SATAN

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Andrew Lockley

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Mar 2, 2023, 3:07:20 AM3/2/23
to geoengineering
https://www.technologyreview.com/2023/03/01/1069283/researchers-launched-a-solar-geoengineering-test-flight-in-the-uk-last-fall/

Researchers launched a solar geoengineering test flight in the UK last fall
The experiment, largely designed to test equipment, took place despite deep concerns about the technology.

By James Temple archive page
March 1, 2023
sun shines through the clouds
GETTY IMAGES
Last September, researchers in the UK launched a high-altitude weather balloon that released a few hundred grams of sulfur dioxide into the stratosphere, a potential scientific first in the solar geoengineering field, MIT Technology Review has learned.

Solar geoengineering is the theory that humans can ease global warming by deliberately reflecting more sunlight into space. One possible means is spraying sulfur dioxide in the stratosphere, in an effort to mimic a cooling effect that occurs in the aftermath of major volcanic eruptions. It is highly controversial given concerns about potential unintended consequences, among other issues.

The UK effort was not a test of or experiment in geoengineering itself. Rather, the stated goal was to evaluate a low-cost, controllable, recoverable balloon system, according to details obtained by MIT Technology Review. Such a system could be used for small-scale geoengineering research efforts, or perhaps for an eventual distributed geoengineering deployment involving numerous balloons.

The “Stratospheric Aerosol Transport and Nucleation,” or SATAN, balloon systems were made from stock and hobbyist components, with hardware costs that ran less than $1,000. 

Andrew Lockley, a research associate at University College London, led the effort last fall, working with European Astrotech, a company that does engineering and design work for high-altitude balloons and space propulsion systems.

They have submitted a paper detailing the results of the effort to a journal, but it has not yet been published. Lockley largely declined to discuss the matter ahead of publication, but he did express frustration that the scientific process was being circumvented. 

“Leakers be damned!” he wrote in an email to MIT Technology Review. “I’ve tried to follow the straight and narrow path and wait for the judgment day of peer review, but it appears a colleague has been led astray by diabolical temptation.” 

“There’s a special place in hell for those who leak their colleagues’ work, tormented by ever burning sulfur,” he added. “But I have taken a vow of silence, and can only confirm that our craft ascended to the heavens, as intended. I only hope that this test plays a small part in offering mankind salvation from the hellish inferno of climate change.”

European Astrotech didn’t immediately respond to an inquiry.

Test flights
The system included a lofting balloon filled with helium or hydrogen, which carried along a basketball-size payload balloon that contained some amount of sulfur dioxide. An earlier flight in October 2021 likely also released a trace amount of the gas in the stratosphere, although that could not be confirmed and the system was not recovered owing to a problem with onboard instruments, according to details obtained by MIT Technology Review. 

During the second flight, in September of 2022, the smaller payload balloon burst about 15 miles above Earth as it expanded amid declining atmospheric pressure, releasing around 400 grams of the gas into the stratosphere. That may be the first time that a measured gas payload was verifiably released in the stratosphere as part of a geoengineering-related effort. Both balloons were released from a launch site in Buckinghamshire, in southeast England. 

There have, however, been other attempts to place sulfur dioxide in the stratosphere. Last April, the cofounder of a company called Make Sunsets says, he attempted to release it during a pair of rudimentary balloon flights from Mexico, as MIT Technology Review previously reported late last year. Whether it succeeded is also unclear, as the aircraft didn’t include equipment that could confirm where the balloons burst, said Luke Iseman, the chief executive of the startup. 

The Make Sunsets effort was widely denounced by researchers in geoengineering, critics of the field, and the government of Mexico, which announced plans to prohibit and even halt any solar geoengineering experiments within the country. Among other issues, observers were concerned that the launches had moved ahead without prior notice or approval, and because the company ultimately seeks to monetize such launches by selling “cooling credits.”

Lockley’s experiment was distinct in a variety of ways. It wasn’t a commercial enterprise. The balloons were equipped with instruments that could track flight paths and monitor environmental conditions. They also included a number of safety features designed to prevent the balloons from landing while still filled with potentially dangerous gases. In addition, the group obtained flight permits and submitted what’s known as a “notice to airmen” to aviation authorities, which ensure that aircraft pilots are aware of flight plans in the area.


Some observers said that the amount of sulfur dioxide released during the UK project doesn’t present any real environmental dangers. Indeed, commercial flights routinely produce many times as much. 

“This is an innocuous write-up or an innocuous experiment, in the direct sense,” says Gernot Wagner, a climate economist at Columbia University and the author of Geoengineering: The Gamble.

Public engagement
But some are still concerned that the effort proceeded without broader public disclosures and engagement in advance.

