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Home , Carbon Engineering, Climate engineering, Solar geoengineering, Weather modification

FUEL TO THE FIRE How Geoengineering Threatens to Entrench Fossil Fuels and Accelerate the Crisis © 2019 Center for International Environmental Law (CIEL)

ABOUT CIEL Founded in 1989, the Center for International Environmental Law (CIEL) uses the power of law to protect the environment, promote human rights, and ensure a just and sustain- able society. CIEL is dedicated to advocacy in the global public interest through legal counsel, policy research, analysis, education, training, and capacity building.

Fuel to the Fire: How Geoengineering Threatens to Entrench Fossil Fuels and Accelerate the by The Center for International Environmental Law is licensed under a Creative Commons Attribution 4.0 International License.

ACKNOWLEDGEMENTS This report was authored by Carroll Muffett and Steven Feit, with additional input from Lili Fuhr and Linda Schneider of the Heinrich Boell Foundation and assistance from Erika Lennon. This report and the body of research that underlies it were made possible with generous support from the Heinrich Boell Foundation. Errors and omissions are the sole responsibility of CIEL.

This briefing note is for general information purposes only. It is intended solely as a discussion piece. It is not and should not be relied upon as legal advice. While efforts were made to ensure the accura- cy of the information contained in this report and the above information is from sources believed reliable, the information is presented “as is” and without warranties, express or implied. If there are material errors within this briefing note, please advise the author. Receipt of this briefing note is not intended to and does not create an attorney-client relationship.

DESIGN & LAYOUT: MARIE MEKOSH, CIEL ORIGINAL TEMPLATE: DAVID GERRATT, NONPROFITDESIGN.COM COVER PHOTO: ©SEAQ68 VIA PIXABAY FUEL TO THE FIRE HOW GEOENGINEERING THREATENS TO ENTRENCH FOSSIL FUELS AND ACCELERATE THE CLIMATE CRISIS

“It’s an problem, and it has engineering solutions... The fear factor that people want to throw out there to say we just have to stop this, I do not accept.”

–REX TILLERSON, FORMER CEO, EXXONMOBIL AND US SECRETARY OF STATE (2012)1

“When serious proposals for large-scale modification are advanced, as they inevitably will be, the full resources of general-circulation knowledge and computational must be brought to bear in predicting the results so as to avoid the unhappy situation of the cure being worse than the ailment.”

–HENRY WEXLER, US WEATHER BUREAU (1958)2

FEBRUARY 2019 ii CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Contents

1 Executive Summary

4 Introduction: Postcards from the Edge of a Climate Breakdown

6 Part 1 The Scientific Basis and Moral Imperative for Urgent Climate Action 9 Part 2 Geoengineering: Removal, Solar Radiation Management, and Beyond “...with Carbon Capture & Storage”: Why CCS is Vital to the Geoengineering Debate Geoengineering May Entrench Interests 11 Part 3 Asphalt Fields and Skies: A Brief History of Fossil Fuels and Early Oil Industry Interest in Weather Modification The Importance of Acknowledging this Early Fossil Fuel Interest 11 Part 4 and Negative Emissions: The Pervasive Role of Carbon Capture, Use, and Storage Carbon In, Carbon Out: Captured Carbon and Enhanced Oil Recovery How Carbon Dioxide Removal will “Save” the Coal Industry Industry’s Pervasive Role in CCS Resarch and Policy Carbon Dioxide Removal and Oil’s Plans for the Next Century : Turning into New Carbon Emissions Enhanced Weathering and Carbon Mineralization Ocean Fertilization and Alkalinization 31 Part 5 Bioenergy, BECCS, and the Real Cost of Fossil Industry Investment in and BECCS 34 Part 6 Paved with Good Intentions: The Danger and Distraction of Solar Radiation Modification Burning Fossil Fuels Proved SRM is Possible—and Demonstrated Its Risks Early Industry Interest in SRM and Stratospheric Aerosol Injection Counting—and Not Counting—the Costs of SRM This is a Test. But is it Only a Test? Industry Influence in SRM The New Climate Denial 47 Part 7 We Must and Can Stay Below 1.5oC without Geoengineering Renewables are Eliminating the Rationale for Coal and Gas in Energy Generation The Pace of Renewable Deployments Consistently Exceeds Official Forecasts The Energy Revolution in the Transport Sector Extends Far Beyond Cars Low-Tech, Win-Win Approaches to Climate Mitigation and Carbon Removal are Ready to Be Scaled Up 59 Part 8 Conclusions 61 Endnotes FUEL TO THE FIRE iii

Acronyms and Abbreviations

AEI American Enterprise Institute IPCC Intergovernmental Panel on BECCS Bioenergy with carbon capture and IPN International Policy Network storage BPC Bipartisan Policy Center LCOE Levelized cost of energy CCC Center LNG Liquefied natural gas CCS Carbon capture and storage MCB Marine brightening CCUS Carbon capture, use, and storage NAS National Academy of Sciences CCW Coal combustion waste NCCC National Carbon Capture Center CDR Carbon dioxide removal NORCE Norwegian Research Centre AS CLARA Climate Land Ambition and Rights OGCI Oil and Gas Climate Initiative Alliance CO2 Carbon dioxide PV Photovoltaic CSLF Leadership SAI Stratospheric aerosol injection Forum DAC Direct air capture SCoPEx Stratospheric controlled perturbation experiment DACCCS Direct air capture with carbon capture SGRP Harvard University’s Solar and storage Geoengineering Research Program

DOE US Department of Energy SO2 EPRI Electric Power Research Institute SR1.5 Intergovernmental Panel on Climate Change’s Special Report on 1.5 degrees EOR Enhanced oil recovery SRM Solar radiation modification EV Electric vehicle TCM Centre Mongstad GHG TJI Thomas Jefferson Institute GW Gigawatt WCA World Coal Association IEA International Energy Agency ZECA Zero Emission Coal Alliance IEAGHG International Energy Agency’s Greenhouse Gas R&D Programme iv CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

© MIRIAM’S FOTOS/PIXABAY FUEL TO THE FIRE 1

Executive Summary

he present report investigates the early, ongoing, and often surprising role of the fossil fuel industry in developing, patenting, and promoting key geoengineering . It examines how the most heavily promoted strategies for carbon dioxide removal and solar radiation modification depend on the continued production and combustion of carbon- intensive fuels for their viability. It analyzes how the hypothetical promise of future geoengineering is already being used Tby major fossil fuel producers to justify the continued production and use of oil, gas, and coal for decades to come. It exposes the stark contrast between the emerging narrative that geoengineering is a morally necessary adjunct to dramatic climate action, and the commercial arguments of key proponents that geoengineering is simply a way of avoiding or reducing the need for true systemic change, even as converging science and technologies demonstrate that shift is both urgently needed and increasingly feasible. Finally, it highlights the growing incoherence of advocating for reliance on speculative and risky geoengineering technologies in the face of mounting evidence that addressing the climate crisis is less about technology than about political will.

Key Findings and Messages

The urgency of the climate crisis is being used Most direct air capture is only viable if it to promote geoengineering. produces oil or liquid fuels.

• Models are increasingly including large-scale carbon • Most current or anticipated commercial applications dioxide removal to account for overshooting (or sur- of direct air capture are for the production of liquid passing 1.5 degrees of warming). (transport) fuels or enhanced oil recovery, both of • Proponents are seeking increased funding and incen- which produce significant CO2 emissions. tives for research and development of carbon dioxide • Leading proponents of direct air capture explicitly removal technologies. market the process as a way to preserve existing ener- • A growing set of actors are considering or pursuing gy and transportation systems. research into solar radiation modification, including • Direct air capture requires large energy inputs, re- outdoor experiments. sulting in either associated emissions or the diversion of renewable resources that would otherwise displace Geoengineering relies heavily on carbon fossil fuels. capture and storage. Carbon mineralization could promote wide • Carbon capture and storage (CCS) are separately or dispersal of hazardous combustion wastes. jointly required for several forms of carbon dioxide

removal. • Achieving large CO2 reductions from mineralization • Most large-scale CCS projects use captured carbon would demand new mining at an unprecedented and for enhanced oil recovery or enhanced coal bed infeasible scale. methane. • Coal combustion waste and other industrial wastes • Proponents of carbon capture and storage estimate have been proposed as alternate feedstocks for miner- that its use for EOR could spur consumption of alization. 40% more coal and up to 923 million additional • The atmospheric impact of using coal combustion barrels of oil in the US alone by 2040. waste would be minimal, and the process would pro- mote coal by monetizing the industry’s largest haz- ardous waste stream. 2 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Reliance on bioenergy with CCS could raise Solar radiation modification is a dangerous emissions, threaten food security, and justify distraction—and is simply dangerous. business as usual. • Techniques to modify earth’s were among the earliest forms of weather modification and geoengi- • Carbon dioxide removal often relies heavily on bio- neering research. energy with CCS (BECCS), despite warnings that its potential is overstated. • Fossil fuel companies have researched environmental modification for decades as a potential profit stream. • BECCS presents the same use and storage problems as fossil CCS and direct air capture. • Global sulfur dioxide emissions from fossil fuel com- bustion show solar radiation modification can affect • Emissions due to land clearance for BECCS could the climate, with profound risks. exceed any reduction in atmospheric CO2. • Solar radiation modification could cause acid • Deploying BECCS at the scale suggested in many and , disrupt and rainfall pat- models would threaten food security and access to terns across large regions, and reduce the growth of land for millions of people. crops and CO2-absorbing plants. • Major oil companies rely on massive deployment of • The most widely touted solar radiation modification BECCS and carbon dioxide removal to justify con- technologies would use sulfate aerosols, which are tinued heavy use of oil and gas for the next century. clearly linked to ozone depletion and acid rain. FUEL TO THE FIRE 3

Fossil fuel interests have raised the profile of We must and can stay below 1.5°C without solar radiation modification. relying on geoengineering.

• Fossil fuel interests played a significant but largely • Clear and achievable pathways exist for keeping the unrecognized role in shaping the research and public world below 1.5°C. debates on solar radiation modification. • All pathways that avoid overshooting 1.5°C of warm- • Despite its risks, solar radiation modification has ing require an early, rapid phase-out of fossil fuels. been promoted as a means to delay or minimize oth- • This transition is ambitious, but achievable by accel- er forms of climate action and allow business-as-usu- erating the deployment of existing renewable energy al reliance on fossil fuels. and energy efficiency technologies. • Despite international moratoria, open-air solar radia- • Low-risk, win-win approaches exist to reduce CO2 tion modification experiments are being actively ex- emissions from the land and natural resource sectors plored. while advancing other • Proponents of solar radiation modification recognize goals. that such tests could open the door to wider-scale • Geoengineering deployments pose a high risk of de- deployment of geoengineering. laying the necessary transition, while creating new threats that compound and exacerbate climate im- Geoengineering is creating new tools for pacts. climate denial—and they are being used.

• Climate denialists have long advocated geoengineer- ing as an excuse for climate inaction. • Recent years have seen a resurgence in geoengineer- ing interest among opponents of climate action. • Contrary to claims by geoengineering proponents, the use of geoengineering by climate denialists is nei- ther uncommon nor coincidental.

Recommendations

Humanity has a limited and rapidly closing window to avoid truly catastrophic climate change. To keep warming below 1.5 degrees, the world must reduce 45% by 2030 and reach net zero emissions by around 2050. By entrenching fossil fuel interests and promoting continued reliance on fossil infrastructure, geoengineering distracts from more viable solutions and threatens to exacerbate the climate crisis, while exposing large parts of the world to new and significant risks. The managed decline of fossil fuels is both a necessary and achievable solution to the climate crisis.

Climate policy should:

• Focus at the national and global level on the rapid, managed decline of fossil fuels and the accelerated transition to a new energy economy in a timeframe that will keep the world below 1.5 degrees of warming. • Ensure that all public infrastructure investments align with the and the 1.5-degree goal. • Avoid policies that promote or subsidize the construction of new fossil infrastructure or extend the economic life of existing fossil infrastructure, including through subsidies for carbon capture and storage, direct air cap- ture, or BECCS. • Prohibit open-air experiments of solar radiation modification techniques. 4 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Introduction: Postcards from the Edge of a Climate Breakdown

t is more than 120 years since Svante leaders, and the general public to recog- mate system.”4 And it shares a common Arrhenius published the first calcula- nize the growing climate threat and to act moniker: geoengineering. tions of global warming caused by while there is still time. human emissions of carbon dioxide Since at least the 1980s, proposals that Even as the world grappled with “inad- humanity attempt to geo-engineer its way I(CO2), eighty years since Guy Callendar published the first evidence that humans vertent” climate change caused by human out of the climate crisis have been gener- were inadvertently modifying the atmo- activity, a smaller cadre of scientists, gov- ally relegated to the fringes of climate sphere at a global scale, and sixty since ernments, and corporations continued to science and policy. This fringe status re- Roger Revelle warned that humankind publish on, invest in, and occasionally flected not only the profound uncertain- was now conducting “a vast geophysical experiment with intentional modification ties and potentially staggering costs of experiment” on the Earth through its un- of the climate and the geosphere at a vari- tinkering with planetary systems, but also bridled combustion of fossil fuels.3 ety of scales—to confront climate change, the profound risks of doing so. to advance goals unrelated to climate Through the ensuing decades, and against change, or both. This body of research Over the last decade, however, and with a backdrop of ever more robust scientific and practice employs a diverse array of increasing speed, geoengineering strate- consensus and ever greater levels of cer- theories, strategies, and technologies, but gies, technologies, and risks have moved tainty, the scientific community has re- shares a common objective: “deliberate from the fringes of climate discourse to- peatedly called on governments, industry large-scale intervention in the Earth’s cli- ward its center. In significant part, this ©DAN BREKKE VIA FLICKR VIA BREKKE ©DAN FUEL TO THE FIRE 5

shift reflects a growing alarm among sci- risks. One such risk is that rather than continued production and use of oil, gas, entists, decision-makers, and concerned provide a solution, geoengineering will and coal for decades to come. And it ex- observers that a substantial amount of further entrench the fossil fuel economy poses the stark contrast between the global climate change is already locked in; and make the transition from fossil fuels emerging narrative that geoengineering is that humanity has yet to act on the cli- more difficult. a morally necessary adjunct to climate mate crisis at anything approaching the action and the commercial arguments ambition, scale, or urgency required; and In light of their history, capacity, and that geoengineering is simply a way of that, accordingly, dangerous ideas once fundamental commercial interests, it avoiding or reducing the need for true considered unthinkable must now be ex- should come as little surprise that fossil systemic change, even as converging sci- amined. As others have documented at fuel companies have been among the ence and technologies demonstrate that length, however, the growing focus on most active and sustained players in the shift is both urgently needed and increas- geoengineering also reflects the persistent, geoengineering space. To date, however, ingly feasible. Finally, it highlights the intensive, and well-resourced efforts of a the nature and extent of the fossil indus- growing incoherence of advocating for relatively small group of scientists and try’s role in geoengineering has received speculative and risky geoengineering tech- industries to push geoengineering tech- inadequate attention and scrutiny. nologies as critical to human rights while nologies into climate debates and poli- at the same time ignoring the pervasive cies.5 The present report represents a first step and disastrous risks to human rights these toward filling that gap. It investigates the same technologies present for both pres- early, ongoing, and often surprising role Many and perhaps most proponents of ent and future generations. of the fossil fuel industry in developing, geoengineering are acting in good faith. patenting, and promoting key geoengi- The scientists, policy experts, activists, neering technologies. It examines how the Many proponents of geoengineering test- and citizens who look to geoengineering most heavily promoted strategies for car- ing and deployment have downplayed or as a potential solution are rightly con- bon dioxide removal and solar radiation dismissed these “excuse for delay” and cerned about the severity of the climate management depend on the continued “” critiques of geoengineer- crisis, the extent of warming to which the production and combustion of carbon-in- ing as overblown and largely theoretical. world is already committed, and the tensive fuels for their viability. It analyzes To the contrary, our analysis demon- dwindling number of paths available to how the hypothetical promise of future strates those risks are both underestimat- avert worst-case scenarios. However, any geoengineering is already being used by ed and—for many geoengineering tech- consideration of geoengineering must major fossil fuel producers to justify the nologies—potentially unavoidable. begin with a thorough examination of its

BOX 1 A Note on Coverage

Given the wide array of geoengineering technologies that have been proposed and the decades-long history of geoengineering research, this report does not address every geoengineering idea that has been proposed, or even all of those that have been seriously considered. It focuses instead on those technologies that figure most heavily in current, ongoing debates about geoengineering testing and deployment. Similarly, and in light of the global nature of the fossil fuel industries, this report could not and does not purport to cover the panoply of fossil fuel industry research into or promotion of geoengineering worldwide. For example, the role of US oil and coal companies is discussed more extensively than that of the European coal industry, © BENITA5 VIA PIXABAY fossil fuel interests in and receive less attention still, and the vast majority of other countries are not addressed at all. CIEL has prepared this report in the hope and expectation that it will spur future research to close such gaps. 6 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

PART 1 The Scientific Basis and Moral Imperative for Urgent Climate Action

n October 2018, the United Nations sector by mid-century,”9 with rapid re- it couples widespread adoption of energy Intergovernmental Panel on Climate ductions by 2030 providing the greatest efficiency and renewable energy technolo- Change (IPCC) released its starkest likelihood of avoiding (or sur- gies with the near elimination of coal warning yet on the growing impacts passing 1.5 degrees of warming). The (-97%), oil (-87%), and gas (-74%) by Iof climate change, the urgent need for IPCC recognized that every scenario re- the year 2050. It closes the remaining gap accelerated climate action, and the dire quires tradeoffs between near-term ambi- through a limited deployment of forest, consequences of further delay. Against a tion, the risk of overshoot, transitional agriculture, and land-use measures, in- growing backdrop of intense , challenges between 2030 and 2050, and cluding and .12 floods, and wildfires worldwide, the re- the amount of carbon dioxide removal This approach is consistent with the port synthesizes and summarizes what has (CDR) that would eventually be re- IPCC’s finding that “1.5°C-consistent long been evident to scientists and in- quired. But it concluded that the risk of pathways would require robust, stringent formed observers alike: The 1.0 degree overshoot, transitional challenges, and the and urgent transformative policy inter- Celsius of warming the planet has already utilization of CDR—with all its atten- ventions targeting the decarbonization of experienced is putting human lives, hu- dant risks and impacts—are all signifi- energy supply, electrification, fuel switch- man rights, and ecosystems at risk around cantly reduced if ambitious action is taken ing, energy efficiency, land-use change, the world. in the near term.10 It cautioned that strat- and lifestyles.”13 egies that prioritize taking concerted ac- In its Special Report on 1.5 degrees tion only after 2030 “face significant risks In each of the three remaining illustrative (SR1.5),6 the IPCC recognized that these of carbon infrastructure lock-in and over- pathways, the IPCC modeled the contin- risks will be increasingly severe and wide- shoot, with the risk that a return to 1.5 ued use of forest and land-use measures, spread in a world projected to be at least degrees could not be achieved.”11 but also incorporated progressively esca- 1.5 degrees warmer. More importantly, lating deployments of carbon capture and in an update to the well-known “Burning storage (CCS) and bioenergy with CCS Embers” diagram, the IPCC confirmed (BECCS).15 The IPCC highlighted the the growing scientific consensus that “The available literature indicates potential value of forest and warming near or above 2.0 degrees would that 1.5°C-consistent pathways measures in accelerating early action on push human and biological systems well would require robust, stringent and climate change and noted the particular into the danger zone across multiple urgent transformative policy benefits of increased conservation and “.” Critically, the interventions targeting the restoration efforts in natural areas for IPCC concluded that limiting warming decarbonization of energy supply, their rapid deployability, lower risk of to 1.5 degrees is still possible, but de- social and environmental impacts, and mands immediate, dramatic reductions in electrification, fuel switching, energy potential for positive co-benefits.16 It ob- greenhouse emissions and a rapid trans- efficiency, land-use change, and served that, as additional information has formation of our global energy system.7 lifestyles.” emerged in recent years on the viability, Specifically, the IPCC concluded that scale requirements, and potential negative — IPCC SR1.514 keeping warming within 1.5 degrees re- impacts of BECCS, projections of its po- quires the world to reduce global carbon tential contributions to global emission dioxide emissions 45% by 2030 and reductions have been declining. The 8 achieve net zero CO2 emissions by 2050. Accordingly, the first, most ambitious, IPCC observed that few reliable models and safest of IPCC’s illustrative pathways for meeting 1.5 targets incorporated di- The IPCC modeled four illustrative path- (Pathway 1) models an immediate and rect air capture with CCS (DACCCS) or ways to achieving those goals. A unifying rapid transformation of our energy sys- other proposed carbon dioxide removal factor in all of the pathways was the “vir- tem to reduce CO2 emissions 58% by technologies. It cautioned, however, in tually full decarbonization of the power 2030 and 97% by 2050. To achieve this, the Summary and throughout the report, FUEL TO THE FIRE 7

FIGURE 1 Reasons for Concern

IPCC, Summary for Policymakers, in GLOBAL WARMING OF 1.5°C: AN IPCC SPECIA`L REPORT ON THE IMPACTS OF GLOBAL WARMING OF 1.5°C 13 (V. Masson-Delmotte et al. eds., 2018), https://www.ipcc.ch/site/assets/uploads/sites/2/2018/07/SR15_SPM_version_stand_alone_LR.pdf. 8 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

that the economic and technological un- FIGURE 2 certainties associated with these ap- IPCC Pathway 1 to 1.5oC proaches, the long projected timelines for their deployment at any meaningful scale, and the moderate to high likelihood of negative social and environmental im- pacts made reliance on these technologies risky and inherently speculative.17

The IPCC expressly declined to incorpo- rate any form of solar radiation modifica- tion (SRM) into its model, citing the per- vasive and profound uncertainties, signifi- cant questions about the feasibility of most SRM approaches, and the high risk of negative impacts.18

Remarkably, and in stark contrast to the cautious language and clear warnings of the IPCC itself, the release of the SR1.5 report has triggered a barrage of stories in the global media arguing that geoengi- neering—whether through large-scale CDR, SRM, or both—may be the only way to save the climate, the planet, and humanity.19 A growing drumbeat of ac- tivists, public officials, and concerned citizens are calling for accelerated public support for development and deployment of these technologies. While these de- mands are sincere, the call for diverting public attention and resources to these geoengineering technologies—and the companies that control or stand to bene- fit from them—is not a backup plan or an policy. Instead, it risks fur- ther entrenching the fossil fuel economy and making it even harder to combat the IPCC, Summary for Policymakers, in GLOBAL WARMING OF 1.5°C: AN IPCC SPECIAL REPORT ON climate crisis. THE IMPACTS OF GLOBAL WARMING OF 1.5°C 13 (V. Masson-Delmotte et al. eds., 2018), https:// www.ipcc.ch/site/assets/uploads/sites/2/2018/07/SR15_SPM_version_stand_alone_LR.pdf. FUEL TO THE FIRE 9

