A Brief Primer on Ocean Fertilization in the CBD and the London Convention and Protocol

by Duncan E.J. Currie LL.B. (Hons) LL.M.

This briefing outlines the principal decisions and resolutions of the Convention on Biological Diversity and London Convention/Protocol relating to ocean fertilization in the context of the Haida Salmon Restoration Corporation’s “Haida Salmon Restoration Project”.

The CBD Moratorium

In May 2008 the Parties at COP-9 of the Convention on Biological Diversity (CBD) decided in Decision IX/16 that the Parties noted the 2007 Statement of Concern of the London Convention and Protocol,[1] urged Parties and other Governments to act in accordance with the decision of the London Convention, recognized the current absence of reliable data covering all relevant aspects of ocean fertilization, without which there is an inadequate basis on which to assess their potential risks, and put into place what is now known as the CBD moratorium:

“4. Bearing in mind the ongoing scientific and legal analysis occurring under the auspices of the London Convention (1972) and the 1996 London Protocol, requests Parties and urges other Governments, in accordance with the precautionary approach, to ensure that ocean fertilization activities do not take place until there is an adequate scientific basis on which to justify such activities, including assessing associated risks, and a global, transparent and effective control and regulatory mechanism is in place for these activities; with the exception of small scale scientific research studies within coastal waters. Such studies should only be authorized if justified by the need to gather specific scientific data, and should also be subject to a thorough prior assessment of the potential impacts of the research studies on the marine environment, and be strictly controlled, and not be used for generating and selling carbon offsets or any other commercial purposes.”

So, this means that the governments (such as the Canadian government, which is a Party to the CBD) have been requested to “ensure” that ocean fertilization activities do not take place until:

1. there is an adequate scientific basis on which to justify such activities, including assessing associated risks, and

2. a global, transparent and effective control and regulatory mechanism is in place for these activities;

with the exception of small scale scientific research studies within coastal waters. Such studies should only be authorized if justified by the need to gather specific scientific data, and should also be subject to a thorough prior assessment of the potential impacts of the research studies on the marine environment, and be strictly controlled, and not be used for generating and selling carbon offsets or any other commercial purposes.

Ocean fertilization was also the subject of negotiations at UNCSD Rio+20 in June this year, and in the outcome documentThe Future We Want,[2] States in paragraph stated that:

“167. We stress our concern about the potential environmental impacts of ocean fertilization. In this regard, we recall the decisions related to ocean fertilization adopted by the relevant intergovernmental bodies, and resolve to continue addressing with utmost caution ocean fertilization, consistent with the precautionary approach.”

It should be noted that to ‘recall’ the decisions in this context means to reiterate or draw attention to them, and so confirms that the decisions of the CBD and the LC/P are still of good standing, as well as that States are still concerned about the potential environmental impacts of ocean fertilization.

London Convention and Protocol


In 2007, the governing bodies of the London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (1972) and the 1996 London Protocol (LC/P)[3]

  • endorsed the “Statement of Concern” of their Scientific Groups, taking the view that knowledge about the effectiveness and potential environmental impacts of  ocean iron fertilization currently was insufficient to justify large-scale operations and that this could have a negative impact on the marine environment and human health;
  • agreed that the scope of work of the London Convention and Protocol included ocean fertilization, as well as iron fertilization, and that these agreements were competent to address this issue in view of their general objective to protect and preserve the marine environment from all sources;
  • agreed that they would further study the issue from the scientific and legal perspectives with a view to its regulation;
  • developed specific terms of reference for the Scientific Groups to discuss ocean fertilization in May 2008 and established the Legal Intersessional Correspondence Group (LICG) to summarize the legal views by Contracting Parties as to whether, and how, the legal framework of the London Convention and Protocol applies to key scenarios on ocean fertilization (LC 29/17, paragraphs 4.14 to 4.29 and annex 6); and
  • stated that “recognizing that it was within the purview of each State to consider proposals on a case-by- case basis in accordance with the London Convention and Protocol, urged States to use the utmost caution when considering proposals for large-scale ocean fertilization operations.  The governing bodies took the view that, given the present state of knowledge regarding ocean fertilization, such large-scale operations were currently not justified.”


Resolution LC-LP.1 (2008) on the Regulation of Ocean Fertilization adopted on 31 October 2008 noted that the Statement of concern’ on large-scale ocean fertilization by the Scientific Groups in June 2007 endorsed by the 29th Consultative Meeting and the 2nd Meeting of Contracting Parties in November 2007, and expanded on by the Scientific Groups in May 2008, remained valid, and noted COP-9 decision IX/16 on 30 May 2008, and provided that Parties:

“2.      AGREE that for the purposes of this resolution, ocean fertilization is any activity undertaken by humans with the principal intention of stimulating primary productivity in the oceans[3]; [3] read: ” Ocean fertilization does not include conventional aquaculture, or mariculture, or the creation of artificial reefs.”

8.       AGREE that, given the present state of knowledge, ocean fertilization activities other than legitimate scientific research should not be allowed.  To this end, such other activities should be considered as contrary to the aims of the Convention and Protocol and not currently qualify for any exemption from the definition of dumping in Article III.1(b) of the Convention and Article 1.4.2 of the Protocol.”

The Contracting Parties agreed that scientific research proposals should be assessed on a case-by-case basis using an assessment framework to be developed by the Scientific Groups under the London Convention and Protocol.


