Governance Recommendations for the For-Profit SAI Startup “Stardust”

Early in 2024 I was invited by the US/Israeli for-profit startup Stardust to work with them on the governance implications of their work on SAI.

The atmosphere is a global public good. Having a for profit startup work on research and development of SAI without any societal green light was already challenging to me. 

The Israel-Gaza war and the resulting humanitarian and geopolitical crisis made the consideration of this proposal that much more difficult. 

Yet – my thinking went – it was essential to address the governance implications. Governments and society had to either ban such activities, or develop governance frameworks within which such entities can operate in socially and environmentally appropriate ways. The state of the climate crisis, as well as the lack of robust governance frameworks for SAI, make it important and urgent to address these issues.

So, I decided to accept, but with the following conditions: 

• I would not join Stardust as such, but rather work as an independent consultant; 

• The report I would prepare had to be made public; 

• If there were disagreements about the analysis or the recommendations, they would be so indicated in the report; and 

• All remuneration I would receive would be given to an organization of my choice.¹ 

The conditions were accepted. The Stardust team and I met a number of times (twice in-person in Geneva and 10 times online). There were two important outcomes of my work:

1. My report entitled “Implications for governance of Stardust’s activities in relation to Stratospheric Aerosol Injection” dated 10 September.²   
2. The Voluntary Code of Conduct³ prepared by the Stardust team, with considerable inputs from me (as referenced in my report above). 

 This article focuses on my report – though admittedly, the more important outcome of this activity is the Code of Conduct, as many of the recommendations I made in the report have been included there. 

What is Stardust doing? 

Stardust aims to de-risk some of the critical technical challenges associated with SAI and to develop the necessary technological building blocks required for a safe, robust, and practical future deployment of SAI. This means the development of a particle to be injected into the stratosphere; a mechanism to inject; and a monitoring and risk management system. 

While Stardust is doing research and development, it will not undertake “deployment”.  Stardust’s fundamental premise is that a potential future decision by policymakers to deploy SAI should be evidence-based, and it aspires to contribute to this effort.  

Stardust expects to demonstrate how the particle they have developed, together with the injection mechanism and monitoring and risk management system, can be used for full deployment – were societies and governments to decide to make use of this technology.  The investors are taking a financial risk in that returns on their investment will happen only if there are eventually buyers of the developed technology.

My recommendations to Stardust

In a perfect world, governments would decide if SAI would be needed, and if they concluded it was, they would delegate some or all parts of the work to some public and some private entities. 

We live, however, in a rather imperfect world. There is no governance framework in place for SAI, nor is there, in any country, a societal conversation leading to a government policy for or against the use of SAI.

The reality is that in such a governance vacuum, there are entities, like Stardust – and presumably soon others to follow – who have decided to work on SAI before society provides a green light. 

Therefore, it is less useful to ask whether entities like Stardust should or should not engage in such activities. Rather, a more useful inquiry is to focus on what they can do, and what society should do, to ensure that their activities do no harm and contribute to a better understanding of the risks and benefits of SAI. This can then help future societal decisions on whether or not to pursue it.

In that light, I have focused my recommendations to Stardust on the following areas: 

Public support for the primacy of cutting emissions 

Given the profound societal implications of their work, Stardust and their investors need to clearly communicate to the public that the solution to the climate crisis is emission reductions combined with removal of excess atmospheric carbon.

Furthermore, SAI – if ever used – could not be considered as part of the solution, but at best a temporary supplement to reduce some of the impacts of a warming planet while the world completes decarbonization.

They should also make it clear that it is the role of governments – ideally through some intergovernmental process – to decide whether or not to deploy SAI and what role the private sector could play in that. 

Supporting public governance 

Stardust should also encourage governments and other actors to develop governance frameworks for research and decision-making on whether or not to deploy SAI. 

This includes supporting suggestions for a de facto moratorium on SAI deployment, until enough is known about the risks and benefits and governance challenges to lift it.

More generally, Stardust should engage in the highest possible levels of transparency about their work, through active outreach to relevant scientific evaluators, and by appointing an advisory group of different stakeholders, including members from academia, civil society and the private sector, representing a range of perspectives.

Finally, Stardust should develop a draft code of conduct – consulting with relevant experts to improve and strengthen it – and make it available publicly. This should be implemented voluntarily as soon as possible, until formal regulation is developed. 

Sharing intellectual property

One of the more controversial aspects of Stardust’s approach is the development of private intellectual property around SAI. 

Stardust should seek to ensure that any intellectual property it acquires can be made available to governments, should they decide to make use of such techniques. This could involve governments or non-state actors buying out the intellectual property rights, or the investors deciding to make it available freely.  

Stardust welcomed the above recommendations, and has already included many of them in its voluntary code of conduct. Now it is up to them to implement them, and up to various state and non-state actors to hold them accountable. 

The views expressed by Perspective writers are their own and are not necessarily endorsed by SRM360. The goal of our Perspectives is to present ideas from diverse viewpoints, further supporting informed discussion of sunlight reflection methods.