PART 2 Geoengineering: Carbon Dioxide Removal, Solar Radiation Management, and Beyond

s noted in the introduction, processes or through the deployment seek to manage the flow of energy within geoengineering has been suc- of complex—and often unproven— and among earth systems. Such proposals cinctly described as the “delib- technologies. Among the most wide- include transferring hotter surface ocean erate large-scale intervention in ly discussed (or heavily touted) CDR water to lower depths or building giant theA Earth’s .”20 The array approaches are: pipes to push low- air into the of techniques and technologies potential- upper atmosphere. To date, these earth ly encompassed within this definition is o Afforestation and reforestation, system modification proposals have re- vast and diverse—ranging from restoring ceived considerably less public attention o Soil sequestration, forests and agricultural soils to spraying than CDR and SRM, and this report will aerosols into the atmosphere to deploying o Bioenergy with carbon capture not discuss them at length. giant mirrors in space. and storage, o Direct air capture with carbon There is ongoing debate about what capture and storage, “...with Carbon Capture should and should not be considered geo- engineering and the categories into which o Enhanced weathering, & Storage”: Why CCS is various geoengineering approaches can be o Ocean alkalinization, and Vital to the divided. The IPCC’s SR1.5 Report ex- Ocean fertilization. pressly avoids the term “geoengineering” o Geoengineering and instead divides the approaches and • Solar radiation modification—also Debate technologies involved into two broad and called solar radiation manage- distinct classes: those which purport to ment—does not attempt to reduce The ways in which geoengineering tech- remove carbon dioxide from the atmo- greenhouse gases (GHGs) in the at- niques are categorized, and what is and is sphere (carbon dioxide removal), and mosphere, but proposes to modify not considered geoengineering, will affect those which alter the Earth’s balance of the earth’s radiation balance in ways law, scientific research, private and public solar radiation (solar radiation modifica- that alter heat absorption at regional capital flows, and the sociopolitical con- 21 tion). Within CDR, the United Nations or global levels and temporarily mask text in which critical public decisions Environment Program further distin- the effects of anthropogenic warm- about geoengineering are made. For that guishes between approaches that are ing. The most widely discussed tech- reason, this report applies an expansive based on natural processes (such as refor- nologies for SRM include: definition of geoengineering, viewing all estation or soil restoration), those involv- technological CDR methods and all ing a mix of nature and technology (such o Atmospheric aerosol injection, forms of SRM as within the geoengineer- as bioenergy with carbon capture and ing umbrella. This comprehensive ap- , storage), and approaches that are primar- o proach is vital to any realistic evaluation ily technological (such as direct air cap- o Marine sea surface brightening, of CDR and SRM methods because of ture with carbon capture and storage).22 and the critical ways in which the various technologies and strategies intersect and o Modifying the albedo, or reflec- • Carbon dioxide removal technolo- interrelate. gies seek to remove emitted CO tivity, of polar ice or promoting 2 polar ice growth. from the atmosphere. Also known as While individual CDR projects may not negative emission technologies, CDR The CDR/SRM dichotomy does not cap- appear to be global in scale, the wide- proposes to “draw down” atmo- ture the full spectrum of geoengineering scale deployment of CDR methods spheric levels of CO , whether 2 proposals and technologies. For example, would reshape the planet. CDR at the through enhancement of natural it does not account for techniques that scale suggested by its proponents would 10 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

lead to massive geological storage of car- weatherization, mineralization, and ocean nologies necessary to pursue CDR and bon dioxide, land-use change over enor- alkalinization may draw heavily on car- SRM at scale. These companies have been mous parcels of land for use in minerals bon capture technologies in their process- involved in geoengineering research and mining or bioenergy production, and po- es and feedstocks, or may require coal debates from their earliest days and are tentially dramatic changes to marine eco- combustion wastes or similar residuals to not separate from—but rather inextrica- systems across large regions. operate at scale. Accordingly, many of the bly linked to—any real-world execution financial and policy incentives which of geoengineering. Further, CDR methods—like SRM could apply to one of these technologies methods and geoengineering generally— would (or do) apply to others. It is not surprising that the fossil fuel in- pose the same risks that are at the heart of dustry has invested and is investing heav- this report. The wide adoption of CDR ily in the technologies that would render techniques risks entrenching fossil fuel Geoengineering May a transition from fossil fuels less urgent. interests and making mitigation efforts But it is important to acknowledge the considerably more difficult. This is espe- Entrench Fossil Fuel depth of those connections. The debate cially true as core CDR technologies are Interests around geoengineering will in part deter- disproportionately owned or funded by mine the trajectory of the global response fossil fuel companies. The IPCC makes clear in SR1.5 that the to climate change. To limit warming to key to limiting warming to 1.5 degrees is 1.5 degrees, the global community will Most significantly, this report considers transition. The path out of a world with need to mobilize massive public and pri- the pervasive role of carbon capture and runaway global warming is not simply a vate resources. It will need to redesign storage within geoengineering and the matter of emissions adding and subtract- systems and restructure vast sectors of the role of the fossil fuel industry in promot- ing up to a certain amount. Entire systems global economy. A focus on geoengineer- ing CCS. As is readily evident from their of energy, land use, urban design, infra- ing risks slowing that transition, diverting titles, and as discussed more fully herein, structure, and industrial production need investments from other more realistic and BECCS, the most widely discussed tech- to shift from a reliance on fossil fuels to more workable solutions, while enriching nological approach to CDR, expressly more sustainable paradigms. and entrenching the very interests at the relies on effective use of CCS. Similarly, heart of the crisis itself. the most widely discussed technologies Geoengineering threatens this transition for direct air capture (DAC) would re- by entrenching the exact systems that Geoengineering proponents are right to quire the operation of large-scale carbon need redesigning. Proponents and experts be concerned. The situation is dire, and storage to dispose of captured carbon un- of CDR techniques acknowledge that the we as a global community should test out less, as is frequently proposed, the cap- “main advantage of sequestration is its and invest in a diverse suite of technolo- tured carbon were simply processed into compatibility with existing fossil fuel in- gies and techniques to combat this crisis. carbon-based fuels, to be combusted and frastructure.”23 SRM, in addition to pos- But the core challenge remains known: re-emitted into the atmosphere. More- ing enormous unknown risks, is acknowl- We need to transition away from reliance over, DAC approaches frequently rely on edged even by its supporters as a perfect on fossil fuels. Anything that moves us CCS as a source of low-carbon fuel to excuse for inaction.24 toward greater reliance will not be a solu- power their own energy-intensive pro- tion, and the push for geoengineering is cesses. Less obviously, but no less signifi- Finally, and critically, the fossil fuel in- likely to do exactly that. cantly, CDR techniques such as enhanced dustry controls huge swaths of the tech- FUEL TO THE FIRE 11

PART 3 Asphalt Fields and Black Carbon Skies: A Brief History of Fossil Fuels and Weather Modification hile widespread public companies to develop pioneering tech- Early Oil Industry and scientific debate niques for clearing -bound airstrips by about geoengineering has massive flaring of fossil fuels.25 By the Interest in Weather only recently emerged 1950s and into the 1960s, rising signs Modification fromW a long period of quiescence and rel- that the Arctic was warming26 spurred a ative obscurity, neither the basic princi- flurry of research and discussion within The oil industry began studying hurri- ples underlying geoengineering technolo- the US and Russian military and scientif- cane formation no later than the 1940s.30 gies nor the fantasy of applying them at ic communities as to how that warming This research was necessary to protect the ever larger scales are recent developments. might be accelerated to produce a perma- industry’s investments in a rapidly ex- Governments, scientific institutions, and nently ice-free Arctic Ocean, whether panding fleet of offshore oil rigs, which private companies, including many fossil through blocking rivers, “blackening po- were often damaged or disabled by hurri- fuel companies, were conducting research lar ice caps,” or using coal plant emissions canes in the Gulf of Mexico. But by no into weather modification and albedo or nuclear blasts to generate persistent ice later than the 1960s, some in the oil in- 27 enhancement more than sixty years ago. and melt the Arctic sea ice. In a dustry were actively exploring techniques 1958 report reviewing and critiquing to control or modify the weather, not just Experimentation with weather modifica- these various projects, Henry Wexler of understand it. In some cases, the concern tion at local and regional scales began in the US National Weather Bureau prof- was related to hurricanes—how to divert the 1930s and began to accelerate and fered a warning that remains prescient their course or dissipate their energy. In diversify in the 1940s. Governments, in- and relevant six decades later: other cases, the purpose was to seed cluding their militaries, were interested in and increase , specifi- using weather modification for a variety “When serious proposals for large-scale cally through the use of petroleum by- of purposes—to make more predict- weather modification are advanced, as products. able, to dissipate fog or redirect storms, to they inevitably will be, the full resources convert ice-covered areas into habitable of general-circulation knowledge and Esso (now ExxonMobil (Exxon)) spent zones, and to use as tools of war. Aca- computational meteorology must be considerable time and money researching demic institutions sought greater under- brought to bear in predicting the results weather modification techniques. As Exx- standing, and oil companies sought to so as to avoid the unhappy situation of on’s chief scientist, James F. Black played 28 protect their financial interests. Industry the cure being worse than the ailment.” a key role in Exxon’s internal research on groups saw weather modification as a carbon dioxide and climate change in the means to protect their existing invest- Yet, by as early as 1965, a landmark cli- 1970s and 1980s.31 Before this, Black was ments and to open new product lines and mate report to US President Lyndon an active contributor to Exxon’s research profit streams. Johnson, led by Roger Revelle of the into intentional weather modification. Scripps Institute, included a suggestion Early science on climate change was fre- that increasing the albedo, or reflectivity, In 1963, Black published two studies de- quently discussed and reported in parallel of the Earth could combat atmospheric scribing Exxon’s experiments in coating 29 with this research, as an “inadvertent” warming. While the prospect of using large areas of land with asphalt, with the form of weather modification. Guy Call- such technological fixes may have retreat- goal of lowering albedo, raising surface lender, whose work in 1938 brought cli- ed into the background, it retained a re- , and increasing rainfall in mate change back into active scientific curring interest for some of the world’s nearby areas.32 In this paper, Black de- debate, spent much of World War II most powerful and well-resourced corpo- scribes how spreading asphalt, which ab- working with the UK’s Petroleum War- rate actors. sorbs sunlight and emanates heat, could fare Department and British and US oil 12 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

alter meteorological conditions at a local by local effects become regional, and intentioned, fully independent people to regional scale to produce rainfall over above which regional effects become pursuing research and deployment of arid areas.33 Experiments of this tech- global. This understanding—that weather these technologies. It is simply to demon- nique were covered in a 1963 edition of modification and strate that the extent to which the fossil Popular Mechanics,34 and Black later pat- exist on a spectrum and are not isolated fuel industry was (and still is) researching ented the process on behalf of Exxon.35 or independent activities—was therefore and supporting various forms of geoengi- While the initial experiments were limit- clear to experts on the subject no later neering—especially the more controver- ed in scope, Exxon envisioned deploying than 1974. sial solar radiation management tech- the technique over tens to hundreds of niques—remains unknown. square miles. These reports from the National Acade- mies of Science and State Uni- The foregoing is far from a comprehen- In 1964, the National Academy of Sci- versity document the oil industry and sive overview of the history of weather ences convened a Panel on Weather and fossil fuel companies’ significant interest modification, or even the history of fossil Climate Modification. In 1966, the Panel in weather modification and climate con- fuel company involvement with it. Rath- published the outcomes of its work in trol at its earliest stages. Critically, it also er, it serves to demonstrate three critical Weather and Climate Modification: Prob- exemplifies the ways in which these inter- points. lems and Prospects,36 which summarized ests were aligned with or reflected in re- the state of knowledge and research needs search by academic institutions and First, as was the case in the history of the in the field of meteorological control. scholars. Fossil fuel companies frequently climate debate, oil companies were there Black participated in two of the twelve hired academics (e.g., Colorado State from the beginning. These companies meetings that contributed to the final University’s M.L. Cornin) as consultants had a strong business interest in under- report.37 Notably, this report also includ- or funded university research programs. standing and controlling the weather to ed a long discussion on then-emerging protect high-value assets and their core climate science and the risk that accumu- One example of the latter is the Universi- markets, and they used their well-re- lating carbon dioxide in the atmosphere ty of California San Diego Center for sourced and sophisticated research appa- could lead to global warming.38 Energy Research,41 created in 1974 via a ratuses to explore their options. grant from the Gulf Oil Foundation.42 In In 1974, Colorado State University pub- addition to several studies relating to cli- Second, these companies saw opportuni- lished a book-length report entitled mate change generally,43 the Center also ties to use waste or by-products of their Weather Modification by Carbon Dust Ab- investigated options for modulating solar production processes—such as carbon sorption of .39 Two of the four radiation balance to combat the effects of black and asphalt—as new profit centers, authors of this report, M.L. Corrin and increased carbon dioxide accumulating in much as they did after 1950 with chemi- C.A. Stokes, had deep fossil fuel industry the atmosphere.44 One of the authors of cals now used for . connections, working for Philips Petro- this paper was directly funded by Shell’s leum and Citgo, respectively.40 This re- graduate funding program.45 Finally, these companies developed a port evaluated the idea of spraying large deep expertise and understanding of wind amounts of carbon black, or soot, in dif- and rain patterns and the manipulation of ferent ways to absorb solar energy and The Importance of incoming solar radiation. Though these modify the weather or climate. preliminary studies may not have been Acknowledging this conducted to combat climate change or This report is significant for several rea- Early Fossil Fuel provide potential alternatives to emissions sons. First, the authors both identify the reduction, once the debate over how to industry’s clear financial incentive in Interest adapt to climate change and the subse- modifying weather to diffuse tornadoes quent debate over whether or not to en- and hurricanes, among other applica- The purpose of identifying this connec- gage in geoengineering began in earnest, tions, and note the utility of using fossil tion is not to claim that all academic in- these companies were better positioned fuels—in this case, petroleum to make terest in weather modification or climate than almost any other institutions to un- carbon black—for these applications. Sec- control stems from fossil fuel industry derstand the parameters of that debate. ond, the report identifies a meso level of funding. As mentioned in the introduc- weather and climate modification, where- tion, there are and always have been well- FUEL TO THE FIRE 13

PART 4 Carbon Dioxide Removal and Negative Emissions: The Pervasive Role of Carbon Capture, Use, and Storage

Most geoengineering approaches being fuel or bioenergy production and use, as Direct air capture, although distinct from actively explored rely on the effective and well as on the social, environmental, and carbon capture from flue gases, would widespread deployment of some form of food security impacts of producing biofu- require the deployment of even more en- carbon capture and storage or carbon els at the scales required to create mean- ergy-intensive technologies and would capture, use, and storage (CCUS). ingful emissions reductions. As its name still require the storage or productive use

implies, however, BECCS will also re- of enormous quantities of harvested CO2. For example, most debate on bioenergy quire the deployment and operation of with carbon capture and storage has CCS infrastructure at an unprecedented Many proposals for enhanced weathering rightly focused on the lifecycle green- scale and in a manner that is economical- or carbon mineralization rely on concen- house gas and pollutant emissions of bio- ly viable. trated streams of carbon dioxide generally

FIGURE 3 ExxonMobil Webpage on Carbon Capture and Storage

Developing Cutting Edge Technology – Carbon Capture and Storage, EXXONMOBIL, https://corporate.exxonmobil.com/en/technology/carbon-capture-and-storage/ carbon-capture-and-storage/developing-cutting-edge-technology-carbon-capture-and-storage (last visited Jan. 3, 2019). 14 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

operating at industrial point sources, or by Shell in 2018, called its Sky Scenar- er, SRM proponents must assume that would arguably constitute forms of waste io.50 The Sky Scenario purports to pres- mitigation efforts will move so slowly that management and storage for coal fly ash ent a potential pathway for the world en- sustained SRM deployments may be nec- (a residual from coal combustion) and ergy transition to achieve the goals of the essary, but just rapidly enough that excess other industrial wastes. Paris Agreement. The scenario, however, GHG concentrations can nonetheless be relies extraordinarily heavily on deploy- brought down to safe levels without re- As discussed more fully herein, CCUS ment of CCS, both to capture fossil fuel course to CDR technologies. technology has been disproportionately emissions and for use with bioenergy. funded, promoted, and controlled by fos- The scenario requires that at least 10,000 Carbon In, Carbon Out: sil fuel companies. CCUS is valuable to major CCS facilities be constructed, de- the fossil fuel industry in three key ways: spite acknowledging that fewer than 50 Captured Carbon and it expands oil production, provides a life- are in operation today.51 Significantly, Enhanced Oil Recovery line to a declining coal industry, and fur- positing CCS deployment at this scale ther entrenches the overall fossil fuel permits Shell to project continued heavy The technology required to remove car- economy. reliance on fossil fuels, particularly oil bon dioxide from gas streams has been and natural gas, until 2100. around for over 70 years.54 While compa- For oil companies, CCS presents an op- nies such as Exxon have recognized the portunity for additional oil production The relationship between CCUS and potential value of these technologies in because the primary uses of captured car- geoengineering strategies based on solar addressing climate change since at least bon thus far identified are the production radiation modification is more complex. 1980,55 the historic development of CO of more oil or other petrochemical prod- 2 Even proponents of capture has been primarily driven by ucts. Exxon proudly declares that it has “a acknowledge the risks of termination commercial purposes unrelated to climate working interest in approximately one- shock—that once SRM begins, any re- mitigation. quarter of the world’s total carbon cap- duction in SRM intensity would lead to 46 ture and storage (CCS) capacity[.]” catastrophically rapid atmospheric warm- The most widespread and commercially Chevron “has invested more than $75 ing unless and until atmospheric green- important of these purposes is enhanced million in CCS research and develop- house gas concentrations have been re- oil recovery (EOR). EOR is a technique 47 ment over the last decade.” BP, in addi- turned to lower levels.52 Accordingly, for extracting new oil from a depleted tion to its seventeen-year sponsorship of many proposed SRM strategies explicitly well—that is, from a once-productive the Carbon Mitigation Initiative, is a cur- presuppose the widespread deployment of well that can no longer be commercially 53 rent sponsor of the CO2 Capture CCS. In the absence of CCUS, howev- exploited through other economic means. Project.48 And Shell has a working inter- est in four CCS projects, discussed in greater detail below.49 FIGURE 4

For coal producers and power generators, Type of CO2 utilization patents especially coal-fired power plants, CCS provides a lifeline to keep the industry operational in a carbon-constrained world. Finally, for all fossil fuels, the promise of technologies that purport to ameliorate the climate crisis while leaving the fossil-based global energy system fun- damentally unchanged provide social, political, and economic cover for compa- nies to advocate for and assume the con- tinued economic viability of that system.

As a result, incentivizing CCUS through policy and relying on it in planning will likely slow the transition away from fossil fuel investments and undermine broader efforts to mitigate climate change.

Rahmad Norhasyima & T.M. Indra Mahila, Advances in CO Utilization Technology: A Patent Landscape Review, 26 This centrality is made explicit in one 2 J. OF CO2 UTILIZATION 323 (2018), https://www.sciencedirect.com/science/article/pii/ proposed two-degree pathway published S2212982018301616. FUEL TO THE FIRE 15

By injecting highly-pressurized CO2 and CCS and geoengineering strategies that cluding plastics, petrochemicals, synthetic water into a depleted well, oil companies encourage CCS because EOR remains fuels, and cements.64 As noted by the can force remaining oil to the surface and the key driver of profitable CCS deploy- Global CCS Institute, however, “the mar- extract it for sale and use.56 Put more sim- ment. Despite decades of research into ket for products derived from non-EOR ply, EOR is a means of oil production, the process, fossil energy with carbon cap- use of CO2 is small relative to what is 65 and its critical input is condensed CO2. ture and storage, especially coal-fired needed to be stored.” The Norway-

Anything that makes that CO2 cheaper power with CCS, cannot compete with based research group NORCE, which will enable oil companies to extract ever the ever-falling cost of renewable ener- actively advocates for CCUS, echoed this more oil from depleted wells, whereupon gy.60 The ability to sell the carbon dioxide view in a presentation at the 2018 climate it will be burned—and emitted to the to an EOR operator is the primary ave- negotiations in Katowice, Poland, observ- atmosphere—just like any other fossil nue through which this expensive process ing that EOR is “currently the only com- fuel. can become profitable. mercially ready process allowing for si- multaneous utilization and storage The first patent for EOR with carbon As a case in point, even with government (CCUS) of industrial-scale volumes[.]”66 dioxide was granted in 1952;57 and by incentives,61 as of December 2018 there Thus, even if one ignores the environ- 1984, the industry was explicitly touting were only two large-scale fossil energy mental and climate impacts of their pro- the technology’s importance to long-term power plants with carbon capture units duction and use, these non-EOR prod- oil production.58 Today, the vast majority operating: the Boundary Dam project in ucts (other than transportation fuels) are of carbon dioxide used in industrial pro- Canada and the Petra Nova plant in the likely to account for only a small fraction 62 cesses is used for EOR, and EOR is ex- . Both are coal-fired, and of CO2 use for the foreseeable future. pected to remain the dominant use of both use the captured carbon dioxide for 63 industrial CO2 for the foreseeable fu- EOR. This reality is reflected in a 2018 land- ture.59 scape review of patents in the CCUS Increasingly, proponents of carbon cap- space. Patents for EOR and enhanced The role of CO2 in EOR is critical to un- ture claim that captured CO2 can be used coal bed methane production accounted derstanding the viability and value of in the production of other products, in- for more than a quarter (26%) of the

FIGURE 5

CO2 Emissions/Storage Balance from Simulated CO2-EOR Case Study

Presentation, Roman Berenblyum, NORCE, Regional business case for CO2-EOR and storage – the subsurface solution toolbox, at 4, http://cop24.co2geonet.com/ media/10127/5_regional-business-case-for-co2eor.pdf (last visited Feb. 6, 2019). 16 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

cally feasible. Moreover, even in those FIGURE 6 CO2 Emissions from Developed Fossil Fuel Reserves, Compared to Carbon Budgets countries where EOR capacity is substan- within Range of the Paris Goals tial, proponents of large-scale CCS de- ployment acknowledge that EOR wells are not a sufficiently large reservoir for stored carbon dioxide.69 Despite the in- dustry’s extensive research into carbon storage,70 as well as research from institu- tions such as the International Energy Agency,71 underground carbon dioxide storage has not been demonstrated to work at the scale needed for the global deployment of CCS some advocates sup- port.

More fundamentally, the oil and gas in existing developed wells already exceeds the total remaining carbon budget needed to give the world even a 50% chance of keeping total rise below 1.5 OIL CHANGE INTERNATIONAL, DRILLING TOWARDS DISASTER: WHY U.S. OIL AND GAS degrees Celsius. Adding developed coal EXPANSION IS INCOMPATIBLE WITH CLIMATE LIMITS 5 (2019), http://priceofoil.org/content/ reserves and cement brings the cumula- uploads/2019/01/Drilling-Towards-Disaster-Web-v2.pdf. tive emissions embedded in the existing fossil fuel resources perilously close to 2.0 degrees even if no new fossil resources 72 3000 patents identified. An additional 200,000 tons of CO2 emitted by the pro- were developed.

53% of patents covered the use of CO2 in duced oil until the well is fully depleted. chemicals or as fuels.67 To reverse these resulting emissions, a In view of the IPCC’s clear warnings that a rapid and dramatic transition away further 200,000 tons of CO2 must be Accordingly, calls for additional CCS or injected into the now fully depleted well from fossil fuels provides the best hope CCUS—or for geoengineering tech- long after the economic incentives for for keeping warming below 1.5 degrees, niques reliant thereon—should primarily doing so have ceased to exist. Yet it is any policy that would promote fossil fuel be understood to drive the expansion of only after these emissions from the pro- production in the name of climate miti- enhanced oil recovery or the production duced oil have been fully offset, and the gation faces a heavy—and likely insur- of combustible fuels. This EOR, in turn, energy penalties that arise from carbon mountable—burden of proof. will necessarily lead to the increased pro- capture itself have been accounted for, A recent change in US law serves as a case duction and consumption of oil, the in- that a CO -EOR project could begin hav- 2 in point. creased GHG emissions that arise from ing any measurable positive impact on its combustion, and increased invest- emissions. ments in the infrastructure for producing, Promoting CCS, DAC, and EOR in distributing, and using fossil fuels. Even were this not the case, EOR faces the US Tax Code two further and fundamental limitations A “Simulated Case Study” of a 20-year when viewed in the context of the global In mid-2018, the US Congress passed the CCS-EOR project presented by NORCE climate crisis. First, and fundamentally, Furthering carbon capture, Utilization, demonstrates one common explanation both the climate crisis and sources of fos- Technology, Underground storage, and for how CCS-EOR would reduce emis- sil fuel emissions are global in nature. Reduced Emissions (FUTURE) Act, sions, as well as the manifest problems Accordingly, to contribute to meaningful which altered a tax credit under Section with that theory.68 (See Figure 5.) In the GHG reductions on a global basis, EOR 45Q of the US Internal Revenue Code.73 simulation, a CCS project begins inject- would need to be available and economi- Prior to the changes, the provision pro- ing CO into a depleted well in 2026, 2 cally viable in the areas where the most vided a tax credit for the underground leading to a massive increase in the oil intensive emissions occur. In reality, how- storage of CO . The credit was worth $20 production from the well. Over the ensu- 2 ever, there is a substantial disconnect be- per metric ton for CO stored in geologic ing three years, from 2026-2029, the rela- 2 tween the areas where large emissions formations, and $10 per ton for CO tively modest amount of CO stored by 2 2 sources are concentrated and areas in used as an injectant for enhanced oil re- injection is dwarfed by an additional which EOR is technically and economi- covery. FUEL TO THE FIRE 17

The FUTURE Act modified Section 45Q Accepting, for the sake of argument, the contrary study of coal-fired power plants in several critical respects. First, it dra- optimistic replacement value claim, the in —suggesting that CCS retrofits matically expanded the size of the credit: structure of the incentive serves to benefit might be economic, particularly if the

up to $35 per metric ton of CO2 used for fossil fuel-based power generation and CO2 was used for EOR—acknowledged EOR or otherwise utilized, and up to $50 make it more difficult to take meaningful that new solar power plants would be

per metric ton of CO2 stored in geologi- climate action. Because the expanded tax more cost effective in most circumstanc- cal formations.74 Significantly, the FU- credit applies to new carbon capture facil- es.83 This study highlights that, for many TURE Act also extended these credits to ities, the effect of the tax credit—and its advocates, CCS is viewed less as a neces- the use of CO2 in chemicals or in any clear intention—will ultimately be to sary step to meeting energy demand in a product for which a commercial market subsidize the deployment of CCS units carbon-constrained world than as a exists. It made direct air capture projects on power plants where they did not exist means of keeping coal economically via- eligible for the credit for the first time. It before, and therefore subsidize those facil- ble in a world of declining carbon bud- also lowered the thresholds for the ities themselves. Not only does this risk gets and rapidly falling renewable energy amount of carbon a facility must capture extending the life of fossil fuel-powered prices.