That assessment framework was developed in 2010 in the “Assessment Framework for Scientific Research Involving Ocean Fertilization” (adopted on 14 October 2010). The Framework provides a tool for assessing proposed activities on a case-by-case basis to determine if the proposed activity constitutes legitimate scientific research that is not contrary to the aims of the London Convention or Protocol.

In essence,

1. An Initial Assessment determines whether a proposed activity falls within the definition of ocean fertilization and has proper scientific attributes, and thus is eligible to be considered and evaluated in this framework. Upon completion of the Initial Assessment, the Secretariat of the London Convention and Protocol should be informed. Contracting Parties may also inform the Secretariat after receiving a proposal, prior to the completion of the Initial Assessment;

2. An Environmental Assessment is carried out, including Problem Formulation, Site Selection and Description, Exposure Assessment, Effects Assessment, Risk Characterization and Risk Management; and

3. The Environmental Assessment then feeds into the decision-making process, which is a determination that a proposed activity is legitimate scientific research, and is not contrary to the aims of the London Convention and Protocol, should only be made upon completion of the entire Framework. There is provision for monitoring: the collection and use of information resulting from monitoring informs future decision making and can improve future assessments.

A decision that a proposed activity is legitimate scientific research and is not contrary to the aims of the London Convention and Protocol should only be made if all earlier steps of the Framework, including the appropriate consultation and communication, have been satisfactorily completed and conditions are in place that ensure that, as far as practicable, environmental disturbance and detriment would be minimized and the scientific benefits maximized.

Consent should be sought from all countries with jurisdiction and/or in the Region of Potential Impact. If the risks and/or uncertainties are so high as to be deemed unacceptable, with respect to the protection of the marine environment, taking into account the precautionary approach, then a decision should be made to seek revision of or reject the proposal. Authorization of the project includes the duration and location of the activity, the requirements for monitoring and reporting, and any other conditions required by Contracting Parties. This authorization should be communicated to the Secretariat and relevant countries.


It is beyond the scope of this summary to conclusively analyze the activities undertaken under the Haida Salmon Restoration Corporation’s “Haida Salmon Restoration Project” and assess it against the CBD and LC/LP resolutions. If the “The Haida Salmon Restoration Project: The Story So Far September 2012” is correct, and the activity did, or was intended to, “replenished vital ocean mineral micronutrients, with the expectation and hope it would restore ten thousand square kilometers of ocean pasture to health,” then this certainly would appear to be an “activity undertaken by humans with the principal intention of stimulating primary productivity in the oceans” and thus qualify as ocean fertilization under LC-LP.1(2008).

The Canadian Environment Minister reportedly told Parliament[4] that “Environment Canada did not approve this non-scientific event. Enforcement officers are now investigating … This government takes very seriously our commitment to protect the environment and anyone who contravenes environmental law should be prosecuted to the full extent of the law.” Based on this statement, it appears that LC-LP.1(2008) and the Assessment Framework were not followed. It would therefore follow that the activity should be considered as contrary to the aims of the Convention and Protocol and not currently qualify for any exemption from the definition of dumping in Article III.1(b) of the Convention and Article 1.4.2 of the Protocol. The application of the Canadian Environmental Protection Act (EPA 1999) to the activity is a matter for Canadian law and Canadian lawyers.

Given the position under the LC/P, it is unnecessary to assess the Project’s activities under the CBD moratorium, but on the facts known to date it seems clear that (1) the activities did not constitute small scale scientific research studies within coastal waters; (2) they were not authorized; (3) they were not justified by the need to gather specific scientific data; (4) were not subject to a thorough prior assessment of the potential impacts of the research studies on the marine environment; and (5) were not strictly controlled by the Canadian government. Clearly they can not be used for generating and selling carbon offsets or any other commercial purposes.

Originally posted by ETC Group.

[1] The LC/P (i) endorsed the June 2007 “Statement of Concern regarding iron fertilization of the oceans to sequester CO2” of their Scientific Groups, (ii) urged States to use the utmost caution when considering proposals for large-scale ocean fertilization operations and (iii) took the view that, given the present state of knowledge regarding ocean fertilization, large-scale operations were currently not justified.

[2] 2012 United Nations Conference on Sustainable Development in Rio de Janeiro (Rio+20) in The Future We Want, confirmed in General Assembly resolution 66/88. United Nations Conference on Sustainable Development in Rio de Janeiro (Rio+20) in The Future We Want, confirmed in General Assembly resolution 66/88 (2012). Athttp://www.un.org/en/sustainablefuture/.

[3] See LC 30/4 25 July 2008, Report by the Legal and Intersessional Group on Ocean Fertilization (LICG)

[4] “Experiment to seed Pacific defended, “Globe and Mail, October 19, 2012.


Convention discourages ocean fertilization

International treaty aims to put rules on geoengineering.

Ocean plankton blooms appear as green patches in the blue of the oceans. Some say they could be used to soak up human CO2 emissions (Images: SeaWiFS Project/NASA and GeoEYE)
Law of the sea: who should regulate the triggering of phytoplankton blooms? NASA

The parties to the London Convention, an international treaty that governs ocean pollution, have agreed that large-scale ocean ‘fertilization’ isn’t yet justified, given gaps in scientific knowledge.

The convention, which regulates activities such as the dumping of garbage at sea, had not previously taken a stand on the notion of throwing nutrients into the ocean with the intention of promoting plankton growth. Such projects have been proposed to help increase ocean productivity and thereby boost the uptake of carbon dioxide from the atmosphere, combating climate change. But critics warn that little is known about the ecological effect of dumping large quantities of nutrients into the sea.

