Carbon dioxide removal is growing. So is the need for a code of conduct.

"The really uncharted territory is what CDR means for environmental and social justice."

A sitka spruce sapling.

Big Tech is shoveling money into carbon dioxide removal as the need for oversight grows.

Photo: Dan Kitwood/Getty Images

Interest in carbon dioxide removal has exploded over the past few years. Money from Big Tech and venture capitalists is funding a growing array of startups, with over $1.4 billion poured into the climate tech space this past quarter. But there are potential ethical issues that should be addressed before the industry gold rush goes too far.

“The really uncharted territory is what CDR means for environmental and social justice, and that’s where I see a lack of understanding,” said Lauren Gifford, a postdoctoral research associate at the University of Arizona, who has studied carbon governance for over a decade. She and other scientists worry that nascent technologies like direct air capture are being deployed without sufficient oversight or forethought about potential unintended negative consequences.

The issues CDR will need to confront are manifold. From noise pollution tied to direct air capture facilities to the ecological impacts of land- and ocean-based carbon removal techniques, the industry has a lot to reckon with as CDR becomes more widely tested and deployed at scale.

Both the scientific community and industry are working to create an ethical framework around carbon removal. Though, to be clear, nothing that’s been put out there so far has had any real enforceability.

In May, researchers published a piece in Frontiers in Marine Science that called for a scientific code of conduct for ocean-based carbon removal, a field that has already come under scrutiny for potentially going too far too fast, without enough consideration of the ecological risks of what startups are attempting. That includes a rogue 2012 experiment to seed the ocean with iron, encouraging a plankton bloom that would suck up carbon dioxide. The proposed code of conduct includes provisions for public or stakeholder engagement, minimization of potential harms and rules about funding.

The CDR community itself is also starting to do some self-examining. The Carbon Business Council, a nonprofit coalition of about 40 carbon management startups, has created an “Oath to Restore the Earth.” Members must sign the document, which includes a promise that, among other things, they will be “cognizant of the implications that my work can have for the biosphere as a whole.”

Ben Rubin, the council’s executive director, said the group was inspired by similar oaths undertaken by those in the medical and legal professions. “By laying out these tenants for responsible growth, I think we really have an opportunity as we scale gigaton removal to do it right and ensure that communities will benefit from where the projects are being located,” he said.

One carbon removal startup, Planetary, is taking it a step further and drafting up its own code of conduct. The company, which developed a process that purifies and stores mine waste in the ocean, plans on depositing its substance in approved ocean outfalls like wastewater treatment plants and power plants.

Pete Chargin, Planetary’s head of strategy and safety, said the startup’s leadership team has always been focused on safety and scientific rigor. At the same time, “On the other side of the ledger, kind of pushing us to go faster, is the fact that the ocean may be going towards a tipping point where it’s impossible to recover,” he said.

When Planetary first started thinking about adopting a code of conduct, Chargin assumed one already existed but was surprised to discover there wasn’t really anything out there they could beg, borrow or steal. “And candidly, the things that were being published were, in my view, not action-oriented,” he said.

He started working with “a few ocean-based NGOs and companies to start bouncing our ideas off them,” and said Planetary hopes to publish a first draft for public comment by the end of the quarter.

Codes of conduct like the Carbon Business Council’s ethical oath and Planetary’s efforts “could go both ways,” according to Gifford. In her view, they’re only as good as how they’re applied. Otherwise they may end up doing more for corporate greenwashing than for ensuring that for-profit carbon removal entities do no harm in the pursuit of drawdown.

Like corporate net-zero pledges, these codes of conduct don’t have teeth; there’s nothing holding pledge makers and oath takers accountable to their promises. In a worst-case scenario, the unfettered growth of the carbon removal industry could cause irreversible harm to local people and ecosystems in service of major polluters eager to pay for removal services.

Still, putting out a public pledge can nudge companies toward responsible behavior. “There's a lot of social pressure that comes to bear,” as well as reputational risk, Simon Nicholson, associate professor of international relations at American University, whose work focuses on global environmental governance, said.

Public pledges can also be strengthened by customer pressure. “You can have lots of good intentions, but you can also have just really shoddy products,” Nicholson said. That’s why he thinks it’s critical that big corporate buyers of carbon removal credits, companies like Microsoft and Stripe, hire teams of researchers to assess the claims of carbon removal startups. (Although it’s worth noting that even discriminating customers like Stripe have invested in carbon removal projects that have later come under scrutiny.)

“You can have lots of good intentions, but you can also have just really shoddy products.”

Climate researchers point to lessons learned from the carbon offset market as a warning sign of what could happen with carbon removal if proper care isn’t taken to put guardrails around a market free-for-all. Forest carbon offset schemes in places like Indonesia, Peru and the Central African Republic have displaced local communities from land “that they have used for generations for subsistence, livelihoods and cultural reasons,” Gifford said. These communities also already tend to be the most affected by, while contributing the least to, climate change. There’s even convincing evidence that some of these forest preservation offset projects are doing more harm than good.

Though young, the carbon removal field is already starting to see shadows of the same problems. Land-based forest restoration often takes place on agriculturally rich and high-demand land in the Global South. One study found that land-intensive CDR could lead to a five-fold increase in the price of food, which would be hugely devastating to local communities.

In any carbon removal project, it’s critical that frontline communities are consulted and included. That means both people living adjacent to project sites as well as the workers doing the removal, said Andrew Bergman, a Ph.D. student in applied physics at Harvard studying CDR and collective governance of infrastructure. Groups like local fishing communities could be significantly impacted by ocean-based CDR projects, for example, and deserve a say in how they’re implemented, if at all.

“You can’t have carbon removal projects override people’s well-being.”

He recommended that companies write an allowance for community and worker seats on their boards into their codes of conduct. These communities are then able to ask questions about where carbon is being stored and what effect it may have on ecosystems or the built environment.

In Bergman’s view, “like so many technocratic interventions,” carbon removal has become an end in and of itself, as opposed to a means to an end. “You can’t have carbon removal projects override people’s well-being,” he said.

Beyond community impact, the other risk with carbon removal is that its existence allows corporations, including fossil fuel companies that back these projects, to continue polluting the atmosphere.

That means the most critical part of a good carbon removal framework is acknowledging that the work must be accompanied by a good-faith effort to reduce emissions so there’s less carbon to pull from the atmosphere in the first place.


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