1. Figures and Tables

Figures

• Figure 1: High-Level Framework for Responsible Research Advancement
• Figure 2: Atmospheric CO₂is removed and durably stored in two steps
• Figure 3: Public Participation Spectrum
• Figure 4: Maritime zones as defined by the United Nations Convention on the Law of the Sea (UNCLOS)
• Figure 5: Canadian Ocean Governance
• Figure 6: Regulatory responsibilities for estuaries, coasts, and marine environments in England
• Figure 7: USA’s Marine Protection, Research, and Sanctuaries Act (MPRSA – 40 CFR Part 222) permitting process
• Figure 8: Major steps for the U.S. EPA to develop and issue permits under the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES)

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Tables

• Table 1: Prioritized Parameters for Environmental Monitoring of OAE
• Table 2. OAE Methods Definitions and Unique Focus Areas for Monitoring
• Table 3: Characteristics of commonly considered OAE feedstocks
• Table 4: List of public engagement strategies
• Table 5: Prioritized parameters and monitoring methods for environmental impact monitoring
• Table 6: Regulation by Marine Zone and Jurisdiction for Key Nations (not an exhaustive list of regulations)
• Table 7: Operational Health and Safety Risks and Mitigation Strategies
• Table 8: Example of a safety protocol for a coastal outfall OAE trial
• Table 9: Acronyms and Definitions
• Table 10: Quality elements for ecological baselining showing the definition for high and good status taken from the Water Framework Directive (WFD) (2000)
• Table 11: UK Estuaries and coastal waters specific pollutants and operational environmental quality standards (EQS)
• Table 12: Environmental Quality Standards (EQS) table for heavy metals used in Europe, taken from Environmental Quality Standards Directive (EQSD)
• Table 13:  U.S. EPA’s recommended aquatic life criteria for discharge measured within a pipeline
• Table 14: Nova Scotia EQSs for Surface Water and Groundwater Discharging to Surface Water

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2. Purpose and Guiding Principles

The objective of this Environmental Impact Monitoring Framework is to provide structured and practical guidance on safely scaling OAE field research. It is intended to help researchers, regulators, and stakeholders design and evaluate environmental monitoring activities that are scientifically rigorous, context-sensitive, and aligned with the evolving understanding of the  potential risks and benefits of OAE. 

Field trials and demonstrations are critical to building real-world evidence on the ecological safety and carbon removal potential of OAE. However, if field activities outpace the growth of the knowledge base and regulations, the risk of unintended environmental harm increases. This framework is therefore guided by the principle that environmental risks remain low and manageable when the scale of activity is matched by proportional gains in scientific understanding. 

To support this, the framework is structured in two parts: 1) an introduction and rationale for the framework’s design, and 2) guidelines for its successful implementation by a range of audiences—from academic researchers and project developers, to regulators and community members. 

OAE harbors unique challenges and opportunities for environmental impact monitoring. Regulatory- and research-guided environmental monitoring, while robust, requires a unifying framework tailored to the specific needs of OAE projects. 

The development of this framework is driven by these Guiding Principles:

• Staged progression through decision gates: Clear benchmarks should guide research progression and risk assessment. Early low-risk trials may require less intensive monitoring than larger longer-duration deployments, but all should be designed to anticipate possible impacts and prevent escalation.
• Based on best available knowledge: Recommendations draw on best available academic and operational knowledge, and they are complementary to available international standards and regulations.
• Flexible across OAE methods: The framework is designed to accommodate a variety of OAE approaches, materials and project environments, providing standards where possible and flexibility where necessary. 
• Monitoring is not a substitute for risk mitigation: Monitoring is the last step in a long process of risk mitigation, which begins with rigorous project planning and dispersal design. Monitoring alone cannot mitigate impacts once they have occurred.
• Designed for practical implementation: The framework balances scientific rigor with operational feasibility and practical realities of dynamic ocean contexts while remaining adaptable over time.

Guided by these principles and building on existing regulations, the goal is to create a framework rooted in precaution and environmental stewardship while remaining practical and adaptable to project operators. This ensures the health and safety of the local environment at a project site while pursuing the broader goal of climate regulation.

Importantly, this framework is provided for informational purposes only. While care has been taken to ensure the accuracy of the methods and assumptions herein, the authors make no representations or warranties regarding the completeness, reliability, or applicability of this framework to any specific project or context. Any use of this framework is at the user’s sole discretion and risk. The authors expressly disclaim any liability for direct or indirect damages or consequences resulting from the use, reliance upon, or interpretation of this framework.

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Methodology 

This report was developed in partnership between PML Applications (the commercial subsidiary of Plymouth Marine Laboratory (PML)) and the Carbon to Sea Initiative, beginning in May 2024 (Appendix E). Several methods were used to produce this framework, including (but not limited to):

1. A thorough analysis of peer-reviewed scientific literature (literature reviewed up to February of 2025 as seen in the reference list), drawing on PML Applications’ experiences in conducting OAE field trials and other environmental monitoring
2. Collaborative engagement with other members of the scientific community (questionnaires, email correspondence, interviews, and workshops) aiming to achieve as much input and consensus as possible, and drawing on relevant expertise in key sections (see list of contributors)
3. Attendance and participation in scientific workshops and cross-pollination with adjacent working groups, including for example:
   1. SeaCURE Workshop – September 2024
   2. eNGO mCDR working group – Monthly meetings
   3. Global Ocean Acidification Observing Network (GOA-ON) mCDR Working group – Monthly meetings
4. Iterative draft development, with phased feedback internally at PML, in collaboration with Carbon to Sea, and through a closed comment period with 27 reviewers
5. An interactive workshop with 33 participants held at the Carbon to Sea 2025 Annual Convening to preview key assets, collect feedback, and deepen discussions on impact threshold tolerance
6. Synthesis of existing legal texts, and additional analysis and review commissioned to inform the regulatory sections. Summary tables of permitted projects in active regions (US, Canada, EU, and UK) were drafted and reviewed by project owners.
7. The public comment period collected and documented comments from the wider community, including 13 reviewers representing OAE projects, regulatory bodies, scientists, and other interested stakeholders.

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4. Environmental Impact Monitoring Framework

Defining an environmental impact

Ocean alkalinity enhancement (OAE) aims to mitigate climate change by increasing the ocean’s capacity to absorb and store carbon dioxide. Yet, like all interventions in dynamic ecosystems, OAE carries the potential to affect marine environments. In this framework, we define an environmental impact as a measurable change in the biological, chemical, or physical condition of a marine ecosystem caused by OAE. Impacts can be positive, neutral, or negative, and the significance of an impact depends on its magnitude, duration, reversibility, context, and perceived benefit of the activity itself.

For an emerging field like OAE, there are no widely accepted quantitative thresholds or reference standards for impacts—aside from general, often country- or treaty-specific guidance on how to conduct environmental impact assessments in marine environments.⁶⁸ Effects may be subtle, localized, or temporally delayed, or they may emerge only under specific environmental conditions. Natural variability—seasonal, spatial, or climate-driven—or other anthropogenic activities can obscure the cause and effect. This means environmental monitoring must be fit-for-purpose, grounded in strong site knowledge, and designed to detect changes that are relevant to ecological function and project decision-making. 

This framework introduces a stage-gated approach to guide the responsible advancement of OAE field research. It offers practical guidance for environmental monitoring across four phases—from early planning to methods validation, field trials, and long-term research and demonstration projects.

Safe research, demonstration, and piloting of OAE hinges on its environmental impact at the organism and ecosystem level. However, environmental monitoring for OAE field trials is novel, complex, and challenging.

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4.1 High-Level Framework for Responsible Research Advancement

While this document is specific to field trials, a preparatory stage is included within this framework, which is key to identifying the main risks early in the research and development (R&D) cycle, as well as identifying partnerships and existing “baseline” data that can add value to the monitoring program. As such, this preparatory stage can guide the formulation of an effective monitoring program and demonstrate due diligence prior to in-water activity.

The choice of “what to measure” must be informed by alkalinization-related risk factors for the OAE method under consideration and by the organisms and habitats at the specific location (Appendix B). The subsequent sections (4.1.1-4) describe the recommended stages of an OAE project from planning to long-term field experiments, noting the environmental monitoring required at each stage. A successful outcome is a prerequisite for moving forward to each subsequent stage, as outlined in Figure 1.

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4.1.1 Stage 1: Planning and Preparation

The first stage in any successful field trial is the Planning and Preparation stage. This stage is where baseline data is collected, relationships with the community are initiated, and operational plans are designed to create a comprehensive understanding of the risks, opportunities, and scientific potential of the project site, i.e., the unique features of the study location that may contribute to or impede the successful execution of OAE field research. 