At its meeting in London last week, the convention endorsed concerns issued in June by its scientific advisory group about the possible effects of large-scale fertilization activities.

Representatives from 35 countries agreed that all forms of ocean fertilization should fall under the convention’s oversight. They agreed to study the issue further and create rules to govern such procedures, next year at the earliest. The rules would be binding to countries signed up to the treaty. Until then, they have urged national marine authorities to use the “utmost caution” when considering proposals for large-scale ocean fertilization operations.

Environmental groups have applauded the move. “We certainly welcome the outcome,” says David Santillo of Greenpeace’s science unit in Exeter, UK. “This intention to regulate ocean fertilization has a lot of political weight, and the view that such operations should not proceed at this time is just the sort of clear message we had hoped for.”

Blooming experiments

In the past, scientific experiments have created algae blooms by dumping iron or other nutrients into patches of ocean. But their findings about the rate of carbon sequestration and the effects on marine ecosystems were ambiguous. The methods have not yet been applied on a large or commercial scale.

Several private companies, including Planktos, based in Foster City, California, plan to fertilize patches of the ocean with iron, with a view to generating verifiable carbon credits that could be sold on evolving global greenhouse-gas-emissions markets.

The Australian company Ocean Nourishment Corporation in New South Wales is also planning to test the idea, this time using urea as a nitrogen-based fertilizer. The firm wants to dump 500 tonnes of dissolved urea in the Sulu Sea between Borneo and the Philippines.

“We do not have a fixed date for this experiment to take place,” says John Ridley, managing director of the corporation. “It is part of our ongoing R&D programme in demonstrating the feasibility of ocean nourishment.” The firm has not yet filed a formal application to the Philippine Bureau of Fisheries and Aquatic Resources for permission to perform the test.

Global commons

The statement of the London Convention will not in itself interfere with the experiments planned by Planktos and the Ocean Nourishment Corporation, which are currently only regulated by any countries overseeing the waters in question.

But environmentalists maintained calls for a voluntary, nation-by-nation moratorium on all fertilization operations until international regulations are in place.

Many also urge other international bodies to set up rules for other acts that interfere on a large scale with the ‘global commons’ of air and water. “We urge governments meeting at the United Nation’s Framework Convention on Climate Change in Bali next month to follow the London Convention’s lead and begin an international process to put all geoengineering technologies under international oversight,” says Jim Thomas of ETC, an environmental group based in Ottawa, Canada. 


Civil Society Petition: Withhold Endorsement of the Ocean Nourishment Project in Sulu Sea, Philippines

by International Tawi-Tawi Organization

We, civil society organizations working on various development issues across the Philippines, recently learned about the Ocean Nourishment Project being promoted by the Australian for-profit entity Ocean Nourishment Corporation (ONC) as a solution to Climate Change. It involves the dumping of tons of urea granules into the ocean to stimulate the growth of phytoplankton that would eventually sequester carbon from the atmosphere.

An article on ocean fertilization published in the 12 September 2007 issue of the New Scientist magazine revealed that ONC is proposing to conduct a large-scale field experiment on its patented urea fertilization technology in Philippine waters. It was confirmed from various sources that the target area of urea dumping is the Sulu Sea in south-western Philippines.

ONC and its affiliate entities are collaborating with the University of the Philippines in the Visayas (UPV) in Iloilo to conduct the experiment in the north-eastern portion of the Sulu Sea, near the province of Antique in Panay Island. We are aware that the Philippines is a signatory to the London Convention on Marine Dumping (referred to here as the London Convention) and have existing laws to stop marine pollution, namely Presidential Decree 600, as amended by P.D. 979.

We are deeply concerned on this Ocean Nourishment Project, particularly involving urea fertilization/dumping into the ocean, on the following grounds:

Serious questions on the scientific basis

There are very serious concerns on the scientific basis of ocean fertilization technology, whether involving nitrogen (urea), iron or other large-scale addition of nutrients or other matters. There are on-going debates among marine scientists worldwide on the merits and potential consequences of the technology. The 2007 Nobel Peace Prize winner, the Intergovernmental Panel on Climate Change (IPCC), has noted that “…ocean fertilization remains largely speculative, and many environmental side effects have yet to be assessed”. We cannot allow the Philippines to be used as an experimental ground for this scientifically questionable technology.

Potential negative environmental consequences

Ocean fertilization has potential negative impacts on the marine environment and human health, including increased production of nitrous oxide and methane, unintended changes in the planktons that could result in production of harmful algal blooms (HAB, or \”red tide\”), , and unknown effects on the ocean food chain. This is particularly alarming in view of the Philippines\’ disastrous experiences with \”red tide\”, largely caused by marine pollution, which have severely affected the livelihood of coastal communities and have posed serious health threats on consumers.

Unknown long-term impacts on marine ecosystems

The long-term impacts of urea dumping on marine ecosystems in general and marine biodiversity in particular are unknown. There are no studies that show the potential effects of nutrient fertilization on seaweed and sea grass populations, as well as on yet to be discovered organisms The fact that the Sulu Sea is home to the Tubbataha Reef Marine Park, a UNESCO World Heritage Site and one of the few remaining large coral reef ecosystems in the world, is a strong reason to stop this project.

Profit-motivated Scheme

Ocean Nourishment Corporation (ONC) has announced its plans to apply for carbon credits under the Clean Development Mechanism (CDM) for carbon-sequestration activity using this technology. ONC has patented this technology in Australia and is also publicly vying for the US$25 million Virgin Earth prize to remove CO2 from the atmosphere.

