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Executive Summary: In light of the challenges impeding substantive global action on climate change mitigation, some have begun to look at geoengineering as a possible alternative. Ocean Iron Fertilization (OIF) is one such strategy that seeks to increase oceanic drawdown of carbon dioxide by stimulating marine phytoplankton growth in large iron-limited swaths of the Southern Ocean. Unfortunately, there remains lingering scientific uncertainty regarding the viability of a sustainable, global scale, iron-induced sequestration pathway. While reduced uncertainty could one day reveal a reasonable, measured approach to leverage OIF under unilateral authority and dynamic management, I argue against attempting to commercialize OIF under any emerging market framework. Current standards for globally recognized compliance offset markets require that a recognized activity is permanent, additional, free of leakage, and absent of adverse side effects. At present, there is not adequate scientific evidence that OIF is any. Worse, measurement challenges, unreliable auditing, ambiguous baselines compromised by high-frequency variability, and uncertain externalities could combine to cripple a market-based approach. Fortunately, the UN London Protocol has banned nonscientific iron fertilization, precluding the adoption of OIF into any international, compliance offset markets. However, voluntary offset markets, or those in which offsets are bought and sold without any federally mandated obligation, are not subject to any legitimate regulatory or enforcement mechanisms. I make that case that absent the appropriate oversight OIF activity on voluntary offset markets motivated by a reasonable market opportunity, the relative ease of deployment, and the perception of an ethical imperative, can, and will continue to, emerge. In turn, I argue that continued research is necessary to help constrain the public perception that voluntary markets depend on by further clarifying the risks, elaborating the challenges, and delegitimizing the promise of an iron bullet.

Southern Ocean Iron Fertilization: An Argument Against Commercialization but for Continued Research Amidst Lingering Uncertainty