO spoke with stated that a sustained effort of coordinated and cooperative research would be needed to determine whether proposed geoengineering approaches would be effective at a scale necessary to reduce temperatures and to attempt to anticipate and respond to potential unintended consequences--including the political, ethical, and economic issues surrounding the use of certain approaches. Specifically, just as the effects of climate change in general are expected to vary by region, so would the effects of certain large-scale geoengineering efforts, therefore, potentially creating relative winners and losers and thus sowing the seeds of future conflict. Federal agencies have funded some research and small demonstration projects of certain technologies related to proposed geoengineering approaches; but these efforts have been limited, fragmented, and not coordinated as part of a federal geoengineering strategy. Officials from interagency bodies coordinating the federal response to climate change stated that their offices (1) have not developed a coordinated research strategy, (2) do not have a position on geoengineering, and (3) do not believe is it necessary to coordinate efforts due to the limited federal investment to date. In the event that the federal government decides to expand geoengineering research, GAO's interviews with experts suggest that transparency and international cooperation are key factors for any geoengineering research that poses a risk of environmental impacts beyond our borders. Further, GAO's past work indicates that a comprehensive assessment of costs and benefits that includes all relevant risks and uncertainties is a key component in strategic planning for technology-based research. According to legal experts and federal agency officials, some existing federal laws and international agreements could apply to geoengineering research and deployment. However, some federal agencies have not yet assessed their authority to regulate geoengineering, and those that have done so have identified regulatory gaps. Although legal experts have identified some relevant international agreements and parties to two agreements have taken actions to address geoengineering, it is not certain whether and how other agreements would apply. Most scientific and legal experts GAO spoke with distinguished the governance of research from governance of deployment and noted that governance of geoengineering research with transboundary impacts, such as SRM approaches, should be addressed at the international level in a transparent manner and in consultation with the scientific community. However, the experts' views on the details of governance varied.

section_title: Letter
paragraphs: I am pleased to be here today to participate in the committee’s hearing on  geoengineering. Changes in the earth’s climate attributable to increased  concentrations of greenhouse gases may have significant environmental  and economic impacts in the United States and internationally. These  impacts are expected to vary across regions, countries, and economic  sectors. Among other potential impacts, climate change could threaten  coastal areas with rising sea levels, alter agricultural productivity, and  increase the intensity and frequency of floods and tropical storms.  Furthermore, the National Academies of Science (NAS) has reported that  human alterations of the climate system may increase the possibility of  large and abrupt regional or global climatic events, and that because  abrupt climate changes of the past have not yet been fully explained,  future abrupt changes cannot be predicted with any confidence, and  climate surprises are to be expected.
Key scientific assessments have underscored the urgency of reducing  emissions of carbon dioxide to help mitigate the negative effects of  climate change; however, many countries with significant greenhouse gas  emissions including the United States, China, and India, have not  committed to binding limits on emissions to date, and carbon dioxide  levels continue to rise. In addition to mitigation, we have reported that  policies to adapt to climate change could help reduce the vulnerability of  countries and regions to potentially adverse impacts and may be viewed as  part of a risk-management strategy for responding to climate change. In  particular, we reported that federal entities such as the President’s Council  on Environmental Quality (CEQ), the Office of Science and Technology  Policy (OTSP), and the U.S. Global Change Research Program (USGCRP)  had begun to develop governmentwide strategies to address climate  change adaptation and reduce the nation’s vulnerability to adverse impacts  from climate change. Recently, some policymakers have begun to raise  questions about geoengineering—deliberate large-scale interventions in  the earth’s climate system to diminish climate change or its impacts—and  what role, if any, it could play in a broad risk-management strategy for  addressing climate change.
A September 2009 study from the Royal Society—the United Kingdom’s  national academy of science—categorized most geoengineering proposals  into two approaches: solar radiation management (SRM), which would  offset temperature increases by reflecting a small percentage of the sun’s  light back into space, thus reducing the amount of heat absorbed by the  earth’s atmosphere and surface, and carbon dioxide removal (CDR), which  would address what scientists currently view as the root cause of climate  change by removing carbon dioxide—a greenhouse gas—from the  atmosphere.