Social impacts

The proponents of urea dumping are brandishing that the phytoplankton bloom resulting from the induced nourishment will increase fish supply and will therefore benefit Filipino fishermen. This is a highly theoretical and debatable claim in view of the serious scientific questions and unknown environment impacts of this technology. Add that to the reality that Philippine fishing grounds are largely dominated by commercial trawlers which have severely marginalized small fisherfolks. The problem of unsustainable exploitation of fish and other marine resources must be addressed directly, not through misguided and potentially highly damaging attempts to fertilize the oceans.

WE, therefore, ask the Secretary of the Environment and Natural Resources and the Director of the Bureau of Fisheries and Aquatic Resources who are mandated to review applications for research in marine and coastal areas to:

1. WITHHOLD THE ENDORSEMENT AND APPROVAL OF THE PROJECT until all scientific issues on the theoretical claims of ocean nourishment, particularly urea/nitrogen fertilization, are resolved by relevant international scientific bodies based on thorough scientific studies on its safety, scientific soundness and environmental sustainability by credible and independent scientists. No permit should be issued for such activities until the London Convention has issued clear legal guidance as to the legal status of ocean fertilization and how it should be regulated.

2. CONDUCT A COMPREHENSIVE ENVIRONMENTAL IMPACT ASSESSMENT (EIA) of the project to ensure that it will not cause adverse impacts on the marine ecosystem. A thorough assessment of the potential socio-economic impacts of the project especially on the livelihoods of small fisherfolks, should also be conducted.

3. CONDUCT BROAD AND INCLUSIVE NATIONAL AND LOCAL CONSULTATION PROCESSES among communities and sectors that will potentially be affected by this proposed project.


London Convention: Climate campaigners oppose meddling with the oceans

Indymedia UK

On Monday 5th November climate change campaigners from Camp for Climate Action, Rising Tide and BioFuel Watch took action against geo-engineering (deliberate modification of Earth’s environment on a large scale) companies who are hoping to make a great deal of money from carbon credits by encouraging the growth of phytoplankton in the oceans . They claim this will ‘sequester’ carbon dioxide, a technology known as ‘ocean seeding’.

The campaigners held a demonstration outside a meeting of the London Convention on the Prevention of Marine Pollution by Dumping of Wastes. The meeting is deciding on the response by the Convention to the attempts to commercialise the technology. They gave out leaflets to delegates calling on the London Convention to take strong action against this dumping of toxic material, and held a banner reading ‘Toxic Dumping: No Climate Solution’.

Campaigner Sarah Mills said: “These companies don’t care about climate change they are just out to make a fast buck out of the carbon market. This risky technofix won’t work but it will be used to enable the rich to keep polluting the planet while the poor feel the worst effects of climate change.”

Leaflet Text:

Toxic dumping is no solution to climate change

What’s the solution to climate chaos? Renewables? Energy efficiency? Using less? Keeping the fossil fuels in the ground?

Not according to geo-engineering companies like CLIMOS, PLANKTOS, OCEAN NOURISHMENT CORPORATION and ATMOCEAN. They are hoping to make a great deal of money from carbon credits for encouraging the growth of phytoplankton in the oceans which they claim will ‘sequester’ carbon dioxide. Methods proposed include dumping large quantities of tiny iron particles, dumping industrial quantities of synthetic urea, and piping up nutrient rich deep ocean waters to the surface.

– It’s dangerous – Ocean seeding has the potential negative impacts on the marine environment and human health. Concerns include increased production of nitrous oxide and methane, unintended changes in the plankton that could result in production of toxic blooms and effects on the ocean food chain. The International Panel on Climate Change (IPCC) have warned that toxic tides and lifeless oceans might result from such geo-engineering activities [deliberate modification of Earth’s environment on a large scale]. One IPCC report said “geo-engineering options…remain largely speculative and with the risk of unknown side-effects”.

– It’s unproven -Science journal Nature published a study on iron seeding authored by forty-seven ocean scientists concluding that such attempts to artificially seed the ocean were unlikely to sequester much carbon dioxide. There is no way of proving how much carbon dioxide is stored or how long it will be locked away for. The scientists say their results “mean the end of the ‘geo engineering’ utopia that consists of artificially seeding the oceans with iron.”

– It’s a scam – Local and international environmental groups are furious at this risky gamble with sensitive marine ecosystems spurred by the opportunity to make a profit from carbon trading. Do these companies really care about climate change or are they out to make a fast buck? In the words of Planktos CEO Russ George “It’s really more of a business experiment than a scientific experiment.” Ocean Nourishment Corporation are expected to claim fishing rights on the basis of increasing fish stocks because of the phytoplankton blooms.

– It’s a red herring – Even if it worked, which there is no evidence for, ocean seeding is not sustainable or an equitable solution to climate change. Ocean Nourishment’s urea dumping scheme is depending on fast depleting natural gas stocks which may not in the future be available on the vast scale needed for ONC’s scheme. Ocean seeding enables a business as usual approach where the richest are able to buy the right to pollute while the poor become more and more marginalised. We have the solutions to climate change at our fingertips – reducing consumption, relocalising economies, and using existing renewable energy technologies sustainably

– It’s a threat to local economies – The livelihoods of millions of small-scale fisher families depend on the coastal waters surrounding the Philippines and Malaysia, but none of the communities have been consulted about the dumping scheme proposed by ONC. Wilhelmina Pelegrina of SEARICE in the Philippines said “Large-scale urea dumping is treating our oceans like a communal toilet. Our already endangered marine ecosystems are the lifeblood of our communities – and ONC must not be permitted to foul them for their own profit”. Ruperto Aleroza of Kilusang Mangingisda, the Philippine Fisherfolks Movement, said “This technology is unacceptable. It is a dangerous technology that could imperil marine environment which is the main source of survival and livelihood of poor fisherfolks in the Philippines. Under Philippine laws experiments like this must undergo environmental impact assessments and free prior informed consent of communities that are potentially affected. ”

We demand a moratorium . No to voluntary codes of conduct.