Best practices in community engagement recommend that relationship building with community members should begin as early as possible in project planning. This will include conversations with regulators (on permitting), nonprofits, civic society, Indigenous communities, fishing communities, research organizations, and relevant people in federal government and academia to collect longitudinal data in the area. Further effort should be made to become familiar with the broader range of individuals who have community influence and who should be involved in decision-making. This early mapping of the community will help operators understand the public perception of OAE,^{69, 70} decision-making authorities, the appetite for engagement, and assets that may accelerate or inform the planning stage. More information can be found in Section 5.

Before release, an impact analysis of the feedstock being deployed is required. Operators should conduct a feedstock risk assessment and review of ecotoxicological information from Material Safety Data Sheets (MSDS), chemical regulations (e.g., the European Union’s Registration, Evaluation, Authorisation and Restriction of Chemicals (EU REACH) regulations), ecotoxicology experiments, or closed system trials. The assessment should aim to understand how the feedstock will interact with the receiving water and ecology and should address any potential risks. Operators may consider generic information for the primary active substance (e.g., Mg(OH)₂) and metal or other impurities separately when documentation for a specific feedstock is not available.⁷¹ 

An understanding of local hydrodynamics through modeling, physical oceanographic measurements, and/or a tracer release experiment(s) is required prior to any field trials. In this stage, planning in situ measurements and potentially hydrodynamic modeling should be done. Modeling is required at both the near-field scale (10-100’s m) and regional scale (100’s m to km). This analysis will constrain the expected dilution of the alkalinity perturbation and thereby enable an assessment of elevated alkalinity concentration exposure times and the spatial extent of alkalinization. The expected concentrations, along with the ecotoxicological information obtained above, can be used to define zones of expected impact and direct further investigations, including defining the domain of interest. Numerical hydrodynamic models are generally a cost-effective solution for this purpose as they can be refined during the R&D cycle and expanded to include chemical speciation and/or ecosystem models for the purpose of environmental impact assessment (see Section 6.4). Nevertheless, physical dilution and dispersal may also be assessed by tracking drifter buoys or mapping tracers such as low salinity from an outfall⁴⁵ or inert dyes (as exemplified in the LOC-NESS⁴³ project, Dalhousie tracer study⁴² and Ebb’s Project Macoma).

Projects must identify local sensitivities, predict environmental impacts, and anticipate safety thresholds. Local research centers, public entities, or community resources may be able to provide and help interpret existing data on sensitive or culturally important species and habitats. Other sensitivities (e.g., hypoxic/anoxic zones or vulnerability to harmful algal blooms) must be identified and appropriately considered in the monitoring plan. At this stage, operators will need to collect data—sometimes existing but often bespoke to the pathways/location—on predicted impacts and anticipated safety thresholds. This will include a combined analysis of all local, lab, mesocosm, and in-situ data, as well as species sensitivity analysis at different life stages to clearly outline the predicted impacts.⁷² Threshold limits should be set based on this data and regulator/community input. These threshold limits will be measured against the baseline and/or control site data during environmental monitoring and will define what is considered an impact. It is important to have baselines and threshold information for all predicted impacts. Without it, monitoring will result in data that are  difficult, if not impossible, to interpret.

Where data do not yet exist, operators must develop a baseline collection plan targeted to capture the natural variability of predicted impact parameters and local sensitivities. Project developers at this stage should compile any and all existing baseline data for their site and assess data gaps. Baseline data are critical for defining an impact and for measuring additionality. It should be a priority for operators to have a robust baseline with a long enough time series to understand seasonal variability and weather events.

If the scientific potential of the planned project is high and if the risks are determined to be tolerable, continue to Stage 2.

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4.1.2 Stage 2: Methods Validation

Following the preparatory phase, the Methods Validation stage aims to demonstrate and validate the dispersal and monitoring methods intended for use in a full-scale trial. Fundamental to this stage is the analysis of physical dynamics at the test site conducted in stage 1. Physical dynamics will determine where monitoring will take place and help operators calculate the minimum amount of alkalinity needed to detect a signal in the essential parameters as verification of the monitoring plan. If baseline data do not exist, begin collecting data using the baseline collection plan from Stage 1. If baseline data or data on locally important species are available, researchers should begin to fill any gaps in these data and/or update them to the present. It is important to have a robust baseline before any dispersal testing begins. More information can be found in Section 6.1.

Using these inputs from Stage 1, operators will design and conduct a full environmental monitoring and dispersal operations test. This can only take place with appropriate/required permits. The lowest possible volume of alkalinity that can still be detected (~10s of tons/year) should be used to minimize the environmental impact of the test while validating the operational and scientific capabilities of the project (e.g., signal detection, magnitude and extent of alkalinity perturbation, and measurement against baseline data). At this stage, monitoring should also try to detect predicted impacts in the receiving water, especially for sensitive organisms. Operators should also seek to surface any gaps in their understanding of the location or operation that must be resolved before a larger-scale trial can proceed. More than one test at this scale may be required to answer all of the questions necessary to advance to Stage 3. In stage 2, the project team should aim to have multiple lines of communication with the community and should be sharing its research activities with this network. As research activities progress, new members of the public may become involved, and the communications and engagement plan should be continually revisited to ensure it is adaptable to a growing community of interest.  

If the predicted impacts are validated in the field and additional knowledge gaps are sufficiently closed, continue to Stage 3.

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4.1.3 Stage 3: OAE Field Pilot

The escalation to Stage 3 should only be made with appropriate/required permits, support from community members, and confidence in the best available science that an increase in scale will not exceed anticipated environmental impact thresholds that have previously been determined to be acceptable. This stage aims to collect data at a scale where CDR-relevant processes can be validated, and to monitor project performance against priority risk metrics. Here, the scale of alkalinity addition will increase to meet research or CDR goals to the approximate range of 100s of tons of alkalinity per year, depending on the purpose of the trial and local priorities. With an increased volume of alkalized water, it should be expected that a signal will be detected among the Attribution and Context-specific parameters. For more information, see Section 6.

In Stage 3, monitoring should increase in line with scale and local priorities, such as identifying any environmental perturbation compared to baseline or impacts to socioeconomically or culturally important species. A robust understanding of the background spatial, seasonal, and interannual variability of the environment and ecosystem is therefore highly desired. Key questions pertain to the spatial and temporal variability of the four key risk factors (elevated pH, chemical speciation changes, elevated particulates, and feedstock metal impurities) and an assessment of OAE-related changes to ecosystems. Monitoring for anticipated impacts should become more rigorous at this stage, as the increased scale may increase the likelihood of their occurrence (e.g., if turbidity is identified in Stage 2 as an anticipated impact, it is more likely to occur in Stage 3 unless otherwise mitigated).

Monitoring should also target increased risk to priority organisms/ecosystems as indicated by the community in Stages 1 and 2, and in collaboration with regulators; see Section 7. An assessment of ecosystem change will include field surveys (e.g., occurrence/abundance of species, biodiversity, ecosystem processes such as respiration) and/or partnership with local environmental monitoring groups as identified in Stage 1. Field observations are to follow established and consistent methodologies throughout to ensure comparable results with other data, as per the Guide to Best Practices in Ocean Alkalinity Enhancement Research.⁶⁷

Multiple trials may be conducted at this stage before moving to Stage 4. Longer-term measurements should be made throughout, including an extended baseline that captures seasonal and, ideally, interannual variability and significant weather events; see Section 6.1 for additional detail on baseline collection. For most parameters, the baseline data collection can only resume after signals of the OAE perturbation have subsided or if the baseline data are collected at an adjacent site outside of the alkaline plume. Baseline data, whenever possible, should aim to capture significant weather events—especially events that occur seasonally or annually such as marine heat waves, seasonal flooding, drought, and other impactful weather—to understand the extremes of natural variability at the site. The occurrence of a significant weather event should be noted in the metadata, and additional monitoring will depend on the type of weather (i.e., flooding may increase turbidity whereas a heat wave may decrease carbon solubility). In addition to natural variability, extended monitoring should aim to understand the potential for delayed-onset and long-term impacts. These are impacts that may occur only after alkalinity has accumulated or at high trophic levels.

It is additionally important to validate the models created in Stage 1 and 2 against field observations and refine the models with the additional data. For example, increased resolution and/or more complex sediment resuspension models may resolve local circulation features that lead to the accumulation of the OAE signal. In turn, this may direct the observational effort to target such locations. Coupled hydrodynamic-ecosystem-biogeochemistry models can identify complex interactions and aid in developing mitigation strategies.^{73, 61}

Activities conducted and data collected in this stage should be highly transparent and available to the public. It is critical at this stage to have an effective communication plan that facilitates regular exchanges of information with significant opportunities to receive feedback from the community. If an earnest effort has been made to build relationships in the community in earlier stages, projects may benefit from recruiting local advocates and receiving the community’s trust to operate.

If the field trial is successful, and if observations and suitable models determine low environmental risk from continuous dosing, continue to Stage 4.