Examples of SRM approaches in the study include the following:  increasing the reflectivity of the earth’s surface through activities such as  painting building roofs white, planting more reflective crops or biomass,  or covering desert surfaces with reflective material;  increasing the reflectivity of the atmosphere by whitening clouds over the  ocean or injecting reflective aerosol particles into the stratosphere to  scatter sunlight; and    space-based methods to use shielding materials to reflect or deflect  incoming solar radiation.
Examples of CDR approaches in the study include the following:    enhancing biological, physical, or chemical land-based carbon sinks to  capture and store carbon in biomass or soil (carbon sequestration), or in  chemically reactive minerals (land-based enhanced weathering);    enhancing biological, physical, or chemical ocean-based carbon sinks  through the introduction of nutrients to promote phytoplankton growth  (ocean fertilization), physically altering ocean circulation patterns to  transfer atmospheric carbon to the deep sea, or adding chemically reactive  minerals to increase ocean alkalinity (ocean-based enhanced weathering);  and  technology-based methods to remove carbon dioxide from the atmosphere  (air capture) and then store the carbon dioxide—for example, in  geological formations (geological sequestration).
According to the Royal Society study, while both approaches are  ultimately designed to decrease temperatures, the discussed SRM  approaches, once deployed, would only take a few years to reduce  temperatures, but would create an artificial and approximate balance  between increased atmospheric greenhouse gas concentrations and  reduced sunlight that would introduce additional environmental risks and  require long-term maintenance. In contrast, the discussed CDR approaches  would take many decades to reduce global temperatures but, with some  exceptions, involve fewer potential environmental risks because they  would return the climate closer to its pre-industrial state. Additionally,  certain SRM approaches, such as atmospheric aerosol injection, are  considered to be relatively inexpensive to implement and generally hold  greater potential for causing uneven environmental impacts beyond  national or regional boundaries, thus risking undesirable social, ethical,  legal, and political implications that would need to be addressed before  any of these technologies are implemented. For example, the European  Union has initiated a research program to study the scientific issues, as  well as the policy implications of SRM geoengineering approaches.  Domestically, NAS will be including geoengineering as part of its pending  report on America’s Climate Choices for Congress, and some  nongovernmental organizations, such as the American Physical Society,  have also undertaken studies to examine these issues in further detail.
Within this context, our testimony today is based on our preliminary  observations for the committee addressing (1) the general state of the  science regarding geoengineering approaches and their potential effects,  (2) the extent to which the federal government has sponsored or  participated in geoengineering research or deployment, and (3) the views  of legal experts and federal officials concerning the extent to which  federal laws and international agreements apply to geoengineering  activities. We expect to provide the committee with the final results of this  review in a report issued later this year. Additionally, due to the interest of  the committee and the strategic relevance of this topic, GAO has initiated  a technology assessment on this topic which is also scheduled to be issued  later this year.
To address these issues, we reviewed relevant studies from peer-reviewed  literature, legal journals, and published policy studies related to  geoengineering. We also identified a list of knowledgeable scientific, legal,  and policy experts based on the following factors: participation on a  geoengineering panel, the number of articles authored in peer-reviewed  literature, and recommendations from other experts. From this list, we  interviewed a sample of experts. Our interviews with other experts are  ongoing. In addition, we met with officials and staff from interagency  bodies coordinating the federal response to climate change, including  OSTP, CEQ, and USGCRP, as well as the Department of Energy (DOE),  which coordinates the Climate Change Technology Program (CCTP)—a  multiagency research and development program for climate change  technology. We also identified and reviewed federal laws and international  agreements; interviewed international law experts; and interviewed  officials from the Environmental Protection Agency’s (EPA) Office of  General Counsel, Marine Pollution Control Branch, and the Office of  Water to discuss how federal laws are being or could be applied to  activities related to geoengineering. Our work is ongoing, and we are  continuing to collect and analyze information related to the objectives and  findings presented in this testimony. We conducted our work on this  testimony from December 2009 to March 2010 in accordance with  generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on our  audit objectives.