Climos believe that by offering to undertake a voluntary code of conduct they can placate the concerns of scientists and environmentalists.

Voluntary codes of conduct allow companies to make their own decisions on what is acceptable behaviour and are a deliberate strategy to stave off regulation by national governments and international organisations who have a responsibility to protect the natural environment in the face of dangerous schemes such as the one proposed.

– We call on the London Convention, national governments and international agencies to reject geo-engineering scams and promote real solutions to climate change.
– We call on Climos, Planktos, Ocean Nourishment Corporation and Atmocean to abandon these mistaken schemes.
– We call on all members of the public concerned about the future to take action on climate change and against the destructive impacts of these companies.

More information:

Canadian NGO, the ETC Group, has collated scientific analyses and civil society critiques of ocean dumping. Information is available at:


Plan to Dump Iron in Ocean as Climate Fix Attracts Debate

A phytoplankton bloom swirls in the waters off islands in southeast Alaska. Nutrients such as iron encourage the tiny marine plants to grow. Studies show the plankton, like trees, remove carbon dioxide gas from the atmosphere, and so could serve as natural carbon sinks. But a plan by a U.S. firm to profit by seeding plankton blooms with iron and selling co-called carbon credits is polarizing experts, many of whom worry that the environmental impacts of such a project are still poorly understood. Photograph by Bill Curtsinger/National Geographic/Getty Images

by Kelly Hearn (National Geographic News)

Global warming is heating up opportunities for companies that can find ways to pull carbon dioxide (CO2) out of the atmosphere and sell “carbon credits” on emerging markets.

But one company’s attempt to dip its toes into free-market climate solutions appears to be headed for a high-seas standoff.

In the coming days to weeks, Planktos, a small California-based “ecorestoration” company, will use a 115-foot (35-meter) research ship to dump a hundred tons of iron dust into international waters some 200 miles (322 kilometers) west of the Galápagos Islands.

Iron—a nutrient naturally carried into the ocean by wind—encourages plankton growth, which can absorb atmospheric CO2, a greenhouse gas.

Planktos ultimately wants to fertilize plankton blooms, measure the carbon they capture, and sell the corresponding credits (related: “Extreme Global Warming Fix Proposed: Fill the Skies With Sulfur” [August 4, 2006]).

Companies that emit greenhouse gases can buy these credits to offset their contributions to global emissions.

Russ George, Planktos’ CEO, testified last week about the project before a U.S. congressional committee. He says nearly a dozen scientific studies are conceptually on his side.

The 57-year-old, who describes himself as a classical ecologist and businessman, says he is simply mimicking Mother Nature by giving greenhouse gas-sucking seas and trees a leg up.

But several environmental groups and marine scientists are raising red flags, while U.S. regulators are asking questions about accountability.

And at least one opponent to the plan isn’t waiting for official regulatory action.

Greenpeace co-founder Paul Watson told National Geographic News that his group the Sea Shepherd Conservation Society plans to send a ship to intercept Planktos’ vessel in open waters.

Carbon Solution or Marine Pollution?

Phytoplankton are tiny floating plants that, like trees, convert CO2 gas from the atmosphere into carbon stored in their tissues.

Some plankton are eaten by marine animals, which return the carbon to the atmosphere during respiration. But some of the plants die and sink to the ocean depths, effectively sealing the carbon away.

“Both plankton and forest restoration projects remove enormous quantities of global-warming CO2 from the atmosphere,” says a statement on Planktos’s Web site.

But the international conservation group WWF, Galápagos National Park, Greenpeace, and Canadian-based ETC have spoken out opposing the plan.

The groups cite scientific studies that say large-scale iron enrichment schemes have too many potential consequences and too few hypothetical benefits.

And the Charles Darwin Foundation, a nonprofit group dedicating to preserving the Galápagos, said in a recent advisory that Planktos’ project “is an unnecessary bet whose possible effects are totally unknown given that there has not been an environmental impact statement.”

Some studies have suggested that sustained fertilization can create low- to no-oxygen conditions in the iron-enriched waters or trigger blooms of harmful types of plankton.

Sally Chisholm, a researcher at Massachusetts Institute of Technology, has published articles about the topic.

Such conditions, she writes, can “shift the microbial community toward organisms that produce greenhouse gases such as methane and nitrous oxide, with much higher warming potentials than CO2.”

Meanwhile the U.S. Environmental Protection Agency (EPA) says it is evaluating Planktos’ plan.

“EPA has informed Planktos that its planned project might require a permit under the Marine Protection, Research, and Sanctuaries Act [also known as the Ocean Dumping Act],” the agency’s Dale Kemery told National Geographic News in an email last week.

“Based on the information currently available, EPA is unable to determine that Planktos’ proposed actions would be subject to regulation under the Ocean Dumping Act. The agency will continue its inquiry into this matter.”