to qualify for the credit. CO2 capture fa- facilities already in existence, but some cilities that begin construction before Jan- analysts have suggested that it may even Missing from the calculation of the car- 81 uary 1, 2024, are eligible for such credits spur new coal or gas plant construction. bon intensity of oil produced via CO2- for twelve years. EOR is the fact that the carbon dioxide The vast majority of EOR projects (and used must have come from an emissions As the NORCE presentation above dem- CCS projects generally) have been initi- source such as a coal or gas power plant— onstrates, even proponents of EOR ac- ated in or proposed for the United States, or, for that matter, a or direct air knowledge that the process of producing, which has the second largest coal fleet in capture facility—for it to be considered a refining, and combusting oil results in net the world after China, as well as one of carbon emissions reduction. This gives carbon emissions, even when carbon di- the oldest fleets. Yet a 2012 global assess- rise to a significant risk of double-count- oxide is stored in the wells used for ment of the viability and potential for ing reductions. For example, the “simu- 75 EOR. retrofitting existing coal-fired power sta- lated case study” of CO2-EOR discussed tions found only 4-25% of installed coal in the preceding section does not appear

Some EOR proponents argue that the capacity in the US was potentially suit- to account for the actual CO2 emissions emissions from the produced oil can be able for CCS retrofit, and that at most source in calculating the emissions bal- ignored because oil from EOR will dis- 6% of installed capacity at least moder- ance for the project. Similarly, one group place other, purportedly more carbon-in- ately suitable for retrofit.82 Indeed, even a supporting the changes to 45Q notes in tense oil from the markets. 76 In the US context, however, the Department of En- ergy’s analysis did not assert EOR would reduce US domestic oil production. In- deed, DOE argued that “increasing do- mestic oil production” would be an “im- portant co-benefit” of promoting CO2- EOR.77

Claims that oil from CO2-EOR would displace more carbon-intensive oil on global markets, instead of adding to the abundant supplies of government-subsi- dized oil on those markets, rely heavily on assumptions and forecasts that are, at best, highly disputed. While optimistic supporters claim that over 80%78 of the oil produced via new EOR will displace oil that would have been produced any- way, other projections suggest a much lower displacement value, closer to 50%.79 In that case, the proposed emis- sions benefits of EOR disappear.80 18 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

their fact sheet that the new tax credits ClearPath, a nonprofit established to “ac- To transform this vision to reality, Clear- both reduce emissions from the US pow- celerate conservative energy solutions,” Path’s founder created the ClearPath Ac- er sector and reduce the carbon intensity makes this case explicit in addressing tion Fund, a political SuperPAC ostensi- 84 of oil produced via CO2-EOR. This What Carbon Capture Means for Natural bly designed to support Republican clean double-counting—of treating both fossil- Gas: energy champions in the United States energy CCS and CO2-EOR as indepen- Congress. As noted by the League of dently valuable for emissions reduction, “Carbon capture is not just crucial to Conservation Voters, recipients of Clear- when in actuality they are linked—allows the future of coal, it’s a valuable insur- Path’s largesse, like Republican Represen- proponents to gloss over the way in ance policy for our booming natural tative Fred Upton, have a demonstrated which this change in US federal tax poli- gas industry. This technology protects record of supporting the fossil fuel indus- cy amounts to a subsidy further entrench- our gas industry from whatever super- try, but an altogether weaker record when ing the fossil fuel industry. charged a future it comes to supporting climate action and Democratic White House will inevita- promoting the deployment of renewable Moreover, were more ambitious climate bly throw at the power sector, while energy.87 policies put in place, carbon-emitting reducing emissions affordably now. entities would be insulated twofold by But without a targeted policy lever Some advocates of the changes to the tax these subsidies: The emissions would be (such as the 45Q tax credit extension credit assert that even if EOR increases lower, due to the carbon capture, and currently being considered by Con- oil production and emissions in the near their ability to absorb costs would be gress) to advance the technology be- term, the credit is necessary to spur the greater due to the subsidization of their fore environmental regulations hit, the development of direct air capture tech- activity. industry will be vulnerable.”85 nologies which will eventually be de- ployed at greater scale. Observers have This is the risk of policy options like the A 2018 report funded jointly by Clear noted that the evidence is limited that the new Section 45Q tax credit. It purports Path and the coal industry’s Carbon Uti- new tax credits will accomplish the DAC- to be climate policy, and it may lead to lization Research Council quantified how promotion goals proponents wish to see,88 marginal emissions reductions in limited the coal, oil, and natural gas industries all a risk fundamental to policies like this circumstances. But the tax credit func- stand to benefit from the push for CCS. and those that would promote DAC gen- tions as a subsidy to the fossil fuel indus- The report concluded that, in the United erally. For reasons discussed in the section try, prolonging and expanding a business States alone, active promotion of CCS on DAC, however, this argument appears model that needs to be radically phased could drive “up to a 40% increase in coal equally at odds with the systemic changes down. production for power from 2020 to necessary to transition to a low-carbon 2040” and generate up to “923 million economy. additional barrels of oil produced annual- ly by 2040.”86

FIGURE 7 Coal Industry’s Vision for CCS: Smokestacks and Rainbows

CO2GEONET, http://www.co2geonet.com/home/ (last visited Feb. 6, 2019). FUEL TO THE FIRE 19

How Carbon Dioxide Viewed in light of rapidly changing In stark contrast to aging coal plants in trends in the industry, CCUS appears the US and Europe, most of China’s coal Removal will “Save” more necessary for the preservation of fleet is relatively new and constructed at the Coal Industry coal than the reduction of emissions from the very large scales considered necessary the energy sector. The International En- for efficient carbon capture. As detailed Carbon capture and storage is commer- ergy Agency (IEA) noted in a 2017 spe- by IEA, the potential for CCS retrofits 98 cially valuable for oil producers because cial report that global demand for coal for China’s coal fleet is enormous. of carbon dioxide’s usefulness in en- had fallen precipitously for two years These investments, however, are not ma- 92 hanced oil recovery. It is valuable for straight. Moreover, IEA noted that the terializing. Instead, the bulk of CCS proj- large point-source producers of carbon decline in coal consumption was not lim- ects in China are planned for use in con- dioxide as a way to keep current business ited to Western Europe and North Amer- junction with enhanced oil recovery, not models intact and resilient to additional ica, but included a decline in China as as part of a fleet-wide strategy to reduce 93 climate policies. For coal-fired power well. Consistent with this trend, a re- emissions from coal combustion. China’s generation specifically, it is becoming cent ClimateScope report from Bloom- CCS program is not only extremely lim- ever clearer that policy support for CCS, berg observed that in 2017, for the first ited, but also heavily dependent on 99 and therefore for coal-fired power, is nec- time ever, “renewables accounted for the EOR. China currently has one large- essary for the long-term viability of the majority of all new power-generating ca- scale CCS facility operating, which uses 100 industry. pacity added” and “the large majority of the carbon dioxide for EOR. Of the the world’s new zero-carbon power ca- eight additional planned or proposed While awareness of the GHG impacts of pacity was built in developing coun- large-scale projects, five plan to use the fossil gas continues to expand, coal re- tries.”94 As IEA acknowledges in its spe- captured carbon dioxide for EOR, with mains widely recognized as the most car- cial report, “without CCUS, coal use will the other three still investigating potential bon intense of the fossil fuels and the be seriously constrained in the future.”95 uses.101 Both the deployment of CCS and most vulnerable to climate policies in the the use of the captured carbon for EOR near term. Moreover, because coal is pri- are positioned as ways to preserve the ex- marily used for large-scale power genera- “CCUS appears more necessary for isting coal fleet rather than as means of tion, it competes with ever-cheaper re- the preservation of coal than the reducing emissions. newables, as well as other forms of power reduction of emissions from the generation (including natural gas). energy sector.” Industry’s Pervasive Much of the advocacy for development Role in CCS Research and deployment of CCS or CCUS is pre- and Policy mised on the assumption that coal will be IEA’s Greenhouse Gas R&D Programme (IEAGHG), whose members include sev- a necessary part of the energy mix for de- In addition to their direct investments in eral major fossil fuel companies and util- cades to come and, specifically, that de- commercial CCS, CDR, and EOR ven- ity operators, made this case more explic- veloping countries will continue to mas- tures, fossil fuel companies have been in- itly in a presentation at the 2018 UN sively expand their coal fleets. Therefore, strumental in the funding, communica- climate negotiations in Katowice, Poland. proponents argue, the global community tion, and advocacy of CCS research and As they note, “CCS enables access to sig- must deploy CCS or CCUS units around CCS policies through a wide array of cor- nificantly higher quantities of fossil fuels the world to account for this growth porate consortia and industry groups, in a 2°C world.” Put more bluntly by the while meeting the goals of the Paris joint industry-government working 89 IEA’s representative, “CCS unlocks ‘Un- Agreement. Yet not even the most opti- groups, and funding partnerships with burnable Carbon.’”96 mistic projections for coal with CCS sug- universities, non-profits, and individual gest the CO emissions in flue gases could 2 The limited deployment of CCS in Chi- researchers. be fully captured,90 and actual rates of na once again demonstrates the centrality capture can be much, much lower. Even Given its importance to their interests of EOR to the operation of carbon cap- with CCS, therefore, fossil energy still and their future, it is not surprising that ture. China contains the world’s largest emits carbon dioxide into the atmo- fossil fuel companies and industry groups coal fleet. As noted by the IEA, China has sphere. And, as concluded by a recent would be active in the development and added significant coal capacity in recent report from the Institute for Energy Eco- promotion of CCS. At the same time, the years, and “[r]educing greenhouse gas nomics and Financial Analysis, despite central commercial incentive underlying emissions while expanding electricity use decades of research into CCS for coal, the their engagement—the perpetuation and in China’s growing economy is likely not process remains “unworkable and too continued expansion of the fossil fuel in- achievable without the early retirement of expensive for fast-changing electricity- dustry—cannot and should not be ig- many coal plants or carbon capture and generation markets[.]”91 nored. From coal plant to oil well, fossil storage (CCS) retrofits.”97 20 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

fuel companies directly and indirectly tionally sponsored by Chevron, Exx- • In 2008, Peabody and Arch Coal benefit from the promotion of CCS and on, Shell, and other fossil fuel com- launched the Consortium for Clean EOR. Payments for capturing or storing panies.103 Coal Utilization at Washington Uni- carbon dioxide, such as those in the Sec- versity in St. Louis.109 tion 45Q tax credit, present a subsidy to • Since funding its creation in 2000,104 both fossil-based power producers and BP has been the primary sponsor105 In addition to funding these university EOR operations. Moreover, payments to of the Carbon Mitigation Initiative programs—most of which still participate reduce the carbon intensity of coal or gas (CMI) at Princeton University, in climate debates today—fossil fuel com- power plants make such plants more resil- which “aims to identify the most panies also funded the creation or opera- ient to carbon pricing or other forms of credible methods of capturing and tion of industry consortia to pursue CCS, climate action, despite failing to eliminate sequestering a large fraction of car- often in conjunction with governments. emissions of carbon dioxide. Finally, be- bon emissions from fossil fuels[.]”106 cause public resources and political capi- Among the earliest and most influential tal are finite, action on or even debate • The same year, fossil fuel companies of the latter is the International Energy 110 over CCS promotion serves to distract also funded the Carbon Sequestra- Agency’s Greenhouse Gas R&D group. from, rather than reinforce, more produc- tion Initiative at MIT, “an industrial Established in 1991, IEAGHG’s mem- tive action on climate change. consortium formed to investigate bership includes major fossil fuel produc- carbon capture and storage technolo- ers (Exxon, Chevron, Shell, Total, RWE, Major oil, gas, and coal companies have gies,” which ran from 2000 until and PetroBras), utility operators and in- created numerous institutes at universities 2016.107 dustry groups (Southern Company, J- to study and promote CCS. For example: Power, EPRI, and Coal Industry Adviso- • In 2002, Exxon, among others, ry Board), and government parties. • In 1998, BP and Kinder Morgan launched the Global Climate and Among the governments, several are actu- spurred the creation of the Gulf Energy Project at Stanford Universi- ally represented by state-owned enterpris- Coast Carbon Center at the Univer- ty.108 es in the fossil fuel or energy sector (Equi- sity of Texas,102 which is now addi- nor (formerly Statoil)). IEAGHG “stud-

FIGURE 8 Membership of IEA’s Greenhouse Gas R&D Programme

Guide to Membership, IEAGHG, https://ieaghg.org/ (last visited Feb. 6, 2019). FUEL TO THE FIRE 21

ties, the Institute is active at the UNFCCC climate negotiations.124

The coal industry separately operates the World Coal Association (WCA), “the only organization that works on a global basis on behalf of the coal industry.”125 This includes advocating for significant (additional) public incentives for CCUS and asserting that zero-emission coal is not only possible but should be a critical part of the solution to climate change.126 Membership for the WCA includes over thirty coal companies, associations, and research groups.127

Finally, in the United States, the Carbon Capture Coalition promotes CCS re- search and deployment. Participants in the coalition include coal, oil, and gas

© VATTENFALL VIA VIA FLICKR VATTENFALL © companies, as well as other industrial ac- tors.128 After the passage of the reformed Section 45Q tax credit, the Coalition de- ies and evaluates technologies that can Finally, a collection of major oil and gas clared that it had “achieved its top federal reduce greenhouse gas emissions derived companies participate in the Oil and Gas priority.”129 This should not be surpris- from the use of fossil fuels,”111 with a fo- Climate Initiative (OGCI).118 This initia- ing, given that when the group was cus on CCS.112 IEAGHG purports to tive, announced in 2014, directs invest- formed in 2011, it was originally called offer only expert opinion rather than pol- ment into CCUS research, among other the National Enhanced Oil Recovery Ini- icy recommendations. As an IEA imple- things.119 In 2018, Exxon, Chevron, and tiative.130 menting agreement, however, IEAGHG joined the OGCI, has a substantial impact on IEA assess- which was cast in media coverage as a This key understanding is especially im- ments of the feasibility and value of CCS major breakthrough, despite the fact that portant when evaluating policy options in technologies. the commitment only raised research response to the climate crisis. Significant funding to $1 billion in total.120 As some public funds have already been invested In 2000, fossil fuel companies formed the observers noted, “The $100 million each in the development of CCS. In Europe, Carbon Capture Project as an industry member commits is a tiny fraction of the European Union and European states collaboration to advance CCS technolo- their overall expenditure and the group have been funding research into under- gy.113 The project has been funded or has been criticized for a lack of ambition, ground storage of carbon dioxide since 131 sponsored by individual corporate mem- and because part of its rationale is to ex- 1990, and in 2009, the EU allocated bers, the United States and Norwegian pand the use of gas.”121 one billion euros to CCS projects specifi- governments, and the European cally.132 As described above, the govern- Union.114 In addition to these institutions pursuing ments of the United States, European CCS directly, fossil fuel companies also Union, and Norway have contributed to In 2009, the US Department of Energy fund a variety of industry bodies and the Carbon Capture Project, and the US (DOE) created the National Carbon front groups to promote CCS to govern- DOE founded and continues to fund the Capture Center (NCCC).115 The NCCC ments and the public. One of the primary National Carbon Capture Center. Over- is funded through a cost-sharing agree- organizations advocating the widespread all, the US government has been funding ment between DOE and several corpo- deployment of CCS is the Global CCS CCS research since 1997,133 with over $5 rate partners, including Southern Com- Institute.122 The Institute lists its goals as billion appropriated since 2010.134 These pany (which manages and runs the cen- building knowledge of CCS, shifting the public expenditures, especially in the ter), Duke Energy, Peabody, Cloud Peak narrative surrounding CCS, and enabling United States, continue today. Without a Energy, American Electric Power, and investment into CCS. Members include a radical shift in public understanding, they Exxon.116 According to a press release, wide array of coal, oil, and gas compa- are likely to increase. Arch Coal was a corporate sponsor as nies, as well as utilities, energy compa- well.117 nies, and others.123 Among other activi- 22 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Carbon Dioxide This distinction was recently put in stark • Boundary Dam is a CCS project at a relief in the United States. BP claimed in coal-fired power plant in Saskatche- Removal and Oil’s the 2018 edition of its energy outlook wan, Canada. The carbon seques- Plans for the Next that “we continue to believe that carbon tered from this plant will be primar- pricing must be a key element of any such ily used for EOR.144 Petroleum Century approach as it provides incentives for ev- eryone—producers and consumers • Quest is a CCS operation in con- The lack of significant progress in CCS alike—to play their part.”140 Nonetheless, junction with the Athabasca Oil deployment over the past several decades the company spent $13 million last year Sands Project in Alberta, Canada.145 has not stopped the major fossil fuel com- to oppose a proposal in the Captured CO2 is intended solely for panies from including it in their outlooks US state of Washington.141 storage, not for use. However, the and projections. Many of the largest oil project is only operational because of and gas companies rely on the promise of Fossil fuel companies similarly have a government funding. As noted on CCS or CCUS in their long-term fore- long history of funding opposition to ac- the Shell website, Quest “was made casts and marketing materials to square tion on climate change, much of it con- possible through funding for CCS the continued expansion of fossil fuel current with their investments in carbon from the governments of Alberta and production with a rhetorical commitment capture and storage.142 Even staunch pro- Canada, which provided C$745 mil- to a low-carbon future. ponents of CCS acknowledge that it must lion and C$120 million of funding be combined with a larger set of climate respectively.”146 It is critical to examine what integrated policies to achieve the Paris goals. Promo- oil and gas companies say about the role tion of CCS, in the absence of robust • Shell co-owns with Gassnova SF, of carbon capture: CCS and CCUS are climate policy, must be understood as A/S Norske Shell, Sasol, and Statoil not a solution to climate change in any something quite different—a form of ASA, a CCS research center in Nor- meaningful way, but rather a means of technological and economic entrench- way. The Technology Centre Mong- averting material regulation of their prod- ment that serves the interests of the in- stad (TCM) is not commercial, but ucts or, in the case of EOR, expanding dustry, not the climate. This understand- rather a test facility to improve CCS production. ing should inform debates over the role of methods, and has been operational CCS in climate policy and illuminate the since 2012.147 The most striking example of this is current state of fossil fuel industry invest- Shell’s Sky Scenario.135 Shell proposes an ment in and advocacy for CCS. • The Gorgon liquefied natural gas ostensibly “net-zero emissions” world that (LNG) project is a partnership still relies on fossil fuels for 30% of ener- Fossil fuel companies have invested and among Shell, Chevron, Exxon, and gy production through at least the end of continue to invest extensively in develop- others at Australia’s Gorgon LNG this century, with the continued high ing and, critically, promoting carbon cap- field. The Gorgon gas field contains combustion of fossil fuels theoretically ture and storage. The claim that carbon 14% naturally occurring CO2, and 136 offset by CCS and BECCS. Other capture will be a critical part of the solu- so would be a massive point source if 137 138 companies, including Exxon, BP, tion to climate change is valuable to the that carbon dioxide were not man- 139 and Total similarly assert the need to industry because of both the windfall it aged.148 As a result, the project will include significant deployment of carbon stands to gain from incentives and the include a carbon dioxide injection capture to meet emissions reduction tar- built-in assumption that CCS is necessary unit. The overall Gorgon project gets. Critically, in all projections, the pro- because fossil fuels remain central to cost is estimated at $55 billion, with duction and consumption of oil and gas global energy production. The acceptance the CCS unit adding another $2 bil- remain robust through the window of the of this assumption thus provides the de- lion.149 Sponsor companies claim projection, as far out as 2100 in Shell’s lay in transition that is the very justifica- that, once completed, it will be “the Sky Scenario. tion for the rush to geoengineering in the world’s largest commercial-scale car- first place. bon dioxide injection project.”150 There is a massive difference between Notably, project sponsors are not positive incentives (like those in Section Shell’s Role in Carbon Capture planning to sell the carbon dioxide 45Q) and negative incentives (like carbon for use in EOR or other applications. taxes). While both can theoretically stim- and Storage: A Case Study Rather, the CCS unit is being added ulate the deployment of CCS, positive because Australian law requires that incentives do so by providing additional Four CCS projects by Shell provide a use- at least 80% of carbon dioxide pro- income to fossil fuel companies, whereas ful illustration of the inherent problems duced from the gas field be captured negative incentives internalize those costs with pursuing CCS as a front-line strat- and stored, or that the company pay to companies. egy to combat climate change.143 for offsets if it fails to do so. The ex- pectation of additional carbon taxes FUEL TO THE FIRE 23

Direct Air Capture: Turning Renewable Energy into New Carbon Emissions

Direct air capture is the process of pulling carbon dioxide molecules from ambient air as opposed to removing them from waste streams, where they exist in consid- erably greater concentrations. Because it

must collect CO2 from the ambient air, where carbon dioxide exists in extremely low concentrations relative to industrial point sources, DAC is much more expen- sive per ton of carbon dioxide removed than CCS and is far more energy inten- sive.

Because DAC does not (directly) rely on

© WTSHYMANSKI VIA VIA WTSHYMANSKI WIKIPEDIA ENGLISH © the combustion of a fuel to operate, how- ever, it is widely promoted as a negative emissions technology and hailed by some may provide another motivation for to promote CCS. As evidenced by the op- proponents as the holy grail of CDR the project.151 The Gorgon CCS unit eration of TCM (and decades of fossil technologies.154 In a 2015 review of re- does not reduce emissions from the fuel industry investment in CCS research search and patent filings in geoengineer- combustion of gas, but rather pre- and development), research costs can and ing, patents for CDR related to direct air vents emissions of CO2 in the gas will be borne by the industry, appropri- removal technologies comprised nearly well that would have otherwise been ately internalizing the cost of one-third of all patent families and more vented into the atmosphere. Due to abatement to polluting industries. For than 44% of total patents filed world- delays in construction of the CCS commercial applications, whether as a wide.155 unit, however, carbon dioxide is be- response to climate policy or positive in- ing vented anyway, leading to a mas- centives promoting CCS, companies will The idea of scrubbing carbon dioxide sive increase in Australia’s green- install CCS units at their facilities if it directly out of the air is not new, with house gas emissions.152 makes economic sense to do so. Where demonstrations dating at least as far back climate policy is in place, they may do so as 1946.156 It wasn’t until 1999, however, These four projects demonstrate the as a business decision, internalizing the that “[s]crubbing ambient air as a means range of CCS financing options. The test costs of their carbon emissions, as at the of reducing greenhouse gas emissions was facility operates as industrial research for Gorgon site. In those rare instances where first suggested[.]”157 the companies involved, and is paid for capturing carbon dioxide for use is eco- primarily by them. Boundary Dam pro- nomical, the industry may deploy CCS as This suggestion came from Klaus Lack- duces carbon dioxide for use in EOR, and well, as at the Boundary Dam power ner, Patrick Grimes, and Hans-Joachim intends to profit from the process. The plant (although that project is facing fi- Ziock in a paper submitted to the 24th Quest facility produces carbon dioxide nancial challenges).153 However, to the Annual Technical Conference on Coal directly for storage, but is being subsi- extent that they require EOR to be via- Utilization & Fuel Systems.158 This re- dized by the governments of Canada and ble, such projects will have little, if any, port, entitled Carbon Dioxide Extraction Alberta with nearly 900 million CAD for benefit for the climate. The alternative is From Air: Is It An Option?, laid out the doing so. Finally, Gorgon’s carbon injec- providing an additional profit center for case for direct air capture as a means of tion program is a response to government fossil fuel operations, as in the case of the dealing with the problem of accumulat- policy, existing and expected, and is de- Quest facility, which then also insulates ing carbon dioxide in the atmosphere. signed to internalize the cost of carbon those operations from effective climate Lackner and his co-authors argued that emissions to the companies producing policies. Instead of fossil fuel companies the primary advantage of DAC is that it them. paying for the carbon they produce, they specifically does not require a shift away would be getting paid to reduce what from fossil-based fuel sources.159 They This framework demonstrates why gov- they are already producing. note that successful deployment of DAC ernment resources should not be diverted 24 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

“completely avoids a restructuring of to- There is very little public information In their 2015 review of geoengineering day’s infrastructure, it uses the atmo- about ZECA, and according to Stephen patents, Paul Oldham and his co-authors sphere to transport the carbon dioxide Rackley’s comprehensive book Carbon found that two companies owned or part- from its source to the disposal site and it Capture and Storage, ZECA “disappeared ly owned by Lackner—Global Research would make it even possible to lower the without trace shortly after it was recog- Technologies167 and Kilimanjaro Ener- atmospheric levels of carbon dioxide, if nized by Scientific American as the ‘Busi- gy168—dominated patent filings in the this turns out to be necessary or desirable” ness Leader in Environmental Science’ for field.169 Together, the two companies ac- (emphasis added).160 2003.”163 Lackner now runs the Center counted for 21 initial filings for patent for Negative Carbon Emissions at Arizo- families representing 329 patent family The following year, Lackner founded the na State University.164 The Center ad- members—more than a third of the 910 Zero Emission Coal Alliance (ZECA), vances “carbon management technologies patents identified for the period.170 Kili- whose express purpose was to develop a that can capture carbon dioxide directly manjaro secured its first major invest- new technology for generating zero-emis- from ambient air in an outdoor operating ment from Arch Venture Partners in Au- sion energy from coal. This alliance was environment.”165 While funding for the gust 2010.171 Commenting on the invest- funded by a consortium of US and Cana- Center is difficult to determine, the posi- ment, Arch Ventures explained that Kila- dian coal companies, including Arch tion of a postdoctoral researcher on direct manjaro Energy hoped to make “tril- Coal.161 It was led by Alan Johnson, a air capture is funded by Shell.166 lions” from the deployment of its DAC Canadian coal executive, until 2004.162 technologies in enhanced oil recovery.172 Notwithstanding these early hopes, Kili- manjaro subsequently closed shop due to FIGURE 9 lack of funding.173 Patent Drawing of Direct Air Capture Technology Yet the commercial dreams of Kilimanja- ro’s backers demonstrate that, as in other forms of CCUS, building and operating DAC technology presumes—and de- pends upon—the existence of adequate commercial markets for the captured car- bon. Unsurprisingly, Kilimanjaro saw that market in EOR. Other proponents envision a distinct but no less direct path between their DAC technologies and the fossil economy.