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4.1.4 Stage 4: Continuous Dosing and Monitoring

This stage aims to simulate long-term operational conditions and assess sustained social and environmental benefits and risks. As the scale of additions increase or move to continuous dosing, so does scrutiny on the environmental impacts of feedstock and any unresolved knowledge gaps. This is because impurities at small scales will be compounded at larger scales. Progression to Stage 4 not only represents the completion of previous stages but a robust understanding of the field site, alkalinity source, and the short- and long-term impacts of alkalinity addition. To reach this stage, it is recommended to adopt an iterative process involving multiple tests and trials in Stages 2 and 3 to gain a complete understanding of the site at scales that minimize negative impacts and maximize knowledge building.

Once a robust understanding of the site and operation is established, operators will conduct sustained environmental monitoring campaigns of critical parameters. The project team must make informed decisions about the parameters that will be monitored long-term and the parameters that can be measured less frequently. For example, if the alkalinity source has proven to rapidly dissolve and be very stable across varied dosing volumes and throughout seasonal variability in earlier stages, the operator may decide to reduce the frequency or number of measurement locations for TSS. These critical decisions must be made in consultation with regulatory bodies and the community and will be documented in a continuous monitoring plan that should be regularly updated as long as dosing continues. This plan must also include procedures to process the data promptly and make it publicly available in perpetuity. This may involve transferring data to an external repository. 

Here, analysis of long-term trends must also be conducted based on the models validated and data collected in Stage 3. A periodic review and appraisal program should critically examine long-term observations for ecological and biogeochemical effects. This will be one step in creating an iterative process that collects and analyzes data long-term, and adjusts the monitoring plan if necessary.

As dosing becomes sustained and as volumes increase, environmental stewardship must extend beyond the field site. Operators should begin assessing the environmental impacts of sourcing alkalinity at increasing scales, including upstream activities such as mining, processing, and transport. These impacts—such as land use, emissions, and ecosystem disruption—should be weighed alongside the anticipated climate benefits of OAE. Tools such as life cycle assessment (LCA)⁷⁴ can help evaluate whether net environmental outcomes remain positive. Integrating these considerations supports ecosystem-based management and responsible scaling.

If long-term data indicate sustained benefits and manageable risks, continue or scale responsibly. Otherwise, halt dosing, revise the approach, or iterate on previous stages. 

Project Closing and Conclusion

Although this framework recommends a staged and responsible progression through increasing scales, a project can off-ramp at any point in this process if it is no longer viable or if it has completed its desired research goals. To close a project, a full analysis of the operational and environmental learnings should be documented and shared with regulators and relevant community members. This includes transparent sharing of data collected into a public repository in accordance with data standards protocol; see Section 9. Infrastructure may also need to be decommissioned and removed.

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5. Stakeholder, Rightsholder, and Public Involvement and Consultation

5.1 Priorities for Engaging Communities

As OAE research advances from controlled laboratory environments to in-ocean field trials, it enters the public domain, where community members, stakeholders, rightsholders, and governing bodies hold a legitimate interest in project activities and outcomes. At this stage, public engagement becomes a critical component of responsible research conduct. Decisions that were once confined to operators and academic researchers increasingly intersect with local governance, public values, and regulatory scrutiny.

Community engagement serves multiple essential functions: it enables more informed decision-making; builds trust between project developers, stakeholders, and local rightsholders; and surfaces site-specific knowledge that may otherwise be overlooked. When communities are excluded from meaningful participation, the resulting sense of disempowerment can undermine project legitimacy and, in some cases, halt implementation altogether. To avoid such outcomes, public engagement strategies must be developed early and with clear intent—framed by the core questions of who, why, when, and how to engage.

Consideration must be given to who will lead the community engagement effort. Certainly, the operators and scientists will be involved, but they should be guided by social science. Creating a map of potential interested or affected parties is a valuable exercise that should involve all team members. Project operators should seek to partner with community advocacy groups, grassroots organizers, or local leaders early on in engagement and maintain consistent points of contact throughout the project. These outside experts may hold valuable knowledge about the local context and ensure that engagement is pursued using best practices. 

Clarifying the rationale for public engagement is a foundational step that shapes the scope, depth, and tone of community interaction throughout a project’s life cycle. In some cases, regulatory requirements may dictate minimum levels of consultation, particularly in the jurisdiction of Indigenous rightsholders or as a permitting requirement. However, beyond these regulatory obligations lies a broader opportunity to engage communities as informed participants in the research process.

Determining the appropriate level of public influence—guided by frameworks such as the Spectrum of Public Participation⁷⁵ developed by the International Association for Public Participation—ensures transparency in how decisions will be made and what role, if any, the public will have in shaping them. Where a high level of influence is offered to communities, projects are more likely to secure enduring support. Critically, the intention behind engagement must be authentic. Project developers should never imply community influence where none exists. Doing so risks eroding credibility and damaging relationships. 

Figure 3: Public Participation Spectrum, developed by the International Association for Public Participation, 2014

The design of a community engagement strategy must be responsive to local priorities, capacity, and context. Early engagement—ideally before site selection—supports relationship-building and allows communities to shape project design in meaningful ways. A comprehensive community engagement and communication plan should include:

1. Background and Local Context: Project overview, objectives, key issues, relevant community groups, and intended engagement level
2. Logistics and Support: Meeting formats, timelines, budget, roles, and resource requirements
3. Communication Components: Target audiences, outreach strategies, communication tools, and tailored messaging
4. Evaluation Plan and Feedback Mechanisms: Methods for collecting input, measuring effectiveness, and incorporating lessons learned

Such plans should be treated as living documents that are adaptable to evolving community needs, shifting project scopes, and new insights gained during implementation.

5.2 Background and Local Context

Identifying relevant stakeholders is not always straightforward. While some participants—such as regulatory agencies, rights holders, or local government bodies—are readily identifiable, others may emerge more gradually. It is important to include not only those who will be directly affected by a project, but also those who perceive themselves as impacted, as both groups can shape the trajectory of public discourse and project outcomes.

Early efforts should focus on mapping the local stakeholder landscape, beginning with formal authorities and expanding to include civil society organizations, community associations, and individuals with knowledge of or interest in the project site. Grassroots outreach is particularly valuable for uncovering local leadership structures and informal networks. Gathering existing information and resources on community perspectives before outreach can further enrich these early efforts, as it provides project operators with additional context on how to best approach community priorities. For example, in parts of the US and Canada, Indigenous communities may have significant cultural connections and hold governance rights to a proposed project area. Resources such as Informing mCDR: Best Practices Guidance for Tribal and Indigenous Engagement provide helpful insight on engaging Indigenous communities and how Traditional Ecological Knowledge can be used to meaningfully inform environmental monitoring design and management of the project. The United Nations Declaration on the Rights of Indigenous Peoples serves as a comprehensive international instrument to promote and protect the collective and individual rights of Indigenous people. 

It is also important to note that interest does not always equate to influence. Community leaders may be constrained by competing priorities, and the individuals most vocal about engagement may not represent the broader population. Understanding what matters to local stakeholders—how OAE intersects with their values, concerns, and objectives—enables project proponents to frame carbon removal in ways that are relevant and compelling at the community level.

5.3 Logistics, Support, and Communication Components

Engagement logistics—ranging from meeting schedules to communication styles—should be designed to lower barriers to participation and should reflect the specific context of the community. Flexibility in format, location, and timing can significantly improve accessibility and foster a more inclusive environment.

Project developers should anticipate a degree of trial and error in identifying the most effective strategies. Consistent and culturally appropriate outreach demonstrates a sustained commitment to transparency and accountability. As community interest increases, project proponents must be cautious not to overextend promises or suggest influence where none can be meaningfully offered. Managing expectations is critical, particularly as the number of stakeholders expands.

Communication strategies should be tailored to the knowledge base and preferences of the community. In many cases, researchers will be operating in environments characterized by low institutional trust and high concern. In such settings, technical messaging must be reframed by using clear and accessible language that is delivered through trusted messengers and familiar channels. When engaging with coastal communities, project leads should reference best practice guidelines such as Engaging Coastal Communities on OAE⁷⁶ and Effective Engagement of the Fishing Community in a mCDR Context.⁷⁷ 

Researchers and project proponents should keep in mind that the research questions and environmental concerns from a scientific perspective do not always map to community concerns. Designing a messaging, engagement, and communications approach that authentically explores and prioritizes community input will create a more successful project and more trusted outcomes. The table below lists various engagement and communication strategies that can be used during the engagement process.

