The Aspen Institute’s Guidance for Ocean-Based Carbon Dioxide Removal Projects
Wil Burns, Visiting Professor, Environmental Policy & Culture Program, Northwestern University
As a number of studies in recent years have concluded, the temperature objectives of the Paris Agreement can likely only be effectuated at this point by a combination of aggressive decarbonization of the global economy AND large-scale deployment of so-called carbon dioxide removal options. The lion’s share of the early research on CDR approaches focused on terrestrial options, such as afforestation/reforestation, regenerative agriculture, bioenergy and carbon capture with sequestration, direct air capture and enhanced mineral weathering. However, growing concerns about the sustainability of many of these approaches at large-scale deployment, as well as cost concerns, and high energy demands in the case of some options, such as direct air capture, has led to an increasing focus on the potential role of ocean-based carbon removal.
Ocean-based CDR has the potential to enhance the already substantial role that the seas play as a carbon sink. However, many of these options, most of which are in nascent research stages, could also pose risk to ocean ecosystems and the livelihoods of those who work in sectors such as fishing or tourism. Two international treaty regimes, the London Convention/Protocol, and the Convention on Biological Diversity, have sought to establish a regulatory framework for ocean-based CDR approaches. However, the focus has primarily been on only one process, ocean iron fertilization, there has been a failure to identify key stakeholders, and potentially key players are not parties to one or more of these agreements. There also appears to be little domestic legal guidance in place for ocean CDR approaches that may take place within coastal waters.
Concerns of this nature, as well as a sense that it may be premature to establish rigid legal rules for emerging ocean CDR technologies, led the Aspen Institute’s Energy & Environment Program to convene a group of experts to provide “guidance to researcher and practitioners on how to enable responsible research and developed of ocean-based CDR activities that may become deployable at scale in a timely fashion.” The drafters of the Guidance for Ocean-Based Carbon Dioxide Removal Projects emphasized that the narrow remit of the group was to set forth key questions to be considered by policymakers, regulators, communities and other key actors in the context of research and testing of ocean-based approaches.
Among the key principles and questions outlined by the Aspen Institute Discussion Group are the following:
§ Definition and verification of Carbon Dioxide Removal Potential. The Discussion Group concluded that research projects should, inter alia, assess: the extent of additional sequestration over and above what would have occurred if the project wasn’t deployed, the longevity or permanence of sequestration, evidentiary protocols for demonstrating proof of concept, the results of full life-cycle accounting of costs and benefits, and how to report, track and regulate flows of carbon removal that might cut across the high seas/one territory and another territory.
§ Catalogue Potential Environmental Externalities (Negative and Positive). The Discussion Group emphasized the need to identify and report on intended and unintended environmental impacts associated with ocean-based CDR, as well as observational baselines, assessment of the reversibility of approaches that manifested themselves in serious negative impacts, and procedures to ensure that robust ecological impacts assessments are conducted.
§ Catalogue Potential Societal Externalities Negative and Positive. The Discussion Group emphasized the need to assess the potential societal impacts of ocean CDR research, protocols for identification of stakeholders, optimal structuring of stakeholder engagement, and assessment of both procedural aspects of stakeholder engagement, such as equity and representation, and substantive outcomes, that is, ensuring that the process was responsive to stakeholder concerns. The Group also called for an assessment of potential disproportionate impacts on certain communities or places, and whether this coincides with climatic or other environmental burdens.
§ Governance, Funding, and Cessation. Finally, the Discussion Group focused on protocols for projects that move from laboratory settings to in situ testing. This includes considerations of engagement of pertinent regulatory regimes at the outset of projects, the adequacy of regulatory institutions at all pertinent scales, the existence of grievance mechanisms, and adequacy of funding for all phases of a project’s operation, including planned or unplanned shutdowns.
The drafters of the Guidance conclude with a series of recommendations for next steps, including test and honing the guidelines through practical applications by policymakers, researchers and other stakeholders. Moreover, they call for a parallel development of a more comprehensive Code of Conduct. Of course, therein may lie the rub. Some ocean-based CDR projects are already selling carbon credits in voluntary carbon markets without operationalizing most of the recommendations in the Guidance, and likely will continue to do unless they are compelled to take more account of the considerations outlined in this document.
This may require more active intervention on the part of prospective investors, purchasers of credits, or government entities. To date, a few companies, including Microsoft and Stripe, have embraced many of these standards in vetting potential carbon removal purchases, but they are the exception to the rule. Incorporation of elements of these guidelines by carbon removal verification companies and organizations, such as Verra’s Verified Carbon Standard, Gold Standard, and the Science Based Targets initiative (SBTi) could help to drive adoption by project developers.
The Aspen Institute has provided a sound foundation for ensuring the integrity, safety and equity of ocean-based CDR. Other key actors must now step up to the plate.