Powering DAC facilities at any significant scale would demand massive amounts of energy, which must come from one of three sources:

• Unabated and high-emitting power plants fueled by coal or natural gas;

• Fossil-fuel-burning power plants equipped with CCS and subject to the numerous limitations and risks described in the preceding sections; or

• Renewable energy sources that would otherwise be directed to other uses that more directly reduce or replace fossil energy demand and use.

In either of the first two scenarios, the Carbon Dioxide Capture and Facility, U.S. Patent No. 9,095,813 (filed Aug. 21, 2009). emissions generated to provide power (and sequester the associated carbon) for FUEL TO THE FIRE 25

Murray Edwards.177 Notably, is FIGURE 10 Carbon Engineering Air-to-Fuels Diagram also a direct funder of Keith’s work at Harvard, sponsoring the Harvard Solar Geoengineering Research Program and, as will be discussed below, funding sever- al workshops and reports on the pursuit of a geoengineering research agenda.

Carbon Engineering has been capturing carbon dioxide since 2015 and has been producing fuels since 2017.178 According to the company, its technology “has sev- eral intrinsic advantages to offer in elimi- nating fossil carbon dioxide emissions from the transportation sector.”179 Cli- mate Engineering claims that its facility

could capture one million tons of CO2 per year, “equivalent to the annual emis- sions of 250,000 average passenger cars.”180 Applying the average vehicle emission rate of 4.6 metric tons per year calculated by the US Environmental Pro- tection Agency181 produces a more realis- tic estimate of 217,000 car-equivalent emissions. At the same time, however, the facility would produce 320,000 liters of synthetic fuel a day. When the emissions from these produced fuels are considered, the climate benefits of the operation are, at minimum, overstated, even before the source of energy inputs and fate of any waste carbon are considered. Assuming Air to Fuels, CARBON ENGINEERING, http://carbonengineering.com/about-a2f/ (last visited Feb. 4, full-time operation and applying the same 2019). EPA emissions factors for vehicles, the fuels produced by the facility would pro- duce 313 million kilograms of emissions a DAC facility would have to be fully models for the three DAC companies per year, equivalent to the emissions of offset by the CO2 it captures before the currently in operation envision the use of 68,000 average passenger vehicles. The facility generates any net CO2 benefit to captured carbon either for EOR or as a climate benefits would be lower still, and the atmosphere. In the third scenario, the competing source of combustion fuel for likely negative, if the captured carbon climate benefit derived from operation of existing fossil-fuel-based technologies. were used to produce jet fuels rather than the DAC facility would need to outweigh synthetic diesel.182 the benefits of putting the substantial Carbon Engineering renewable energy it requires to alternate In January 2019, Chevron and Occiden- uses. Canadian company Carbon Engineering tal Petroleum announced major invest- is emblematic of this approach. Founded ments into Carbon Engineering.183 A Proponents of DAC argue that, even with in 2009 by Harvard professor174 and press release from Carbon Engineering its significant energy penalties, DAC may prominent geoengineering advocate175 notes this added capitalization as the be necessary to draw down emissions , Carbon Engineering holds “first significant collaboration between a from CO2 sources that are not readily multiple patents for technologies to cap- DAC developer and the energy indus- amenable to CCS, such as vehicle ex- 184 ture CO2 from the air and convert cap- try.” Notably, the announcement also haust, and to address emissions in sectors tured CO2 to synthetic fuels or other makes clear that Occidental’s interest in where a transition to cleaner energy uses.176 The company is privately funded, direct air capture is the use of carbon di- sources is difficult, such as aircraft emis- although known investors include Bill oxide in enhanced oil recovery.185 sions. Ironically, however, the business Gates and Canadian tar sands magnate 26 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Global Thermostat mer Exxon executives as well. In 2009, These connections do not suggest undue Chichilnisky and Eisenberger authored a fossil fuel company influence over the Direct air capture company Global Ther- paper, Global Warming and Carbon-Neg- operation of the company, but rather ex- mostat was founded in 2010 by Graciela ative Technology: Prospects for a Lower- pose the intimate relationship between Chichilnisky and Peter Eisenberger.186 Cost Route to a Lower-Risk Atmosphere, fossil fuel interests and the business of While most funding for Global Thermo- which argued for “expanded R&D efforts direct air capture. Global Thermostat stat is private and therefore unknown to aimed at advancing air extraction tech- promotes a carbon capture technique that the public—a recent presentation indi- nology.”188 This paper was co-authored uses process heat from power plants or cates that energy company NRG was an by Chance and Roger W. Cohen, another other industrial sources, and which can early investor187—the company maintains former Exxon scientist turned climate be used to capture carbon dioxide directly significant connections to the fossil fuel skeptic, who was at the time also affiliat- from the air, or from flue gases like con- industry. Moreover, the business model ed with Global Thermostat.189 In 2014, ventional CCS.192 While a flagship proj- as proposed serves the same functions as Eisenberg published another paper, enti- ect to produce carbon dioxide for carbon- carbon capture and storage described tled Control, arguing for the ne- ated beverages has received a great deal of above, entrenching fossil fuel interests cessity of closing the global attention, and while Global Thermostat and expanding oil production. by pulling carbon dioxide out of the at- identifies both plastics and petrochemi- mosphere.190 In the paper, Eisenberger cals as potential mid-term markets, com- Eisenberger is a former Exxon engineer, thanks both Cohen and Klaus Lackner pany statements appear to recognize that and two of the company’s chief advisors, for their contributions.191 the major large-scale markets for captured Ronald Chance and Rocco Fiato, are for-

FIGURE 11 Audi Graphic Showing Use of Direct Air Capture to Produce Diesel Fuels

Fiona MacDonald, Audi Has Successfully Made Diesel Fuel From Carbon Dioxide And Water, SCIENCE ALERT (Apr. 27, 2015), https://www.sciencealert.com/ audi-have-successfully-made-diesel-fuel-from-air-and-water. FUEL TO THE FIRE 27

CO2 continue to lie in EOR and liquid mixes and in modern combustion en- Second, the seeming advantage that DAC fuels.193 gines.196 carbon-based fuels and materials have is that they can substitute for traditionally Like proponents of CCS, Global Ther- This is emblematic of the risks of DAC. produced materials and fuels. But as dis- mostat claims to offer a solution to the As with CCS, the largest and most com- cussed above, and as outlined in the carbon emissions problem of fossil fuels, mercially viable markets for CO2 lie in IPCC’s SR1.5, the solutions that will ostensibly obviating the need to phase the production of new fossil fuels through drive emissions reductions and limit at- fossil fuels out of the energy mix. In both EOR or enhanced coalbed methane re- mospheric warming involve entire para- an article from 2011 and a 2018 presen- covery197 and in the direct production of digm shifts and changes in systems of tation, Chichilnisky explicitly frames transport fuels and, to a lesser extent, transportation, electricity production and Global Thermostat’s technology as a way plastics and other petrochemicals. Propo- distribution, industry and , to protect the $55 trillion in global ener- nents of DAC argue that these new prod- and others. That a fuel can drop in might gy infrastructure.194 ucts—be they plastics, synthetic fuels, or be advantageous for its own use and other materials—would substantially re- adoption, but it further entrenches, rather Climeworks place those produced by fossil fuels, re- than dislodges, the systems and infra- ducing emissions via substitution. This structure upon which the fossil economy Climeworks, the third DAC company argument, however, has several major is built. currently operating, similarly promotes deficiencies. the carbon dioxide it captures as a prod- uct for sale to food and beverage compa- First, on a basic level, DAC requires Enhanced Weathering nies, for use in materials, or for use in enormous energy inputs to operate. As fuels.195 In partnership with automaker such, DAC can’t be considered in isola- and Carbon Audi, Climeworks has been developing tion from the energy it requires and their Mineralization e-fuels made from captured carbon diox- related emissions. If DAC is powered by ide since 2014. These fuels are made with renewable energy, as long as that energy Direct air capture typically refers to the carbon dioxide captured from the air, could be used in place of fossil energy use of machines to separate carbon diox- water, and electricity. The “e-diesel” cre- sources, it must be understood to enable ide molecules from the ambient air. ated from this process, as noted in an fossil energy sources to exist as it com- There are, however, other techniques. Audi press release, is a drop-in fuel, petes for energy inputs. It is, essentially, One of the most widely discussed is en- meaning it can be used with current fuel the opposite calculation of increasing en- hanced weathering, alternatively called ergy efficiency. carbon mineralization.

FIGURE 12 Pathways for Fly Ash Application in Carbon Capture, Use, and Storage

Abdallah Dindi et al., Applications of Fly Ash for CO2 Capture, Utilization, and Storage, 29 J. OF CO2 UTILIZATION 82 (2019), https://www.sciencedirect.com/science/ article/pii/S221298201830492X. 28 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

FIGURE 13 Fly Ash Contamination Pathways

Abdallah Dindi et al., Applications of Fly Ash for CO2 Capture, Utilization, and Storage, 29 J. OF CO2 UTILIZATION 82 (2019), https://www.sciencedirect.com/science/ article/pii/S221298201830492X.

Carbon dioxide in the air naturally reacts tific research institutions as well as fossil Although the National Academies of Sci- with alkaline chemicals in surface rocks, fuel companies.200 Shell in particular re- ence and others are calling for additional combining to form stable compounds. searched and patented a process for car- research into carbon mineralization, there Because neither solid rock nor the carbon bon mineralization.201 is currently little commercial effort to dioxide in the air are very reactive, this deploy the form of above-ground, or ex- process takes a very long time. The pro- Carbon mineralization faces several chal- situ, carbon mineralization that might be cess can be sped up, theoretically seques- lenges to its successful deployment. Simi- considered air capture or CDR. Nonethe- tering significant carbon dioxide either larly to ocean alkalinization, discussed less, this proposed method of carbon re- directly from the atmosphere (as a form below, the amount of material that would moval and storage is already being con- of CDR) or from already concentrated need to be used substantially exceeds the sidered as an outlet for fossil fuel by- carbon dioxide sources (as a form of car- amount of coal mined annually. Esti- products. bon storage).198 mates indicate that six to eight tons of ore would be needed for use in mineraliza- Residuals from coal combustion, also Carbon mineralization was first proposed tion for each ton of coal burned, not in- known as fly ash or coal combustion in 1990, although Klaus Lackner’s work cluding the emissions from mining, trans- waste (CCW), contain chemicals that can in 1995 is credited with providing the portation, or process energy.202 Neither of be combined with carbon dioxide in car- “details and foundation” for much of the the two most promising natural minerals bon mineralization processes. For this later carbon mineralization research ef- for this process—olivine and serpen- reason, several proponents have suggested fort.199 Since then, the process has re- tine—is or could be economically mined using coal combustion wastes and other ceived considerable attention from scien- at anything approaching this scale. industrial wastes, including brine solu- FUEL TO THE FIRE 29

tions resulting from oil and gas produc- eralization, the amount of carbon dioxide floor at the end of their lives, accelerating tion,203 in carbon mineralization process- sequestered would amount to less than the carbon-pump function of many sur- es.204 0.1% of US carbon dioxide emissions.206 face marine organisms. Another study estimates that carbonation For coal producers and large-scale coal of all coal fly ash globally would only ac- The original research into iron fertiliza- consumers, the prospect of using coal count for 0.25% of emissions from coal- tion—at least as identified in this re- combustion waste and other industrial fired power plants.207 view—was done outside the purview of residues for carbon storage or removal fossil fuel companies.211 This changed in holds obvious appeal. Coal combustion The industry is likely aware of these limi- 1992, when Exxon funded a study by wastes are among the largest unmanaged tations. The Institute for Clean and Se- Wallace Broecker and T.H. Peng follow- waste streams in many countries. In the cure Energy—a research organization ing up on earlier research they had con- United States, for example, coal combus- with funders including Chevron, The ducted on the topic.212 Exxon was not tion wastes are the second largest waste Wyoming Clean Coal Technology Fund, alone in exploring iron fertilization. stream after municipal solid wastes. Their and John Zink Company (a Koch Indus- When the Australian government tremendous volumes and high level of tries subsidiary), among others208—exam- launched the “first in situ iron fertiliza- heavy metals and other toxins render the ined this in at least one study from tion experiment” in the 209 safe disposal of CCW difficult and costly, 2011. This study concluded that “CO2 a few years later, Australian fossil fuel and and decades of inadequate regulation in mineralization with naturally occurring minerals conglomerate BHP Billiton was many countries have led to massive stock- minerals is unlikely to be feasible in the among the small group of participating piles of CCW that can leak into ground near term,” and that availability of indus- institutions.213 The experiment triggered waters, lower air quality, and result in trial wastes for mineralization is limit- a statement of concern under the London catastrophic events when impoundments ed.210 Incentives for carbon mineraliza- Convention on and fail. As concerns about CCW—and as a tion, then, risk providing carbon-emis- ultimately contributed to a 2008 decision result, the potential for effective regula- sion-intensive industries with subsidies under the Convention on Biological Di- tion—have continued to rise, coal pro- for their waste disposal—again inverting versity to place a moratorium on iron ducers and users alike have begun to ag- the principle that those who pollute fertilization activities.214 gressively explore options for reframing a should internalize the costs of their pollu- hazardous waste stream into a useful re- tion—without the ability to sequester Ocean alkalinization has received more source. Reframing CCW not as toxic meaningful amounts of carbon dioxide attention from both the public and fossil waste but as a feedstock for carbon stor- from the atmosphere. fuel companies. As opposed to iron fertil- age and removal could help fossil fuel ization, alkalinization involves neutraliz- producers and users pull two rabbits out ing the carbon dioxide absorbed by ocean of one hat—enabling the continuation of Ocean Iron Fertilization surface waters, theoretically enabling business as usual while providing a ratio- more carbon dioxide to be absorbed from nale for industry to transfer costly and and Alkalinization the atmosphere. unmanageable waste problems from one The ocean is the primary for part of the environment to another in the Ocean alkalinization was first proposed as the majority of carbon dioxide released ostensible name of climate action. a CDR method in 1995 by Haroon into the atmosphere. Another option Kheshgi, one of Exxon’s chief climate Since at least the early 2000s, the coal considered by those looking to sequester researchers.215 In 1998,216 Kheshgi pub- industry has promoted the idea of using carbon from the atmosphere is increasing lished a second study exploring the use of CCW in soil remediation and reforesta- the capacity of the oceans to absorb and artificially increased ocean alkalinity to tion efforts as a form of carbon sequestra- store carbon. Two widely discussed meth- neutralize carbon dioxide accumulation tion, despite significant risks that doing ods for doing this are ocean iron fertiliza- from fossil fuel combustion. so could impair plant growth and leach tion and ocean alkalinization. toxic metals into ground and surface wa- The idea hasn’t been promoted to the Ocean iron fertilization is the process of ters.205 degree that DAC or BECCS has, in part dumping iron into marine areas where because of the staggering amount of ma- Despite the interest, there are significant phytoplankton is likely to grow. The the- terial required. Like carbon mineraliza- limits to how much impact this method ory is that iron is the limiting nutrient tion, ocean alkalinization would require of mineral carbonation could have. One holding back more robust growth of cer- mining for alkaline ore at a massive, glob- US-based study on the extent to which tain plankton and that adding iron to al scale, and the energy consumed trans- such wastes could be used concluded that those marine ecosystems would cause porting it from its terrestrial source to its even if all the cost-effective alkaline in- massive plankton blooms. These plank- oceanic destination would eliminate dustrial waste were used for carbon min- ton, forming their cells from carbon in much of the benefit. the ocean, would then sink to the ocean 30 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

FIGURE 14 Origen Power Diagram Showing Enhanced Weathering Process Powered by Natural Gas and Reliant on CCUS

Origen Power, Written evidence submitted by Origen Power, http://data.parliament.uk/WrittenEvidence/CommitteeEvidence.svc/EvidenceDocument/Energy%20 and%20Climate%20Change/Energy%20Revolution/written/32773.html (last visited Feb. 4, 2019).

In 2008, Shell made an early investment in fuels.218 Cquestrate appears to have carbon emissions from the natural gas in an open-access company called Cques- ceased operation sometime after 2009, combustion, Origen Power assumes that trate to pursue such efforts.217 To make and a for-profit company Origen Power waste CO2 produced in the process will the energy-intensive process viable, was subsequently created to promote a be stored underground, demonstrating Cquestrate proposed that calcination revised version of the concept.219 Origen the technologies’ continued reliance on might be powered using “stranded gas” Power proposes to burn natural gas in a CCS.220 Tim Kruger, the founder of both that could not otherwise economically fuel cell, creating both electricity for sale Cquestrate and Origen Power, is also the reach markets and either releasing process and waste heat to decompose limestone program manager for Oxford University’s emissions into the atmosphere or captur- into calcinated lime, which can then be Geoengineering Program.221 ing them through CCS for use in EOR or used for direct air capture. To offset the FUEL TO THE FIRE 31

PART 5 Bioenergy, BECCS, and the Real Cost of Carbon Accounting

he most widely discussed form A 2018 analysis of BECCS prepared for Reducing the immense impacts of of CDR—and the CDR strat- the Carbon Sequestration Leadership Fo- BECCS on food security would require egy most widely relied upon in rum (CSLF) acknowledges that BECCS diverting biofuel land conversions away current climate models and has the theoretical potential to mitigate from croplands and into natural areas. As Tscenarios—is bioenergy with carbon cap- up to 3.3 gigatons of carbon per year, but noted by CSLF’s BECCS report, howev- ture and storage. cautioned that achieving reductions at er, converting large areas of forest to bio- this scale would require planting bioener- energy production would create net emis- Bioenergy is energy produced via the gy crops on up to 580 million hectares of sions of up to 135 gigatons of carbon by combustion of biological material. Bioen- land, or roughly one-third of all arable 2100.225 This would transform bioenergy ergy is typically divided into two catego- land on Earth.222 As has been widely rec- from a carbon sink to a massive carbon ries, biomass and biofuels. Biomass is any ognized, the conversion of arable land at source even before the potential emissions non- or minimally processed organic ma- even a fraction of the scale envisioned in from CCS itself were considered.226 terial that can be combusted for energy. most models would have profound impli- Traditional biomass includes wood, dis- cations for food security in a growing Notwithstanding these risks, the compar- carded food and oils, or other plant mate- world. atively greater technical feasibility of rial. Alternatively, biofuels are processed BECCs relative to other technological fuels produced from organic feedstocks, fixes has made it attractive for geoengi- as opposed to fossil fuels. “There is no scenario in which neering proponents and climate modelers bioenergy alone will remove CO2 alike. Models of decarbonization can use Both biomass and biofuels—collectively from the atmosphere on a net basis.” BECCS as an accounting tool to offset called bioenergy—have been touted as carbon dioxide emitted from other sourc- carbon-neutral alternatives to fossil fuels. es and fill gaps in projected energy needs. Regardless of whether the fuels burned The transformation of land at this scale In fact, earlier iterations of the IPCC de- are biofuels or fossil fuels, the process has implications not only for global food carbonization pathways were criticized for emits CO2 and other GHGs into the at- security, but for the lives, livelihoods, and doing exactly this. More recently and mosphere. Whereas the carbon in fossil human rights of communities around the more conspicuously, Shell’s Sky Scenario, fuels has been stored for millions of years, world. Those impacts would be most which has been lauded for its ambition, however, the carbon released by burning heavily felt by indigenous peoples, forest relies heavily on BECCS (and fossil CCS) biomass or biofuels was drawn from the communities, subsistence farmers, and to reach its targets.227 atmosphere and incorporated into the poor and marginalized communities in plants, algae, or other organic sources regions subject to food shortages or food Due to the array of challenges with re- that become bioenergy feedstocks. price shocks. Beyond its human impacts, spect to scalability, , social Whether bioenergy is as carbon neutral in the large-scale production of bioenergy acceptability, and human rights, however, practice as it is in theory remains subject would have significant impacts on water the IPCC notes that the projected contri- to ongoing debate. supplies and ecosystems. Moreover, as bution of BECCS to climate reduction CSLF’s Bioenergy Carbon Capture and targets has steadily declined in recent There is no scenario in which bioenergy Storage Task Force observed, converting years.228 Accordingly, the IPCC expressly alone will remove CO2 from the atmo- the necessary land to bioenergy would cautioned in SR1.5 against overreliance sphere on a net basis. To make that even itself generate significant direct CO2 on BECCS as a mitigation or carbon re- theoretically possible, bioenergy must be emissions due to land cover change, loss moval strategy and excluded BECCS en- combined with CCS to capture and store of forests and grasslands, soil disturbance, tirely from its most ambitious transfor- the carbon dioxide emitted when biomass and increased use of agricultural chemi- mation scenario.229 or biofuels are burned. If this could be cals, thus reducing its climate benefit.223 done at scale, proponents claim, BECCS Indirect emissions from producing and As noted above, any potential benefit of could operate as a massive offset to other using bioenergy would reduce those ben- BECCS as a CO2 removal strategy de- emissions and help reach the Paris goals. efits still further.224 pends on how the CCS component of 32 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

FIGURE 15 Excerpt from Summary of Global BECCS Projects

CARBON SEQUESTRATION LEADERSHIP FORUM, TECHNICAL SUMMARY OF BIOENERGY WITH CARBON CAPTURE AND STORAGE (BECCS) 20 (2018), https://www.cslforum.org/cslf/sites/default/files/documents/Publications/BECCS_Task_Force_Report_2018-04-04.pdf.

BECCS is deployed. With limited excep- their key advantage is compatibility with Fossil Industry tions, the economics of the CCS compo- systems of fossil fuel combustion, and like nent of BECCS are the same as in other the DAC-produced fuels discussed above, Investment in Biofuels CCS-reliant technologies. Thus, the most they do not contribute to a systemic and BECCS likely use of captured CO2 in BECCS change in transportation and reliance on projects is EOR. fossil fuels. The pursuit of biofuels dates back at least to the 1970s, and patent filings demon- The report on BECCS prepared for Most models that have considered wide- strate that oil companies were early pio- CSLF in 2018 agreed, acknowledging scale deployment of BECCS have consid- neers and proponents of biofuel develop- that EOR provided the primary econom- ered bioenergy from terrestrial biomass, ment.232 The Gas Research Institute ic market for CO2 from BECCS facilities rather than biofuels. Notably, however, of (GRI)—a research apparatus formed in and highlighting that three of the only eight operational or completed BECCS 1976 and funded by the natural gas in- five operational BECCS projects world- projects reported to CSLF, seven were for dustry—was funding research into biofu- wide were designed for EOR.230 ethanol, and all benefited from govern- el production no later than the 1980s233 ment subsidies for biofuels.231 As dis- and continued until 1990.234 The GRI As the paucity of active projects suggests, cussed in the prior section on DAC, the also collaborated with the American Gas biofuels and BECCS occupy an uncertain production of combustible transport fuels Association, the US Energy Research and place in the future of global energy sup- as a supplement to or drop-in replace- Development Administration, and the ply. Outlooks for energy demand by the ment for fossil fuels serves to perpetuate US Department of Energy to pursue a major integrated oil and gas companies and reinforce the existing fossil-fuel-based marine biomass energy research program, predict modest growth in bioenergy pro- energy and transport infrastructure rather from 1968 until 1990.235 While the re- duction and consumption, yet these same than transform it. Even where biomass is search into marine biofuels was originally companies remain invested in biofuels used, BECCS serves fossil fuel interests conducted for the purpose of producing and promote them as the clean future of by promoting CCS generally and dis- fuels, the option of using such marine energy. While biofuels can be consider- tracting from other ambitious and trans- algae growth as a carbon sink became a ably less carbon-intense than fossil fuels, formative climate solutions. subject of significant discussion in the 1990s.236 FUEL TO THE FIRE 33

energy, or both.246 Bioenergy has to com- pete with other energy sources, so the CCS unit would not be added unless it were specifically incentivized. However, carbon pricing or other policies to incen- tivize carbon storage (such as the credits in Section 45Q) apply to BECCS as well as fossil energy with CCS. Put another way, BECCS is not likely to be the result of market alignment from unrelated pru- dent climate policies, but rather needs to be deliberately incentivized, and as such, the deployment of BECCS would require significant expenditure of public resourc- es. Moreover, much of this deliberate in- centivization would apply to fossil fuel energy production, leading to the prob- lems outlined in the sections on CCS and EOR above.