In June EPA sent a memo to the International Maritime Organization (IMO), an organization established by the United Nations to work with governments and the shipping industry to prevent marine pollution.

The document informed IMO that EPA has no power to regulate Planktos, because the company had chosen not to fly a U.S. flag—a move that would allow the ship to avoid U.S. regulations.

The memo also advised the member states of the London Convention—a global agreement on pollution controls—to carefully evaluate Planktos’ plans.

Scientific Endeavor

Planktos officials defended their project in a telephone interview and series of emails with National Geographic News, saying they are being attacked by fringe environmentalists and mischaracterized by U.S. officials.

W. David Kubiak, the company’s communication director, said the two-year, six-bloom pilot projects are not large scale.

The project, he says, is more about correcting what at least one scientific study says are diminishing phytoplankton populations.

“The most critical issue that we originally set out to address was this collapse at the base of the ocean food chain,” Kubiak said.

“All the climatic and economic benefits that emanate from that restoration work are wonderful to be sure but are not the most critical points of this work.”

Planktos’ company documents also say that their pilot projects will make up the longest, largest, and most comprehensive study of phytoplankton ecology.

In addition to studying carbon-cycle implications, the company says it plans to evaluate factors such as the effects of the blooms on ocean acidity and nitrogen levels as well as populations of marine life that graze on the plankton.

But not all scientists agree on the extent of the plankton decline, noting that natural cycles of productivity make it hard to detect long-term trends based on year-to-year variability.

Some experts also dispute the claim that the project represents a significant scientific undertaking.

Planktos, they say, has a relatively small ship, limited scientific expertise, and only basic equipment to sample and measure changes.

As for the regulatory debate, Planktos’ Kubiak says the firm has made no decision about which flag to fly on its ship. He and company CEO George both said the company asked EPA for guidance but failed to receive information.

“We still hope to work with them constructively and are postponing any ship decisions until that is clarified,” Kubiak said in an email.

“Wondrous Feature”

CEO George, meanwhile, said the project is still planned to launch in late July or early August.

Planktos’ project is downwind and down current from the Galápagos Islands and would not impact that ecosystem in any way, he said.

“There are already [plankton] blooms around Galápagos,” he added. “How is it that the wondrous feature that makes the Galápagos such a treasure is somehow a problem?”

He also challenged critics who warn of potentially negative environmental consequences of iron-enhanced plankton blooms. “Where is there a documented case of any of those concerns really being exhibited?” he asked.

Due to short time frames and scales, no studies have directly proven unintended negative consequences of large-scale ocean fertilization.

But MIT’s Chisholm and other scientists have expressed doubts that the project won’t have environmental repercussions.

Calling the idea environmentally benign “is inconsistent with almost everything we know about aquatic ecosystems,” she wrote.

Many studies predict that iron would alter the ocean’s food webs and biogeochemical cycles in unintended ways.

“We have learned this from inadvertent enrichment of lakes and coastal waters with nutrients from agricultural runoff, something we have been trying to reverse for decades,” she wrote.

Ken Buesseler, a senior scientist at the Woods Hole Oceanographic Institution, says that the effectiveness of ocean fertilization as a means of mitigating climate change has not been a focus of prior studies and is not well known.

“Only carbon that reaches the deep sea is isolated from the atmosphere long enough to impact atmospheric CO2 and hence climate,” he said, adding that it is difficult to measure how much carbon gets stored.

“So there is little evidence to go on when making claims about the efficacy of a commercial operation.”

Originally posted to National Geographic News.

Company plans ‘eco’ iron dump off Galapagos

by Catherine Brahic (New Scientist)

Ocean plankton blooms appear as green patches in the blue of the oceans. Some say they could be used to soak up human CO2 emissions (Images: SeaWiFS Project/NASA and GeoEYE)

Update 25 June 2007: The scientific working group of the London Convention expressing its concern regarding “the potential for large-scale ocean iron fertilisation to have negative impacts on the marine environment and human health” on 22 June. The group has requested that the full London Convention, which meets on 5-9 November 2007 “considers the issue of large-scale ocean iron fertilisation operations with a view to ensuring adequate regulation of such operations”. Read the full statement of the scientific working group here.

Original article, 22 June 2007: A private company’s plans to dump 100 tonnes of iron particles into the Pacific Ocean off the Galapagos, to trigger a plankton bloom, are being discussed by the International Maritime Organization today.

The chief executive of carbon-offsetting firm Planktos says the scrutiny is unwarranted as the amounts of iron his company will dump are minuscule.

Planktos is a private company which sells UN-approved carbon credits and uses the money for forestry projects. It plans to sell carbon “off-set” credits to fund future ocean iron-dump projects.

The US company is also one of a few budding organisations seeking to operate large-scale experiments to dump fine iron particles into the ocean in order to boost the growth of tiny plant plankton, called phytoplankton.

Natural clouds of iron dust deposited on the sea by the winds can trigger large plankton blooms that can be seen from space as greenish patches in the midst of blue ocean waters.

In the past 20 years, 10 ocean expeditions around the world have attempted to trigger phytoplankton blooms by purposefully seeding the waves with fine iron dust.

Controversial experiment

Some believe these experiments could be a solution to rising levels of carbon dioxide in the atmosphere: as the phytoplankton grow into blooms, they absorb the gas from the atmosphere, much like trees do. A portion of this sinks to the sea floor when the plankton die, effectively transferring CO2 from the atmosphere to the bottom of the ocean.