Table 4: List of public engagement strategies^{78, 79, 80}

Public Engagement Strategy	Advantages	Disadvantages
Public “town hall” type meetings	Allow a gathering of multiple interested parties to exchange information.	It can feel impersonal and limit the ability to tailor the message to the audience.
A series of public consultation meetings	Provide more opportunities for people to attend compared to a single “town hall.”	Time and cost.
A series of stakeholder workshops	May answer particular questions or gain insights into specific areas of the OAE project.	Restricted by stakeholder availability and willingness to participate.
Community-led listening sessions	Allow local community members and groups to create their own agenda to be heard.	Little to no influence over the agenda.
Communities of practice	Offers a longer term collaboration among like-minded practitioners.	Time and cost. This requires substantial interest in mCDR in a specific region.
Thematic consultation meetings (e.g., local fishery, youth climate action)	Invite deeper engagement by focusing on a specific topic in a small group setting.	This can lead to an imbalance of influence over the project if one industry or group is overrepresented.
Public notices (including leaflets and newsletters posted to locals)	May be distributed by local groups trusted by their audience.	Purely informational with no mechanism for input or feedback.
Local press releases (e.g., distributed to online, television, radio, and newspaper news sources)	Cover a larger readership and have a low associated cost.	Lack of control on what the published news story reports.
Science workshops/educational campaigns	Help address gaps in understanding in a hands-on way.	Mainly directed at or integrated into educational and academic programs, and therefore is often focused on youth
Websites, e-newsletters, or virtual town halls	Low cost and direct control over content.	Limited opportunities for interpersonal relationship and trust building.
Public input mechanisms such as surveys, comment form, or public review periods	Provide direct and measurable feedback from the community.	Additional administrative burden to monitor and manage input.

5.4 Evaluation plan and process

Engagement strategies must remain dynamic and responsive to changing project and community conditions. As field activities scale or attract broader attention, the composition of stakeholders may shift, and engagement approaches must adapt accordingly.

Regular evaluation provides the means to assess the effectiveness of engagement efforts and identify areas for improvement. Feedback may be collected through formal tools—such as surveys, comment forms, or public review periods—or through more informal mechanisms, such as community listening sessions.

When early engagement efforts have successfully established trust, community members are more likely to provide candid and constructive feedback. This iterative process reinforces mutual accountability and strengthens long-term relationships. Critically, engagement does not end with the completion of field trials or the cessation of dosing; ongoing dialogue may be necessary to address post-project monitoring, reporting, or community concerns. In this way, engagement is not a single phase of project development, but a continuous and evolving practice embedded throughout the life of an OAE initiative.

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7. Regulatory Considerations for Ocean Alkalinity Enhancement

When researchers and technology developers initiate early-stage in-ocean research and demonstration efforts in diverse jurisdictions, they must navigate regulatory frameworks that were often not designed with marine carbon dioxide removal (mCDR) in mind. Project developers will need to engage with regulators to implement various water, waste, and environmental protection laws. Given that OAE represents a novel scientific and climate use case for regulators, project proponents may face some unanticipated requirements as both parties navigate the application of existing law. 

However, as the OAE sector develops and grows, there has been increased direct engagement with regulators, and clear implications for the sector are beginning to emerge. For example, in the USA, the Fast-Track Action Committee (FTAC) on mCDR provided advice for project proponents on responsible, safe, and effective mCDR research.¹⁴⁹

How to engage with regulators

It is important to note that each audience is at a different point in its learning journey, and you may be the first to introduce the concept of OAE to a particular regulator or perhaps you may be speaking to an expert ocean biogeochemist. Calibrating your message and approaching each discussion with mutual respect, humility, and authenticity will help to earn the collaboration needed to create progress for your project. Below are a few tips for successful regulatory engagement:

• Understand your regulatory landscape: Becoming familiar with the jurisdictions, regulatory officials, and relevant procedures before engagement can help ensure efforts are targeted to the appropriate decision-makers.
• Co-design rather than present: Do not wait until you have a fully baked design; rather, invite regulators to help define acceptable thresholds, monitoring metrics, or experimental constraints. This builds trust and shared ownership of decisions.
• Use a range of engagement formats: Meetings, workshops, bilateral discussions, “site visits,” and informal briefings all help share and invite different perspectives in. 
• Lower barriers to participation: Because regulators have many competing priorities and limited staff, offer one-pagers, executive summaries, and flexible meeting modes to engage more easily.
• Be responsive and formalize feedback loops: Solicit feedback, adjust methods, and emphasize iterative learning as a matter of course. 
• Understand the regulator’s position: The role of the regulator is to primarily ensure legislation is adhered to, but in some cases the regulator may not be able to adapt thresholds or constraints to the project, despite a compelling case that the proposal is safe.

Relevant regulatory frameworks for OAE

This section offers a practical synthesis of how current regulatory frameworks may apply to future projects while also pulling from real-world permitted projects across the United States, Canada, the United Kingdom, and elsewhere. Across jurisdictions, most applicable laws and permitting processes have been developed to protect environmental quality and ecosystem health, with few such laws and permitting processes directly naming emissions reduction targets. Consequently, regulators understandably prioritize environmental risk and safety, evaluating proposals first and foremost on minimizing impact on marine life, maintaining water quality, and ensuring public and stakeholder transparency.

Alignment with a nested, multi-level governance structure

Environmental regulation for OAE must consider formal and informal guidance at all levels of government. 

• At the international level, treaties and norms, laws—such as The United Nations Convention on the Law of the Sea (UNCLOS), the London Convention and the London Protocol (LC/LP), the Conservation and Sustainable Use of Marine Biological Diversity of Areas Beyond National Jurisdiction Agreement (BBNJ)—and the no-harm rule of customary international law establish broad principles on environmental protection, pollution prevention, environmental quality standards, and scientific research allowances. 
• At the regional/national/federal level, countries implement international obligations and regional frameworks (such as the European Union’s Water Framework Directive) and address national concerns through domestic laws – such as the US Clean Water Act (CWA) and Marine Protection, Research, and Sanctuaries Act (MPRSA), Canada’s Canadian Environmental Protection Act (CEPA), Oceans Act and Fisheries Act, the UK’s Environmental Permitting Regulations, and Germany’s transposition of the Water Framework Directive. 
• At the subnational/regional level, states, provinces, regional bodies, and other subnational actors implement delegated national authorities and, in some cases, their own regulations, which are adapted to local ecological and societal contexts, such as state-level National Pollution Discharge Elimination System (NPDES) permits in the US, or provincial watercourse permits in Nova Scotia, Canada. 

Project-level permitting occurs at the national and subnational level, through project-specific permit requirements, which will be influenced by site-specific risk assessments and monitoring plans. These project approvals may deviate from typical water quality thresholds, allowing higher pH or suspended solids, if justified by rigorous monitoring, temporary conditions, public or stakeholder review, and the project’s public interest or research value.

This multi-layered system ensures a range of environmental protections, while also allowing flexibility for responsible innovation. However, the system does create complexity as project developers must often navigate complex, overlapping, or ambiguous legal frameworks, with each having different triggers and interpretations of risk. 

Please be aware that the following section does not offer legal advice and should not be used to forego legal consultation. This area of regulation is dynamic and aspects of what is written here may currently be under review or revision. To avoid inaccuracies we have erred on the side of generalization, but project developers should be aware of potential additional regulations specific to their area.

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7.1 International Regulatory Framework

London Convention (1972) and London Protocol (1996) (LC/LP)

The London Convention and the London Protocol regulate the at-sea disposal of waste or other matter from vessels and aircraft, and from platforms and other structures. Disposal must be permitted by the country under whose jurisdiction it occurs. Notably, however, permits are not required for the “placement of matter for a purpose other than mere disposal thereof, provided that such placement is not contrary to the aims of” the LC/LP. 

The parties to the LC/LP have adopted multiple statements and resolutions clarifying that “legitimate scientific research” (which has yet to be defined) into mCDR is allowed (2008) and providing an assessment framework to guide the evaluation of research projects (2010). An amendment to the LP establishes specific rules for certain “marine geoengineering” activities (2013), but it has not yet entered into force. Some forms of OAE may fall within the definition of marine geoengineering, but even so, the 2013 amendment is not directly applicable to OAE (2023).¹⁵⁰

The United Nations Convention on the Law of the Sea (UNCLOS)⁹⁶

The United Nations Convention on the Law of the Sea (UNCLOS) establishes the legal architecture for ocean governance. Among other things, UNCLOS divides the maritime space into zones such as internal waters, territorial sea, contiguous zone, exclusive economic zone (EEZ), continental shelf, and the high seas. The jurisdiction, rights, and obligations of States vary by maritime zone, and thus, the location of an OAE activity has regulatory implications. 

Article 210 of UNCLOS obliges coastal states to “prevent, reduce, and control pollution of the environment by dumping” within their jurisdiction, and to adopt laws and regulations to this effect. More broadly, Part XII of UNCLOS establishes a broad, precaution-based duty under Articles 192 and 194 for all States to “protect and preserve the marine environment” and to take “all necessary measures” to control “any source” of marine pollution, which has been interpreted as requiring states to address the increasing amount of CO₂ in the ocean.¹⁵¹  While UNCLOS sets this foundational mandate, it delegates the creation of more detailed marine dumping frameworks to global and regional agreements. 