In addition to its policy problems, a widespread belief in the availability of BECCS, like SRM (which will be dis- © STEPHEN PATE VIA FLICKR VIA PATE STEPHEN © cussed in the next section),247 creates se- vere moral hazard. BECCS is attractive in part because it allows modelers to de- crease their near- to medium-term ambi- Fossil fuel companies continue to invest Thus, even though major oil and gas tion. Including substantial BECCS in a extensively in biofuels, in large part due companies promote biofuels as a allows for modelers to exceed de- to renewable fuel standards.237 Exxon solution and actively seek government termined carbon budgets and count on maintains a substantial investment in subsidies linked to biofuels, there is lim- “negative emissions” from BECCS to Synthetic Genomics, Inc., a company ited evidence that these companies are make up the difference.248 that makes biofuels from algae.238 Shell seriously looking to deploy them on a holds the rights to biofuels produced by scale that would meaningfully displace oil Critically, this kind of potential pathway, 239 240 SBI Bioenergy, Inc. Chevron, To- and gas. Rather, the benefit of biofuels— called “overshooting,” is not guaranteed 241 242 tal, and Eni, to name a few, also in- as noted on several company websites—is to work. While it may feel intuitive in a vest in and produce biofuels. that they are drop-in fuels that don’t dis- model, we do not know that overshoot- rupt the functioning of fossil fuel produc- ing and then reducing atmospheric car- Despite these investments, multinational tion and distribution systems. bon dioxide concentrations will work as oil and gas companies do not appear to expected. Moreover, overshooting risks be planning for a massive expansion in A 2013 presentation245 by Wolfgang Hei- hitting tipping points from which posi- biofuel production and use. Shell’s Sky dug, Senior Analyst of the CCS Unit for tive feedbacks lead to significantly in- Scenario depicts an expansion of BECCS the International Energy Agency, reveals creased warming. The IPCC specifically for use in electricity production, but it the way in which the direct promotion of counseled against overshooting in its contends that oil will remain the primary BECCS would be a financial windfall for SR1.5,249 yet this is the plan set out in provider for liquid fuels.243 Exxon’s and the fossil fuel industry. In this presenta- Shell’s Sky Scenario.250 BP’s energy forecasts, including those tion, Heidug presents the results of an with decarbonization scenarios, similarly analysis of various incentive policies for show a muted role for biofuels as a re- BECCS. In short, BECCS does not be- placement for, or even supplement to, oil come sufficiently incentivized unless there for liquid fuels.244 is a positive subsidy for CCS, use of bio- 34 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

PART 6 Paved with Good Intentions: The Danger and Distraction of Solar Radiation Modification

neering to hold global mean tempera- therefore, and for reasons detailed in the olar radiation modification refers preceding sections, proponents of SRM to the suite of ideas proposed to ture constant would thus require that its deployment be sustained for a long must also assume the same large-scale combat global warming by reduc- deployment of commercially viable ing, reflecting, or intercepting time, dependent on this residence 258 CCUS, DAC, and BECCS. Ssunlight before it has a chance to warm time.” the atmosphere. Long before oil compa- If geoengineering were used to simply With atmospheric GHG concentrations nies proposed paving entire landscapes to slow the rate of climate change rather now surpassing 400 parts per million and change rainfall patterns251 and spraying than fully prevent warming, they argued, global emissions reductions still woefully black carbon into the atmosphere to the length of SRM deployment could be inadequate, the potential for deploying weaken hurricanes,252 scientists under- reduced—to periods ranging from 40 to SRM—or at least testing it—has become stood the potential for changes in the 840 years depending on the speed of the subject of serious discussion. Eminent earth’s albedo (the amount of sunlight transition and emissions reductions.259 climate scientist Michael MacCracken reflected back into space) to modify the The authors, including Carbon Engineer- has advocated for geoengineering research climate at local, regional, or larger ing founder David Keith, acknowledged and deployment for nearly three decades, scales.253 that the only way to reduce these time- but succinctly captures the sentiment lines, other than minimizing emissions in among a growing body of informed ob- The strategies proposed for doing so are servers: diverse, including injecting sulfur or oth- the first place, would be to combine them 260 er aerosols into the atmosphere; brighten- with CDR. To a significant extent, ing marine clouds by injecting or sulfur dioxide from purpose-built ves- 254 sels or existing ships; spreading tiny FIGURE 16 microbeads or foam-enhancing surfac- Early ExxonMobil Patent for Using Asphalt to Change Rainfall Patterns tants in the oceans;255 deploying mirrors in space;256 and covering in sheeting,257 among many others.

While proponents of CDR promise to

pull CO2 out of the atmosphere as a means of reducing climate impacts, SRM proponents take a different approach, seeking not to remove atmospheric green- house gases, but to mask or countermand their effects for the decades to millennia

it takes to return CO2 concentrations to safe levels. As three leading geoengineer- ing advocates observed in 2014:

“Carbon dioxide released to the atmo- sphere can affect the Earth’s climate for millennia, thus in the absence of methods used to accelerate the remov-

al of CO2 from the atmosphere, CO2 emissions commit us to millennia of altered climate. Using solar geoengi- Cloud Formation and Subsequent Moisture Precipitation, U.S. Patent No. 3,409,220 (filed Mar. 26, 1965). FUEL TO THE FIRE 35

“With the prospects for the future beyond dispute. Indeed, we have already energy that reaches the earth’s surface, now viewed with sufficient alarm and done so. The question is: at what cost? sulfate aerosols have a slight but measur- confidence to cause leaders of the able cooling effect that increases with world, despite all the uncertainties their concentration in the atmosphere.262 described in the IPCC Assessment Burning Fossil Fuels The atmospheric residence time of sulfate Reports, to unanimously agree that aerosols is far shorter than that of CO2, so the world’s fossil fuel energy system Proved SRM is the cooling effect from individual parti- must be replaced, the limitations of Possible—and cles is temporary, but for decades the the present national commitments to steadily rising SO2 emissions were suffi- emissions reductions would seem to Demonstrated Its Risks cient to mask a substantial portion of ac- favor serious international consider- cumulated warming across the Northern For more than a century, even as fossil ation of near-term global-scale inter- Hemisphere.263 fuel combustion raised global tempera- vention.”261 tures through the emission of CO2 and Even assuming this interference with the Unlike many proposed CDR methods, other greenhouse gases, the emission of global energy balance were unambiguous- sulfur dioxide (SO2) from the same fuel- and as discussed further below, there is ly positive, however, SO2 emissions have broad agreement that some SRM ap- burning sources was having the opposite other, more immediate effects on human proaches would be able to reduce solar effect. SO2 emissions from power plants, health264 and the environment.265 Most ships, automobiles, and other sources irradiation and lower temperatures across significantly, atmospheric SO2 is one of large areas. Humanity’s ability to effect generate sulfate aerosols that reflect a the primary causes of acid rain and con- such changes, even at a global scale, is large proportion of sunlight back into tributes to ozone depletion.266 space. By reducing the amount of solar 36 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

While acknowledging the evident health tently with ships, but in a safer Early Industry Interest 272 benefits of SO2 regulations then being way.” in SRM and considered by the International Maritime Stratospheric Aerosol Organization, Fugelsvedt and colleagues The National Academy of Sciences noted that cleaning up ship pollution (NAS) noted this linkage between fossil Injection would reduce the modest but noticeable combustion and key geoengineering tech-

cooling effect those SO2 emissions had on nologies when discussing the prospects Ironically, as measures to address sulfur the climate.271 The authors recommended for geoengineering in its 1992 report Pol- dioxide’s negative effects are slowly bring- that this broader context be considered in icy Implications of Greenhouse Warming. ing emissions down in many parts of the evaluations of possible regulatory mea- Citing earlier work by SS Penner, the 267 world, a small but growing chorus of sures. Others saw in the shipping example NAS panel suggested that emissions of voices is proposing that humanity inject a potential justification for new geoengi- just “1 percent of the fuel mass of the still more SO2, sulfate aerosols, or other neering research: commercial aviation fleet as , materials into the stratosphere in the between 40,000 and 100,000-foot (12- to hope that the cooling it generates will “The upcoming change does offer a 30-km) altitude for a 10-year period, mask the climate impacts of rising green- different way of thinking about inten- would change the planetary albedo suffi- house gas concentrations. This injection tional efforts to cool the climate, ciently to neutralize the effects of an 273 of aerosols into the upper atmosphere, known as geoengineering, according equivalent doubling of CO2.” Penner stratospheric aerosol injection (SAI), re- to some proponents of research in this headed the Center for Energy Research at mains the most widely discussed ap- area. Rather than some radical experi- UC San Diego, which, as briefly noted proach to SRM, and, despite the risks, ment, deliberate geoengineering could earlier in this report, was founded with a sulfur dioxide and sulfate aerosols remain instead be seen as a way of continuing grant from the Gulf Oil Foundation. the most widely discussed candidates for to do what we’ve been doing inadver- Penner also chaired the Department of SAI.268

Bolstering this strategy is that, since sul- fur dioxide is a common waste product of FIGURE 17 Illustration of How Carbon Dust Would Be Generated and Dispensed from Jet Aircraft fossil fuel combustion, the necessary feed- stocks for both SAI and some forms of marine cloud brightening (MCB) are readily available in an economy powered by fossil fuels.

In a recent, ironic example of these link- ages, some proponents of geoengineering have suggested that, by reducing the albe- do effects of ship emissions, recent regu- lations designed to protect public health by reducing SO2 emissions from global shipping fleets have the unfortunate side effect of “interfering” with an ongoing inadvertent experiment in geoengineer- ing.269 As Jan Fugelsvedt and colleagues summarized in a 2009 article:

“One might consider SO2 emissions as a form of inadvertent geoengineering due to the cooling effects. Indeed, the proposed geoengineering scheme of deliberately seeding low-level clouds over the oceans to enhance their albe- do would lead to a forcing mechanism

similar to continued SO2 emissions from shipping.”270 W.M. GRAY ET AL., WEATHER MODIFICATION BY CARBON DUST ABSORPTION OF SOLAR ENERGY 73 (1974), available at http://www.alachuacounty.us/Depts/epd/EPAC/William%20M.%20 Gray%20-%20Weather-modification%20by%20Carbon%20Dust%20Absorption%20of%20Solar%20 Energy%201974.pdf FUEL TO THE FIRE 37

Energy’s Fossil Energy Research Working FIGURE 18 Group, a joint enterprise between indus- Graph by Keith and Dowlatabadi Suggesting that SRM Could be Cheaper than try and academic researchers created to Reducing CO2 Emissions improve the viability of shale oil, coal liquefaction, and other fossil fuel technol- ogies.274

Penner’s original 1984 paper, co-au- thored with a graduate student funded by Shell Oil, made the motivation for pro- posing geoengineering explicit:

“The notion that the most economical energy source will be replaced globally in response to longterm climate model predictions is probably false. Before policy matters of this type can be dis- cussed reasonably, careful assessments must be made of alternative global measures that do not require curtail- ments of fossil-fuel applications.”275

In lieu of reducing fossil fuel use, Penner argued that “desired changes in Earth albedo through judicious introduction of small particles can probably be accom- plished at acceptable cost through the use of modified combustors on high-flying aircraft.”276

While its application in the climate con- text may have been novel, the concept of using modified aircraft emissions to alter David W. Keith and Hadi Dowlatabadi, A Serious Look at Geoengineering, 73 TRANS. AM. GEOPHYS. Earth’s albedo and affect the climate was UNION 289 (1992), https://agupubs.onlinelibrary.wiley.com/doi/abs/10.1029/91EO00231. not. It had been proposed by Russian scientist Mikhail Budyko in the early 1970s and periodically echoed by scien- from a mixture of coal and jet fuel, the A handwritten note on one of Penner’s tists and industry researchers in the ensu- feedstocks might be secured for as little as papers expressed the view that “[m]any ing years. As discussed in Part 3, above, three cents per ton.279 famous scientists have later copied this this was one of many strategies detailed idea without acknowledgment of my by industry-linked researchers in 1974 to Penner noted potential concerns that 1992-93 proposal.”281 Wallace Broecker, increase control of the climate while cre- stratospheric injections of this kind might himself receiving climate funding from ating new markets for petroleum prod- damage the stratospheric ozone layer and Exxon at the time,282 briefly discussed the ucts. indicated that this justified some experi- idea—and provided additional cost esti- mentation into possible effects. Nonethe- mates—in his 1985 book How to Build a In a follow-up paper in 1993, Penner less, he argued that the potential availabil- 277 Habitable Planet, but provided no cita- further elaborated on the strategy. Us- ity of a low-cost technology to decrease tions.283 Long-time SAI advocate David ing jet fuel consumption figures provided temperatures made it “appropriate to de- Keith cited both Broecker and NAS for to him by the American Petroleum Insti- lay drastic and excessively costly measures the concept in his widely cited 1992 re- tute, Penner estimated that if one percent 280 284 on CO2 reduction.” Indeed, he argued, view A Serious Look at Geoengineering. (2 million tons per year) of jet fuel were climate modeling itself should proceed on In further evidence of industry’s role in converted to stratospheric emissions, just the assumption that the results of geoen- geoengineering research, Keith’s 1992 under four years would be required to gineering experiments would likely be article was funded in part under a con- lower temperatures sufficiently to offset known long before there was certainty tract with the Electric Power Research 1.5°C of warming due to climate regarding the need for climate mitigation 285 278 Institute. change. If the particles were created of other kinds. 38 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Significantly, Keith, like Penner before compared not only to the costs of climate layer, SAI would do nothing to reduce him, argued that one significant reason damages, but also to the cost of emissions the caused by CO2 for exploring geoengineering technologies reductions, was expressly restated in the deposition and, indeed, could exacerbate was the potential to manage the impacts paper’s conclusion.291 Far from envision- the problem. of climate change much more cheaply ing SRM as a necessary fail-safe if mitiga- than could be achieved through abate- tion technologies failed to fully eliminate There is broad recognition within the ment alone. In a figure accompanying the GHG emissions, the authors instead con- scientific community, moreover, that paper, Keith and his co-author highlight- cluded that SRM might prove a useful both SAI and MCB—will have signifi- ed that the marginal cost of deploying and economical component of a broader cant effects on rainfall patterns across SRM—described in the graph as a “solar climate management system—one fo- large regions and that these effects may be shield” (represented by the flat line la- cused not on eliminating the drivers of “telegraphed” to regions far removed beled B in the graph)—could be dramati- climate change, but on simply keeping from injection sites.294 Like SAI, marine cally lower than achieving an equivalent pace with their mounting atmospheric cloud brightening is designed to increase amount of climate mitigation by reducing impacts. the amount of sunlight reflected back US greenhouse gas emissions by six giga- into space by raising Earth’s albedo. tons of CO2 per year (represented by “When SRM is considered as one ele- However, while SAI focuses on deploying 286 curves C1 and C2 in the graph). ment of climate strategy that also in- SO2 or other aerosols in the stratosphere, cludes mitigation and adaptation, it is MCB involves changing the reflectivity of

While the details have changed in some meaningful to compare costs and in marine clouds by injecting SO2, sea wa- respects, the core concept of using modi- this sense one can conclude that the ter, or other aerosols into the atmosphere fied jet exhaust to inject particulates or cost of SRM deployment of quantities above the marine environment, using aerosols into the stratosphere remains sufficient to alter by either existing ships or fleets of purpose- essentially intact in modern proposals for an amount roughly equivalent to the built vessels. Models have repeatedly indi- SAI. In a recent review of SAI injection growth of anticipated GHG forcing cated that the application of either cate- options, for example, David Keith and over the next half century is low, gory of technology at large scales would co-authors concluded that the most eco- though SRM does not thereby miti- have significant impacts on global hydro- nomically viable approach to SAI would gate the risks of the accumulated logical cycles. be to modify existing Boeing 747 aircraft GHGs that extend far beyond this 292 or develop new airframes to inject SO2 time window.” For example, multiple studies have shown into the stratosphere at 60,000 feet.287 that geoengineering in the Arctic could (The lead author on the report, Justin lead to significant changes in precipita- McClellan, worked in business develop- Counting—and Not tion in tropical regions of both ment for a Boeing subsidiary.288 The third the Northern and Southern hemispheres, author, Jay Apt, was director of the Elec- Counting—the Costs of increasing monsoon precipitation in the tricity Industry Center, which was co- SRM Northern hemisphere but dramat- founded by and receives ongoing core ically reducing rainfall across the Ama- support from Electric Power Research As the preceding section demonstrates, zon.295 Rainfall losses of this scale would Institute (EPRI).289) As with Penner de- one of the recurring rationales for explor- trigger profound impacts on Amazonian cades earlier, Keith and colleagues ac- ing SRM is that its costs—while substan- ecosystems and on the indigenous peoples knowledged that this economic analysis tial—might be lower than the near-term and local communities dependent upon was relevant not only as a necessary sup- costs of mitigation efforts. As with CDR, those ecosystems, and they would com- plement to climate mitigation efforts, but however, the economics of SRM may pound the moisture losses caused by cli- as a cost-competitive alternative to those depend on how narrowly costs are calcu- mate change itself. Despite this, engineer efforts: lated. and MCB vessel designer Stephen Salter expressed optimism that the people of “We think this work demonstrates In their 2012 cost assessment of SAI de- Brazil would gladly accept these losses clearly that it is feasible by showing livery methods, Keith and McClellan ac- knowing that the Amazon’s loss was off- that several independent options can knowledged that their analysis did not set by increased rain in the Horn of Afri- transport the required material at a consider the “implications of risks [of ca.296 To address the hydrological imbal- cost that is less than 1% of climate SAI] and of the imperfect climate com- ances created by geoengineering, Salter damages or the cost of mitigation.”290 pensation offered by SRM, and the costs proposes a globe-spanning network of associated with these issues.”293 In addi- vessels injecting seawater into the atmo- The authors’ assessment that solar geoen- tion to significant risks of acid precipita- sphere from predetermined locations and gineering using SAI was cost effective tion and potential impacts to the ozone in carefully orchestrated but periodically FUEL TO THE FIRE 39 © NEIL PALMER/CIAT NEIL ©

recalibrated sequences, with each injec- sulting expert for industry defendants pensating affected communities for the tion designed to offset and rebalance the accused of mismanaging waste oil,301 ar- impacts to their lands, rights, livelihoods, ones that came before.297 gued that the most feasible and economi- and lives. As in the context of CDR, such cal solution to climate change would be assumptions occur with troubling fre- Acid rain, ozone loss, and significant dis- to cover 4 million square miles of quency in proposals for the deployment ruption of hydrological cycles are not the with plastic sheeting. Gaskill calculated of SRM. only risks posed by SAI and other SRM that the project would cost $500 billion technologies. These risks include com- per year for 150 years—$75 trillion in Moreover, were large-scale SRM ended pounding the disruptive impacts of cli- total. These costs, he concluded, com- before atmospheric CO2 concentrations mate change itself, reducing crop yields298 pared “very favorably” to the Department had been returned to safe levels, global and solar energy production by reducing of Energy’s “$10/ton goal to managing temperatures would rapidly rise to the the amount of solar radiance reaching the carbon from power plant emissions.”302 levels dictated by those concentrations. earth’s surface,299 and affecting the fre- This rapid temperature increase and the quency and intensity of tropical cy- The majority of the project expenses associated disruptions to geophysical, eco- clones,300 among others. would go into purchasing the plastic from logical, and social systems that would en- the petrochemical companies that make sue are known collectively as “termina- Moreover, as evidenced in the Salter pa- it. The land, Gaskill assumed, would be tion shock.”304 SRM proponents argue per, SRM proponents often acknowledge given away free of charge.303 that these risks might be managed by pro- vast inequities in the distribution of the tecting SRM installations against attacks costs and benefits of SRM technologies, At first blush, the idea of covering the or disasters,305 phasing out SRM gradual- but assume those disparities will simply world’s largest deserts in plastic and as- ly over a long period of time, or restrict- be accepted by local populations or dealt suming the countries and communities ing the degree to which SRM is used in with later. affected would freely consent seems pro- the first place.306 foundly naive. Yet it parallels the contin- In the early 2000s, environmental chem- ued heavy reliance on BECCS in climate There is also the significant risk that the ist Alvia Gaskill reviewed available tech- mitigation scenarios and the implicit as- deployment of or even experimentation nologies for geoengineering and shared sumption that much of the world’s arable with SRM could increase global insecuri- his findings and proposal with the US land can be converted from food produc- ty and increase the potential for conflict Department of Energy. Gaskill, a con- tion to biofuels, generally without com- regionally or more broadly. Given the 40 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

FIGURE 19 Impact of Cloud Geoengineering on Rainfall for 2030-2059

Stephen Salter and Alan Gadian, Coded Modulation of Computer Climate Models for the Prediction of Precipitation and Other Side-effects of Marine Cloud Brightening 3 (research proposal, Jan. 25, 2013), http://www.homepages.ed.ac.uk/shs/Climatechange/DECC%20coded%20modulation.pdf.

military origins of some early geoengi- mate change disrupts rainfall patterns of or even the research into SRM: that neering technologies, the active explora- across large areas, conflicts over access to the promise of future geoengineering will tion of military technologies such as mis- water resources are likely to grow, both provide an excuse to delay climate mitiga- siles or shells for SRM deploy- within and between countries.309 Given tion or to reduce the scale of ambition. ment, and the use of early weather modi- its potential effects on rainfall patterns, fication tools in military conflicts, some storms, and crop production—including In the geoengineering context, this is of- observers have highlighted the serious risk at great distances from SRM deployment ten referred to as the moral hazard argu- that geoengineering or geoengineering sites—geoengineering could dramatically ment—the risk that the perceived ability technologies might be intentionally uti- compound resource-related conflicts in to manage the climate crisis by engineer- lized for military purposes.307 A less dis- regions affected by food insecurity, water ing the climate itself will suppress ambi- cussed but even more pervasive risk is stress, and ongoing disputes over access to tion by governments, corporations, and that geoengineering could exacerbate un- and control of glacial melts, monsoon individuals to reduce emissions of green- derlying, often long-standing sources of rains, and the rivers and floodplains they house gases. tension between groups or countries, re- run through. sulting in the outbreak or recurrence of Proponents of geoengineering deploy- ment or research routinely argue that military conflict. In 2007, the United Moral Hazard and the States Department of Defense recognized these risks are overstated, noting that all the potential for climate change itself to Geoengineering ‘Fail-Safe’ but the the most strident proponents of compound pre-existing tensions in this SRM acknowledge that SRM must be way, serving as a “threat multiplier” that Beyond the risks attendant to individual coupled with emissions reductions and increases the likelihood and potential technologies, however, is a more funda- emissions must ultimately be brought scale of violence.308 For example, as cli- mental risk inherent in the development under control. FUEL TO THE FIRE 41