subsections: section_title: Substantial Uncertainties Remain Regarding Geoengineering Approaches and Their Potential Effects
paragraphs: Substantial questions remain on the efficacy and potential environmental  impacts of proposed geoengineering approaches, in part, because  geoengineering research and field experiments to date have been limited.  According to the experts we spoke with, research related to proposed  SRM geoengineering approaches is sparse. According to recent studies,  much of the research into SRM approaches to date has been limited to  modeling studies to assess the effects of either injecting sulfur aerosols  into the stratosphere or brightening clouds to reduce incoming solar  radiation at the earth’s surface and produce a cooling effect. For example,  one study found that combining a reduction of incoming radiation with  high levels of atmospheric carbon dioxide could have substantial impacts  on regional precipitation—potentially leading to reductions that could  create drought in some areas. Based on our literature review and  interviews with experts to date, only one study has been published for a  field experiment related to SRM technologies—a Russian experiment that  injected aerosols into the middle troposphere. : Update  and Recommendations (Paris: 2007). commercial applications of technology exist for injecting and monitoring  the long-term storage of carbon dioxide in geologic formations. The IEA  stated that the oldest of these started as a private-sector project in 1996  and now continues under funding from the European Commission.  However, these projects are primarily associated with public and private  initiatives to study, develop, and promote carbon capture and storage  technologies as a greenhouse gas emissions reduction strategy, rather than  the large scale that would be required to significantly alter the climate  through geoengineering. Similarly, some ocean fertilization experiments  using iron have been conducted as part of existing marine research studies  or small-scale commercial operations. One expert familiar with these  experiments noted that, while they improved scientific understanding of  the role of iron in regulating ocean ecosystems and carbon dynamics, they  were not specifically designed to determine the implications of ocean  fertilization with iron as a geoengineering approach for large-scale  removal of carbon dioxide from the atmosphere.
Due to the limited amount of geoengineering research conducted to date,  the experts we interviewed stated that a sustained program of additional  research would be needed to address the significant uncertainties  regarding the effectiveness and potential impacts of geoengineering  approaches. Additionally, these experts noted that for certain approaches  where transboundary impacts would be likely during field experiments,  international cooperation for research would be necessary. Specifically,  recent studies highlight the limitations of current models to accurately  predict the environmental impact of SRM technologies at a regional  scale—which would be necessary to accurately gauge potential impacts  that might interfere with agricultural production for certain regions.  Furthermore, studies indicate that, even for the most tested methods  applicable to geoengineering, such as geological sequestration and ocean  fertilization with iron, uncertainties remain surrounding the potential cost,  effectiveness, and impacts of pursuing these approaches at a scale  sufficient to reduce the amount of carbon in the atmosphere.
Due to the potential for disparities in environmental outcomes from using  these technologies—similar to the expected regional variation in climate  change impacts—experts that we spoke with said that the political,  ethical, legal, and economic issues surrounding the potential impacts of  geoengineering technologies warranted close examination. These experts  generally agreed that the policy implications for SRM and CDR approaches  were very different. For example, certain SRM approaches, such as  atmospheric aerosol injection, are generally perceived as being less costly  to implement and would act more quickly to reduce temperatures than  CDR approaches. However, these approaches are also associated with a  greater risk of environmental impacts that cross national boundaries— which would have political, ethical, legal, and economic ramifications.  Furthermore, according to several of these experts, the policy implications  of SRM approaches are complicated by the fact that there are likely to be  both positive and negative outcomes for nations or regions, and that one  nation, group, or individual could conceivably take unilateral action to  deploy one of these technologies. Experts emphasized that it is important  to begin studying how the United States and the international community  might address the ramifications of unilateral deployment of an SRM  approach that would result in gains for some nations and losses for others.  In contrast, with the exception of ocean fertilization, two of the experts we  interviewed stated that most CDR approaches, such as air capture, would  have limited impacts across national boundaries and could, therefore,  mostly involve discussions with domestic stakeholders about societal,  economic, and political impacts similar to those of existing climate change  mitigation strategies. However, the Royal Society study noted that large- scale deployment of CDR approaches such as widespread afforestation— planting of forests on lands that historically have not been forested—or  methods requiring substantial mineral extraction—including land or  ocean-based enhanced weathering—may have unintended and significant  impacts within and beyond national borders.
section_title: Federal Agencies Have Sponsored Some Research Activities, but These Activities Are Not Part of a Coordinated Federal Geoengineering Research Strategy
paragraphs: Our observations to date indicate that federal agencies such as DOE,  National Science Foundation (NSF), U.S. Department of Agriculture  (USDA), and others have funded some research and small-scale  technology testing relevant to proposed geoengineering approaches on an  ad-hoc basis. Some examples are as follows:    For SRM approaches, DOE, through its Sandia National Laboratories, has  sponsored a study investigating the potential unintended consequences  and economic impacts of sulfur aerosol injection. Additionally, DOE has  contributed a small amount of funding for modeling studies related to  cloud-brightening and stratospheric aerosol SRM approaches at its Pacific  Northwest National Laboratory—an effort that is primarily funded by the  University of Calgary. For CDR approaches, DOE has sponsored research  in both land-based and ocean-based carbon storage, including small-scale  demonstration projects of geological sequestration as part of its Regional  Carbon Sequestration Partnerships. In conjunction with other partners,  DOE also provided funding for a study on carbon dioxide air capture  technologies.