Shuchi Talati, a scholar in residence at American University who is forming a nonprofit focused on governance and justice issues in solar geoengineering, fears there’s a growing disregard in this space for the importance of research governance. That refers to a set of norms and standards concerning scientific merit and oversight of proposed experiments, as well as public transparency and engagement.

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“I’m really concerned about what the intent here is,” she says. “There’s a sense of them having the moral high ground, that there’s a moral imperative to do this work.”

But, she says, forging ahead in this way is ethically dubious, because it takes away any opportunity for others to weigh in on the scientific value, risks, or appropriateness of the efforts before they happen. Talati adds that part of the intent seems to be provocation, perhaps to help break what some perceive to be a logjam or taboo holding up stratospheric research in this area. 

David Keith, a Harvard scientist who has been working for years to move ahead with a small-scale stratospheric balloon research program, questioned both the scientific value of. the effort and its usefulness in terms of technology development. In an email, he noted that the researchers didn’t attempt to monitor any effect it had on atmospheric chemistry. Nor did the work present a feasible “pathway to use this method for deployment at reasonable cost,” he wrote.

“So in some deep sense, while it’s much more thought out, much less cowboy than Make Sunsets, I see it [as] similar,” Keith said.


When asked if being provocative might have been a partial goal of the effort, Keith said: “You don’t call something SATAN if you’re playing it straight.”

Lockley stressed that the effort was “an engineering proof-of-concept test, not an environmentally perturbative experiment,” and that they obtained the standard approvals for such flights. 

“I’m unaware of any prior approval process which should have been followed but was not,” he wrote in an email. “A review body may be useful, if it was able to provide good-faith and practical feedback on similar low-impact experimental proposals in future.”

Moral hazards and slippery slopes
There are a variety of concerns about deploying solar geoengineering, including the danger that carrying it out on large scales could have negative environmental side effects as well as uneven impacts across various regions. Some fear that even discussing it creates a moral hazard, undermining the urgency to address the root causes of climate change, or that researching it sets up a slippery slope that increases the chances we’ll one day put it to use.

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But proponents of research say it’s crucial to improve our basic understanding of what such interventions would do, how we might carry them out, and what risks they could pose, for the simple fact that it’s possible that they could meaningfully reduce the dangers of climate change and save lives. To date, though, not much has happened outside of labs, computer models and a handful of efforts in the lower atmosphere.

Several earlier proposals to carry out research in the stratosphere have been halted or repeatedly delayed amid public criticism. Those include the SPICE experiment, which would have tested a balloon-and-hose stratospheric delivery system but was halted in 2012, as well as the Harvard proposal that Keith is involved with, known as SCoPEx. 

The National Oceanic and Atmospheric Administration has begun conducting stratospheric flights, using balloons and more recently jets, as part of a growing US geoengineering research program. But its stated intention is to conduct baseline measurements, not to release any materials. One hope behind the efforts is to create an early detection system that could be triggered if a nation or rogue actor moves forward with a large-scale effort.

The challenges in conducting even basic, small-scale outdoor experiments that carry minimal environmental risks has increasingly frustrated some in the field—and left at least a few people willing to move forward without broad public disclosures in advance, perhaps in part to force the issue.


Scientists routinely conduct outdoor experiments without seeking up-front public permission, when doing so doesn’t present clear dangers to public health or the environment, and reveal their studies and peer-reviewed results in journals only after the fact. 

The question is whether solar geoengineering research demands greater up-front notification, not because the experiments themselves are necessarily dangerous but because of the deep concerns about even discussing and researching the technology.

Columbia’s Wagner says the field should err on the side of transparency. But he also says it’s important to strike the right balance between how much researchers must reveal in advance, how easily carefully designed projects can be blocked, and how much support major research institutions provide for an important area of inquiry. 

“This sort of thing is a direct response to other institutions’ reluctance to proceed with even seemingly innocuous research,” he says.


Daniele Visioni

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Mar 2, 2023, 3:18:49 AM3/2/23
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Glad you had fun, Andrew.

For me, this is clear proof of your unseriousness and childishness - not to mention the overall threat you pose to this research field as a whole towards any kind of legitimacy.

I personally don’t want to be associated even remotely with anything you do now or in the future, so this will be my last message on this group before I unsubscribe.


On 2 Mar 2023, at 09:07, Andrew Lockley <andrew....@gmail.com> wrote:


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Andrew Lockley

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Mar 2, 2023, 3:58:08 AM3/2/23
to Daniele Visioni, geoengineering
Dan,

Thanks for raising your concerns, although an initial private discussion would have been preferred. 