Some experts believe that experimenting with ocean iron-dumps should be accelerated and that academic research has been too limited. However, most are concerned that iron-dumping may have disastrous effects on the local ecology and biodiversity. Phytoplankton are right at the bottom of the marine food-chain and tampering with the amount of phytoplankton in the oceans may effect the entire marine ecosystem.

Victor Smetacek of the Alfred Wegner Institute for Polar and Marine Research agrees that too little is known about phytoplankton. That is precisely why he would like to see more iron fertilisation experiments carried out under international agreement and regulated by a United Nations body. “I am probably the only senior scientist who is advocating this, however,” he told New Scientist. “The way I see it is the experiments should be run by scientists [not by private companies], but the scientific community as a whole is against this.”

Smetacek has just received funding from the Indian government to carry out an iron fertilisation experiment in the Scotia Sea, off the coast of Antarctica, in 2008. In the long run, he says iron fertilisation activities should be run by a dedicated United Nations body.

Outside the law?

Each of the 10 expeditions carried out so far have dumped up to 10 tonnes of iron particles. Planktos intends to take the iron fertilisation experiments further than publicly-funded research has so far.

It is planning six expeditions, each of which will dump up to 100 tonnes of iron. It says it will study the plankton bloom more extensively and for longer than has been done in the past.

A US civil society organisation called the International Center for Technology Assessment (CTA) believes that Planktos’s planned activities are in breach of law.

“There is a law against dumping material into the ocean without permits. Yet, this is exactly what Planktos plans on doing,” says staff attorney George Kimbrell of the CTA. “We are asking the US Environment Protection Agency [EPA] to launch an immediate and full investigation into Planktos’s ocean-dumping activities.”

When New Scientist contacted the EPA, it was told that Planktos has indicated to the agency that it will dump the iron particles from a ship registered outside the US, thereby avoiding any conflict with the US Ocean Dumping Act. “This is no longer within our jurisdiction,” an EP official said.

Natural substance

Planktos, whose US-registered research ship Weatherbird II is currently having equipment fitted for the first iron fertilisation expedition – scheduled to take place in international waters off the coast of the Galapagos – says that it has not yet decided whether or not it will operate from this vessel.

Planktos chief executive Russ George told New Scientist that it is awaiting formal notification that its activities are not legal under US law.

If it receives such notification, says George, it will consider dumping the iron from a foreign ship and carrying out the subsequent monitoring research from Weatherbird II.

George says the quantities of iron his company is proposing to dump are well below quantities that require EPA approval under the US Ocean Dumping Act.

“The act states that if you are putting a natural substance into the ocean you don’t have to apply for a permit,” says George. He says the iron particles he uses are very finely ground particles of haematite, a rock that is naturally rich in the mineral.

Low concentrations

“The other clause is that if you don’t raise the concentration of the substance in the ocean to 0.01% of acute toxicity levels you don’t need to apply,” says George.

“We are seeking to raise concentration of iron to something in the neighbourhood of 50 parts per trillion. When I looked up the acute toxicity of iron I couldn’t find it, but I could find that the concentration of iron in breast milk is tens of parts per million. Over the counter iron supplements contain 100 ppm.

“We are a million times below the level required to maintain life, not 0.01% below the level of acute toxicity,” concludes George. “When I pointed that out to the EPA they said: ‘Well we don’t have to go by that’.”

George says he is now awaiting formal notification from the EPA in order to decide what ship to dump his iron from. The EPA says the matter is no longer under its jurisdiction because Planktos has told them it will not dump from a US ship.

Careful evaluation

Meanwhile, the US government has apparently not turned its back on the matter entirely. The scientific working group of the International Maritime Organization’s London Convention, which regulates dumping at sea, is meeting from 18 June to 22 June in Spain.

A document submitted by the US government has required that Planktos’s activities be considered by the IMO.

The document states: “Because this iron release project will not be done by vessels flagged in the US, or by vessels leaving from the US, the US government does not have jurisdiction to regulate this project under its law implementing the London Convention.

“The US believes that the iron addition projects proposed by Planktos, Inc. should be evaluated carefully by any state that has appropriate jurisdiction over this activity.”

Originally posted by New Scientist.

Open reply to Planktos

by Jim Thomas (ETC Group)

As well as dealing with Monsanto in Munich this week, ETC Group has also been raising the alarm about a massive geo-engineering experiment scheduled for this month around Galapagos by Planktos Inc.

The New York Times carried a very uncritical piece about Planktos earlier in the week, which was also picked up by The Times in London and The Independent also in the UK. ETC then put out a news release pointing out that the scientists of the IPCC (UN climate science body) were about to be very critical of geo-engineering in their report and that 47 scientists writing in the journal Nature had been critical of it last week! You can read more about that here. One of the places this opened up a debate was on environmental blog Gristmill. And what a debate! Planktos Comunications director David Kubiak posted a bizarre and vitriolic attack on ETC’s news release and then went on to challenge us to an open debate.

We like the idea of an open debate. We also think Plantos should respect the precautionary principle and if they want such a debate in good faith would hold off their planned trial. Below is the response to Planktos that we have just posted to Gristmill

In response to Planktos:

On this forum David Kubiak, Planktos Communications Director, posted a blustery (and bizarre!) attack on ETC Groups recent news release about his company’s impending iron fertilization experiment in the vicinity of the Galapagos Islands. Yesterday was a busy day for ETC Group because we concluded — and won — a 13 year old lawsuit against Monsanto that has led to the rejection of Monsanto’s species-wide soybean patent. (see www.etcblog.org where we will also post this note).  The trial hearing was in Munich and we’ve been busy.  Below however is our response to Planktos.