NSF has funded projects relevant to both SRM and CDR approaches. For  SRM approaches, NSF has sponsored some modeling studies for  stratospheric aerosol injection and for a space-based SRM approach. NSF  has also funded research investigating the ethical issues related to SRM  approaches. For CDR approaches, NSF is supporting projects related to  carbon storage in geological formations, saline aquifers, and biomass.
Relevant to CDR approaches, USDA has supported research that  examined land-based carbon storage approaches, such as biochar—a  way to draw carbon from the atmosphere and sequester it in charcoal  created from biomass—through its Agricultural Research Service, and  carbon sequestration in soil and biomass as part of its Economic Re Service.
National Aeronautics and Space Administration (NASA) funded a research  study investigating the practicality of using a solar shield in space to  deflect sunlight and reduce global temperatures as part of its former  independent Institute for Advanced Concepts program. Additionally,  scientists at NASA’s Ames Research Center, independent of headquarters,  held a conference on SRM approaches in 2006, in conjunction with the  Carnegie Institution of Washington.
EPA has also sponsored research related to the economic implications of  SRM geoengineering approaches through its National Center for  Environmental Economics.
In addition to these efforts, federal officials noted that a large fraction of  the existing federal research and observations on basic climate change  and earth science could be relevant to improving understanding about  proposed geoengineering approaches and their potential impacts. For  instance, according to federal officials, ongoing research conducted by  USGCRP agencies related to understanding atmospheric circulation and  aerosol/cloud interactions could help improve understanding about the  potential effectiveness and impacts of proposed SRM approaches.  Similarly, these officials said that basic research conducted by USGCRP  agencies into oceanic chemistry could help address uncertainty about the  potential effectiveness and impacts of CDR approaches, such as ocean  fertilization.
Staff from federal offices coordinating the U.S. response to climate  change—CEQ, OSTP, and USGCRP—stated that they do not currently  have a geoengineering strategy or position. Additionally, a USGCRP  official stated that, while the USGCRP could establish an interagency  working group to coordinate a federal effort in geoengineering research,  such a group is not currently necessary because of the small amount of  federal funding specifically directed toward these activities.
In the event that the federal government decides to fund a coordinated  geoengineering research strategy, our review of relevant studies and  interviews with experts to date identified some key factors for  policymakers to consider when designing a federal strategy for  geoengineering research. For example, the Royal Society study noted that  when there is a likelihood of transboundary impacts, such as the discussed  SRM approaches, as well as one discussed CDR approach, ocean  fertilization, transparency and international cooperation are key factors  for pursuing geoengineering research. This point was reiterated by several  experts at a recent panel discussion at the American Advancement for  Science annual meeting. However, a couple of experts we interviewed  noted that federal research for geoengineering approaches without likely  transboundary impacts could be conducted independently of other  countries, as is the case with the majority of currently proposed CDR  approaches, such as air capture. Additionally, due to the variety of  geoengineering approaches, several of the experts we interviewed  recommended that federal geoengineering research should be an  interdisciplinary effort across multiple agencies, and should be led by a  multiagency coordinating body, such as OSTP or USGCRP.
Recent GAO work offers insights on key considerations for assessing risk  and managing technology-based research programs. For example, we have  reported on the advantages of using a formal risk-management approach  and applying an anticipatory perspective when making decisions under  substantial uncertainty. Specifically, we reported that outlining the  various alternative policy responses and the risks and uncertainties  associated with pursuing each alternative is particularly important when  prospective interventions require long lead times, high-stakes outcomes  would likely result, and a delayed intervention would make impacts  difficult to contain or reverse—conditions that could be considered  relevant to the risks associated with climate change impacts. Furthermore,  our review of DOE’s FutureGen project—a program that partners with the  electric power industry to design, build, and operate the world’s first coal- fired, zero-emissions power plant—found that a comprehensive  assessment of the costs, benefits, and risks of each technological option is  an important factor when developing a strategic plan for technology-based  research.