I believe you have had sight of the abstract a few weeks ago, via the GeoMIP conference submission. It's therefore surprising that you've chosen now to raise this issue. Did you have any concerns with the abstract specifically? If so, I would have welcomed your direct comments at the time. I can also make a preprint copy available to you personally, if you believe you may have comments that would help with revising the manuscript.

As you were one of perhaps a very small group access to the abstract, perhaps you could detail the steps you took to secure work that was of interest to the media? I am sure I'm not the only one who's mindful of leaks in the academic process. It would be nice to be able to submit abstracts and drafts without worrying they will be illicitly distributed.

I think you may be implying concerns about the experiment name. Could you perhaps describe why "stratospheric aerosol transport and nucleation" was an unsuitable name for an experiment designed to test craft for inducing, and later monitoring, stratospheric aerosol transport and nucleation? If your concerns are with some other aspect of the work, perhaps you could explain your views on what should or should not have been done? FWIW, I've never challenged your right to conduct research, nor anyone else's. If you choose to challenge mine, a proper discussion of your reasoning would be good to hear. 

Finally, I'm sorry that you regard me as "unserious". The facts might cause others to reach a different conclusion. I've been active in the geoengineering community for over a decade (I think you would have been high school, when I started). Despite never being paid, I've built up an h-index of 7. Simultaneously, I've supported this list, the CDR group, the @geoengineering1 twitter handle, and latterly the Reviewer 2 Does Geoengineering podcast - generally spending much more time supporting other's careers than in furthering my own. 

You are of course free to set up better community resource, if you think mine are "unserious". 

As a final note, you may wish to note that I've got a paper submitted after revisions about the legitimacy of private geoengineering. That may prompt a calmer discussion of views on the matter. 

Andrew Lockley 


Stephen Salter

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Mar 2, 2023, 4:24:31 AM3/2/23
to andrew....@gmail.com, Daniele Visioni, geoengineering

Hi All

You could delay  balloons bursting by fitting a pressure relief valve to vent gas when the outside pressure fell below some chosen value.

Stephen

Emeritus Professor of Engineering Design

School of Engineering

University of Edinburgh

Mayfield Road

Edinburgh EH9 3DW

Scotland

0131 650 5704 or 0131 662 1180

YouTube Jamie Taylor Power for Change

 

From: geoengi...@googlegroups.com <geoengi...@googlegroups.com> On Behalf Of Andrew Lockley
Sent: 02 March 2023 08:58
To: Daniele Visioni <daniele...@gmail.com>
Cc: geoengineering <geoengi...@googlegroups.com>
Subject: Re: [geo] SATAN

 

This email was sent to you by someone outside the University.

You should only click on links or attachments if you are certain that the email is genuine and the content is safe.

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Andrew Lockley

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Mar 2, 2023, 4:50:41 AM3/2/23
to Stephen Salter, geoengineering
One of the key research findings was that the volume of the gas in the balloon rises quicker than the vent or pump can dispose of the gas. It can't be stopped. You can't recover the canopies unless you slow the ascent to a unsafe speed. 

david....@carbon-cycle.co.uk

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Mar 2, 2023, 5:05:54 AM3/2/23
to andrew....@gmail.com, Stephen Salter, geoengineering

Andrew,

 

Please can you expand a bit regarding your comment of unsafe slow assent vs difficulty venting. This sounds like something of importance. I have always assumed that venting or slowing down the speed would be an option. Understanding this sounds quite important. I would note that weather balloons seem to have a solution to this but I may be mistaken.

 

I would also point out that by doing the work that you did that you underscored the value of why actual experiments need to happen. It is essential.

 

Regards,

 

 

David Sevier

 

Carbon Cycle Limited

248 Sutton Common Road

Sutton, Surrey SM3 9PW

England

 

Tel 44 (0) 208 288 0128

www.carbon-cycle.co.uk

Andrew Lockley

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Mar 2, 2023, 5:12:32 AM3/2/23
to David Sevier, Stephen Salter, geoengineering
Minimum ascent speed is set by
A) need to clear commercial airspace
B) need to predict flight path 
C) need to safely retrieve the balloons 

A rising balloon expands. A fast-rising (ie safe) balloon cannot be vented fast enough to overcome this - it is launched above its "escape velocity". The experiment met its immediate objectives but showed that a fully recoverable balloon system is not viable, using this approach. It would only be viable if you were able to accept very long distance drift - 100s or 1000 of miles.



Stephen Salter

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Mar 2, 2023, 5:45:03 AM3/2/23
to Andrew Lockley, geoengineering

Andrew

What about an upside down parachute deployed at the right time?

Stephen

Andrew Lockley

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Mar 2, 2023, 5:49:10 AM3/2/23
to Stephen Salter, geoengineering
All UK balloons have a parachute already. The speed of ascent is insufficient to inflate them. 

