SilverLining comment on the proposed “AGU Ethical Framework Principles on Climate Intervention Research”
As submitted to AGU
SilverLining is committed to safe climate research and evidence-based insights related to near-term climate risk and climate intervention. We recently submitted a comment addressing our concerns with the proposed “AGU Ethical Framework Principles on Climate Intervention Research,” highlighting both its potential implications and the process by which it has been crafted.
As champions of transparent, inclusive, and objective scientific discourse, we are sharing our thoughts and urging the community to join the conversation. You can read our full comment below.
We are supportive of the concerns driving the AGU’s Ethics Framework effort; but we are concerned that the deficiencies in the draft document and the process by which it is being developed pose risks to the generation of scientific evidence on climate interventions, to scientific independence and objectivity, and to its own stated goals of transparency, inclusiveness and justice. Some of these risks may extend to interrelated areas of research, such as research into weather modification and the effects of pollution aerosols. The current process has not adequately considered these risks or described how it will address them.
We have found that comments and workshop input in advance of the June 2022 draft were not significantly incorporated, and that the latest draft preserves the original document’s primary recommendations substance. Our specific concerns are described below:
Substantive Issues Concerning Science, Equity and Justice
The recently released framework covers a very broad range of activities (many of which are not in the AGU scope of expertise) and named but undefined requirements that are required before research is allowed. It is not clear if, when and how the AGU would establish the proposed new regulatory framework or the details of how it would function to enforce the framework principles. Presumably, critical scientific activity and advancement would be inhibited until the framework and process are resolved— something that could take years.
Functionally and practically, the proposed “principles” will slow research and prevent small, process-focused field studies from occurring. This is in tension with the AGU’s existing position statement on climate intervention research, which states that “substantial research and evaluation efforts are urgently needed to determine the effectiveness, risks, and opportunities of CI and inform societal decisions about possible implementation,” and “robust CI research programs require controlled field experiments.”
The document does not discuss any downside risks for research, including the many ways in which its recommendations could delay, inhibit or bias research. It also does not discuss the implications, including ethical, justice, and equity implications, of the risks associated with reducing the information available for informed decision-making in the context of catastrophic public safety risks from climate change.
Experimental activity has been described by major governmental and intergovernmental assessment reports as necessary for addressing critical questions in climate intervention research. In our opinion the poorly defined (or even undefinable), burdensome requirements on all experimental activity described in the document poses a substantial and possibly insurmountable barrier to the progress of the type of small-scale experiments that are critical for process understanding and information projections of impacts at larger scales. For example, according to the EFCIR, experiments at any scale need to:
Address 5 types of environmental justice (distributive justice, intergenerational justice, procedural justice, corrective justice, and ecological justice) (bullet 7, page 5)
Register under existing mechanisms (though it is not clear to which mechanisms this comment refers)
Go through an Institutional Review Board (though this board does not exist and remains completely undefined in the framework)
Follow standards and reporting structure for SRM experiments (though what these standards and reporting structure are is not defined)
What these requirements actually mean in terms of the process for researchers is not articulated anywhere in the document. There is currently no body that has set standards for what would constitute “addressing” these 5 types of environmental justice – and it’s not clear how one would do so for, for example, a small-scale, “de minimus” study with no measurable environmental or health impact. It is not clear what “existing mechanism” one would use to register a study where no existing environmental or health thresholds are exceeded, nor what the “standards and reporting structure for SRM experiments” are. There is no named Institutional Review Board at this time, and there is no discussion of what its remit or composition would encompass.
It is also unclear who would create the mechanisms for achieving this, how the specifics might be defined, how they relate to existing regulations and scientific practices, and what impact this has on the timing and independence of research.
As well described in scientific literature and assessments, there are significantly different scales of outdoor climate intervention research activities and there is already an infrastructure in place for managing the scale that falls below significant environmental impact (“de minimus”). This document fails to distinguish scales of activity, leading to misleading and confusing framing regarding small-scale outdoor research and conflation with the type and scale of activity that could have environmental and climate impacts, and that should rightly be subject to informed public debate. As a result, the document ignores an important class of climate intervention research that assessments have described as critical for evaluating climate intervention approaches and that already has an adequate framework for governance in place.
Climate interventions leverage natural processes that are the subjects of study and experimentation that are physically similar (or even identical) to studies relevant to weather modification research, pollution impacts research and climate basic science. These include physically similar release experiments in the atmosphere and ocean. New procedures and the introduction of influences that might impair scientific independence may have unintended consequences on these fields. This has not been adequately discussed or addressed.
Importantly, the negative impacts on research arising from these principles will have the greatest impact on researchers operating in open, democratic, academic and public interest contexts where there is an interest in promoting ethical and just science and policy. Procedural barriers and delays created by these recommendations are likely to result in research instead moving forward in closed communities—such as within defense and commercial sectors or autocratic regimes—with the unintended consequence of less transparent and equitable circumstances and heightened risks.
Process Issues Concerning Transparency, Inclusion and Reference to Evidence
It is not clear who in AGU is responsible for drafting this document, approving its contents, and reviewing (and ultimately making decisions regarding) the comments received in the public input processes. There is an Advisory Board overseeing the EFCIR process, but there is no authorship given on the latest “framework” document. We understand that the Advisory Board listed on the EFCIR did not have the opportunity to sign off on the framework or clear understanding of whether it was written by EFCIR-related staff at AGU or others, and authors are not listed on the site.
From a process point of view, the authorship, decision-making and comment adjudication for the AGU Ethics document process are not transparent, raising concerns that the recommendations may be counter to its community’s concerns and the AGU’s own statement on climate intervention. It is not clear that the process for developing the EFCIR document is consistent with AGU’s own practices.
The comment process is not transparent and provides no option for publication of the comments or responses from the parties responsible for generating the Ethical Framework. In the first round of comments, there was no evidence of substantive influence on the original document. It is not clear whether any parties, including those elicited for comments or via ‘listening meetings’ and events have meaningful influence or approval over the final document. A 2000 character limit imposed on comments in the current process is an unusual and striking limitation that inhibits meaningful substantive input.
There are scant references to evidence to support sweeping statements about approaches to governance and the need for highly unusual, broad and sweeping new processes and procedures for science. Such recommendations are typically accompanied by empirical evidence that demonstrates their effectiveness and applicability.
The Ethical Framework does not include research and analysis on existing laws and scientific funding agency practices, which is an important aspect of consideration of new procedures for physical science.
The entire process emphasizes regulatory and decision-making processes imposed on research rather than possibilities for improving equitable participation in research by researchers in developing countries, access to tools and information and transparency. This is a substantial deficiency. For example, to promote its goals of transparency and equity, the AGU might be able to consider areas such as journal access, access to data and analysis tools, and funding for international collaborators and research funding mechanisms for international and interdisciplinary collaboration.
Given the above concerns, we propose suspending the current process for drafting the AGU Ethics Framework to support careful review by both the Advisory Board and the AGU Council.
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