section_title: Existing Federal Laws and International Agreements Could Apply to Certain Geoengineering Activities, but Regulatory Gaps Remain
paragraphs: Existing federal laws and international agreements were not enacted or  negotiated with the purpose or intent to cover geoengineering activities,  but according to legal experts and federal officials, several existing federal  laws and international agreements could apply to geoengineering research  and deployment, depending upon the type, location, and sponsor of the  activity. Domestically, however, interviews with agency officials to date  and our past work indicate that federal agencies have not yet assessed  their statutory authority to regulate geoengineering activities, and those  that have done so have identified regulatory gaps. Examples include the  following:
EPA has authority under the Safe Drinking Water Act to regulate  underground injections of various substances and is using this authority to  develop a rule that would govern the underground injection of carbon  dioxide for geological sequestration, which could be relevant to future  CDR approaches. EPA issued a proposed rule on geological sequestration  in July 2008. EPA officials told us that the final rule is currently scheduled  to be issued in the fall of 2010. However, as EPA officials noted, the  rulemaking was not intended to resolve many questions concerning how  other environmental statutes may apply to injected carbon dioxide,  including the Comprehensive Environmental Response, Compensation and  Liability Act of 1980 (CERLCA) and the Resource Conservation and  Recovery Act of 1976 (RCRA), which apply to hazardous substances and  wastes, respectively. The White House recently established an  interagency task force on carbon capture and storage to propose a plan to  overcome the barriers to widespread deployment of these technologies.  The plan will address, among other issues, legal barriers to deployment  and identify areas where additional statutory authority may be necessary.
Under the Marine Protection, Research and Sanctuaries Act of 1972, as  amended, certain persons are generally prohibited from dumping material,  including material for ocean fertilization, into the ocean without a permit  from EPA. Although EPA officials told us that the law’s ocean dumping  permitting process is sufficient to regulate certain ocean fertilization  activities, including research projects, they noted that the law was limited  to disposition of materials for fertilization by vessels or aircraft registered  in the United States, vessels or aircraft departing from the United States,  federal agencies, or disposition of materials for fertilization conducted in  U.S. territorial waters, which extend 12 miles from the shoreline or coastal  baseline. Consequently, a domestic company could conduct ocean  fertilization outside of EPA’s regulatory jurisdiction and control if, for  example, the company’s fertilization activities took place outside U.S.  territorial waters from a foreign-registered ship that embarked from a  foreign port.
Additionally, agency officials and legal experts noted that other laws such  as the National Environmental Policy Act of 1969 (NEPA) could also apply  to certain geoengineering activities. For example, NEPA requires federal  agencies to evaluate the likely environmental effects of certain major  federal actions by using an environmental assessment or, if the projects  likely would significantly affect the environment, a more detailed  environmental impact statement. A geoengineering activity could well  constitute a major federal action requiring a NEPA analysis.
Although some geoengineering approaches, such as geological  sequestration of carbon dioxide in underground formations, would not  involve international agreements because the activities and their effects  would be confined to U.S. territory, other SRM and CDR approaches  would. Legal experts we spoke with identified a number of existing  international agreements that could apply to geoengineering activities but  none directly address the issue of geoengineering. Our initial work  indicates that parties to two international agreements have taken action to  address geoengineering activities, but it is still uncertain whether and how  other existing international agreements that legal experts have identified  as potentially relevant could apply to geoengineering.
In our work to date, legal experts have identified a number of existing  international agreements, such as the 1985 Vienna Convention for the  Protection of the Ozone Layer and the 1967 Treaty on Principles  Governing the Activities of States in the Exploration and Use of Outer  Space, that could be relevant for injection of sulfate aerosols into the  stratosphere and placement in outer space of material to reflect sunlight,  respectively. However, these agreements were not drafted with the  purpose or intent of applying to geoengineering activities and the parties  to those treaties have not determined whether or how the agreement  should apply to relevant geoengineering activities.
