Consideration of Potential Externalities

While generally outside of the direct scope of quantification and carbon accounting, the assessment of potential externalities — i.e., the indirect or unintended ecological, socioeconomic, biodiversity, and community effects, both positive and negative, of conducting carbon removal interventions in the ocean — is essential for demonstrating that the carbon removal system has created a net positive impact.

It is critical that the ancillary impacts of carbon cycle interventions on ocean chemistry, marine ecosystems, and human communities be carefully assessed — while also recognizing the devastating ecological and socioeconomic impacts caused by imbalance in the global carbon cycle. Where not directly measurable today, the approach to addressing these externalities must mature towards the ability to be effectively quantified, whether via existing measurement approaches or newer and emerging impact metrics (biodiversity reporting, quantitative and socioeconomic metrics, etc.).

Ensuring Net Positive Environmental and Ecological Impact

To ensure net positive impact, deployments are evaluated using a multi-stage approach that includes measuring baseline environmental conditions, modeling anticipated Earth system changes prior to conducting deployments, developing an initial environmental impact assessment unique to the system location and intervention, and maintaining long-term monitoring plans for all interventions.

. EIAs should seek to identify and predict the impacts of deployments in terms of total carbon removed, ancillary impacts, and co-benefits— while also accounting for potential impacts of scale (both spatially and temporally) — and contextualize impacts in relation to a business-as-usual, no-action baseline for the ocean system. These EIAs must be conducted in accordance with local and national requirements, or proactive in the absence of such requirements. They must be validated by independent third parties and made available for public review.

As the project progresses, ‘boundary conditions’ and control rules around levels of a potential externality that cannot be exceeded must be collectively established so that a project can be paused if significant negative impacts are measured and observed. While responsible organizations conducting this work must have defined internal mechanisms in place for this circumstance, these boundary conditions need to be developed as an industry, in partnership with regulators and the scientific community, to assure effective oversight and regulatory clarity.

Laboratory testing of carbon buoy materials must also be conducted to screen for any potential pollutants and toxins that could be introduced into the marine environment.

Methods for the accurate assessment of ecological impacts will be informed by ongoing research and continuously refined based on the best available scientific understanding.

Scientific Collaboration and Transparency

Research plans must be shared and discussed with an independent Scientific Advisory Board or similar impartial expert body prior to planned deployments for additional oversight and to inform the design and implementation of open ocean interventions. Collaboration with the scientific and oceanographic community must continue to be proactively sought out to advance shared learning, including through the sharing of data and research results. Lastly, avenues for ongoing dialogue must be established with oceanographic, scientific, and academic leaders, including through new industry-academia research collaborations and coalitions where they do not exist.

This collaboration will accelerate the creation of standardized measurement approaches across the industry.

Effective Governance

Multi-stakeholder governance, including responsible research frameworks and the establishment of a code of conduct for ocean carbon removal practitioners, will be critical for ensuring responsible action in the ocean by all actors. As the ocean carbon removal industry matures, it will be critical that there is a level of self-governance and policing around actors who fail to adhere to these scientific and ethical standards.

While these standards continue to be developed at an , organizations conducting interventions in the ocean must be clear about the principles that inform their ethical decision-making from initial research up to eventual deployments. These principles must be demonstrable in practice and aligned with standards for responsible conduct (as determined by diverse stakeholders across the industry), which can serve as a gating mechanism towards subsequent phases of research or operations. Smaller scale, low-risk research and deployment activities can be utilized to efficiently develop, test, refine, and operationalize effective governance structures that are designed for real-world application. This will ensure the creation of practical and actionable standards that mitigate risks and assure compliance without delaying critical research.

In the current absence of established governance structures at an industry level, the following areas of consideration can serve as a guide by which to demonstrate project maturity and ethical decision-making:

• Science and research: Is the project based on foundational science? Has the project identified key research questions and developed plans to address them?

• Environmental and ecological: Has the project effectively considered the potential environmental and ecological impacts of planned activities, both positive and negative?

• Legal and regulatory: Does the project have clear permission to operate and an understanding of the legal and regulatory frameworks that impact the proposed activities?

• Technical: Do those conducting the project activity possess the technical capacity to understand project impacts, and effectively monitor and measure results?

• Social, community, and equity: Have those conducting the project worked with all relevant local and community stakeholders to educate, engage, and garner feedback on plans and research?

• External verification and oversight: Have those conducting the project ensured that independent expert parties can effectively review and validate the project work, approach, and results?

• Internal organizational structure: Do those conducting the project have organizational checks and balances in place to ensure decisions are science-based and responsibly agreed upon?

• Information sharing and transparency: Has the project demonstrated the necessary level of transparency around processes, plans, and results such that reviewers and the public can effectively evaluate the proposed system?

Compliance in these areas may be demonstrated via a number of pathways, including but not limited to publicly available educational materials (i.e., white papers, research roadmaps, and project-specific experimental plans), defined oversight processes (i.e., consultation with an independent scientific advisory board, independent and documented reviews of work against defined standards such as ISO by accredited auditors), and records of project-specific documentation (i.e., permitting, stakeholder consultation records, and pre- and post-EIAs).

Failure to meet applicable standards in any individual category risks social license and trust, and may prevent the project from proceeding as planned.

Specific to regulatory oversight, clear permitting and permission to operate at the relevant local, state, federal, tribal, and international levels must be demonstrated prior to planned deployments, including alignment with any current or future national or subnational compliance carbon programs within proposed operational locations.

Socioeconomic Impact

Organizations conducting interventions in the ocean must engage coastal communities by seeking the perspectives and guidance of community leaders and in community forums, funding consultations with these communities where appropriate, and hiring local talent. Organizations must also establish ongoing feedback mechanisms, including grievance resolution processes, for all affected stakeholders.

Coastal communities often bear the heaviest burden of climate change. High-paying and living wage reliable jobs in these areas can advance livelihoods for waterfront communities and provide waterfront workers the opportunity to positively impact their own communities. These communities and industries possess inherent knowledge of, and experience working in, their local ocean; as such, they are ideal candidates for employment — especially given that their existing professions and livelihoods may be impacted by climatic shifts (fishing, aquaculture, and more) — and often require minimal retraining and skills development. The ocean is a cultural foundation of coastal communities around the world, and its decline has caused a crisis of identity that manifests itself in myriad ways. Restoring career opportunities for these communities has positive effects well beyond the financial implications.

Where possible, underutilized infrastructure should be repurposed and revitalized, further investing in communities and reviving community resources.

Over time, site-specific and measurable socioeconomic impact assessments must be designed and conducted to establish baseline socioeconomic conditions and include relevant economic, cultural, and social considerations. These assessments must be designed in partnership with affected communities and monitored over the life of the project.