Earlier this month, the U.S. Environmental Protection Agency (EPA) closed a public comment period on research permits for the Woods Hole Oceanographic Institution’s (WHOI) LOC-NESS project, which was funded in part by a $5 million grant from the Carbon to Sea Initiative. The project seeks to investigate whether enhancing the ocean’s alkalinity — a process called OAE — could be an effective tool for reducing atmospheric carbon levels. In order to advance understanding of OAE as a potential tool against climate change and establish a permitting path for responsible OAE research, we urge the EPA to approve the LOC-NESS permit.

Much more research on OAE is needed and WHOI’s effort is a key step in the right direction. This effort will advance foundational knowledge of OAE while contributing to the study of potential environmental impacts. This is a major step forward in determining whether OAE could become one of humanity’s most effective tools in preventing the worst effects of climate change, alongside emissions reductions.

WHOI is seeking approval from the EPA to conduct OAE research in federal waters south of Massachusetts through a rigorous permitting process. The proposed field trial builds on years of research by leading scientists and would demonstrate that existing regulatory processes can support timely, rigorous, and innovative climate research. When approved, LOC-NESS will be the first in-water ocean-based carbon removal research permitted under the Marine Protection, Research and Sanctuaries Act (MPRSA). 

Carbon to Sea was joined by twenty leading scientific and environmental organizations in calling for the EPA to approve the permits, including Phil Renforth from Heriot-Watt University, Matthew Eisaman from the Yale Center for Natural Carbon Capture, and David Koweek from Ocean Visions, among others.

The climate crisis is currently the greatest threat to the health of our oceans and broader environment, and large-scale carbon removal will be a necessary complement to emissions reduction efforts in order to meet the goals of the Paris Agreement. That’s why responsible research to evaluate the efficacy, safety, and scalability of carbon removal methods, like OAE, is so critical and urgent. 

To that end, WHOI is seeking to conduct a two-phase field study that releases controlled amounts of alkaline solution into surface waters off the coasts of Martha’s Vineyard and Cape Cod. Researchers would then closely monitor how this addition impacts the ocean’s natural alkalinity and the amount of carbon dioxide it absorbs. Within two minutes of the initial release of the alkaline solution, seawater pH within the alkalinity release path is expected to return to levels within the EPA’s National Recommended Water Quality Criteria for saltwater aquatic life. More information about the proposed study can be found HERE.

The proposed research and these permits represent an important step forward for the U.S. in developing an effective and timely regulatory process for oCDR and can provide a closer look at the vast potential of OAE as one approach. 

Our full comment is available HERE. Excerpts of support from the Federal Register for the LOC-NESS project provided below.

  • Bigelow Laboratory for Ocean Sciences: “Ocean Alkalinity Enhancement (OAE) is one promising approach through which humans may be able to enhance ocean uptake of CO2. However, it is necessary to study the efficacy and impacts of this approach. Further, this research should be conducted by an independent, trusted expert. The proposal by WHOI to conduct a small-scale OAE test experiment is an important, and safe, step towards testing OAE.”
  • Carbon to Sea Initiative: “The proposed research offers a way to substantially increase CO2 uptake and conversion to long-lasting bicarbonate in affected waters. We fully agree with the EPA’s tentative determination that this research, “is not likely to result in significant adverse impacts to water quality, marine ecosystems, human health, or other uses of the ocean.”
  • Calcarea, Inc: “I see the LOC-NESS project as a key component of the pressing need to move from basic science research about climate change, to harnessing our national talent pool of scientists and engineers to help mitigate the consequences and causes of climate change. We must simultaneously convert to an electrified economy AND remove CO2 from the atmosphere, either through avoided emissions from point sources or by direct removal from the atmosphere, as proposed by the LOC-NESS group.”
  • Environmental Defense Fund: “EDF sees scientific merit in the proposed LOC-NESS project. The type of research proposed in this project is needed to begin understanding the effectiveness, potential, and impacts of OAE interventions on the complex and dynamic marine environment. Because mCDR research is in early stages of development, limited field trials also hold the potential for providing critical insights into how mCDR interventions and their impacts on CO2 are monitored, reported, and verified, a critical element to ensure mCDR addresses the objectives of climate mitigation and environmental safety, with findings subject to scrutiny and shared broadly with the public.”
  • Equatic: “WHOI’s LOC-NESS project employs carefully designed experiments to test the effectiveness of ocean alkalinity enhancement for CDR while advancing our knowledge of MRV approaches and tools for ocean-based CDR. Learnings from studies such as WHOI’s LOC-NESS benefit the mCDR field and society at large.”
  • Exploring Ocean Iron Solutions: “The scientific and societal merits far outweighs the local and temporary impacts to marine ecosystems and the ocean geochemistry. There is an urgency to conduct this work and approval of this field study is a key milestone moving forward in the process to better understand our mCDR options to remove atmospheric CO2, which is the cause of the climate crisis.”
  • Heriot-Watt University: “While previous research has assessed the environmental impact this technology in the laboratory or within encapsulated field experiments, very few experiments explore addition to the open ocean. The rigorously designed experiments proposed by the LOC-NESS team are vital to understanding the feasibility of these approaches. The outcomes of this work will have global significance, the risks to local marine life will be minor and highly ephemeral.”
  • Institute for Responsible Carbon Removal: “Field-based research is needed to understand the efficacy of such an approach, and any effects that might occur to humans and ecosystems if such an approach were to be deployed at much larger scales. This kind of field trial research also supports broader public and community engagement on these technologies, as it produces important information that publics and communities want and need to know about the prospect of deploying such approaches in the future”
  • Massachusetts Office of Coastal Zone Management: “Given this solid foundation, the experiments proposed for Phase 1 and then the larger Phase 2 of the LOC-NESS project are well-timed and appropriately-scaled progressions into the type of field experimentation needed to verify the efficacy of mCDR and monitor for unintended environmental impacts. This study has the potential to inform future work as mCDR research continues and possible commercial-scale applications are developed.”
  • Ocean Conservancy: “Ocean Conservancy finds that the LOC-NESS Phase 1 Project represents a thoughtful step forward in developing the scientific community’s understanding about how to carry out ocean alkalinity enhancement research in a precautionary way and we support the issuance of this limited, small-scale permit.”
  • Ocean Visions: “This is the first planned field trial of ocean alkalinity enhancement on a coastal shelf environment anywhere in the world. Simply put, the scientific merit of this work is outstanding and positions the United States as a leader in mCDR research and development.”
  • Sabin Center for Climate Change Law at Columbia Law School: “The Sabin Center supports efforts to conduct safe, responsible, and scientifically-sound research into OAE and other mCDR approaches, including controlled in ocean field trials like those proposed by WHOI. Such research is critical to improve understanding of mCDR and determine whether any particular technique might be used to help combat the climate crisis (alongside necessary emissions reductions and other climate response strategies).”
  • World Resources Institute: “There is significant uncertainty in these estimates and at-sea testing is needed to determine practical or feasible potential of OAE and to understand other impacts. Rigorous monitoring will be critical to guiding further research in this space. WHOI’s position as a trusted and credible scientific institution that is purely focused on research makes them well placed to conduct this work.”