Regulating the Unthinkable: Climate Interventions as a Test Case for Risk Governance - Preprint

[Geoengineering News]

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5923846

Authors: Alberto Alemanno, Masahiro Sugiyama

December 15, 2025

Abstract

As the risk of climate overshoot grows, attention increasingly turns to climate interventions, such as Solar Radiation Modification (SRM) and Carbon Dioxide Removal (CDR), that is, technologies designed to actively alter the climate system beyond conventional mitigation and adaptation. The article addresses questions of institutional legitimacy and recognition justice, the implications of international legal fragmentation, competing approaches to risk analysis, the application of precautionary and prevention principles, market governance of CDR, the role of intellectual property regimes, and regional perspectives. The most striking tension centres on how risks should be analysed and compared. Climate intervention governance does not exist in a vacuum. Still, it is an emerging field shaped by partial institutional coverage, normative contestation, and private-sector acceleration against a background of limited public salience. This article situates climate intervention governance within broader debates on risk regulation. Building on and critically synthesizing the contributions published in the European Journal of Risk Regulation’s Special Issue devoted to the governance challenges posed by SRM and CDR, the article identifies cross-cutting themes that will shape governance debates in the coming years. It concludes that climate intervention governance is ultimately a test case for contemporary risk analysis and regulation, as well as collective self-governance, under conditions of radical uncertainty.

Source: SSRN

[Greg Rau]

 “Regulating the Unthinkable” re CDR? Why is CDR unthinkable?  Or is this just more fearmongering? Think on this:

1) non-human CDR is already saving our bacon to the tune of 20+ Gt/yr CO2 removed from air.

2) we must protect the CDR happening in 1) and augment it with additional CDR, nature-based or otherwise, if we are going to stabilize air CO2 concentrations (and climate).

3) we must do 2) and do additional CDR if we are going to hasten the return of air CO2 concentrations (and climate) to “normal” levels in a timeframe shorter than a millennium.

That is, it’s unthinkable not to deploy CDR (and do emissions reduction) if we are serious about managing air CO2. Unfortunate that SRM and CDR are again lumped together here despite having very different benefit/risk profiles.  

Perhaps the authors meant regulating CDR and SRM is unthinkable, but that doesn’t make sense either since a lot of thinking and regulation has been done on other big, global, existential issues like energy, food, nuclear weapons, trade, etc. Why is CDR any different?  If the complaint is none of the global regs are ever perfect, that’s not an issue unique to CDR. Both CDR and its regulation are thinkable, so let’s get going on the doable part, and not single out CDR as something uniquely scary.

Greg

Sent from my iPhone

On Dec 20, 2025, at 5:36 AM, Geoengineering News <geoengine...@gmail.com> wrote:



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