Douglas MacMartin

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Mar 2, 2023, 9:30:11 AM3/2/23
to andrew....@gmail.com, Daniele Visioni, geoengineering

Andrew,

 

I second Dan, and your juvenile response to him regarding your choice of project name should leave no doubt on anyone’s part that you don’t take this subject seriously. 

 

Had you actually been paying attention to the field as you claim to have been, you would be aware that there are broad public concerns, that trust is paramount, and that transparency is essential, as has been consistently recommended in every list of recommendations ever written on the subject – and your excuse of hiding while waiting for peer review is pathetic given that what’s needed would be transparency in advance about the existence of the test and the purpose, not about results.

 

You also know that your test has zero engineering value to the field since there’s no viable pathway to getting meaningful radiative forcing through balloons anyway.  There are certainly plausible engineering tests that could have value, but IMO this isn’t one of them.

 

So cost-benefit analysis… the benefit of your “test” is zero, but the cost, in terms of potentially setting back perceptions of the field and engendering a backlash against actual real legitimate science, is non-zero.  Hopefully people will appropriately ignore this stunt and recognize that it is neither directly damaging nor actually relevant to SAI. 

 

doug

 

From: geoengi...@googlegroups.com <geoengi...@googlegroups.com> On Behalf Of Andrew Lockley
Sent: Thursday, March 2, 2023 12:58 AM
To: Daniele Visioni <daniele...@gmail.com>
Cc: geoengineering <geoengi...@googlegroups.com>
Subject: Re: [geo] SATAN

 

Dan,

Andrew Lockley

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Mar 2, 2023, 9:58:26 AM3/2/23
to Douglas MacMartin, geoengineering
Doug,

I'll answer your points in turn below. I've removed Dan from the cc list as he wished to withdraw from the discussion. 

Andrew 


On Thu, 2 Mar 2023, 14:30 Douglas MacMartin, <dgm...@cornell.edu> wrote:

Andrew,

 

I second Dan, and your juvenile response to him regarding your choice of project name should leave no doubt on anyone’s part that you don’t take this subject seriously.  

What specifically was juvenile about my response to Dan?


How is a decade of unpaid work not serious?


Is the project name sillier or less descriptive than these examples - some of which are now scientifically standard? https://www.businessinsider.com/15-fantastic-scientific-acronyms-2014-1

 

Had you actually been paying attention to the field as you claim to have been, you would be aware that there are broad public concerns, that trust is paramount, and that transparency is essential, as has been consistently recommended in every list of recommendations ever written on the subject – and your excuse of hiding while waiting for peer review is pathetic given that what’s needed would be transparency in advance about the existence of the test and the purpose, not about results.

I submitted a paper to multiple journals describing the airframe test and it was never even sent for review. I can't force publication or review of a paper. Other than this strategy, when and how do you think I should have announced the experiment? 

What do you think that the consequences of any prior announcement would have been? 

How well has prior consultation worked, when it was tried previously? 

 

You also know that your test has zero engineering value to the field since there’s no viable pathway to getting meaningful radiative forcing through balloons anyway. 

The purpose of the test was not to get "meaningful radiative forcing". It was to demonstrate an inexpensive, multi role aircraft that could be used for small scale experiments - much as scopex was intended, but with cheaper, expendable and swarming aircraft. 

I certainly do not know that balloons cannot be made to work at scale. I have already got designs in mind that may overcome the limitations revealed by this test. 

There are certainly plausible engineering tests that could have value, but IMO this isn’t one of them.

You've not had sight of the paper yet, AFAIK. I always value your opinions, but recognise these may differ from my own, and that they may change as more information becomes available. 

 

So cost-benefit analysis… the benefit of your “test” is zero, but the cost, in terms of potentially setting back perceptions of the field and engendering a backlash against actual real legitimate science, is non-zero.  Hopefully people will appropriately ignore this stunt and recognize that it is neither directly damaging nor actually relevant to SAI. 

I've described the relevance above. 

Oliver Morton

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Mar 3, 2023, 6:09:42 AM3/3/23
to geoengineering
I am not condoning Andrew's action, but I am not convinced by Doug's argument that its results are necessarily harmful (though Doug says "non-zero", I think it is clear that he expects a negative result). If this leads to a fuller, open discussion of what sort of experiments are and aren't appropriate, and of what if any legitimate means there might be for discouraging the inappropriate, I think the community could find itself in a better place, and with better understood courses for future action. I think that requires constructive debate about pre-registration, applicable forms of suasion that are in line with liberal assumptions about research autonomy, national v international positions and more. 

It seems to me that if lots of serious people treat it as enough to simply denounce Andrew, they may, by so doing, empower the backlash Doug fears. An even tempered discussion about what was wrong with this and what should have been done differently might help more by defining what sort of envelope there should be around "respectable" experiments and what appropriate measures individuals, the community and authorities might take to discourage things outside that envelope.