At the same time, UNCLOS explicitly affirms the importance and legitimacy of marine scientific research. Under Articles 238-265, States not only have the right to conduct marine scientific research but they are also obliged to “promote and facilitate” it, “promote international cooperation,” and “create favourable conditions” for research, subject to coastal State conditions and with coastal State consent. These provisions ensure that responsible marine research can proceed in accordance with scientific norms, transparency, and coastal State authority. 

UNCLOS is broadly accepted within the international community, with 167 countries and the European Union as parties to the agreement.¹⁵²

Figure 4: Maritime zones as defined by the United Nations Convention on the Law of the Sea (UNCLOS)¹⁵⁰

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7.2 National and Subnational Legal Frameworks

International law is not directly binding on private actors. As a result, the permitting and other regulation of individual projects occurs at the national and subnational levels. Proactively engaging regulators—often many months ahead of formal applications—lays the foundation for smoother permitting. Most OAE permit decisions hinge on a clear demonstration of environmental risk management, while some permitting authorities also want to see a demonstration of how the project contributes to the region’s environmental and climate obligations. 

As the science and experience in the field of OAE continue to evolve, engaging with regulators should be a collaborative exercise in risk management, emphasizing transparency, protective thresholds, adaptive planning, and feedback loops that improve as new information is learned. Project developers and researchers should be ready to provide answers to these common areas of inquiry: 

1. Project Scope, Site, and Regulatory Context – Overview of project goals, activities, location, equipment/platforms, team credentials, timeline, and regulatory requirements 
2. Material Transport, Storage, and Discharge/ Placement and Material Characterization – Details about the substances or materials to be released/placed in the ocean, expected volumes, pH/alkalinity change, concentrations of any contaminants, release/placement points and mechanisms, project duration, and logistics for on-shore storage, at-sea transport, and management of any waste streams
3. Environmental Risk Assessment – Demonstrated understanding of local baseline conditions (chemistry, and commercially, culturally or ecologically important species and habitats), pre-project baseline survey obligations, modeled dispersion/dilution, impact thresholds, qualitative risk assessments; and any avoidance, minimization, or mitigation measures
4. Monitoring and Reporting Plan: Real-time measurements and control systems, sampling locations/frequency, data review protocols, public disclosure mechanisms, post-project monitoring commitments, minimum data-retention period, permittee reporting schedule, and on-demand access for regulators
5. Operational Controls and Safety: Infrastructure layout, start-up / shut down protocols, spill or exceedance response measures, team roles and training, species-protection timing windows, adaptive management triggers, and mandatory halt/termination criteria
6. Governance and Stakeholder Coordination: Impact on Indigenous groups and other members of the community, plans to engage with authorities and decision-makers, data sharing, and review timelines
7. Post-Project Stewardship: If warranted and required by regulators, plans and/or obligations for site decommissioning or habitat restoration 

Depending on the nature of the project, additional information may also be required. 

OAE projects are actively permitted or in exploration stages around the world. The table below highlights just a few nations to illustrate the types of regulations that may be relevant for researchers or developers in these regions. This is not an exhaustive list, and there may be additional laws that apply to specific projects that are not included here. These additional laws include federal and subnational acts under which a researcher may need to obtain approval, meet a standard, or seek an exemption. It is important to remember that the permitting authorities are bound to base their assessments on objective criteria and plausible arguments on a case-by-case basis. Additionally, regulators involved in marine conservation or spatial planning may have relevant information about where conservation areas may be sited in the future and the viability of OAE research projects. There are very few relevant precedents, and each decision process is unique.

Table 6: Regulation by Marine Zone and Jurisdiction for Key Nations (not an exhaustive list of regulations)

	USA	Canada	UK	Iceland
Authorities with Relevant Jurisdiction or Influence	U.S. Environmental Protection Agency U.S. Army Corps of Engineers U.S. National Oceanic and Atmospheric Administration U.S Fish and Wildlife Service U.S. Bureau of Ocean Energy Management State Agencies and local bodies (e.g., state environment agencies with delegated NPDES programs)	Environment and Climate Change Canada Fisheries and Oceans Canada Impact Assessment Agency of Canada Crown-Indigenous Relations and Northern Affairs Canada Provincial Authorities (e.g., Nova Scotia Environment and Climate Change, Ministry of Environment and Climate Change Strategy, British Columbia)	Environment Agency Centre for Environment, Fisheries and Aquaculture Science Marine Management Organisation Inshore fisheries and conservation authorities Natural England Joint Nature Conservation Committee Local authorities	Icelandic Environment and Energy Agency (Umhverfisstofnun) Ministry of Environment, Energy and Climate Icelandic Coast Guard Icelandic Transport Authority Local water regional committees Ministry of Foreign Affairs National Planning Agency Ministry of Industries
Maritime Zone	Potentially Relevant Laws and Regulations for OAE Pilots and Demonstrations
Internal waters and rivers (landward of baseline)	Clean Water Act (CWA)  Rivers and Harbors Act (RHA) Endangered Species ActMarine Mammal Protection Act State-level water quality and coastal zone management programs	Canadian Environmental Protection Act (disposal at sea) Fisheries Act Canadian Navigable Waters Act Impact Assessment Act Provincial Acts e.g. Nova Scotia Environmental Act, British Columbia Environmental Management Act	Environmental permitting regulations (discharge consents) Water Environment Regulations (good ecological and chemical status) Abstraction permits (currently through the Water Resources Act) Salmon and Freshwater Fisheries Act Habitats Regulations Act Town and Country Planning Act	Water Management Act  Regulation on Water Management Chemicals Act
Coastal /transitional waters (seaward of baseline)	Clean Water Act (CWA)  Marine Protection, Research, and Sanctuaries Act (MPRSA) Endangered Species Act Marine Mammal Protection Act State and local laws, including coastal Zone Management programs	Canadian Environmental Protection Act (disposal at sea) Fisheries ActOceans Act	Water Environment Regulations (good chemical and chemical status) Salmon and Freshwater Fisheries ActMarine and Coastal Access Act (including marine protected areas) Habitats Regulations Marine Works (Environmental Impact Assessment) Regulations The Offshore Marine Conservation (Natural Habitats, &c.) Regulations	Act on Territorial Waters, EEZ and Continental Shelf Act on Prevention of Marine & Coastal Pollution  Water Management Act Chemicals Act
Exclusive economic zone / Outer Continental Shelf	Marine Protection, Research and Sanctuaries Act Endangered Species Act Marine Mammal Protection Act Outer Continental Shelf Lands Act	Canadian Environmental Protection Act (disposal at sea) Fisheries Act Oceans Act (MPA jurisdictions)	Marine and Coastal Access Act (including Marine Protected Areas) Habitats Regulations Marine Works (Environmental Impact Assessment) Regulations
High seas	Domestic laws apply based on the vessel flag, the citizenship of individuals on board the vessel, and the location where material is loaded onto the vessel.

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7.2.1 USA

The USA is a party to the London Convention and has signed—but has not ratified—the London Protocol. The Marine Protection, Research and Sanctuaries Act (MPRSA)¹⁵³ implements the London Convention domestically and regulates most activities, such as OAE, involving the introduction of substances into the ocean from vessels or other vehicles. The MPRSA applies to activities seaward of the “baseline” out to 12 nautical miles of the U.S. coast and anywhere in the world if the vessel used is registered or loaded in the U.S. It should be noted that the MPRSA applies to substances transported via vehicles and does not apply to discharges via outfalls or pipes, which are instead regulated under the Clean Water Act (CWA).  

Under the MPRSA, the U.S. Environmental Protection Agency (EPA) generally oversees permitting for a wide range of activities, such as OAE, that may introduce matter into the ocean. It provides distinct permitting pathways for scientific research and commercial activities. However, MPRSA permits for the placement of dredged or fill material on beaches are overseen and issued by the U.S. Army Corps of Engineers (USACE). When issuing permits under the MPRSA, EPA, and USACE, these permitting bodies must consult with other agencies, such as National Oceanic and Atmospheric Administration (NOAA), the U.S. Fish and Wildlife Service, etc., on matters under these agencies’ jurisdiction that may be impacted by the proposed activity.

Additionally, under the Rivers and Harbors Act, USACE is responsible for permitting associated structures below the mean high-water line. If structures will be attached to the seabed of the U.S. outer continental shelf, a lease or other authorization may also be required from the Bureau of Ocean Energy Management under the Outer Continental Shelf Lands Act. 

Coastal outfalls in the territorial sea are regulated under section 402 of the Clean Water Act (CWA). Activities landward of the baseline are similarly regulated under the CWA, with permitting authority often delegated to the states. In general, discharges of pollutants from point sources into waters of the United States require a National Pollutant Discharge Elimination System (NPDES) permit from the EPA or an authorized state agency under the CWA. Some discharges (of material classed as “dredge” or “fill”) require permits from USACE under section 404 of the CWA. In some cases, both 402 and 404 permits may be required.