Moreover, once the parties make such determinations, they may have  limited applicability because international agreements generally are only  legally binding on countries that are parties to the agreement. For  example, the 1996 Protocol to the Convention on the Prevention of Marine  Pollution by Dumping of Wastes and Other Matter (also known as the  London Protocol) generally prohibits the dumping of wastes or other  matter into the ocean except for the wastes and matter listed in the  London Protocol and for which a party to the agreement has issued a  dumping permit that meets the Protocol’s permitting requirements. In  2006, the parties to the London Protocol agreed to amend the Protocol to  include, in certain circumstances, geological sequestration of carbon  dioxide in sub-seabed geological formations on the list of wastes and other  matter that could be dumped. However, only the 37 countries that are a  party to the London Protocol and who have not objected to the  amendment would be legally bound by it.
In two instances, the parties to international agreements have issued  decisions but not amended the agreements regarding the agreement’s  application to ocean fertilization, including research projects. Generally  these decisions by the parties are not considered to be legally binding,  although they would aid in interpreting the international agreement.  Specifically, the two instances are:    Over the course of the last 2 years, parties to the Convention on the  Prevention of Marine Pollution by Dumping of Wastes and Other Matters  and the London Protocol to the Convention have decided that the scope of  these agreements include ocean fertilization activities for legitimate  scientific research. Accordingly, they have asked the treaties’ existing  scientific bodies to develop an assessment framework for countries to use  in evaluating whether research proposals are legitimate scientific research  and, therefore, permissible under the agreements. In addition, the parties  have agreed that ocean fertilization activities other than legitimate  scientific research are contrary to the aims of the agreements and should  not be allowed. Meanwhile, the parties are considering a potentially legally  binding resolution or amendment to the London Protocol concerning  ocean fertilization.
In 2009, the parties to the Convention on Biological Diversity issued a  decision requesting that parties to the Convention ensure that ocean  fertilization activities, except for certain small-scale scientific research  within coastal waters, do not take place until there is an adequate  scientific basis on which to justify such activities and a global, transparent,  and effective control and regulatory mechanism is in place. The decision  also urged the same from governments not party to the agreement.
In our interviews with legal experts to date, they suggested that  governance of geoengineering research should be separated from the  governance of deployment because scientists and policymakers lack  critical information about geoengineering that would inform governance  of deployment. The legal experts we spoke with all agreed that some type  of regulation of geoengineering field experiments was necessary, but had  different views as to the structure of such regulation. For example, some  suggested a comprehensive international governance regime for all  geoengineering research with transboundary impacts, under the auspices  of the United Nations Framework Convention on Climate Change or  another entity, while others suggested that existing international  agreements, such as the London Convention and Protocol, could be  adapted and used to address the geoengineering approaches that fall  within their purview.
The scientific and policy experts we spoke with largely echoed the same  themes and issues that the legal experts raised. Interviews with scientific  experts to date suggest that governance issues related to geoengineering  research with the potential for transboundary impacts should be  addressed in a transparent, international manner in consultation with the  scientific community. Some scientific and policy experts noted that the  approach adopted by parties to the London Protocol engaged the scientific  community about developing guidelines for assessing legitimate scientific  research proposals that are not contrary to the treaties’ aims, rather than  prohibiting the scientific research necessary to determine the efficacy and  impacts of ocean fertilization. Regarding geoengineering deployment,  some scientific and policy experts noted that similar to the difficulties  presented by achieving international consensus in carbon mitigation  strategies—where there are definite “winners and losers” in terms of  economic and environmental benefits—establishing a governance regime  over geoengineering deployment for certain approaches may be equally  challenging due to questions about whether deployment is warranted, how  to determine an appropriate new environmental equilibrium, and  compensation for adverse impacts, among other issues.
Mr. Chairman, this concludes my prepared statement. We look forward to  helping this committee and Congress as a whole better understand this  important issue. I would be pleased to respond to any questions that you  or other members of the committee may have at this time.
section_title: GAO Contacts and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact Frank Rusco,  Director, Natural Resources and Environment at (202) 512-3841, or  ruscof@gao.gov. Contact points for our Offices of Congressional Relations  and Public Affairs may be found on the last page of this statement.  Contributors to this testimony include: John Stephenson, Director; Tim  Minelli, Assistant Director; Ana Ivelisse Aviles; Charles Bausell Jr.;  Frederick Childers; Judith Droitcour; Lorraine Ettaro; Brian Friedman;  Cindy Gilbert; Gloria Hernandezsaunders; Eric Larson; Eli Lewine; Madhav  Panwar; Timothy Persons; Jeanette Soares; Joe Thompson; and Lisa Van  Arsdale.
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