I now intend to go and read Andrew's paper

o



Andrew Lockley

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Mar 3, 2023, 9:07:40 AM3/3/23
to Oliver Morton, geoengineering
I'm inclined to take what Oliver says as gospel. Instead of denouncing me for summoning SATAN, perhaps I can invite the congregation of the list to consider an alternative? 

It may be possible for some of the high priests of geoengineering to convene an inquisition, for vetting proposed experiments for herecy. A sort of pearly stage-gate, if you will.

I would be happy to confess my impure experimental thoughts, if I could be assured that this would remain within the confessional. 

If my experiment's soul was weighed in the balance and found wanting, I would be perfectly willing to see it cast into the abyss. 

Approval from such a conclave would ensure that I could go ahead knowing I was doing only righteous deeds. 

Jim, Simone, Doug, David M., Oliver, Alan, Wake, Pete - will you (and others) answer this higher calling? I would be happy to go through purgatory before accepting your eternal judgement.

A




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Jessica Gurevitch

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Mar 3, 2023, 10:38:15 AM3/3/23
to andrew....@gmail.com, Oliver Morton, geoengineering
Weighing in here on this very interesting issue. I agree with Oliver Morton that there is real value here, but I see the value as cautionary. In reality, Andrew Lockley's experiment is not going to change the climate, but it is a rogue implementation of a climate intervention. This makes an emphatic point, as does the Mexico 'sunset' experiment, that the people working on International Governance have no time to spare, because the ultra-billionaires who might be tempted to do something similar at a larger scale, and care not a whit what anyone says or thinks, could also initiate interventions. As Andrew said, this was not illegal...at this point. I think these two examples can add urgency to the argument that Governance must proceed now, quickly.
As for the name that Andrew used for his project...it is ill-informed, as is the snarky justification in this post. There are many people whose belief system considers Satan a real entity, and it is disrespectful to treat these widely held beliefs trivially. If you have any claim to value diversity, inclusion and belonging, one doesn't ridicule or trivialize deeply held cultural beliefs, in my opinion. Even if you yourself don't believe that Satan is a real entity or force, Satan is nevertheless a widely recognized symbol of evil, and evil is neither trivial nor a joke. Unfortunately, as we see in Ukraine and elsewhere, there is very real evil in the world, and trivializing it is arrogant and dangerously mistaken, in my view. 
Jessica Gurevitch, Distinguished Professor and Head of Forestry and Natural Resources, Purdue University

Andrew Lockley

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Mar 3, 2023, 10:54:33 AM3/3/23
to Jessica Gurevitch, Oliver Morton, geoengineering
Jessica I've taken on board your point that the SATAN branding (while perhaps usefully provocational in the UK) is more literally believed elsewhere - and therefore probably isn't appropriately cross cultural. I remember a similar problem with mitigation being described as a "Manhatten project", which outraged the Japanese delegates at the conference where it was discussed. But it's too late to change this branding now, partly due to the leak. 

However, I take issue with "rogue". I'm not a rogue. I WANT regulation. I am INVITING regulation (or provoking it, depending on how you consider my actions). I am saying here (as I have said before) that I'll submit to any appropriate vetting body - one that's knowledgeable, fair, and respects any pledges of confidentiality and due process it offers.

Without such a regulatory body, how am I supposed to know what constrains I should observe? I can't be expected to predict what might trigger individual list members to denounce me. Nor should I rely on government agencies lacking specialist expertise and jurisdiction. Nor on universities committees more eager to manage their institutional reputations than to govern science. 

Andrew 


David desJardins

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Mar 3, 2023, 11:01:49 AM3/3/23
to daniele...@gmail.com, geoengineering
On Thu, Mar 2, 2023 at 12:18 AM Daniele Visioni <daniele...@gmail.com> wrote:
I personally don’t want to be associated even remotely with anything you do now or in the future, so this will be my last message on this group before I unsubscribe.

I don't want to be associated with Andrew Lockley either, but he's just one of very many members of this list. I can just ignore him like I ignore lots of other people. Subscribing to this list certainly shouldn't be seen as endorsing the views of everyone who posts here. 

Stephen Salter

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Mar 3, 2023, 12:35:52 PM3/3/23
to andrew....@gmail.com, Jessica Gurevitch, Oliver Morton, geoengineering

Hi All

I ask as an ignorant non-legal person, please could one of the many expert ethicists and political decision makers help me understand the difference between the release of very small quantities of medicinally benign material aimed at helping all species intended to advance knowledge which can easily be stopped as against the release of very much larger quantities of materials, already known to be dangerous, but profitable to a small number of very rich people.

