Dan

I think this discussion should move to the geoengineering rather than
CI group since it addresses policy rather than science and accordingly
I have cc'd to that group instead.

on the substance:

It is clear that

(1) the CBD exception stands, so activities are limited to "small
scale scientific research studies within coastal waters";  and
(2) the evaluation under LC/LP must be undertaken as required under
RESOLUTION LC-LP.1 (2008) ON THE REGULATION OF OCEAN FERTILIZATION
(ADOPTED ON 31 OCTOBER 2008)

So for the first point this is not coastal waters so it fails the test
of the CBD exception straight away.  It has also not yet been
determined whether or not 300 square km is small scale. If Germany and
India is using "the utmost caution" you would think they would
consider thsi a bit large.  This breach of the CBD moratorium is
significant especially for Germany who currently hold the presidency
of the CBD and when it was teh German Minister who personaly brokered
the language of the CBD moratorium.

Secondly  As far as the evaluation under the LC/LP is concerned, the
decision states that legitimate scientific research should be defined
as 'as those proposals that have been assessed and found acceptable
under the assessment framework;' (which doesn't yet exist) and that
'ocean fertilization activities other than legitimate scientific
research should not be allowed. ' Ergo, the activity 'should not be
allowed'.

So yes there is Para 6, which you cite as a stop gap measure saying
how the evaluation should be conducted pending the assessment
framework:  ie that until 'specific guidance' is available, parties
should use the 'best available guidance' (defined in footnote 4) to
evaluate... so that is 2 requirements: (1) to evaluate and (2) to use
the stated guidance (which is not limited to the stated decisions etc)

Obviously, it requires the evaluation to be conducted according to
that stated guidance (has it been? -I see no evidence). Nor does it
state that 6 overrides 7 and 8: i.e. activities which have not been
evaluated according to para 6 should not be allowed.

So even within the terms of the london convention agreement, Germany
and India would need to show (1) that an evaluation was conducted and
(2) that it used the best available guidance, including, but not
limited to, the instruments cited, AND that parties are using the
'utmost caution' AND (2) contracting parties did all this to "ensure
protection of the marine environment consistent with the Convention
and Protocol;"

Finally, as noted above, the decision actually cites the text of the
CBD decision , which states only  "the exception of small scale
scientific research studies within coastal waters".


For others here is the relevant text of the LC/LP in full:

The LC/LP agreed (in relevant extracts) (relevant sections in bold italics)

NOTING decision IX/16 on 30 May 2008 of the 9th Meeting of the Conference of the

Parties to the Convention on Biological Diversity which "requests
Parties and urges other

Governments, in accordance with the precautionary approach, to ensure
that ocean fertilization

activities do not take place until there is an adequate scientific
basis on which to justify such

activities, including assessing associated risks, and a global,
transparent and effective control and

regulatory mechanism is in place for these activities; with the
exception of small scale scientific

research studies within coastal waters";


4. AGREE that scientific research proposals should be assessed on a
case-by-case basis using an assessment framework to be developed by
the Scientific Groups under the London Convention and Protocol;

5. AGREE that the aforementioned assessment framework should include,
inter alia, tools for determining whether the proposed activity is
contrary to the aims of the Convention and Protocol;

6. AGREE that until specific guidance is available, Contracting
Parties should be urged to use utmost caution and the best available
guidance[4] to evaluate the scientific research proposals to ensure
protection of the marine environment consistent with the Convention
and Protocol;

7. AGREE that for the purposes of this resolution, legitimate
scientific research should be defined as those proposals that have
been assessed and found acceptable under the assessment framework;

8. AGREE that, given the present state of knowledge, ocean
fertilization activities other than legitimate scientific research
should not be allowed.


[4] Such guidance includes, but is not limited to: previous agreements
of the Consultative Meetings/Meetings of Contracting Parties; Annex
III to the London Convention and Annex 2 to the London Protocol; the
considerations for evaluating ocean fertilization proposals developed
by the Scientific Groups (LC/SG 31/16, annex 2, appendix 3); and the
Revised Generic Waste Assessment Guidance (LC 30/

On Fri, Jan 9, 2009 at 1:32 PM, Dan Whaley <[email protected]> wrote:
>
> I think it is very unfortunate that Jim has misquoted the UN IMO
> London Convention ruling here.  Having sat through the LC process
> personally for a week last October, they most defintely were specific
> in their decision *not* to preclude projects before the assessment
> framework is agreed upon-- we probably spent several hours on this
> point alone.  Greenpeace's David Santillo participated in the drafting
> of this language.
>
> Here is the specific section:
>
> "6. AGREE that until specific guidance is available, Contracting
> Parties should be urged to
> use utmost caution and the best available guidance to evaluate the
> scientific research
> proposals to ensure protection of the marine environment consistent
> with the Convention
> and Protocol;"
>
> In addition, Victor was very careful to meet with the German EPA and
> to get their green light prior to sailing.  To say this is in "clear
> defiance" of the UN is completely incorrect.
>
>

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