To receive an NPDES permit, regulators apply technology-based effluent limitations (TBELs) and water quality-based effluent limitations (WQBELs) to ensure that the applicable water quality standards are achieved (Figure 8 in the appendix).

The process to earn an MPRSA or CWA permit for OAE is summarized in Figures 7 and 8 in the appendix.

Using permissible pH concentration limits as an example, the EPA states that, for open ocean waters where the depth is substantially greater than the euphotic zone, the pH should not be changed more than 0.2 units from the naturally occurring variation, nor should the pH be outside the range of 6.5 to 9.0.

For shallow, highly productive coastal and estuarine areas where naturally occurring pH variations approach the lethal limits of some species, changes in pH¹⁵⁴ should be avoided, but, in any case, they should not exceed the 6.5-9.0 limits. The EPA also provides recommendations for maximum concentrations of pollutants (as measured within the pipeline) to protect aquatic life when discharges occur through a pipeline (Table 10 in the appendix). 

For each permitting case, the state, territory, or tribe reviews the permit and documentation to determine whether to waive or grant a Clean Water Act section 401 certification (indicating that the permit will achieve the applicable state water quality standards). If state or public review of the permit results in changes to the draft permit, a second round of review or public notice and comment might be needed. For most NPDES permits, an authorized state is the permit-issuing authority, and much of the process is similar to the process followed when EPA issues the permit.

Examples of permitted OAE projects in the United States include: 

LOC-NESS Project
Organizations	Woods Hole Oceanographic Institution (WHOI)
Date	August 2025
Location	Wilkinson Basin, Gulf of Maine, USA
Method	Controlled release of NaOH into the surface ocean to study CDR
Permit Type	Research permit under the Marine Protection, Research and Sanctuaries Act (MPRSA), U.S. Environmental Protection Agency (EPA)
Permit Scope	Controlled addition of up to 167,5000 gallons of purified alkalinity (NaOH), co-released with up to 275 gallons of Rhodamine water tracer dye
Status	Completed and Permitted
Reference	2025 Field Trial Press release, Permit Announcement from LOC-NESS, EPA Fact Sheet

Project Macoma
Organizations	Project Macoma, LLC, a subsidiary of Ebb Carbon
Date	The permit is effective December 1, 2024 and expires November 30, 2028. Discharge authorization is effective for two years from the start of the pilot project.
Location	Port Angeles Harbor, Washington, USA
Method	Electrodialysis: removing acid from seawater, resulting in the release of alkaline seawater to stimulate the uptake of atmospheric CO2
Permit Type	Individual National Pollutant Discharge Elimination System (NPDES) permit (granted under Federal Clean Water Act), Department of Ecology, State of Washington. (In addition to about 9 other operational permits)
Permit Scope	Discharge of alkaline‑enhanced seawater for a two‑year pilot; pH limit at discharge point between 7-12; pH must remain 7.0–8.5 at the edge of the mixing zone; continuous flow‑rate and water‑quality monitoring required
Status	Permitted
Reference	Department of Ecology Water Quality Permitting and Reporting Information System page for Project Macoma

Coastal Enhanced Weathering Pilot, Duck, NC
Organizations	Vesta PBC Research Collaborators:Hourglass Climate (independent monitoring), USACE Engineer Research and Development Center, and The Coastal Studies Institute
Date	2024+
Location	Duck, North Carolina, USA
Method	Deployed milled olivine sand in nearshore waters to accelerate natural weathering processes for purposes of CDR. Approximately 8,200 metric tons of olivine sand were deployed at approximately. 25 feet depth, 1,500 feet offshore from Duck, NC.
Permit Type	U.S. Army Corps of Engineers (USACE) under the Clean Water Act, North Carolina Department of Environmental Quality (NCDEQ) approved project under the Coastal Area Management Act (CAMA)
Permit Scope	USACE authorized placement of up to 7,000 cubic yards of olivine sand in nearshore waters for research purposes
Status	Permitted and Ongoing pilot
Reference	Project Page and research overview on the Vesta website

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7.2.2 Canada

Canada is a party to both the London Convention and the London Protocol, which prohibit dumping of all but low risk materials at sea. The Canadian Environmental Protection Act (CEPA, 1999) is the legislation that enforces the Convention and Protocol, by establishing permits and other requirements for activities involving “disposal at sea” and protection of the marine environment from land-based sources of pollution. 

CEPA requirements may apply to a subset of OAE activities, as a “disposal at sea”, if the activities include deposition of a substance from a ship, aircraft, or platform or other structure into the ocean. “Disposals at sea” of scheduled substances may be allowed under CEPA pursuant to a permit issued by Environment and Climate Change Canada (ECCC). 

There is also a collaboration between Fisheries and Oceans Canada (DFO) and the National Oceanic and Atmospheric Administration (NOAA) in the USA around the issues of ocean acidification¹⁵⁵ which includes information on ongoing OAE research in the two countries, and these considerations may weigh on DFO’s decision to grant a disposal permit

ECCC’s published guide¹⁵⁶ on disposal at sea permits provides a list of activities that do not require a disposal at sea permit. These activities include the placement of a substance for “a purpose other than disposal” so long as the placement is not contrary to the purpose or the aims of the LC/LP and so long as it is approved pursuant to departmental policy (which has not been fully developed). Applications are reviewed by the Disposal at Sea Program Regional staff.

The Canadian Fisheries Act is primarily administered by DFO, although ECCC is responsible for administering and enforcing provisions addressing the deposition of deleterious substances. A substance is considered “deleterious” if its addition to water degrades or alters the water’s quality to the point that it is deleterious to fish, fish habitat, or the human use of fish. The Fisheries Act aims to protect fish and fish habitat in marine and freshwater environments by prohibiting deposition of “deleterious substances.” Authorization under the Fisheries Act may be required for proposed activities that impact fish or fish habitat, and DFO may impose conditions on such activities if the activities are authorized. An activity that deposits deleterious substances into water frequented by fish, or under conditions where the deleterious substance may enter such waters, may also be authorized and prescribed specifically by regulation under the Fisheries Act. An example of such a regulation is the Wastewater System Effluent Regulations (WSER)¹⁵⁷ under the Fisheries Act, which regulates the release of effluent from wastewater systems. 

Since 2019, certain decisions made under the Fisheries Act require the consideration of Indigenous knowledge and of the impact of the decision on the rights of Indigenous peoples as well as accommodation of the duty to consult. Any permitting sought by a project proponent for OAE may be subject to accommodation based on consultation. 

In addition, other federal legislation, such as the Species at Risk Act (SARA) and the Migratory Bird Conventions Act (MBCA), prohibit the disturbance or harm of listed species and their habitats. Both the SARA and MBCA permit activities that may result in these prohibited outcomes in very specific circumstances. Specifically, the Fish and Fish Habitat Protection Program, administered by DFO, ensures compliance with relevant provisions under the Fisheries Act and SARA. The program reviews proposed works, undertakings, and activities that may impact fish and fish habitat. If a project is taking place in or near water, the proponent is responsible for understanding project-related impacts on fish and fish habitat, applying for authorization, adhering to any conditions of authorization, and applying measures to avoid and/or mitigate impacts to fish and fish habitat. 

Notably, the Oceans Act allows for the establishment of marine protected areas (MPAs) in Canada’s internal waters, territorial sea, or EEZ, to conserve and protect species, habitats and their ecosystems. Oceans Act MPA regulations specify permissible and prohibited activities, based on the site’s conservation objectives which could have implications for potential OAE projects.

Specifically, for an OAE project, these impacts could include (but are not limited to) precipitation of compounds on the benthic community and changes to water chemistry, resulting in impacts on aquatic species. In cases where impacts on fish and fish habitat cannot be avoided or completely mitigated, proponents should submit a Request for Review to DFO. A review will determine whether authorization under the Fisheries Act is required. 

In addition to the statutes above, any structures—such as pipelines, outfalls, diffuser systems, platforms, or intake systems—constructed, altered, moved, or decommissioned in navigable waters require prior approval from the Minister of Transport under the Canadian Navigable Waters Act. Some kinds of “works” may not require approval if they are accepted by the Minor Works Order. Any “major work” set out in the Major Works Order will require approval. Structures that may be considered minor work may include buoys, piers, or works that are minimally intrusive or temporary. 

The Impact Assessment Act (IAA) is used to plan for and assess major projects that may cause significant adverse environmental effects (e.g., hydroelectric dams, large-scale marine development, major coastal infrastructure, power plants). All projects, or types of projects, listed in the IAA Physical Activities Regulations will require approval through the impact assessment process, in applicable jurisdictions. 