 

 

From: geoengi...@googlegroups.com <geoengi...@googlegroups.com> On Behalf Of Andrew Lockley
Sent: 03 March 2023 15:54
To: Jessica Gurevitch <jessica....@stonybrook.edu>
Cc: Oliver Morton <oliver...@economist.com>; geoengineering <geoengi...@googlegroups.com>
Subject: Re: [geo] SATAN

 

This email was sent to you by someone outside the University.

You should only click on links or attachments if you are certain that the email is genuine and the content is safe.

Jessica I've taken on board your point that the SATAN branding (while perhaps usefully provocational in the UK) is more literally believed elsewhere - and therefore probably isn't appropriately cross cultural. I remember a similar problem with mitigation being described as a "Manhatten project", which outraged the Japanese delegates at the conference where it was discussed. But it's too late to change this branding now, partly due to the leak. 

Hawkins, David

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Mar 3, 2023, 1:55:37 PM3/3/23
to andrew....@gmail.com, Jessica Gurevitch, s.sa...@ed.ac.uk, Oliver Morton, geoengineering
Of course it is perverse that our societies have failed to act against releases of GHGs but that is not a persuasive argument for those who believe there should be some form of advance review of outdoor SRM experiments.  Like it or not, the need for social license for such experiments appears to have become a reality.  And additional "unlicensed" experiments will increase the calls for some form of review.  In my view it is better for the research community to engage on formulating a workable, efficient review procedure.  That will require conversations beyond the research community.


From: geoengi...@googlegroups.com <geoengi...@googlegroups.com> on behalf of Stephen Salter <S.Sa...@ed.ac.uk>
Sent: Friday, March 3, 2023 12:35 PM
To: andrew....@gmail.com <andrew....@gmail.com>; Jessica Gurevitch <jessica....@stonybrook.edu>

Cc: Oliver Morton <oliver...@economist.com>; geoengineering <geoengi...@googlegroups.com>
Subject: RE: [geo] SATAN
 

donn viviani

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Mar 3, 2023, 3:27:12 PM3/3/23
to andrew....@gmail.com, Jessica Gurevitch, s.sa...@ed.ac.uk, dhaw...@nrdc.org, Oliver Morton, geoengineering

There is an EPA authority, the Toxic Substances Control Act, TSCA, that can require risk information be developed and submitted to EPA for review prior to releasing chemicals into the environment, at scale, for a new use:

TSCA Section 5(a) Significant New Use Rules (SNURs) can be used to require notice to EPA before chemical substances and mixtures are used in new ways that might create concerns     


EPA could either publish a list of chemicals that require fate, risk and/or other information prior to using them for a particular use, e.g., SRM, cloud seeding, or possibly ocean fertilization.  My reading of the statute indicated it’s also possible they could simply publish a “use” without knowing the chemical beforehand, such as listing SRM, when that is a “novel” use of any chemical.   I’m a chemist not a lawyer, so that last idea is speculative


TSCA is here http://uscode.house.gov/view.xhtml?path=/prelim@title15/chapter53&edition=prelim


Citizens can also petition EPA under TSCA section 21 asking that EPA publish a SNUR, by showing there is a possibility of unreasonable risk to human health and the environment if a chemical is used in a particular fashion.  This would be similar to CPRIs petition to regulate GHGs under TSCA, now being litigated.   See https://cprclimate.org/


I’m happy to provide more information. 

 

.donn



Ron Baiman

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Mar 3, 2023, 3:28:06 PM3/3/23
to dhaw...@nrdc.org, andrew....@gmail.com, Jessica Gurevitch, s.sa...@ed.ac.uk, Oliver Morton, geoengineering
Hi David et al.,

Not particularly anxious to wade into another debate over these issues but I think it's important to set (at least my understanding of) the record straight.

In its latest Nevada launches Make Sunsets gave advanced notice and received permission (https://makesunsets.com/blogs/news/3-launches), and I believe Andrew did the same with his SATAN balloon launching experiment in the UK.  I'm not a legal expert, but I believe that in both countries (certainly in the US) people are not (except in very special cases  to which this does not apply) for their intentions but only on the basis of their actions.

 I understand that both of these were politically provocative actions, but they did cause harm to anyone. So the issue is political. Do these kinds of efforts serve to "move the ball forward or backward"?  As I've stated in other threads,  I believe that Make Sunsets has moved it forward and (with appropriate public regulation and monitoring and possibly using other aerosols) could potentially morph into an effective private direct climate cooling company.