As this report demonstrates, however, the for reducing near-term ambition and de- This is a Test. But is it potential to avoid or minimize other laying significant emissions reductions forms of climate action—including re- into the future: Only a Test? ducing the world’s reliance on fossil fu- els—have been a recurring theme in “The notion of geoengineering as a Notwithstanding the long scientific his- CDR and SRM research alike for de- fallback option provides a central—or tory of the concept, and its periodic ex- cades. As DAC and SRM advocate David perhaps the only—justification for ploration by both corporations and gov- Keith acknowledged in 1992, taking large-scale geoengineering seri- ernments, the public conversation over ously. A fallback strategy permits more SRM remains in its early stages. Early and “The existence of a fallback is critically confidence in adopting a moderate sometimes unauthorized experiments into important as it allows more confidence response to the climate problem: with- other forms of geoengineering led to in choosing a moderate response strat- out fallback options a moderate re- mounting concern among informed ob- egy. Moderate responses are difficult sponse is risky given the possibility of servers that open-air experimentation to implement when catastrophic con- a strong climatic response to moderate with SRM might soon begin. In response sequences are possible from weak an- levels of fossil-fuel combustion.”313 to these concerns, the Convention on thropogenic climate forcing. Fallback Biological Diversity adopted a decision in strategies permit moderate responses As abundantly documented in the sec- 2010 creating an effective moratorium on to be adopted with the knowledge that tions that follow, the potential to avoid, geoengineering, including experimenta- should these prove inadequate an al- delay, or minimize necessary reductions tion. This decision, however, is neither ternate mitigative option is avail- in GHG emissions remains a recurring, ironclad nor irreversible.314 able.”310 explicit ambition of many geoengineering proponents—both within industry and As geoengineering generally and SRM The same year Keith issued this EPRI- within the advocacy and policy commu- specifically become more prominent in funded paper, EPRI founder and presi- nities. This is, in an important sense, a the climate dialogue, interest in carrying dent emeritus Chauncey Starr put the rational and predictable response of cor- out open-air geoengineering experiments matter more bluntly. In a paper co-au- porations and governments. Climate is increasing.315 Among the most widely thored with fellow climate denialist Fred change mitigation, the reduction of discussed of these potential experiments is Singer, Starr argued that the “scientific greenhouse gas emissions, and the shift the stratospheric controlled perturbation base for a greenhouse warming is too un- away from a fossil fuel-based economy experiment (SCoPEx) co-led by David certain to justify drastic action at this will not be without costs. While there Keith (Mission Scientist) and Frank time.”311 Significantly, Starr and his co- will be enormous benefits, both concen- Keutsch (Principal Investigator) of Har- authors argued that action to address cli- trated and diffuse, there are also near- vard University.316 Keutsch is a professor mate risks was unjustified because we term costs to climate action and difficult of chemistry and at could always geoengineer our way out of decisions that need to be made quickly. A Harvard; Keith serves as faculty director the problem—either by sucking CO2 political leader deciding between prudent for Harvard University’s Solar Geoengi- from the atmosphere or by deploying climate action now versus another gover- neering Research Program (SGRP)317 techniques to block incoming sunlight: nance priority may choose the latter if and, as discussed in the section on direct they believe that SRM implementation air capture, is the founder of Carbon En- “If greenhouse warming ever becomes will buy time. gineering. a problem, there are a number of pro-

posals for removing CO2 from the This fundamental problem—that solar Unlike some programs that seek only to atmosphere. . . . If all else fails, there is geoengineering is the perfect excuse for pursue governance, the SGRP takes “an always the possibility of putting ‘Ve- inaction—is exactly what makes its im- active stance on research with a unique netian blind’ satellites into earth orbit plementation aligned with fossil fuel in- mandate to develop new path-breaking to modulate the amount of sunshine terests. It is therefore unsurprising that, technologies that might improve solar reaching the earth.”312 from the earliest conversations about so- geoengineering’s effectiveness and reduce lar geoengineering through the present its risks.”318 In conjunction with that Unlike Starr, Keith highlighted the po- day, the fossil fuel industry has been in- mandate, SCoPEx is designed “to ad- tentially prohibitive costs of deep GHG volved in the conception of solar geoengi- vance understanding of the risks and effi- reductions but did not argue that reduc- neering options—often using fossil fuel cacy of SRM,” with particular attention tions were wholly unnecessary. Like other by-products—and the promotion of to the potential impacts of SRM on the SRM advocates, however, Keith repeated- SRM as a climate option. ozone layer. Keutsch, Keith, and their ly emphasized that the availability of geo- co-workers acknowledge the potential for engineering provided a strong rationale stratospheric aerosol injection to damage 42 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

the ozone layer, but assert that the im- Troublingly, both the SCoPEx design ing full global intervention and, in pacts on ozone may be reduced if the at- and the broader context in which it is essence, imposing human control of mospheric cooling induced by SRM re- implemented suggest that the goal of the the complex global climate system, duces the transport of into experiment is to move the technology for- establishing a research program to ex- the lower stratosphere.319 The SCoPEx ward, rather than to demonstrate that it is plore potential regionally focused, tro- experiment is thus designed to inform safe for deployment. As evidenced by pospheric interventions might serve as these competing hypotheses about the their ongoing research outside of SCo- a useful interim step between not in- impacts of SRM. A second function of PEx, Keith and his coworkers continue to tervening at all and jumping straight the experiment is to better analyze how actively research, refine, and promote to global-scale intervention.”326 sulfate particles behave following injec- strategies for SRM even as the deploy- tion—including the size, dispersion, and ment of SCoPEx is debated. This fact As documented more fully below, Mac- resulting duration of particles, all of highlights another widespread concern Cracken is far from alone in this view which will influence their reflectivity and among critics of geoengineering: that ex- that a principal benefit of open-air testing efficiency for radiative forcing.320 periments such as SCoPEx are designed is that it eases the path to large-scale de- less to expose the potential risks of SRM ployment. This perspective is shared by Keith and other proponents of open-air technologies than to narrow the universe the American Enterprise Institute and in testing of geoengineering routinely argue of potential risks, while demonstrating one important instance, discussed further that such experiments are needed to de- the basic feasibility of geoengineering below, by NASA. termine whether geoengineering will be technologies and opening the door to safe and, if so, under what conditions. It deployment at progressively larger scales. is notable in this regard that the SCoPEx Industry Influence in proponents originally intended to deploy In fact, some long-time geoengineering sulfuric acid in the experiment,321 but advocates explicitly acknowledge that a SRM modified their testing plans in the wake principal function of early testing is to lay As discussed more fully above, the pros- of public concern with the potential envi- the foundation for early, active deploy- pect of tinkering with Earth’s albedo— ronmental effects of sulfate aerosols. As a ment. In 2016, for example, MacCracken whether in the atmosphere, in the oceans, result, the proponents subsequently pro- acknowledged that testing and deploy- or on the earth’s surface—was an area of posed to initiate the experiment with ice ment exist on a tightly woven continu- early and active inquiry in weather modi- and calcium carbonate instead, while um. MacCracken argued that, unless geo- fication and geoengineering. Fossil fuel leaving open the possibility of injecting engineering interventions begin in the interests, including particularly the oil sulfate aerosols at a later stage.322 near term and gradually scale up, there is industry, were early and active partici- the risk that geoengineering research re- pants in this research.327 For decades, Notably, however, Keith and others con- sults might go unused. however, it was widely recognized that tinue to assume the use of SO2 or similar sulfate aerosol precursors in papers mod- “Thus, while scientific and technologi- the risks and side effects of SRM far out- 328 eling the large scale deployment of cal questions that merit additional re- weighed any potential benefits. SRM.323 As they acknowledge in a 2017 search and, while governmental efforts Beginning in the 1990s, the concept of paper, research on SRM implementation are needed that develop appropriate actively deploying SRM on a global scale continues to focus on increasing the governance mechanisms for deciding was resurrected—either as a last-ditch stratospheric burden of sulfate aerosols, how to optimally intervene, putting solution to the climate crisis or as a quick “in part because it is (arguably) the only off initiation of actual climate inter- and relatively inexpensive fix to mask the SRM method with a strong natural ana- vention until there is much greater impacts of accumulating greenhouse gas log that can produce relatively uniform understanding might well lead to a emissions. Producers and users of fossil [increases in radiative forcing] using exist- situation where the transient condi- fuels were key actors in this resurgence. ing technologies.”324 Regardless of the tions associated with restoring the specific testing material deployed in ex- past’s milder conditions might them- As noted in the preceding section, the 325 periments, therefore, any actual deploy- selves be unacceptably disruptive.” utility industry’s Electric Power Research ment of SAI is likely to rely heavily on Institute co-funded David Keith’s early In these circumstances, MacCracken be- sulfate aerosols, with their attendant side research into geoengineering in 1992. lieves, geoengineering experiments pro- effects. Ironically, open-air experiments That same year, EPRI founder and presi- vide a useful stepping stone to wide-scale small enough in size to minimize the risk dent emeritus Chauncey Starr wrote a deployment: of harm from these materials also increase series of papers actively disputing the the risk that they will be too small to fully state of climate science, emphasizing un- reveal such side effects. “As an alternative to jumping from undertaking no intervention to initiat- certainties and arguing against action to FUEL TO THE FIRE 43 © QIMONO VIA PIXABAY VIA QIMONO ©

address the crisis. In one of the most in- Watts’s book Engineering Response to , carbon taxes, and cap- fluential of these papers, co-authored Global Climate Change.333 Kheshgi, Flan- and-trade proposals and instead urged with fellow climate denialist Fred Singer, nery, and other industry scientists were a increased R&D funding for geoengineer- Starr argued, “The scientific base for a constant, conspicuous presence in meet- ing, his term for using “technologies that greenhouse warming is too uncertain to ings and reports that returned geoengi- would avoid harmful climate change justify drastic action at this time.”329 neering to the center of the climate de- while allowing emissions.”336 Among oth- Should climate risks ever prove signifi- bate. er options, Lane noted, this could include cant, the authors argued, we could geoen- “increasing earth’s albedo to offset the 330 gineer our way out of the problem. NASA Workshop on Solar warming effects of rising GHG concen- trations.”337 EPRI’s contributions to the field, howev- Radiation Management er, pale in comparison to those by Exxon Lane was listed as the lead author on the and other oil industry actors. In 2006, NASA and the Carnegie Institu- NASA workshop report published in tion of Washington Department of Glob- 2007. The report outlined two alternate Exxon scientists Haroon Kheshgi and al Ecology hosted a workshop to deter- visions to justify research into SRM geo- Brian Flannery were actively writing mine the research needs of the scientific engineering. The first was that mitigation about geoengineering, and specifically community regarding solar geoengineer- efforts might fail and render geoengineer- SRM and ocean alkalinization, from the ing.334 In addition to Keith and Exxon’s ing necessary, in which case it would be 1990s onward, with Kheshgi proving par- Kheshgi, the participants included Lee useful to have tested, cost-effective tech- ticularly active and influential.331 Both are Lane of the American Enterprise Institute nologies on the shelf.338 The second, acknowledged for their contribution to (AEI),335 which at the time maintained an which received more extensive and more MacCracken’s 1991 paper Geoengineering active and ongoing campaign to under- positive treatment, argued that the devel- the Climate.332 In 1997, Flannery and mine public confidence in climate sci- opment and “preemptive” deployment of Kheshgi were primary authors of a chap- ence. In an AEI report published that SRM could “buy time” because imple- ter on geoengineering in Robert G. same year, Lane had argued against the menting GHG reductions would require 44 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

the development of “new, far lower cost greenhouse gas abatement by delaying Emergencies,345 was released by Novim, a emission abatement technologies.”339 At emissions reductions while lowering the nonprofit group founded at the Universi- its heart, this vision of geoengineering “present value” of climate damages.342 ty of California Santa Barbara the previ- was less about addressing the climate cri- Notably, the authors recognized that one ous year. Drawing on the work of a spe- sis than avoiding economic disruptions important benefit to this accelerated test- cially convened study group, the Novim caused by prematurely reducing emis- ing and deployment of geoengineering report outlined a research agenda for sions: was that there would be more time to stratospheric aerosol injection, the most choose other courses of action if the re- commonly advocated form of SRM.346 “Economic efficiency requires mini- sults from geoengineering proved disap- The lead author and study group conve- mizing the present value of the sum of pointing or disastrous.343 ner, Steve Koonin, was Chief Scientist at the damages from climate change and BP when the group was convened.347 A the costs of reducing those damages. This vision of geoengineering outlined in brief “Note on Conflicts” in the report By constraining the rise in tempera- the NASA workshop report—that early acknowledges that Koonin’s role at BP ture, solar radiation management de- deployment of SRM would provide an could be perceived as a conflict, as “some ployment could reduce the damages of excuse to delay other forms of climate readers may perceive anyone working at climate change. At the same time, action; that even with advance testing any oil company to have an interest in postponing the deepest emission cuts and experimentation, significant adverse distracting society from the job of reduc-

until cheaper abatement technology is impacts might not become apparent until ing global CO2 emissions, since the use of available is a key to abatement cost-ef- after SRM was deployed at scale; and that their products creates these emissions.”348 fectiveness.”340 early reliance on SRM was justified be- Nonetheless, the study group concluded cause other forms of climate action could that “no individual brings a conflict of Presciently, the workshop report also be used to save the day if SRM failed— interests, either personal or professional, highlighted that early testing, if success- turns widely touted rationales for geoen- to this work.”349 Moreover, despite dis- ful, would naturally increase pressure for gineering testing and deployment on closing Koonin’s relationship with BP, deployment of the technology: their heads. other connections remained undeclared. Robert Socolow of Princeton was and is “Nevertheless, should experimentation Ironically, the benefits and likely progres- the director of the Carbon Mitigation confirm the efficacy and safety of solar sion of early testing highlighted in the Initiative, a program funded primarily by radiation management, a preemptive NASA report validate one of the recur- BP.350 Keith, who also participated, deployment offers major advantages. ring critiques of SRM testing: that a pri- founded Carbon Engineering the same These include: mary function of that testing is to acceler- year this report was released. ate the early deployment of the technol- • The opportunity for efficient de- ogy. As both the report authors and geo- Koonin became Under Secretary for Sci- ployment growing logically and engineering critics seem to agree, exten- ence at the US Department of Energy in progressively out of testing; sive research programs are likely to lead May 2009, shortly before the Novim re- • The possibility of lowering the to progressively larger-scale open-air ex- port was released. In 2014, he ran a con- present value of both damages periments, which will blur the lines be- troversial op-ed in the Wall Street Journal from climate change and the costs tween SRM research and SRM deploy- entitled “Climate Science is Not Set- of greenhouse gas abatement; ment.344 While proponents of SRM re- tled,”351 followed three years later by an- search may disagree that they are advocat- • A more direct rationale for near other op-ed proposing a “red team” exer- ing for its ultimate deployment, in the term research and development; cise to test the scientific consensus on absence of ironclad prohibitions and a climate change.352 Scott Pruitt, climate • More time to implement other stronger global commitment to emissions denier and controversial head of the US policies should deployment of mitigation, it is reasonable to expect that Environmental Protection Agency under full-scale solar radiation manage- SRM research will be considered the first Donald Trump, tried but failed to hire ment produce disappointing re- step to SRM deployment. Koonin to carry out this exercise.353 sults or unacceptable side ef- fects.”341 Novim Climate Engineering Bipartisan Policy Center’s Climate As envisioned by the report authors, Report Remediation Report therefore, early geoengineering experi- ments would lead, logically and progres- Another report released in 2009 has had Another report came two years later. In sively, to the deployment of geoengineer- an equal or greater impact on the geoen- 2010, the Bipartisan Policy Center ing technologies. These technologies, in gineering debate. The report, entitled Cli- (BPC), a US think tank, convened a turn, could reduce the near-term costs of mate Engineering Responses to Climate “Blue Ribbon Task Force on Climate FUEL TO THE FIRE 45

Remediation.” The task force was to “de- 2018, the Harvard Project on Climate cussing and researching solar radiation velop recommendations for the US gov- Agreements and the SGRP conducted a management and geoengineering as a ernment concerning geoengineering re- research workshop on the governance of whole. As will be discussed below, the search and oversight policy.”354 In 2011, solar geoengineering.361 Among the research networks for geoengineering are the task force released a report urging the funders of the project is BP.362 The Har- surrounded and interpreted by a parallel US government to invest in a federal geo- vard Environmental Economics Program, group of industry-linked individuals and engineering research program.355 This with which the Project on Climate Agree- institutions, who are actively promoting BPC report does not provide a specific set ments is closely affiliated, receives fund- SRM to policymakers and the public of funders. However, the 2011 BPC an- ing from Chevron and Shell.363 alike, often in terms that prioritize indus- nual report contains a list of supporters try interests and maintaining the status including the ExxonMobil Foundation, The universe of individuals and institu- quo. American Gas Association, Dominion tions shaping the debate over SRM, once Resources, Eni, Entergy, Alliance Energy, relatively limited, has been growing rap- It bears repeating that the simple belief in America’s Natural Gas Alliance, Chevron, idly in recent years, particularly as repre- the efficacy or necessity of SRM has ma- ConocoPhillips, Exelon, Pioneer Natural sentatives of civil society and the Global terial impact on efforts to pursue needed Resources, Schlumberger, Shell Oil, and South demand a greater role in the de- mitigation and adaptation. As acknowl- Southern Company.356 bate. These communities are by no means edged in Novim’s note on conflicts of monolithic in their perspectives. While interest, and extensively documented in BPC has been extensively criticized for skepticism and concern about geoengi- the next section, efforts to pursue SRM— the apparent influence such funding ar- neering are widely shared among environ- in earnest or merely as a distraction— rangements hold over the topics it ex- mental and human rights non-govern- may be directly aligned with efforts to plores and the conclusions it reaches.357 mental organizations, a small but signifi- stall emissions reduction efforts, efforts Several reports have focused specifically cant number of organizations have ex- which the fossil fuel industry has been on the heavy influence of BPC’s oil, gas, pressed cautious support—or at least po- and continues to be engaged in. and chemical industry donors on the out- tential openness—to the development of comes of its ostensibly unbiased work.358 geoengineering governance, research, or Perhaps unsurprisingly, BPC continues to limited testing. Actors from the Global The New Climate support not only geoengineering research, South have expressed a diversity of per- but the increase of subsidies through spectives from outright opposition to Denial 45Q, the use of those subsidies to deploy geoengineering research to a simple de- Investigations from InsideClimate News, direct air capture,359 and the use of the mand for a seat at the table and a role in the LA Times, Climate Investigations captured carbon for EOR, drop-in fuels, that research.364 Center, and others have revealed deep and plastics.360 Accordingly, it would be inaccurate to and persistent connections between fund- suggest that the fossil fuel industry re- ing by fossil fuel companies and the deni- Why Industry Influence Matters mains the sole instigator or driver of con- al of climate change or opposition to cli- temporary debates over geoengineering. mate action. This funding frequently The NASA, Novim, and BPC reports are There is evident and significant interest flows through layers of front groups and among a handful of extremely influential in both the scientific understanding and astroturf organizations and is often hard documents on SRM that have helped legal control of SRM among scientists, to track. Still, many key climate-action- move geoengineering from the far fringes politicians, activists, scholars, and entre- opposed individuals and organizations are of the climate debate toward its center. In preneurs from an array of sectors and dis- well-known recipients of fossil fuel fund- addition to a 2009 report from The Roy- ciplines. ing and are also active promoters of geo- al Society, these reports are among the engineering, especially solar radiation most influential developments in the At the same time, it is impossible and management. public debate around SRM. All three unwise to ignore the recurring influence were funded or heavily influenced by fos- of fossil fuel industries and interests in One of the more prominent figures in sil fuel interests and individuals closely the research and policy agenda for geoen- this space is Julian Morris, the director of connected to those interests. gineering. Representatives of the indus- the International Policy Network (IPN) try, or individuals funded by companies and former director of the Environmental This industry influence in SRM, while within the industry, have been present at Programme at the Institute for Economic perhaps less pervasive than at earlier stag- every stage. Fossil fuel companies have Affairs. Both the Institute and IPN are es, continues today. Many of the same funded, sometimes in large part, work- known to have received significant fund- individuals and institutions that receive 365 shops, reports, individuals, and institu- ing from Exxon. Morris is a prominent fossil fuel funding remain deeply engaged tions that have helped develop the do- denier of the validity of climate science in the space. For example, in September mestic and international agenda for dis- and has worked for multiple organiza- 46 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

tions funded by fossil fuel companies. In Geoengineering Project and lead author These descriptors make it clear that AEI 2008, he published an article entitled of the report on NASA’s 2006 SRM was aware of the potential for climate Which Policy to Address Climate Change?, workshop, testified to the US Congress in regulation in the United States between first published by IPN and later repub- support of a program of geoengineering 2008 and 2010. Notably, after 2010, lished by the Institute.366 In this article, research.376 Lane reiterated and amplified when federal climate policy in the United Morris proposed geoengineering as the the economic messages from that work- States seemed unlikely to advance, the preferred alternative to greenhouse gas shop, arguing that SRM research was nec- Geoengineering Project disappeared. mitigation efforts, simultaneously down- essary because some nations considered playing the certainty of the risks posed by measures to reduce GHG emissions not The influence of these think tanks, many climate change and the risks of geoengi- worth the cost.377 AEI has been funded by of which actively deny the reality of cli- neering.367 Notably, Morris argues that Exxon, Amoco, Donors Capital Fund, mate science or oppose action on climate, geoengineering should be left to the pri- and the Charles G. Koch Foundation,378 should be understood as both a signal and vate sector, rather than government con- has engaged in direct opposition to cli- a risk. As a signal, they make clear that trol.368 mate science,379 and continues to oppose those institutions that oppose action on action on climate change.380 Indeed, even climate, either for commercial or ideolog- David Schnare, senior environmental fel- as Lane completed NASA’s workshop ical reasons, likely see geoengineering as a low at the Thomas Jefferson Institute report in 2007, AEI and Exxon were diversion of public and political will. (TJI), has advocated for geoengineering caught offering a group of scientists Moreover, because of the influence these deployment.369 Schnare has repeatedly $10,000 each to publicly dispute the organizations have, such promotion of argued that climate change does not pose findings of the latest IPCC report.381 geoengineering compounds the already a significant threat or, alternately, that it problematic political and moral hazard is too late to solve the problem.370 TJI has From approximately 2008 to 2010, Lane risks of geoengineering research and de- received funding from the opaque Do- and AEI advocated aggressively for re- ployment. nors Trust and Donors Capital Fund, a search into and consideration of geoengi- pair of organizations that provide funding neering.382 In addition to his testimony Evidence has already emerged that this to numerous climate denial groups, as before the US Congress, Lane hosted a concern is one that should be taken seri- well as the Charles G. Koch Founda- conference on geoengineering383 and au- ously. In 2008, Newt Gingrich, former tion.371 thored several articles, book chapters, and Speaker of the US House of Representa- other writings.384 One of these papers, An tives and fellow at the American Enter- Schnare has advocated for geoengineering Analysis of Climate Engineering as a Re- prise Institute,389 cited AEI’s work on on several occasions,372 but two notable sponse to Climate Change, was produced geoengineering in his opposition to the moments were in 2007 and 2008. In for the climate-action-opposed Copenha- Climate Security Act of 2007, which 2007, Schnare testified before the US gen Consensus Center (CCC)385 and later would have created a national cap-and- Senate Committee on Environment and incorporated into a book by CCC presi- trade program for the United States.390 Public Works regarding the effects of cli- dent Bjørn Lomborg.386 More recently, at a hearing in November mate change on the Chesapeake Bay. In 2017, Representatives Lamar Smith and his testimony, he expressly advocated for AEI’s Geoengineering Project appears to Randy Weber—both noted climate deni- geoengineering and conversely claimed have simply disappeared after 2010. alists—indicated their support for dedi- that climate mitigation was the real threat While it is difficult to know exactly why, cated research into geoengineering as a to the bay.373 In 2008, Schnare delivered the change in the political context of the climate solution.391 a conference paper at the Heartland Insti- United States may offer an explanation. tute’s International Conference on Cli- The event description for the June 2008 Most proponents of geoengineering re- mate Change entitled Climate Change conference on geoengineering notes, search acknowledge the political and and the Uncomfortable Middle Ground: “Congress is likely to enact federal cli- moral hazard risks of geoengineering and The Geoengineering and “No Regrets” Poli- mate legislation in 2009.”387 Another even acknowledge how these ideas can be cy Alternative.374 In his presentation at the event, an AEI-sponsored discussion panel used by those opposed to emissions re- Heartland Institute conference, Schnare titled Evaluating the Geoengineering Op- duction. Despite these acknowledge- argued for immediate solar geoengineer- tion in February 2010, was framed as fol- ments, they continue to push for addi- ing.375 Again, even the most strident ad- lows: “At a time when Congress prepares tional research and investment in the de- vocates of SRM research acknowledge for a looming battle about the Environ- velopment of these techniques. Because that it is nowhere near ready for deploy- mental Protection Agency’s plans to regu- these risks have real impacts on the de- ment at scale. late greenhouse gases under the Clean Air bate over climate responses and climate Act, could geoengineering, also known as policy, they cannot be lightly dis- The following year, Lee Lane, co-director climate engineering, offer a better alterna- missed.392 of the American Enterprise Institute’s tive?”388 FUEL TO THE FIRE 47

PART 7 We Must and Can Stay Below 1.5oC without Geoengineering

The question thus arises: Can we keep logical immaturity; limited physical and scale such measures… Even in the global temperature increase below 1.5°C understanding about their effective- uncertain case that the most adverse without relying on geoengineering technolo- ness to limit global warming; and a side-effects of SRM can be avoided, gies? A growing body of research suggests weak capacity to govern, legitimize, public resistance, ethical concerns and not only that the world must do precisely that, but that it can. Indeed, setting aside the false promise of geoengineering and FIGURE 20 focusing on accelerating the energy tran- IPCC Pathway 1 to 1.5oC sition, is the safest, surest way to confront the climate crisis.

In its Special Report on 1.5 degrees, the IPCC cautioned explicitly and repeatedly regarding the inherent limitations and profound risks of relying on geoengineer- ing approaches to solve the climate crisis.

As noted by the IPCC, and discussed throughout this report, potential path- ways with a high deployment of BECCS and other technological CDR methods include a high likelihood of exceeding (overshooting) the 1.5-degree limit, and rely on CDR to bring temperatures back down over long periods of time. With respect to those methods, the IPCC ob- served that:

“Most CDR options face multiple fea- sibility constraints, which differ be- tween options, limiting the potential for any single option to sustainably achieve the large-scale deployment required in the 1.5°C-consistent path- ways described in Chapter 2 (high confidence).”393

The IPCC found the risks of relying on SRM greater still. Accordingly, it de- clined to incorporate SRM in any form into its modeled pathways to 1.5 degrees.