Firstly, we would like to be clear to Mr Kubiak and others that  these are not Mr Thomass arguments (as he characterised them). They are the position of ETC Group. There is no need to personalise this debate.

Secondly, we note that Planktoss vitriolic “rebuttal” actually sidesteps most of what was in the news release namely that UN IPCC , the most eminent body of climate scientists in the  world ,overseen by governments, have decided that geo-engineering schemes – and ocean fertilisation in particular – are unproven,  unlikely to work and raise serious risks. This is published today (Friday) but was leaked to the media some days ago.The same message came very clearly from a paper last week in Nature (Blain et al.). signed by 47 internationally-respected ocean scientists.  It says just about everything anyone needs to know about this company that Planktos did not address these two scientific reports in its rebuttal but opted, instead, to attack paper tigers and spread invective.

Planktos  also invited ETC Group  to an open public debate. Of course we agree and have specific proposals to expedite this debate (see below).

Regardless, Planktos should accept the Precautionary Principle and immediately announce that it will suspend its iron fertilization trial until there is a public debate and, also, pending the results of a transparent technical evaluation of their project conducted by a panel of internationally-respected ocean scientists drawn from the IPCC and including experts from the Pacific region where the experiment is intended.  If Planktos is not prepared to do this and does not recognize the Precautionary Principle, the world community should be concerned.

We propose three public debates.  The first debate should take place as quickly as possible in Ecuador (which has the sovereign responsibility for the UNESCO World Heritage Site). Dr Elizabeth Bravo of Accion Ecologia can arrange this debate and can also facilitate appropriate discussions with the Ecuadorian government at the same time.  It is not necessary for ETC Group to be involved in this debate, Ecuadorians are capable of attending to their own concerns.  We’ll be happy to forward contact information to Planktos.

ETC Group is quite prepared to participate in the second and third debates.  We propose a second debate during the UN Commission on Sustainable Development now taking place (until May 11) in New York City.  If we can reach quick agreement on this, it may be possible to arrange a side-event during the CSD to which governments and civil society organizations could be invited.  This would allow for a full debate.  Time is short, but we are prepared to undertake organizational work for this debate. If the time frame is too short a side-event could also be arranged at the UN in New York the following week at the Permanent Forum on Indigenous issues which commences its 6th session on 14th may 2007.

Finally, we propose a debate before the UN Convention on Biological Diversity and its SBSTTA (scientific subcommittee) when it meets in Paris July 2 – 6. at that time it will be considering teh biodiversity impact of climate mitigation schemes.  Again, we believe we can arrange for a side-event that will allow for the debate to be witnessed by governments and civil society.

As to the points which Planktos unhelpfully characterised as  deceptions. Below are some replies. As we already noted this really did not seem to address the substance of our news release.

  • The reference to Galapagos came repeatedly from Planktos who launched their so-called voyage of recovery to Galapagos back in  March linking it explicitly with Darwins Voyage. Indeed after reading Planktos communications for some time this forum is the first time we have  seen a more precise reference of where the dumping site is intended. We are not sure if we share Planktoss view that the deeper waters  of the Pacific are anemic and lifeless.
  • ETC Group bears no responsibility for the Planktos website being four years out of date or using the technical word nanoparticles in a non-technical manner. It is true that Mr.Kubiak told us last week that the particles would be at around the micron scale in a telephone conversation. His comment was correctly acknowledge in our news release.  He also said the company had never used the term nanoparticle which is not true. As the company’s communications officer, he should perhaps become more familiar with his own website.  “Nanotechnology” is not a scare term.  Many companies use the term (sometimes incorrectly as here) to exaggerate the “cutting edge” nature of their technology.
  • Regarding Nuclear Fusion Cold fusion is believed to be a form of Nuclear Fusion .We merely stated that Planktos has a mirror company involved in Nuclear fusion. Its hard to see how that is a smear.. D2fusion describes their work variously as Cold Fusion Low Energy Nuclear Reactions, and  Chemically Assisted Nuclear Reactions,..
  • Ulf Riebesell was not the only critic of iron fertilization quoted in Nature. The forty-seven scientists  who co-authored the paper under discussion went out of their way within the paper to say that their paper should not be used to justify iron fertilization schemes. On their own website they also said that they saw their finds as the end of the dream of iron fertilization. When we contacted the lead author, Stephane Blain he was particularly emphatic that they did not want geo-engineers to misleadingly use their findings to justify their case – in the way Planktos apparently have.
  • It is unfair to both Dr Elizabeth Bravo (of Accion Ecologica) and Dr Paul Johnston (of Greenpeace) to characterize them as misled. Both are highly respected and very experienced environmentalists with enviable international reputations. It is also slightly ironic since Greenpeace rather claim that Planktos misled them: Planktos, having used a personal connection in Greenpeaces US office to borrow an inflatable boat , went on to portray Greenpeace as supportive of Planktos during a PR stunt in Washington DC Harbour recently. Greenpeace USA had to send threatening legal letters to have that misrepresentation removed from the Planktos website.
  • ETC are glad to see that Planktos will surrender any prize money to charity.
    Nonetheless Planktos own communications has very much emphasised the money that Planktos hope to make – especially to investors  who have been invited to buy stock in the company. As we noted in our news release Planktos CEO Russ George has called this more of a business experiment than a scientific experiment.