I don't know the details of Andrew's effort, and agree that the SATAN moniker was unfortunate, but I tend to believe that anything that we can do to spur awareness, discussion, and debate over the urgent (and as I think most of us believe existential for human civilization) need for direct climate cooling now (or as soon as reasonably prudently possible depending on method (https://pdfhost.io/v/kUvEpsGdb_Understanding_the_Urgent_Need_for_Direct_Climate_Cooling_0209233 ) is generally a positive contribution to our epochal challenge of a scope and within a expedited timeline never before encountered in human history.

Best,
Ron


Ron Baiman

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Mar 3, 2023, 3:29:27 PM3/3/23
to dhaw...@nrdc.org, andrew....@gmail.com, Jessica Gurevitch, s.sa...@ed.ac.uk, Oliver Morton, geoengineering
* did not cause harm*

Clare James

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Mar 3, 2023, 3:51:41 PM3/3/23
to geoengineering
The EPA is a domestic agency for the USA - a good example of why international governance may ?should? be sought for geoengineering (if academics can stop slapping each other with gloves and drawing up meaningless letters asking to ban research). Until then, forum shopping will continue. 

David Hawkins

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Mar 3, 2023, 3:54:24 PM3/3/23
to rpba...@gmail.com, dhaw...@nrdc.org, andrew....@gmail.com, Jessica Gurevitch, s.sa...@ed.ac.uk, Oliver Morton, geoengineering
To clarify, my intent is not to pass judgement on Andrew's experiment (and I have already posted my criticism of Make Sunset's actions, especially their claims and efforts to sell "cooling credits").  My point is a pragmatic one:  continued experiments without some form of advance review (and I do not regard the reported phone call from Make Sunsets to the FAA as advance review) are going to encounter increasingly strong objections. To avoid reactions that could seriously interfere with useful research, experimenters should welcome efficient review processes and engage with others to create them. 

George Collins

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Mar 3, 2023, 4:32:22 PM3/3/23
to geoengineering
Hi Stephen--

Since nobody I'm aware of is saying that Andrew's action is ethically and politically equivalent to widespread for-profit physically dangerous pollution, I take it that the question behind your question is something like "[How could] [t]he release of very small quantities of medicinally benign material aimed at helping all species intended to advance knowledge which can easily be stopped [be harmful?]"

Well:
  1. Can actions be politically and socially harmful even if they are not immediately, physically harmful?
  2. Can pure statements (actions consisting only of public speech) cause political and social harm?
  3. If so, can actions which function as public speech, but which also have a physical, non-speech component, cause political and social harm?
  4. Finally, can an action be harmful even if the person who performed the action did not intend to cause harm?
If you answer these four questions in the affirmative, that answers the original question, as long as Andrew's action has at least some public speech component—some associated statement that goes beyond its immediate physical consequences. One can inquire whether any public action doesn't have at least some such component, but a lesser claim is needed here, as I think it's crystal clear that this one does, based on its design, its procedure, its timing, its framing (from the name on down), the general tenor of Andrew's response, and Andrew's specific statements on this list (e.g. "I am INVITING regulation . . . or provoking it").

I have my own opinions about whether, how, and why the action was harmful, but that's not the question you asked.

Best,
George

Sent: Friday, March 3, 2023 9:35 AM
To: andrew....@gmail.com <andrew....@gmail.com>; Jessica Gurevitch <jessica....@stonybrook.edu>

Cc: Oliver Morton <oliver...@economist.com>; geoengineering <geoengi...@googlegroups.com>
Subject: RE: [geo] SATAN
 

renaud.derichter

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Mar 4, 2023, 5:21:14 PM3/4/23
to geoengineering
The UK Government’s View on Greenhouse Gas Removal Technologies and Solar Radiation Management
.....................

The Government is not deploying SRM, and has no plans to do so.

Regulation 

We would expect any deployment of GGRs to comply with local, national and international regulation and guidance. Some forms of GGR are already regulated. For instance, in England, large-scale afforestation is covered by Environmental Impact Assessment Regulations. In addition, work has been undertaken to examine how existing international instruments could apply: 

• The Government has supported the Convention on Biological Diversity (CBD) in its review of existing regulatory instruments. Following consideration of this review, the 13th Conference of the Parties (COP) to the CBD adopted a decision in 2016 noting that more research is needed. The COP also recalled a previous decision in 2010 which invites Parties to take a precautionary approach on any geo-engineering activities that may affect biodiversity until there is an adequate scientific basis to justify such activities, with the exception of small-scale, controlled scientific research studies.

 • The Government has contributed to work under the London Protocol on the prevention of marine pollution by dumping of wastes and other matter, to adapt the instrument to meet this new challenge. This has resulted in adoption by Parties to the London Protocol, in October 2013, of an amendment to regulate ocean fertilisation activities and, potentially, other forms of marine geo-engineering. The UK was the first country to ratify the amendment, in 2016. 