“Uncertainties surrounding solar radi- ation modification (SRM) measures IPCC, Summary for Policymakers, in GLOBAL WARMING OF 1.5°C: AN IPCC SPECIAL REPORT ON constrain their potential deployment. THE IMPACTS OF GLOBAL WARMING OF 1.5°C 13 (V. Masson-Delmotte et al. eds., 2018), https:// These uncertainties include: techno- www.ipcc.ch/site/assets/uploads/sites/2/2018/07/SR15_SPM_version_stand_alone_LR.pdf. 48 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

potential impacts on sustainable devel- “These are pathways with very low Goals, a group of twenty researchers led opment could render SRM economi- energy demand facilitating the rapid by Sven Teske released a first-of-its-kind cally, socially and institutionally unde- phase-out of fossil fuels and process model detailing the changes needed to sirable.”394 emissions that exclude BECCS and achieve the climate targets of the Paris CCS use and/or pathways with rapid Agreement within sectors, within regions, The IPCC nonetheless identified a path- shifts to sustainable food consumption and for the planet as a whole.397 Affirm- way by which the world can stay below freeing up sufficient land areas for af- ing and amplifying the work of the 1.5 degrees of warming while avoiding forestation and reforestation. Some IPCC, Teske and his co-authors conclude SRM, BECCS, DACS, and other specu- pathways use neither BECCS nor af- that realistic pathways exist to keep the lative CDR technologies, and making forestation but still rely on CDR world below 1.5 degrees without using more limited use of nature-based carbon through considerable net negative CCS or geoengineering, but emphasize

reductions achieved through afforesta- CO2 emissions in the AFOLU sector that staying within 1.5 degrees requires tion, reforestation, forest conservation, around mid-century.”396 the virtually complete elimination of fos- and land use.395 sil fuel emissions and fossil fuel infra- Critically, these pathways place an early, structure by 2050. More specifically, It found that the pathways with the high- heavy priority on reducing energy de- global coal production must decline by est likelihood of keeping warming to be- mand and rapidly phasing out fossil fuels. 95% from 2015 levels by 2050, including low 1.5 degrees relied on only limited the complete elimination of lignite. Nat- deployments of CDR from natural sourc- A new analysis released in February 2019 ural gas production must be reduced by es. demonstrates that this change is feasible. 94%, and oil must fall to less than 9% of In Achieving the Paris Climate Agreement current production.398

FIGURE 21 One Generation Decarbonization Without CCS or Geoengineering

SVEN TESKE, ACHIEVING THE PARIS CLIMATE AGREEMENT GOALS: GLOBAL AND REGIONAL 100% RENEWABLE ENERGY SCENARIOS WITH NON-ENERGY GHG PATHWAYS FOR +1.5°C AND +2°C (2019), https://www.springer.com/gb/about-springer/media/press-releases/corporate/ achieving-the-paris-climate-agreement-goals/16443362. FUEL TO THE FIRE 49

Renewables are fossil fuel infrastructure does not yet ir- (PV) and wind, have made them increas- reparably commit the world to 1.5 de- ingly cost competitive against fossil fuel Eliminating the grees of warming. As Christopher Smith infrastructure around the world. A recent Rationale for Coal and and his co-authors noted in Nature Com- analysis by Carbon Tracker concluded munications, “geophysics does not yet that new wind and solar plants will be Gas in Energy commit the world to a long term warm- cheaper than 96% of existing coal-fired Generation ing of > 1.5 C.”400 Immediate action pro- power plants globally by 2030.401 vides a greater than 50% chance of stay- Transforming our economy at this speed ing below that limit if the world simply China is emblematic of this trend. China and scale poses a profound challenge, but phases out existing fossil fuel infrastruc- is both the largest consumer of coal-fired not an insurmountable one. However, ture at the end of its design lifetime. power and the global leader in renewable the longer we delay the transition, the energy deployments. After an extended smaller the chance we have to avoid cata- Our technological capacity to make this period in which renewable energy grew so strophic warming.399 transition is greater than is widely recog- quickly that it exceeded available subsi- nized. Over the last two decades, rapid dies, and in which deployment costs fell Provided we stop bringing new fossil fuel declines in the costs of renewable tech- dramatically, China announced in Janu- infrastructure online now, our existing nologies, particularly solar photovoltaics ary 2019 that it would remove the caps

FIGURE 22 Lazard Analysis Showing Wind and Solar PV are Cost Competitive with Natural Gas in Some Circumstances

Levelized Cost of Energy and Levelized Cost of Storage 2018, LAZARD (Nov. 8, 2018), https://www.lazard.com/perspective/ levelized-cost-of-energy-and-levelized-cost-of-storage-2018/. 50 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

for deploying unsubsidized renewables FIGURE 23 nationwide. The news sent renewable Cumulative Installed Solar PV Capacity: Global energy stocks in the country soaring.402 At the same time, this growth only increases the challenges to China’s existing fleet of coal-fired power plants. A separate analy- sis by Carbon Tracker found that 40% of the country’s coal-fired power stations are already losing money, and that this figure could rise to 95% by 2040. Carbon Tracker projects that it will be cheaper to build new wind farms than operate exist- ing plants by 2021, and that a new solar PV installation could be cheaper than coal by 2025.403

India, the second largest builder of new coal plants after China, has also seen new coal plant builds stall at growing rates, as long-standing barriers to renewable ener- gy deployments are eased.404 In early 2019, the country announced plans to bid out 500 gigawatts (GW) of new re- newable energy capacity by 2028, with the goal of adding 40 GW of non-hydro renewables per year.405 Infographic, Meister Consulting Group, The energy world is undergoing massive transformation (Mar. 2015), https://web.archive.org/web/20160413062109/http://www.mc-group.com/wp-content/uploads/2015/03/ The economics of the energy transforma- MCG-Renewable-Energy-Revolution-Infographic.pdf. tion are increasingly affecting natural gas as well. In its most recent analysis of the levelized cost of energy (LCOE) of com- peting power generation technologies, global consulting firm Lazard concluded a prior analysis, battery storage is increas- all have in common that the renewable that both solar PV and wind have become ingly performing the same function as energy potential exceeded the current 408 an increasingly attractive resource relative quickly or more quickly. As a result, and projected energy demands over to gas-fired power generation.406 For ex- deployments of grid-scale storage are ac- the next decades by an order of magni- 409 411 ample, solar PV installations had a lower celerating. In the US, the epicenter of tude.” LCOE than gas peaking plants across ev- the fracking boom for natural gas, this For at least two decades, however, energy ery region evaluated. Onshore wind was could render some 6 GW of new natural 410 experts have systematically underestimat- cheaper than or competitive with com- gas peakers unnecessary by 2027. ed the pace of innovation, cost reduc- bined-cycle gas turbine plants across tions, and deployment for renewable en- those same regions. While Lazard recog- ergy and energy efficiency technologies. nized that additional breakthroughs in The Pace of Renewable In 2015, Meister Consulting Group con- storage technology were needed to fully Deployments ducted a performance comparison of 15 replace fossil infrastructure, recent years separate long-term forecasts of renewable have witnessed precisely such break- Consistently Exceeds energy deployments by an array of insti- throughs.407 Official Forecasts tutions, corporations, and nonprofits.412 For example, a key rationale for continu- Across the board, it found that long-term Over the long term, the potential capac- forecasts had underestimated the speed ing to rely on natural gas in the face of ity for energy production from renewable falling renewable energy prices is that nat- and scale of renewable energy deploy- sources far exceeds projected global ener- ments, often dramatically. ural gas can be dispatched quickly to re- gy needs. As Teske observes, for example: spond to rapid changes in electricity de- “Over the past 15 years, a number of mand. However, as the Center for Inter- “Various research projects have anal- predictions—by the International En- national Environmental Law reported in ysed renewable energy potentials and ergy Agency, the US Energy Informa- FUEL TO THE FIRE 51

tion Administration, and others—have FIGURE 24 been made about the future of renew- Cumulative PV Capacity: Historic Data vs. IEA WEO Predictions able energy growth. Almost every one of these predictions has underestimat- ed the scale of actual growth experi- enced by the wind and solar markets. Only the most aggressive growth pro- jections, such as ’s Energy[R]evolution scenarios, have been close to accurate.”413

More tellingly, even Greenpeace had un- derestimated the speed of change with respect to both wind power and solar photovoltaics.414 Since 2005, Greenpeace has released a series of Energy Revolution reports intended to present an ambitious but feasible vision for addressing climate change. In its 2007 scenario, Greenpeace projected the world would install 60 GW in solar photovoltaic capacity by 2013.415 By 2010, Greenpeace had revised that 2013 projection dramatically upward to 75 GW of solar power.416 As Meister not- ed, however, actual installed global capac- ity for solar PV reached 140 GW.417 Ac- tual deployments had more than doubled the most ambitious projection in the space of six years. The International En- ergy Agency, whose World Energy Outlook is the most widely used reference for global energy deployments, fared much Auke Hoekstra, Photovoltaic Growth: Reality Versus Projections of the International Energy Agency – With 2018 worse, underestimating 2013 solar PV Update, STEINBUCH (Nov. 19, 2018), https://steinbuch.wordpress.com/2017/06/12/ deployments by 600% in 2006 and by photovoltaic-growth-reality-versus-projections-of-the-international-energy-agency/. over 200% in 2010.418

In the ensuing years, renewable energy In 2007, Greenpeace estimated that the world within a 2 degree target. To stay projections by both IEA and the US En- world might achieve 7,134 GW of in- within 1.5 degrees, the pace of change ergy Information Administration have stalled renewable capacity by 2050.420 By will need to accelerate still further. continued to dramatically understate the 2015, the more conservative of two Green- actual pace of growth.419 (See, for exam- peace scenarios projected the world In arguments that have been widely dis- ple, Figure 17.) In light of this continued would install nearly 7,800 GW by 2030, credited, some prominent geoengineering failure to properly predict renewable en- thus achieving a higher renewable target advocates have cautioned against such an ergy growth, IPCC renewable energy sce- two decades sooner.421 In the more ambi- expansion. (See Box 2: The Curious Case narios built on the deeply pessimistic and tious scenario, Greenpeace projected that of Dr. Keith and the Wind Farms.) demonstrably inaccurate assumptions of the world could achieve 100% renewable these bodies must be treated with pro- energy by 2050.422 found skepticism. The Energy Revolution Installed solar surpassed 390 GW by the The significance of these potential under- end of 2017,423 added another 98 to 109 in the Transport Sector estimates is even more striking when pro- GW in 2018, and is projected to add be- jections are evaluated over the longer Extends Far Beyond tween 109 and 125 GW per year in 2019 time horizons relevant to meeting the and 2020, with growth continuing to Cars 1.5-degree target. accelerate over time.424 Continued prog- Even as the world increases its supply of ress at this pace would help keep the renewable energy, however, it must dra- 52 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

matically reduce and ultimately eliminate nounced significant investments in elec- provide the primary route to mobility for 442 CO2 emissions from the transport sector. tric vehicle development and deployment, the country’s growing population. Chi- Proponents of inaction and of geoengi- and several companies or sub-national na has deployed more than 400,000 elec- neering alike have long argued that emis- jurisdictions had adopted phase-out dates tric buses to replace traditional and high- sions caused by transportation will be far for internal combustion engines.438 By the emitting diesel buses,443 with 30 Chinese more difficult to eliminate because much end of 2018, China had placed more cities announcing plans to fully electrify of the transport sector poses range, than a million electric vehicles on the their municipal transit by 2020.444 Just a weight, and energy density demands that road and announced new policy measures few years after the technology was ridi- battery electric technologies can’t meet. designed to further accelerate EV produc- culed for lacking any viable market, elec- tion.439 In addition, dramatic sales of Tes- tric buses account for 13% of global bus However, just as in the energy sector, the la’s Model 3 sedan, combined with the fleets and rising, and Bloomberg New rate of technological development and pending rapid rollout of other new EVs Energy Finance projects that electric bus- the adoption of electric vehicles (EVs) are to global markets, led an oil industry in- es will be cheaper to own and operate far outpacing past projections. As Teske vestment analyst to caution that rules of than their diesel counterparts within the observes, “Transport modelling has fossil fuel demand growth long consid- next two to three years.445 shown that the 2.0°C and 1.5°C path- ered unchangeable are, in fact, changing: ways can be met when strong and deter- Medium- and heavy-duty freight vehicles mined measures are taken, starting imme- “That’s 150,000 cars that don’t con- are following a similar path, with early diately.”436 Therefore, in the 1.5-degree sume gasoline. And it’s not just Tesla. innovators in the electric truck space now pathway outlined in Achieving the Paris Porsche, Audi, and BMW are all com- racing against startups and global manu- Climate Agreement Goals, reliance on in- ing out with all-electric vehicles in facturers alike to bring fleets of battery ternal combustion engines declines with 2019. So the inelasticities of demand electric trucks to both long-haul and increasing speed after 2022, falls to in this market are fundamentally short-haul markets.446 Given the heavy roughly 10% by 2040, and gradually ta- changing.”440 fuel demands and correspondingly high pers out as legacy vehicles reach end of emissions from road transport, the com- life.437 Critically, these advances extend well be- paratively short range requirements of yond cars to nearly every segment of the most medium-duty freight vehicles, and The accelerating research and deploy- transport sector. India, the world’s fourth the potential economies of scale associat- ment of EV technology for passenger cars largest producer of automobiles, has been ed with vehicle fleet operations, the po- is only the most visible sign of this revo- comparatively slow in its advancement of tential for rapid deployment and early lution. By early 2018, every major car electric cars441 but is accelerating electrifi- emissions reductions from this segment is manufacturer in the world had an- cation of two-wheeled vehicles, which particularly significant.

FIGURE 25 Rapid Decline of Internal Combustion Engines under 2oC and 1.5oC Scenarios

Johannes Pagenkopf et al., Transport Transition Concepts, in SVEN TESKE, ACHIEVING THE PARIS CLIMATE AGREEMENT GOALS: GLOBAL AND REGIONAL 100% RENEWABLE ENERGY SCENARIOS WITH NON-ENERGY GHG PATHWAYS FOR +1.5°C AND +2°C (2019), https://www.springer. com/gb/about-springer/media/press-releases/corporate/achieving-the-paris-climate-agreement-goals/16443362, at 140 (Figure 6.10). FUEL TO THE FIRE 53

BOX 2 The Curious Case of Dr. Keith and the Wind Farms

In late 2018, Harvard Professors Lee Miller and David Keith published two papers on the power density of wind and solar power, the potential land requirements for meeting all or substantially all of a country’s primary energy demand with wind or solar, and the potential environmental and social impacts of large-scale deployments. The first of these papers calculated the power densities for wind and solar installations, and argued that, because these power densities were low, deploying wind or solar at sufficient scale to meet a substantial portion of primary needs would exceed the available land in many countries. By way of example, the authors suggested that meeting 40% of Germany’s energy © LUKAS BIERI VIA PIXABAY needs with wind power would require that all of the country’s land be dedicated to wind power.425 The article met with a rapid and critical response from Stanford renewable energy expert Mark Jacobsen,426 who noted that Miller and Keith had dramatically overestimated the land requirements of wind power—and thus its impacts on other land uses and the environment.427

In a second paper, published at the same time, Miller and Notwithstanding such critiques, the Miller and Keith papers Keith highlighted that turbulence caused by wind turbines generated a flurry of stories in the popular media warning creates temporary and highly localized temperature increases about wind power’s potentially harmful impact on the above wind installations. Remarkably, they extrapolated from climate.432 One outlet that initially published and then this impact that the climate benefits of large-scale wind revised its story on the research changed its headline to read: power might be substantially offset by these temperature “A new study on the side effects of wind energy is almost increases.428 In a Harvard University press release announcing begging to be misused by climate change deniers.”433 As the research, Keith opined, “The direct climate impacts of predicted, the papers were welcomed by both geoengineering wind power are instant, while the benefits of reduced advocates and climate deniers alike.434 emissions accumulate slowly.” Accordingly, he argued, “If your perspective is the next 10 years, wind power actually Neither the research papers, nor the Harvard press release has—in some respects—more climate impact than coal or announcing their publication, disclosed Keith’s role as a gas. If your perspective is the next thousand years, then wind leading advocate of solar radiation modification nor his power has enormously less climatic impact than coal or personal financial stake in direct air capture, a technology gas.”429 Renewable experts again debunked the findings.430 In that would be substantially less valuable in an economy that a frank and detailed rebuttal, Mark Jacobsen concluded that transitioned rapidly to renewable energy.435 “these results are 100% wrong and should not be relied on to affect policy in any way.”431

Even in the most challenging transport Asia.447 To date, these deployments have have the potential to significantly reduce segments, such as shipping, the drive to focused on coastal, intra-coastal, and river emissions from both shipping and road deploy battery electric technology is shipping, where shorter haul distances transport. For example, an electric cargo growing. Recognizing the tremendous and access to shore facilities allow more carrier currently under development in potential cost savings of substituting elec- frequent charging. These vessel categories Norway will replace an estimated 40,000 tricity for diesel and marine fuels, the first account for a substantial portion of ship- heavy truck journeys per year.448 In early battery electric cargo ships and ferries are borne freight in Europe and Asia, and, 2019, global shipping leader Maersk also now being deployed in Europe and when battery technologies are deployed, announced that it would begin deploying 54 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW © OMEGA DESIGN DRUTEN DESIGN OMEGA ©

batteries to reduce fuel costs on ocean-go- Low-Tech, Win-Win plants and soils such as afforestation and ing container vessels as early as 2020.449 reforestation, soil carbon enhancement, Approaches to Climate and other conservation, restoration, and Moreover, despite the stringent power Mitigation and Carbon management options for natural and and safety requirements of aircraft, EV managed land, and coastal ecosystems.”454 technology is now in active development Removal are Ready to for use in private and commercial air op- Some of these approaches, including erations.450 Aircraft manufacturer Boeing Be Scaled Up those for afforestation and reforestation, and airline operator JetBlue have jointly Even as it cautioned about the risks and pose both benefits and potentially signifi- invested in Zunum Aero, which plans to uncertainties of BECCS, DACS, and oth- cant risks for indigenous peoples, small- bring a hybrid-electric commuter plan to scale agriculture, and the environment 451 er technological forms of carbon dioxide market by 2020. British-based EasyJet removal, the IPCC recognized the avail- depending on how and at what scale they plans to begin electric aircraft operations are deployed. Others, however, offer sig- 452 ability and potential benefits of more nat- by 2030. And Norway has announced ural approaches to CDR. Among these nificant potential for win-win scenarios plans for all short-haul flights originating are approaches for “the enhancement of that reduce atmospheric CO2 while pro- in the country to be 100% electric by terrestrial and coastal carbon storage in tecting the environment and improving 2040.453 the resilience of local communities. Im- FUEL TO THE FIRE 55

portantly, many of these win-win ap- FIGURE 26 Mitigation Potential Across All Ecosystem-Based Pathways proaches could be implemented almost immediately, with relatively modest costs and a high likelihood of local and public support.

A 2018 study by the Climate Land Ambi- tion and Rights Alliance (CLARA) exam- ined in detail the risks, benefits, scalabil- ity, and potential impact of these ap- proaches.455 While recognizing and em- phasizing the risks of BECCS, plantation forestry, biofuel production, and other large-scale monocultures, the CLARA study identified a wide range of policy tools that could store or draw down at-

mospheric CO2 while simultaneously ad- dressing needs for adaptation, food secu- rity, access to fresh water, and communi- ty land rights. These win-win climate tools include:

• Protecting and restoring natural for- ests, peatlands, and grasslands; • Restoring forest ecosystems by fos- tering natural regeneration and refor- estation; • Improving forest management prac- tices to reduce emissions from exist- ing forests; • Applying agro-ecological principles to increase carbon uptake through agroforestry and conservation of ag- ricultural soils; • Addressing the climate impacts of livestock production; and • Reducing meat consumption and food waste.456

Considered together, these achieve miti- gation and carbon removals of nearly 15 gigatons per year by 2050. The authors of the CLARA report acknowledged that not all of these approaches can be de- ployed to the full potential of natural sys- tems. For example, were natural forests to recover to their pre-industrial extent, the arable land available for food production or other human uses would be substan- tially reduced.457 They noted, however, that adopting complementary strategies KATE DOOLEY ET AL., CLIMATE LAND AMBITION RIGHTS ALLIANCE, MISSING PATHWAYS to reduce meat consumption and food TO 1.5C: THE ROLE OF THE LAND SECTOR IN AMBITIOUS CLIMATE ACTION (2018), https:// waste could free up significant areas of www.climatelandambitionrightsalliance.org/report. 56 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

FIGURE 27 Land-Use Sequestration Pathways Showing Annual Sequestration Rates Over Time

Malte Meinshausen and Kate Dooley, Mitigation Scenarios for Non-Energy GHG¸ in SVEN TESKE, ACHIEVING THE PARIS CLIMATE AGREEMENT GOALS: GLOBAL AND REGIONAL 100% RENEWABLE ENERGY SCENARIOS WITH NON-ENERGY GHG PATHWAYS FOR +1.5°C AND +2°C (2019), https://www.springer.com/gb/about-springer/media/press-releases/corporate/achieving-the-paris-climate-agreement-goals/16443362, at 79-93.

land for recovery of natural ecosystems or Meinshausen noted that large-scale refor- amount equal to all historic emissions for agroforestry. estation, particularly in the tropics and from land use.462 The many benefits of subtropics, had the largest potential to this approach would include increased Recognizing the important contribution contribute to climate mitigation, with the protection, reduced , of indigenous peoples and forest commu- second greatest gains coming from better improved at the local scale, and nities to meeting conservation and cli- protecting existing forests from illegal and reductions in . mate goals, the authors highlighted the unsustainable logging.460 By setting aside critical need to address issues of land ten- a portion of existing, actively logged for- As the CLARA report cautioned, howev- ure and to fully respect and protect the ests for ecosystem restoration, atmospher- er, these figures represent only the theo- control of indigenous peoples over their ic carbon could be reduced while simulta- retical potential of land-based strategies, traditional territories as intrinsic elements neously restoring ecosystem functions and the levels of achievable storage and of climate solutions.458 and increasing the resilience of natural carbon removal would likely be much biological communities.461 lower once competing needs for food se- Kate Dooley of the University of Mel- curity and land tenure are taken into ac- bourne, one of two lead authors on the Taking the median of the pathways iden- count. Thus, the authors argue, land-use CLARA paper, further extended this tified, the protection and restoration of strategies should be adopted only as a analysis in a contribution to Teske’s natural forests and agricultural soils has complement to ambitious and aggressive Achieving the Paris Climate Agreement the theoretical potential to store nearly mitigation efforts, including a rapid tran- Goals.459 Dooley and co-author Malte 152 gigatons of carbon by 2150, an sition away from fossil fuels. FUEL TO THE FIRE 57

As Teske concluded, “the important re- A recent analytical survey of potential For the survey, a team of 17 researchers sult of this study is that the addition of climate interventions in the world’s from leading universities and research land-use CO2 and other GHG emission oceans reached similar conclusions, find- institutes around the world reviewed 13 pathways to energy-related scenarios ing that an array of known and imple- potential interventions in the world’s yields scenarios that stay below or get be- mentation-ready strategies have higher oceans that included both geoengineering low 1.5 °C warming without a reliance benefits and lower risks for climate, coast- technologies (cloud brightening, albedo on massive net negative CO2 emission al communities, and marine ecosystems enhancement, ocean fertilization, and potentials towards the second half of this than strategies based on geoengineer- alkalinization), deployment of renewable century.”463 ing.464 energies, adaptation, and more nature-

FIGURE 28 Comparison of 13 Potential Ocean-Based Climate Solutions

Jean-Pierre Gattuso et al., Ocean Solutions to Address Climate Change and Its Effects on Marine Ecosystems, 5 FRONTIERS IN MARINE SCI. (2018), https://www. frontiersin.org/articles/10.3389/fmars.2018.00337/full. 58 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

based strategies, such as restoring coastal FIGURE 29 ecosystems and vegetation, protecting Assessment of Cobenefits and Disbenefits of 13 Ocean-Based Climate Solutions habitats and species, and reducing pollu- tion and .

Potential interventions were evaluated based on their impact, duration, techno- logical readiness, cobenefits, and absence of “disbenefits” (negative impacts).

Consistently, and as discussed in this re- port, geoengineering and similar techno- logical interventions to climate impacts on the oceans were characterized by low to very low degrees of technical readiness, limited zones of potential positive impact, high risks of negative impacts, and few, if any, cobenefits. By contrast, strategies such as scaling up renewable energy, re- storing and conserving coastal vegetation, and protecting biota and ecosystems from overexploitation, pollution, and have high to very high de- grees of technological readiness, benefits that are permanent in duration, high lev- els of cobenefits, and a general absence of Jean-Pierre Gattuso et al., Ocean Solutions to Address Climate Change and Its Effects on Marine Ecosystems, 5 FRONTIERS IN MARINE SCI. (2018), https://www.frontiersin.org/articles/10.3389/fmars.2018.00337/ 465 negative impacts. full.