Even if an OAE research pilot or demonstration project is not a designated project and does not presumptively require an impact assessment (IA), engagement with the Impact Assessment Agency of Canada (IAAC) before the commissioning phase is possible to ensure compliance with the IAA. If an IA is ordered, IAAC may require the proponent to submit a detailed project description. The initial project review conducted by the agency will determine if a full IA is required. If so, comprehensive environmental, socioeconomic studies, public engagement, and Indigenous consultations will be required. The timelines for the IA process are set out in the Act, and include: up to 180 days for IAAC’s initial review, up to 300 days for the IAAC’s impact assessment report from the agency to the minister, and up to 90 days for a final decision. 

Each province has specific legislative environmental assessment requirements, for example, a project assessment under the Nova Scotia Environment Act. Each provincial environmental assessment may have slightly different technical standards that a project proponent must satisfy in the assessment. As an example of a technical requirement, the EQSs in Nova Scotia^{37, 38} for Surface Water and Groundwater Discharging to Surface Water are available in Table 12 in Appendix D. Nova Scotia has an Environment and Climate Change Department¹⁵⁸ that has a specific approval process, as published on its website.

Figure 5: Canadian Ocean Governance

Examples of permitted OAE projects in Canada include: 

Planetary Technologies
Organizations	Planetary Technologies, Nova Scotia Power, Dalhousie University
Date	2023+
Location	Halifax, Nova Scotia, Canada
Method	Mineral-based Alkalinity Enhancement with Mg(OH)2 addition to the cooling water outflow of Nova Scotia Power’s Tuft’s Cove Generating Station. 1,000 net tons removed so far, 10,000 tons annual site capacity.
Permit Type	Standalone provincial permit issued by the Nova Scotia Department of Environment and Climate Change (NS-ECC)
Permit Scope	Chemical storage, spill contingency plans, air quality, water quality, and noise. Stated end-of-pipe pH and total suspended solids limits
Status	Ongoing pilot
Reference	Project Page on Planetary website159

CarbonRun
Organizations	CarbonRun, Dalhousie University
Date	2025+
Location	Nova Scotia, Canada
Method	Addition of crushed limestone to rivers to raise their pH, storing CO2 as dissolved bicarbonate in the river and ultimately the ocean
Permit Type	Water Withdrawal Permit for processing purposes. River Liming is a designated activity under the Watercourse Alteration Permit, administered by Nova Scotia Environment and Climate Change (NSECC). Some activities may proceed by way of notification only, in particular if they improve fish habitat. Activities are exempt from Federal Environmental Impact Assessment (precedent). Fisheries Act Species-At-Risk is relevant when a species’ habitat is present (historical or contemporary).
Permit Scope	All necessary permits are scoped per-project and active.
Status	Permitted, Project active (not public)
Reference	Frontier Purchase Agreement160 details, Canada Department of Fisheries, Overview of Liming Techniques.161

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7.2.3 UK

The UK is a party to both the London Convention and the London Protocol. In the UK, marine-based research and deployment activities are regulated through a comprehensive system of water and environmental laws, including, for example, the Environmental Permitting (England and Wales) Regulations 2016, through which permits are issued, and the Marine and Coastal Access Act 2009, through which licences are issued. The following UK government resources provide information on permitting and licensing requirements for projects: environmental permit or marine license. While several government agencies are involved in authorizing activity in the marine environment, the Environment Agency and Marine Management Organization are of greatest relevance to mCDR activities, along with Natural England, JNCC, and Cefas, all of which are statutory advisors to the UK government.

In addition, the Water Environment Regulation (Water Framework Directive) (England and Wales) 2017 transposes the EU standards into UK law to ensure inland, transitional, and coastal waters maintain “good ecological” status up to one nautical mile from baseline or “good chemical status” through 12 nautical miles from baseline.¹⁶² Through the Water Framework Directive (WFD) assessment (Clearing the Waters for All),¹⁶³ the UK provides guidance on how to assess the impact of any estuarine or coastal activity . A WFD assessment should be carried out in three stages: screening, scoping, and then the impact assessment (if required). The screening stage will identify if scoping is required, and then the scoping stage will identify all potential risks to each receptor (hydromorphology, biology, habitats, and fish), water quality, and protected areas. The WFD includes a template that can be used for this activity¹⁶⁴ and provides suggestions for using the Water Body Summary Table¹⁶⁵ and Magic Maps¹⁶⁶ to find information on the location and size of WFD habitats. Invasive non-native species (INNS) should be included in the impact assessment if the activity could introduce or spread INNS to the OAE delivery site.

An environmental quality standard (EQS) is a set level of concentration of specific pollutants in water bodies, established to ensure the water maintains or achieves a “good status”. For most of the substances covered by the EQSs, the regulator will set numerical limits in permits, so that compliance results in the waters meeting the EQSs. A summary of the UK Government EQS¹⁶⁷ limits is available in the appendix (Table 11). 

For coastal outfalls, regulations specify pH limits at the edge of the initial mixing zone (IMZ), defined as the region where the effluent rises under its own buoyancy. The distance between the outfall and the IMZ edge is variable in space and time, depending on tidal flows and mixing by winds, but it is generally in the order of tens of metres.¹⁶⁸

Biological safeguards are embedded through obligations such as those under the Eels Regulations (England and Wales) 2009, which regulates the impact of structures on eel movement and migration, and which may require the installation of fish screens and other mitigations to facilitate eel movement. The Salmon and Freshwater Fisheries Act 1975 aims to protect fish species, spawning environments, and habitats potentially impacted by chemical discharge. Additionally, the Water Resources Act 1991 governs abstraction and pollution of controlled waters, making the Act a primary tool for oversight of project-related water quality interventions. For OAE, this necessitates securing a water discharge consent and/or permit from the Environment Agency for wastewater and chemical release, along with necessary monitoring and mitigation planning. While not specific to OAE, these regulations collectively create a layered control system that the relevant authorities use to assess and regulate ocean activities. 

In addition, other agencies may become involved in the permitting process if a proposed location for OAE activities is protected or has species of concern. For example, Natural England has responsibility for nature conservation, and it provides advice to the EA (the regulator) about the English coastal region within territorial waters. For another example, OAE materials themselves may fall under regulation (such as the EU’s REACH regulation (EC No 1907/2006), which requires chemical imports of more than one tonne per year to be registered with the European Chemicals Agency (ECHA).⁶⁹ To aid OAE field trial time management, it must be understood that applications for permits or licenses for novel activities may take as long as 1-2 years.

Figure 6: Regulatory responsibilities for estuaries, coasts, and marine environments in England

EA =  Environment Agency, EPR = Environmental Permitting Regulations, IFCA = Inshore Fisheries and Conservation Authorities, JNCC = Joint Nature Conservation Committee, NE = Natural England, SAFFA = Salmon and Freshwater Fisheries Act, SSSI = Site of Special Scientific Interest, WER = Water Environment Regulation, WFD = Water Framework Directive, WRA = Water Resources Act.

Examples of permitted OAE projects in the UK include: 

SeaCURE
Organizations	Exeter University, Plymouth Marine Laboratory, SEA LIFE Weymouth Aquarium
Date	2024+
Location	Weymouth, United Kingdom
Method	Direct Ocean Capture via electrodialysis with release of basic CO2-depleted seawater
Permit Type	Bespoke Environment Agency Discharge Permit
Permit Scope	Discharge permit to release pH-adjusted seawater between a pH of 7 and 10. Daily discharge limit up to 14,200 m3/day. Permit issued for the period of research contingent on an annual fee.
Status	Ongoing pilot
Reference	Project Announcement

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7.2.4 Iceland

Iceland is a party to both the London Convention and the London Protocol, placing it under the same international duties as the other nations in this section. At the national level, a robust body of legislation shapes ocean activities. 

Under the Act on Territorial Waters, Exclusive Economic Zone, and Continental Shelf (Act No. 41/1979),¹⁷⁰ Iceland defines its marine jurisdiction, extending from internal waters through the continental shelf. This Act establishes a strong environmental precaution posture: Chapter V requires the avoidance of any pollution-causing activity, and Chapter VI mandates that all scientific research in marine zones receive pre-approval. This approval is typically provided by the Ministry of Foreign Affairs, with consultation from a range of expert authorities. Applications for research – including alkalinity additions – must be submitted at least six months in advance and receive a decision within four months. Project descriptions must include methodology, substances used, timing, vessel/equipment types, and involvement of Icelandic or foreign research entities.

In addition, the Act on Prevention of Marine and Coastal Pollution (Act No. 33/2004)¹⁷¹ prohibits the disposal of any substance into the sea without a permit. However, it provides an important exception for lawful scientific research, when approved under the 1979 Act above. 