• At the Montreal Protocol meeting in November 2019, the UK supported a decision asking the Protocol’s Scientific Assessment Panel to assess research related to SRM, and its potential effect on the stratospheric ozone layer. This assessment will be included in the next Montreal Protocol Quadrennial Assessment Report (due to be published in 2022).
geoengineering-UK-position-statement.pdf

David desJardins

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Mar 5, 2023, 11:14:16 PM3/5/23
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On Fri, Mar 3, 2023 at 3:28 PM Ron Baiman <rpba...@gmail.com> wrote:
I don't know the details of Andrew's effort, and agree that the SATAN moniker was unfortunate, but I tend to believe that anything that we can do to spur awareness, discussion, and debate over the urgent (and as I think most of us believe existential for human civilization) need for direct climate cooling now (or as soon as reasonably prudently possible depending on method is generally a positive contribution to our epochal challenge of a scope and within a expedited timeline never before encountered in human history.

If your action raises awareness but almost everyone reacts negatively and becomes less sympathetic to what you're trying to do, how can that possibly be a "positive contribution"? It's like the idiots gluing themselves to paintings. It just makes the public think less of the whole idea; they don't know how to evaluate the science, but if the people arguing for X are obnoxious and arrogant and dismissive, then most people are going to lean against X as a result.

Tamas Bodai

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Mar 5, 2023, 11:43:41 PM3/5/23
to da...@desjardins.org, rpba...@gmail.com, geoengineering
I totally get the idea behind gluing yourself to famous paintings. It’s the grotesque situation that we value paint on canvas in millions (of dollars, of course), while we head to extinction. Reading such articles on BBC again and again really made me think. I would glue myself to a painting too if i didn’t fear my career would go bust. Call me an idiot, Sir. You say that most people react negatively to such a move. But it’s just your pronunciation not a fact. 

I have a beef also in general with calling other people unserious just because they have a different approach. It is very typical of conservative well established academics. Of course, this note covers not just picking a monicker or ways to raise awareness, but pursuing a research topic. Young scientists are all too often discouraged by senior ones. The basis being that the senior scientist never thought of that idea, or, is unable to compete in that arena. 

Regarding some saying that the Make Sunsets and Andrew’s campaign point to an urgent need of discussion and to rapidly paced steps towards global governance of SRM geoengineering. I’m quite sceptical. What sort of global governance of CO2 emission have we achieved through dialogue? Consider also the years spent and the time we — allegedly — have. To clue ourselves up, we just have to implement SRM etc. into integrated assessment models and see what is likely to happen. 

Btw. Andrew’s acronym is unlucky and off-putting to my taste too. But i view it just so that he got carried away, overstepped a line perhaps. Obviously, he was excited, and in that state of mind it could be difficult to think straight and get everything right, or, as intended.

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David desJardins

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Mar 5, 2023, 11:52:56 PM3/5/23
to Tamas Bodai, geoengineering
On Sun, Mar 5, 2023 at 11:43 PM Tamas Bodai <boda...@googlemail.com> wrote:
I totally get the idea behind gluing yourself to famous paintings. It’s the grotesque situation that we value paint on canvas in millions (of dollars, of course), while we head to extinction. Reading such articles on BBC again and again really made me think. I would glue myself to a painting too if i didn’t fear my career would go bust. Call me an idiot, Sir. You say that most people react negatively to such a move. But it’s just your pronunciation not a fact. 

I think it’s pretty undeniable that people gluing themselves to paintings have made the general public less sympathetic to their cause. Does anyone really question that??

It sounds like you already agreed with the cause so you can’t use yourself as a person who was converted to the cause by others gluing themselves to paintings. I think there are basically zero such people.

Tamas Bodai

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Mar 6, 2023, 12:01:06 AM3/6/23
to David desJardins, geoengineering
You have a point there... Still, i wish we lived in the age when computers were interconnected and people could easily promote a call to a poll, and have that poll easily set up and be done without (much) human assistance. 



Dr. Maiken Winter

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Mar 6, 2023, 1:57:11 AM3/6/23
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I think it would be extremely important that we do not repeat that bad press of people who do not understand the urgency or do not want to understand the urgency.  People have different approaches to try to safe humanity. Some speak and write a lot, some demonstrate, some glue themselves. We need all of them. And we all need to stand up together and defend our backs against the majority of stupidity.

I think it is awful, not timely and not understandable when climate scientists repeat the bad press against the last generation. I though you understood the urgency, no?

Actually, here in Germany the press is becoming more and more positive. People don´t like it, but they start to understand.

They don´t need to be liked. They need to be understood. And they need the focus on the urgency. If people like you just repeat the bad press, then of course things look quite dire for their movement. Do you want that?

Maiken

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