Taken together, these studies demon- strate that, while the early and rapid phase-out of fossil fuels is central to stay- ing below 1.5 degrees, a wide array of feasible, technologically ready, and widely beneficial strategies exist to help address the climate crisis without relying on risky and uncertain geoengineering technolo- gies. FUEL TO THE FIRE 59

PART 8 Conclusions

After a century of early warnings and de- This report suggests a different conclu- pends on the widespread, economical cades of relative inaction, the global com- sion: that the only feasible way to keep deployment of carbon capture and stor- munity now faces an ultimatum: Act im- the world below 1.5 degrees is to rapidly age—and thus on the continued produc-

mediately to reduce global CO2 emissions transform our fossil economy. Drawing tion of burnable fuels through enhanced 45% by 2030 and to net zero by around on the history, present landscape, and oil recovery, enhanced coal bed methane, 2050, or commit humanity and the earth future prospects for geoengineering, this or fossil fuel substitutes produced from to catastrophic levels of climate change. analysis demonstrates the numerous and biofuels or direct air capture. The window of opportunity is narrow dangerous ways in which geoengineering and closing rapidly. Making the necessary threatens to further entrench the fossil This dependence on and promotion of reductions will demand an immediate infrastructure that drives climate change CCS would extend the lifetimes of exist- and dramatic transition of our economy and to commit present and future genera- ing coal and gas infrastructure and pro- away from fossil fuels and toward cleaner, tions to the compounded risks of both mote the construction of new fossil infra- safer forms of energy. climate change and large-scale geoengi- structure, which would continue produc- neering. ing and burning fossil fuels for decades to come. Faced with the stark realities of climate change and a continued lack of ambition Carbon Dioxide Removal is the Direct air capture requires enormous en- from major governments, a growing Carbon (Fossil Fuel) Industry in ergy inputs, consuming renewable energy number of proponents argue that assum- that could otherwise be used to displace ing the world can make the needed Another Form fossil-fueled power. Moreover, DAC is changes is naïve and dangerous, and that, intended for use in the further produc- accordingly, humanity must consider To a profound degree, the viability of tion of liquid fuels or, like CCS, in en- other options. strategies for carbon dioxide removal de- hanced oil recovery, creating powerful incentives to slow the transition away from internal combustion engines.

BECCS poses enormous risks to human rights, is fundamentally reliant on CCS, and may not be feasible or even emis- sions-negative at scale.

Meanwhile, enhanced weathering will only be viable—if at all—if it benefits coal-burning utilities and similar indus- tries seeking to dispose of massive, toxic stockpiles of coal combustion waste and industrial slag.

Moreover, even as CDR technologies promote new oil and gas production, the prospect of future negative emissions en- ables major oil, gas, and coal producers to project the continued use of their prod- ucts for decades to come, discouraging needed investments in cleaner, more vi-

© CATHY (HAGLUNDC) VIA FLICKR VIA (HAGLUNDC) CATHY © able alternatives. 60 CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW

Solar Radiation Management is a which is routinely discounted or deferred As this report demonstrates, the distrac- by many advocates of SRM. tion of geoengineering is not simply dan- Dangerous Distraction—and gerous; it is unnecessary. While most pro- Simply Dangerous Whether open-air experiments could re- posed approaches to CDR and SRM re- duce the risks associated with particular main speculative, the technologies we Since at least the 1960s, human interfer- technologies is uncertain. That such test- need to reduce emissions, transform our ence with the earth’s radiation balance ing would provide a rationale for wider economy, and confront the climate crisis has been seen as a potential driver of fu- deployment of the technologies involved are available, proven, and scalable. ture profits for fossil fuel producers and is likely. That geoengineering is more Confronting the challenge of climate users. Since the beginning of the modern likely to compound the climate crisis change is not a matter of future technol- climate debate, these same companies than to alleviate it is clear. ogy, but present political will and eco- have looked to geoengineering as a prom- nomic investment. ising alternative to emissions reductions. Geoengineering Does Not Solve the Problem at the Heart of the Elected officials, bureaucrats, activists, For at least three decades, the fossil fuel and the public are being forced to reckon industry has argued that the prospect of Climate Crisis: Reliance on Fossil with geoengineering, in part because of solar radiation management and other Fuels the severity of the crisis and in part be- forms of geoengineering justifies delaying cause fossil fuel interests have helped ush- or minimizing other actions to address The evidence outlined in this report er geoengineering into the public debate. climate change. points to a simple but essential truth: Al- The global community now has to decide most all geoengineering proposals serve to whether it will take the hard steps to rap- That perspective has been repeatedly entrench and benefit fossil fuel interests idly and equitably transition its econo- echoed by other geoengineering propo- rather than solve the climate crisis. By mies away from fossil fuels and into more nents as well, who envision a future in promoting the development of new fossil sustainable systems, or whether it will bet which the world continues burning fossil fuels and costly fossil infrastructure, by on unproven, questionably effective, and fuels and actively controls the earth’s ra- diverting resources away from proven dangerous technologies that serve the in- diation balance for decades or centuries mitigation strategies to costly boondog- terests of the industry at the root of the to mask the resulting climate impacts. gles, and by sustaining the myth that climate crisis. meaningful climate action can be safely Even the least speculative of these tech- delayed or narrowly constrained, geoengi- nologies pose profound and widely recog- neering threatens to undermine real solu- nized risks to the climate, agriculture, and tions at the time when they are most ur- the environment—the consideration of gently needed. FUEL TO THE FIRE 61

CHAPTER 6 Endnotes

1. Rex Tillerson, CEO, ExxonMobil Corp., 15. See id. 127 (1965), https://babel.hathitrust.org/cgi/ Speech to Council on Foreign Relations: 16. See Mitigation Pathways, in Global pt?id=uc1.b4116127;view=1up;seq=9. The New North American Energy warming of 1.5°C, supra note 9, at 121. 30. See Center for International Paradigm: Reshaping the Future (June 27, 17. See, e.g., id. at 121, 123 and §2.3.4.2; Ove Environmental Law (CIEL), Smoke and 2012), https://www.cfr.org/event/ceo- Hoegh-Guldberg et al., Impacts of 1.5°C of Fumes: The Legal and Evidentiary bases speaker-series-conversation-rex-w-tillerson. Global Warming on Natural and Human for Holding Big Oil Accountable for 2. Henry Wexler, Modifying Weather on a Systems, in Global warming of 1.5°C 268, the Climate Crisis 10-11 (2017), https:// Large Scale, 128 Science 1059 (1958), Cross-Chapter Box 7 (V. Masson-Delmotte www.ciel.org/wp-content/uploads/2017/11/ https://www.jstor.org/stable/1755896. et al. eds., 2018), https://www.ipcc.ch/site/ Smoke-Fumes-FINAL.pdf. 3. See Spencer Weart, Timeline, The assets/uploads/sites/2/2019/02/SR15_ 31. See James F. Black, InsideClimate News Discovery of Global Warming (Feb. Chapter3_Low_Res.pdf [hereinafter Impacts (Sept. 15, 2015), https://insideclimatenews. 2018), https://history.aip.org/climate/ of 1.5°C, in Global warming of 1.5°C]; org/news/15092015/james-black. See timeline.htm. Heleen de Coninck et al., Strengthening and generally Exxon: The Road Not Taken, 4. The Royal Society, Geoengineering Implementing the Global Response, in Global InsideClimate News, https:// The Climate: Science, Governance And warming of 1.5°C 316, § 4.3.7 (V. insideclimatenews.org/content/Exxon-The- Uncertainty ix (2009), https://eprints. 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See Intergovernmental Panel on 11:47 AM), https://www.nbcnews.com/ Popular Mechanics 180 (1963) (on file Climate Change, Global warming of news/us-news/last-ditch-global-warming-fix- with authors). 1.5°C: An IPCC Special Report on the man-made-volcanic-eruption-n918826. 35. Cloud Formation and Subsequent Moisture impacts of global warming of 1.5°C 20. The Royal Society, supra note 4, at ix. Precipitation, US Patent No. 3,409,220 above pre-industrial levels and related 21. See Summary for Policymakers, in Global (filed Mar. 26, 1965). global greenhouse gas emission warming of 1.5°C, supra note 8, at §§ 36. See Panel on Weather and Climate pathways, in the context of 4.3.7-4.3.8. Modification, Weather and Climate strengthening the global response to 22. See United Nations Environment Modification: Problems and Prospects the threat of climate change, Programme, The Emissions Gap Report (1966), http://sonmi.weebly.com/ sustainable development, and efforts 2017 58-66 (2017), https://wedocs.unep. uploads/2/4/7/4/24749526/weather_and_ to eradicate poverty (V. Masson- org/bitstream/handle/20.500.11822/22070/ climate_modification_problems_and_ Delmotte et al. eds., 2018), https://www. EGR_2017.pdf. prospects_1966.pdf. ipcc.ch/sr15/ [hereinafter Global warming 23. Martin I. Hoffert et al., Advanced Technology 37. See id. at 163-68. of 1.5°C]. Paths to Global Climate Stability: Energy for 38. See id. at 82. 7. See id. a Greenhouse Planet, 298 Science 981, 983 39. See W.M. Gray et al., Weather 8. See IPCC, Summary for Policymakers, in (2002), http://mcensustainableenergy. Modification by Carbon Dust Global warming of 1.5°C C.1 (V. pbworks.com/f/Global Climate Stability Absorption of Solar Energy (1974), Masson-Delmotte et al. eds., 2018), https:// Technology Paths - Hoffert.pdf. http://www.alachuacounty.us/Depts/epd/ www.ipcc.ch/site/assets/uploads/ 24. See generally Albert C. Lin, Does EPAC/William%20M.%20Gray%20-%20 sites/2/2018/07/SR15_SPM_version_ Geoengineering Present a Moral Hazard?, 40 Weather-modification%20by%20 stand_alone_LR.pdf [hereinafter Summary Ecology L.Q. 673 (2013), https://law. Carbon%20Dust%20Absorption%20 for Policymakers, in Global warming of ucdavis.edu/faculty/lin/files/ELQ. of%20Solar%20Energy%201974.pdf. 1.5°C]. MoralHazard.pdf. 40. See id. at 168. 9. J. Rogelj et al., Mitigation Pathways 25. James Rodger Fleming, The Callendar 41. See History: How We Became the Center for Compatible with 1.5°C in the Context of Effect 49-61 (2007), http://www.colby. 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54. See R.E. Sweatman et al., Industry CO2 EOR industrial process that uses CO2, such as, (1997), https://www.sciencedirect.com/ Experience Relevant for Carbon Capture and machining coolant and lubricant, grit science/article/pii/S0196890496002695. Storage (CCS), Oil & Gas Journal (Dec. 7, blasting, e.g. for smoothing and paint 72. See Oil Change International, Drilling 2009), https://www.ogj.com/articles/print/ removal, cryogenic cleaning, quick freeze Towards Disaster: Why U.S. Oil And volume-107/issue-45/general-interest/ processes, production and use of R744 Gas Expansion Is Incompatible With

industry-co-sub-2.html. refrigerant, CO2 based dry cleaning solvents, Climate Limits 5 (2019), http://priceofoil. 55. See Imperial Oil Limited, Review of perishable shipping container pre-cooling, org/content/uploads/2019/01/Drilling- Environmental Protection Activities perishable shipping inert environment Towards-Disaster-Web-v2.pdf. for 1978-1979 2 (1980), https://www. maintenance, beverage carbonation, fire 73. Furthering carbon capture, Utilization, desmogblog.com/sites/beta.desmogblog. suppression, plant fertilization, horticulture, Technology, Underground storage, and com/files/DeSmogBlog-Imperial%20 agriculture, silvaculture, aquatic algae Reduced Emissions Act, 26 U.S.C. §45Q Oil%20Archives-Review%20 production, enhanced oil recovery, water (2018). Environmental%20Activities-1980.pdf softening, Solvay process, propellant, 74. Id.

(“Technology exists to remove CO2 from pressurizing gas, e.g. for aer osol cans, 75. See International Energy Agency (IEA), stack gases but removal of only 50% of the inflation gas, e.g. for life rafts, supercritical Storing CO2 Through Enhanced Oil CO2 would double the cost of power CO2 extraction, semi conductor Recovery 31 (2015), https://www.iea.org/ generation.”). See also Brendan DeMelle & manufacturing, organic solvent, perfume publications/insights/insightpublications/ Kevin Grandia, “There is no doubt”: Exxon aromatics, decaffeinating beverages, e.g. Storing_CO2_through_Enhanced_Oil_ Recovery.pdf FUEL TO THE FIRE 63

76. See, e.g., U.S. Department of Energy, Conservation Voters (July 16, 2018), com/resources/ccs-database-public/ (last Carbon Capture, Utilization, and Storage: http://origin.lcv.org/article/mi06-clean- visited Jan. 3, 2019) (select “China” from Climate Change, Economic energy-fred-upton-misses-mark/. Country menu and “Large-scale CCS Competitiveness, and Energy Security (issue 88. See Simon Bennet & Tristan Stanley, US facility” from Category menu). brief, 2016), https://www.energy.gov/sites/ Budget Bill May Help Carbon Capture Get 101. See id. prod/files/2016/09/f33/DOE%20Issue%20 Back on Track, IEA (Mar. 12, 2018), 102. See Gulf Coast Carbon Center (GCCC), Brief%20-%20Carbon%20Capture%20 https://www.iea.org/newsroom/news/2018/ GCCC, http://www.beg.utexas.edu/gccc Utilization%20and%20 march/commentary-us-budget-bill-may- (last visited Jan. 3, 2019); Julie Berwald, Storage_2016-08-31.pdf. help-carbon-capture-get-back-on-track. GCCC, The Carbon Question: The 77. See id. at 3. html. Gulf Coast Carbon Center Has Got

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Fuel CO2 Neutralization by Marine CaCO3, springer.com/ 248. See Leo Hickman, Timeline: How BECCS 12(2) Global Biogeochemical Cycles article/10.1007%2FBF00027683 (“The Because Climate Change’s ‘Saviour’ 259 (1998), https://agupubs.onlinelibrary. idea of enhancing growth of marine algae is Technology, CarbonBrief (Apr. 13, 2016, wiley.com/doi/epdf/10.1029/98GB00744. not new, in fact, it has been previously 8:00 AM), https://www.carbonbrief.org/ 217. See About Us, Cquestrate, http://www. considered as a means to grow biomass to beccs-the-story-of-climate-changes-saviour- cquestrate.com/about-us/ (last visited Feb. serve as fuel for energy production[.]”). technology. 4, 2019). 234. See, e.g., Kimon Bird et al., Effects of Marine 249. See Summary for Policymakers, in Global 218. See Detailed Description of the Idea, Algal Proximate Composition on Methane warming of 1.5°C, supra note 8, at 20. Cquestrate, http://www.cquestrate.com/ Yields, 2(3) J. of Applied Phycology 207, 250. See Shell International, supra note 50. the-idea/detailed-description-of-the-idea/ 212 (1990), https://link.springer.com/ 251. See discussion supra note 32, and (last visited Feb. 4, 2019). article/10.1007%2FBF02179777 accompanying text. (acknowledging support from the Gas 252. See discussion supra note 39, and Research Institute). accompanying text. FUEL TO THE FIRE 67

253. See discussion supra Asphalt Fields and Global Warming, MIT Tech. Rev. (Jan. 22, 286. Id. Black Carbon Skies: A Brief History of 2018), https://www.technologyreview. 287. Justin McClellan, David W. Keith & Jay Fossil Fuels and Weather Modification. com/s/610007/were-about-to-kill-a-massive- Apt, Cost Analysis of Stratospheric Albedo 254. See, e.g., Christopher Mims, “Albedo Yachts” accidental-experiment-in-halting-global- Modification Delivery Systems, 7 Envtl and Marine Clouds: A Cure for Climate warming/. Research Letters (2012), https:// Change?, Scientific American, Oct. 21, 270. Jan Fuglesvedt & Terje Berntsen, Shipping iopscience.iop.org/ 2009, https://www.scientificamerican.com/ Emissions: From Cooling to Warming of article/10.1088/1748-9326/7/3/034019/ article/albedo-yachts-and-marine-clouds/. Climate—and Reducing Impacts on Health, meta. For the detailed methodology 43 Envtl Sci. Tech. 9,057, 9,060 (2009), underlying the analysis see Justin 255. See, e.g., Julia Crook et al., Can Increasing https://pubs.acs.org/doi/full/10.1021/ McClellan et al., Aurora Flight Albedo of Existing Ship Wakes Reduce Climate es901944r?src=recsys. Sciences, Geoengineering Cost Analysis Change?, 121(4) J. of Geophysical 271. See id. (2010), http://agriculturedefensecoalition. Research: 1,549 (2016), 272. Temple, supra note 269. org/sites/default/files/file/ https://agupubs.onlinelibrary.wiley.com/ 273. National Academy of Sciences, supra geoengineering/16M_2010_Aurora_Flight_ doi/full/10.1002/2015JD024201. note 256, at 453. Sciences_Geoengineering_Cost_Analysis_ 256. See National Academy of Sciences, 274. See Press Release, UC San Diego, Dr. Final_Report_October_30_2010_ Policy Implications of Greenhouse Stanford S. Penner selected to head Fossil AR10_182_University_of_Calgary_Keith. Warming 448 (1992), https://www.nap. Energy Research Working Group (March pdf. edu/read/1605/chapter/1. 17, 1978), https://library.ucsd.edu/dc/ 288. Justin McClellan was employed by Aurora 257. See discussion infra, note 302, and object/bb46770853. And see, e.g., Stanford Flight Sciences Corporation until 2015. See accompanying text. Penner, Assessment of Long-Term Research Justin McClellan, LinkedIn, https://www. 258. Douglas MacMartin, & David Needs for Coal-Liquefaction Technologies linkedin.com/in/justinmcclellan/ (last Keith, Solar Geoengineering to Limit the Rate (technical paper, 1980), https://www.osti. visited Feb. 5, 2019). Although Aurora of Temperature Change, Phil. Trans. of gov/biblio/766251. Flight Sciences is a subsidiary of Boeing The Royal Society 11 (2014), https:// 275. Stanford Penner et al., Active Measures for (Aurora Flight Sciences, http://www. royalsocietypublishing.org/doi/full/10.1098/ Reducing the Global Climate Impacts of aurora.aero/ (last visited Feb. 5, 2019)),

rsta.2014.0134. Escalating CO2 Concentrations, 11(6) Acta Boeing’s links to the author are not 259. See id. at 8. Astronautica 345, 345 (1984), https://www. disclosed in the paper. 260. See id. at 2 (“This implied framing in sciencedirect.com/science/article/ 289. See Presentation, Carnegie Mellon existing analyses could have a significant pii/0094576584900456 Electricity industry Center (CEIC), Jay Apt, effect on perceptions of SRM risks as it 276. Id. Faculty Introduction: Jay Apt 4 (2010), implies that, once deployed, there is a 277. See Stanford Penner & John Haraden, A http://smartgrid.cmuportugal.org/wp- necessity to maintain an SRM deployment Low Cost Technology for Increasing Earth’s content/uploads/2010/10/Jay-Apt-Faculty- either for millennia or until CO2 Albedo to Mitigate Temperature Rise, 18 Introduction-for-Meeting-at-IST-Lisbon- concentrations were sufficiently reduced”). Energy 1087 (1993), https://ac.els-cdn. October-11-2010.pdf (“Core funding: A.P. com/036054429390057K/1-s2.0- Sloan Foundation and EPRI.”). 261. Michael MacCracken, The Rationale For 036054429390057K-main.pdf?_ 290. McClellan, Keith & Apt, supra note 287, at Accelerating Regionally Focused Climate tid=5ec9bbdc-8d72-4821-b468-21f0cb62d 2. Intervention Research, 4(12) Earth’s 9e0&acdnat=1548660114_660e8ddee616d 291. See id. at 6 (emphasis added). Future 649, 652 (2016), https://agupubs. 0a009f658e9db2989b3. 292. Id. at 6-7 (emphasis added). onlinelibrary.wiley.com/doi/ 278. See id. at 1088. 293. Id. at 7. epdf/10.1002/2016EF000450. 279. See id. 294. See, e.g., Andy Jones, Jim Haywood & 262. See Aerosols and Incoming Sunlight (Direct 280. Id. at 1088 Olivier Boucher, Climate Impacts of Effects), NASA Earth Observatory (Nov. 281. Handwritten annotation to SS Penner, A Geoengineering Marine Stratocumulus Clouds, 2, 2010), https://earthobservatory.nasa.gov/ Low Cost / No Regrets View of Greenhouse 114 J. Geophys. Res. Atmos. 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They America, with particularly detrimental Change 129, 160-61 (Susan Solomon et al. gave me, like, $30,000 a year for five years, impacts on the Amazon rain forest. These eds., 2007), https://www.ipcc.ch/site/assets/ to do what I wanted.”). results show that, while some areas benefit uploads/2018/02/ar4-wg1-chapter2-1.pdf. 283. Wallace Broecker, How to Build a from geoengineering, there are significant 264. See Sulfur Dioxide Basics, US EPA, https:// Habitable Planet 274-275 (1985), areas where the response could be very www.epa.gov/so2-pollution/sulfur-dioxide- https://www.ldeo.columbia.edu/~broecker/ detrimental with implications for the basics (last visited Feb. 5, 2019). Home_files/How%20To%20Build%20 practical applicability of such a scheme.”). 265. See What is Acid Rain?, US EPA, https:// A%20Habitable%20Planet.pdf 295. See, e.g., Aditya Nalam et al., Effects of Arctic www.epa.gov/acidrain/what-acid-rain (last 284. David W. Keith & Hadi Dowlatabadi, A Geoengineering on Precipitation in Tropical visited Feb. 5, 2019). Serious Look at Geoengineering, 73 Trans. Monsoon Regions, 50 Climate Dynamics 266. See id. Am. Geophys. Union 289, 292 (1992), 3,375 (2018), https://link.springer.com/ 267. See, e.g., Mercè Labordena et al., Blue Skies https://agupubs.onlinelibrary.wiley.com/ article/10.1007/s00382-017-3810-y. Over China: The Effect of Pollution-Control doi/abs/10.1029/91EO00231. 296. See Stephen Salter and Alan Gadian, Coded on Solar Power Generation and Revenues, 285. See id. at 292 (The acknowledgments states: Modulation of Computer Climate Models PLOS ONE (2018), https://journals.plos. “This work was supported under NSF grant for the Prediction of Precipitation and org/plosone/article?id=10.1371/journal. SES 9022738 and EPRI contract RP Other Side-effects of Marine Cloud pone.0207028. 3236.”) The research by Keith and his Brightening 2 (research proposal, Jan. 25, 268. 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297. See id. 311. S. Fred Singer, Roger Revelle & Chauncey aircraft-implications-cost-and-feasibility; 298. See Jonathan Proctor et al., Estimating Starr, What to Do about Greenhouse Douglas MacMartin, Katharine Ricke & Global Agricultural Effects of Geoengineering Warming: Look Before You Leap, 5 Cosmos: David Keith, Solar Geoengineering as Part of Using Volcanic Eruptions, 560 Nature 480 A Journal of Emerging Issues (1992) at an Overall Strategy for Meeting the 1.5oC (2018), https://www.nature.com/articles/ 1, https://pdfs.semanticscholar.org/9e66/9c Paris Target, 376 Phil. Trans. of the s41586-018-0417-3. 695effa8fa73ce3fa6bea331c2f85b107a.pdf . Royal Society (2008), https://keith.seas. 299. See Christopher Smith et al., Impacts of 312. Id. at 8. harvard.edu/files/tkg/files/macmartin_ricke_ Stratospheric Sulfate Geoengineering on 313. David Keith, Geoengineering the Climate keith_ptrs.pdf. 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Action (2018), https://www. wind-power-cause-local-warming-2018-10 com/article/4207663-electric-truck-boom- climatelandambitionrightsalliance.org/ (originally titled “Climate effects of wind begin; Executive Analysis of Electric Truck report. power cause local warming”). Market, Forecast to 2025, Report Linker 456. See id. 434. See, e.g., Anthony Watts, Harvard: Wind (Dec. 2017), https://www.reportlinker.com/ 457. See id. at 15 and 17. Power Will Create Significant Warming of p05281649/Executive-Analysis-of-Electric- 458. See id. at 5-8. 0.24C, Plus Eat Up 5 to 20x More Land Truck-Market-Forecast-to.html. See also 459. Malte Meinshausen and Kate Dooley, Than Thought, Watts Up With That? Brett Williams, 9 Futuristic Trucking Projects Mitigation Scenarios for Non-Energy GHG¸ (Oct. 4, 2018), https://wattsupwiththat. That Will Compete With Tesla’s Semi, in Teske, supra note 399, at 79-93. com/2018/10/04/harvard-wind-power-will- Mashable (Nov. 16, 2017), https:// 460. 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FUEL TO THE FIRE How Geoengineering Threatens to Entrench Fossil Fuels and Accelerate the Climate Crisis

Fuel to the Fire: How Geoengineering Threatens to Entrench Fossil Fuels and Accelerate the Climate Crisis investigates the early, ongoing, and often surprising role of the fossil fuel industry in developing, patenting, and promoting key geoengineering technologies. It examines how the most heavily promoted strategies for carbon dioxide removal and solar radiation modification depend on the continued production and combustion of carbon-intensive fuels for their viability. It analyzes how the hypothetical promise of future geoengineering is already being used by major fossil fuel producers to justify the continued production and use of oil, gas, and coal for decades to come. It exposes the stark contrast between the emerging narrative that geoengineering is a morally necessary adjunct to dramatic climate action, and the commercial arguments of key proponents that geoengineering is simply a way of avoiding or reducing the need for true systemic change, even as converging science and technologies demonstrate that shift is both urgently needed and increasingly feasible. Finally, it highlights the growing incoherence of advocating for reliance on speculative and risky geoengineering technologies in the face of mounting evidence that addressing the climate crisis is less about technology than about political will.

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