Comments to USGCRP Strategic Plan Update

The U.S. Global Change Research Program (USGCRP) coordinates the climate change research efforts of 13 Federal agencies “to assist the Nation and the world to understand, predict, assess and respond to human-induced and natural causes of global change.” In 2012, the USGCRP published its strategic plan that outlined its priorities and goals for the following decade. This past November, the USGCRP released a draft of an update to this strategic plan for public comment, in which the USGCRP specifically asked for input about what role it could play in coordinating research related to carbon removal—i.e. “negative emissions”—solutions. Below is my letter to Dr. Michael Kuperberg, Executive Director of the USGCRP, in response to this request for comment.

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January 30, 2016

Dear Dr. Kuperberg,

Thank you in advance for the opportunity to comment on the latest update to the USGCRP strategic plan for 2012-2021. I am writing to address the request for comments about “climate intervention” research (Page 22, lines 31-42), with a particular focus on how the USGCRP can design their research coordination efforts around “carbon removal” (also called “carbon dioxide removal” or “CDR”) most effectively.

I recommend that the USGCRP address carbon removal in the following four ways:

  1. Completely separate discussion on carbon removal and albedo modification, as carbon removal research is best governed in conjunction with—and with the same strong safeguards and governance—as conventional climate mitigation research.
  2. Identify and communicate what research the US Government is pursuing today that is related to carbon removal.
  3. Coordinate carbon removal research efforts across agencies to ensure knowledge is shared effectively and swiftly.
  4. Assist in the coordination of the development and demonstration of carbon removal solutions.

Recommendation 1: Completely separate discussion on carbon removal and albedo modification, as carbon removal research is best governed in conjunction with—and with the same strong safeguards and governance—as conventional climate mitigation research.

It would be misleading to characterize carbon removal research as “climate intervention.” Importantly, the aim and objective of carbon removal is not climate intervention. Instead, carbon removal aims to reduce historical human influence on the climate system by decreasing the amount of excess carbon dioxide in the atmosphere—essentially reversing the influence of anthropogenic greenhouse gas (GHG) emissions. In this regard, carbon removal approaches share a common purpose with conventional climate mitigation technologies, which also seek to reduce human influence on the climate system (by reducing future anthropogenic GHG emissions). In fact, the IPCC defines “mitigation” as “an anthropogenic intervention to reduce the sources or enhance the sinks of greenhouse gases” [emphasis added].

Given the shared objective of carbon removal and mitigation approaches, research into carbon removal should proceed in conjunction with other climate change mitigation research—and with the same set of strong safeguards and governance that would apply to this research. There are significant risks, uncertainties, and challenges surrounding most carbon removal solutions, but these risks are similar in nature and scope to the risks of conventional climate mitigation approaches. Strict governance and ethical consideration is needed of carbon removal and of conventional mitigation approaches, and research programs should consider the issues surrounding carbon removal and conventional climate mitigation using the same criteria.

In contrast, the purpose of albedo modification technologies is to introduce a new form of human influence on the climate system by altering the amount of sunlight absorbed by the Earth. This difference in purpose from carbon removal and mitigation, as well as the novel risks and uncertainties introduced by this new type of climate influence, will require separate governance and ethics considerations. Again, carbon removal approaches need strict and thorough governance and ethical consideration, but the type of governance questions for carbon removal are of a nature best addressed in conjunction with conventional climate mitigation approaches, not in conjunction with albedo modification approaches. Given the divergence between carbon removal and albedo modification approaches, I recommend removing any language in the USGCRP’s update to the strategic plan that combines research efforts of albedo modification and carbon removal approaches.

Recommendation 2: Identify and communicate what research the US Government is pursuing today that is related to carbon removal.

Despite the large role that many climate models suggest carbon removal solutions can play in meeting climate goals, it remains very difficult to identify what research the US Government is pursuing today in relation to carbon removal. To address this situation, I recommend that the USGCRP endeavor to produce a cross-cutting report that identifies all of the research that the US Government is pursuing related to carbon removal (including research into climate mitigation solutions that hold carbon removal potential), and update this report at regular intervals. Communicating what work the US is doing related to carbon removal to policymakers around the world will help foster the global cooperation needed to meet international climate goals.

Recommendation 3: Coordinate carbon removal research efforts across agencies to ensure knowledge is shared effectively and swiftly.

Carbon removal approaches span many industries (including energy, agriculture, and forestry), and thus research into this topic falls under the jurisdiction of a number of Federal agencies. Because of the USGCRP’s comprehensive membership, it is ideally positioned to help each agency set priorities for their own research in a way that reduces duplicative efforts. Some of the key areas where the USGCRP can coordinate carbon removal research across agencies include:

  1. Soliciting external stakeholder input on research priorities. The USGCRP can work with organizations such as the National Academy of Sciences and other leading academic institutions to help identify research priorities for USGCRP member agencies that have the greatest impact on addressing uncertainties and mitigating risks associated with carbon removal and related mitigation solutions.
  2. Advancing multi-sector climate systems modeling. The USGCRP can help foster interagency collaboration to strengthen climate models by improving linkages between terrestrial sequestration approaches and impacts to land and food prices, water and nutrient availability, and land use change (both direct and indirect).
  3. Developing the science needed for measurement and verification of carbon removal projects. The USGCRP’s Carbon Cycle Science Interagency Working Group can work with practitioners developing and regulating carbon removal projects to understand what additional science is needed to measure and verify GHG sequestration projects reliably, and can help direct Agency funding to address the most pressing obstacles. The USGCRP can also engage working groups to help develop science-based accounting standards for various carbon removal approaches.
  4. Researching materials science for better carbon capture. The USGCRP can coordinate the research into materials science to improve our ability to capture CO2 from the atmosphere.

Recommendation 4: Assist in the coordination of the development and demonstration of carbon removal solutions.

Development and demonstration of carbon removal solutions are needed in addition to basic science and research to inform policy related to carbon removal. However, the mandate of the USGCRP does not include solution development and demonstration at this time, and there is no organization analogous to the Climate Change Technology Program (CCTP) of the George W. Bush Administration that is responsible for cross-agency collaboration and coordination of climate solution development and demonstration. To address this issue, the USGCRP can work with the Administration to implement an official CCTP analog that includes carbon removal solutions, and/or collaborate with White House and Congressional officials in an ad hoc manner to ensure that carbon removal solutions development priorities align with USGCRP research activities and priorities, and that solution development efforts are informed by the best science available from the work of the USGCRP.

 

Thank you again for considering these comments.

Sincerely,

Noah Deich