In freshwater and coastal systems landward of the baseline, the Water Management Act (Act No. 36/2011) and its affiliated Regulation No 935/2011 transpose the EU Water Framework Directive standards into the Icelandic legal framework. Iceland is considered a single River Basin District (IS1). IS1 is divided into four water regions, each of which has a dedicated water region committee that includes representatives from the local authorities and the local health inspectorates and which is led by a representative from the Icelandic Environment Agency. The role of the water region committees is to coordinate the work within each water region and gather information when it comes to the river basin management plan, monitoring plan, and their implementation, especially the Programme of Measures. The Water Framework Directive assigns ecological and chemical “good status” to water bodies, and requires environmental impact assessments and permitting for interventions that might alter water quality or ecosystem integrity. Oversight is coordinated by regional water management structures under the Environment Agency of Iceland.¹⁷² The EQSD indicates maximum allowable concentrations (MAC) and annual average concentrations (AA) of some key substances that are known contaminants to potential OAE materials. A section of this table is available in the appendix.

Because OAE projects frequently involve chemical additions or tracer usage, Iceland’s Chemicals Act (Act No. 61/2013) and Fluorinated Greenhouse Gases Regulation (Reg. No. 1066/2019) impose controls on the handling, storing, and disposing of substances such as sodium hydroxide and sulfur hexafluoride. Permits are required, and operational protocols— including staff training and safety data sheet availability—must be in place. 

Oversight of these activities is shared across government agencies. The Ministry for Foreign Affairs considers, evaluates, and issues ocean science research permits. The Ministry for the Environment, Energy, and Climate is responsible for policy development and strategic oversight across environmental protection, climate action, nature conservation, and energy regulation. The Environment and Energy Agency of Iceland oversees the administration of climate, environmental, and energy affairs, as well as resource management issues.¹⁷³  The Ministry of Industries is responsible for the management, research, and monitoring of the conservation and utilization of fish stocks and other living marine resources and the seabed. The Marine and Freshwater Research Institute will conduct scientific research and advice related to the conservation and utilization of fish stocks and other living marine resources and the seabed. The Icelandic Coast Guard plays an important role in regulating infrastructure and marine use. Prior approval is needed for the use and deployment of equipment or objects in navigable waters from the Icelandic Transport Authority and prior approval for the use of telecommunications is needed from the Electronic Communications Office of Iceland.   

There are not currently any permitted OAE research projects in Iceland.

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9. Transparent Data Publishing and Reporting Guidelines

This section is co-authored by Jacqueline Long and is adapted from the Ocean Alkalinity Enhancement Data Management Protocol.¹⁸²

Transparent data publishing and reporting practices are central to maintaining a record of carbon removal and environmental monitoring that is of high integrity, is verifiable, and lives in perpetuity. To achieve these goals, the FAIR Guiding Principles for Scientific Data Management and Stewardship¹⁸³ were published and subsequently adopted by the EU.¹⁸⁴ The FAIR principle highlights the need to improve the Findability, Accessibility, Interoperability, and Reuse of data and acts as a set of guidelines for scientific data management to improve data infrastructure and services. Data collected as part of OAE field trials and operations should be well structured and standardized to maximally support intercomparison and to accelerate learning across projects, and it should be made openly available for the research and regulatory community. All data should be managed in accordance with FAIR to improve accessibility of the data that will form baseline environmental data for future OAE operations. 

Data that comply with the principles of FAIR must be:

Findable

F1. All data are assigned a unique and life-long identifier.

F2. Data are accompanied by rich metadata (as per R1).

F3. Metadata include the identifier of the data described.

F4. All data are registered in a searchable database.

Accessible

A1. All data are retrievable by their identifier using a standard process.

A1.1 The process and database are open and free.

A1.2 The process allows for an authentication procedure where necessary.

A2. Metadata are accessible, even when the data they describe are no longer available.

Interoperable

I1. All data must use a formal, accessible, and shared language.

I2. All data must use respectful, accessible, and courteous vocabulary.

I3. All data must include accurate and useful references to other data where appropriate.

Reusable

R1. All data must be fully described with a number of accurate and relevant keywords.

R1.1. All data must be released under an accessible data usage licence.

R1.2. All data must have a traceable source.

R1.3. All data must meet domain-relevant standards.

Before executing any OAE activity, a data plan should be transparently shared that defines what data are anticipated to result from the project, and how data will be collected, monitored, stored, and shared. 

Regulatory Reporting

Beyond the open data-sharing practices described above, OAE projects are subject to mandatory reporting obligations that vary by jurisdiction and that must be identified and met throughout a project’s lifecycle. These obligations fall into two broad categories. The first category concerns the conditions attached to the permits and authorizations that allow an OAE activity to proceed. Permitting authorities typically require periodic submission of monitoring data, compliance reports, and notification of any exceedances of permitted thresholds or deviations from the approved monitoring plan (see Section 7). The second category concerns operational and occupational reporting independent of the OAE permit itself, including the recording and reporting of workplace accidents, injuries, near-misses, spills, and other safety incidents in accordance with applicable occupational health and safety regulations (e.g., OSHA in the United States or the equivalent national authority) and any maritime or environmental incident-reporting requirements (see Section 8). Practitioners should establish clear procedures for both categories before field activities begin, ensuring that responsibility for each reporting obligation is assigned, that submission timelines and recipients are understood, and that records are maintained in a manner that satisfies regulators and supports transparency.

OAE Field Data Standards

In addition to, and informed by, the FAIR standards, Carbon to Sea has published a Data Management Protocol¹⁸² specifically for the OAE community. The protocol shares guidance and templates for submitting data for various types of projects and measurements in OAE. Metadata standards offer a common framework for submitting qualitative data that helps make experimental data understandable, discoverable, and reusable by humans and machines. The framework includes key details such as the method of collection, units, location, timestamps, data quality, and licensing. Guidelines for data management outline the specific requirements and recommendations for submitting data associated with OAE research. It covers general guidelines for adjusted and raw data, in situ sensor data, sediment processes, and biological/physiological data. Additionally, it provides instructions for creating unique project and experiment IDs to facilitate cross-linking of datasets (particularly for research cruises and other projects) and timelines for archiving data. Controlled vocabulary and column header names are also provided to ensure consistent naming structures for the comparability of data across projects.

Most important for the long-term preservation of data is the choice of the repository where the data is submitted and stored. Data can be stored in any scientific data repository that provides long-term preservation of data (ideally with version control capabilities), metadata hosting, and data citations with a unique DOI. Data may be stored in more than one repository if necessary; however, it is strongly recommended to choose a single repository to aid in discoverability. The choice of data repository may often be dictated by funder requirements. However, we make the following recommendations for data repositories.

• Discrete and sensor data, along with data from field trial studies, are recommended to be stored at:
  • NOAA’s Ocean Carbon and Acidification Data System (OCADS) (includes metadata schema reflecting most of the contents in this protocol, up to 1 GB storage) 
  • Zenodo (up to 50 GB storage)
  • SEANOE
  • BCO-DMO (NSF-funded projects only)
  • SeaDataNet (must be in an affiliated node)
  • NOAA NCEI (must apply for a data agreement)

Data can also be backed up and stored in secondary locations. For ease of use, a secondary repository with a quicker submission workflow—such as Zenodo, Figshare, or PANGAEA—is recommended; other openly accessible options, such as GitHub or other domain-specific archives, are also permissible.

Additionally, Carbon to Sea and Submarine Scientific are developing an OAE Field Data Commons as an OAE-specific data platform for academic and private sector projects to share their experimental data. The OAE Field Data Commons builds on the standards and metadata requirements established by the OAE Data Management Protocol¹⁸² to provide a unified data repository that is easily accessible, searchable, and integrable with existing data repositories. The platform will allow project practitioners to search across relevant standardized datasets using category filters, including method type and site location, which will enable practitioners to conduct cross-site comparisons and other meta-analyses to inform their future project decision-making.

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Appendix B.
Existing Literature Demonstrating the Biological and Ecological Impacts Associated with OAE

The following is a short (illustrative) list of recent papers that demonstrate the biological and ecological impacts associated with OAE. These could be used in developing monitoring plans.

• Suessle, P., Taucher, J., Goldenberg, S. U., Baumann, M., Spilling, K., Noche-Ferreira, A., Vanharanta, M., & Riebesell, U. (202-). Particle fluxes by subtropical pelagic communities under ocean alkalinity enhancement. Biogeosciences, 22(1), 71–86. https://doi.org/10.5194/bg-22-71-2025
• Albright, R., Caldeira, L., Hosfelt, J., Kwiatkowski, L., Maclaren, J.K., Mason, B.M., Nebuchina, Y., Ninokawa, A., Pongratz, J., Ricke, K.L., Rivlin, T., Schneider, K., Sesboüé, M., Shamberger, K., Silverman, J., Wolfe, K., Zhu, K., Caldeira, K., 2016. Reversal of ocean acidification enhances net coral reef calcification. Nature 531, 362–365. https://doi.org/10.1038/nature17155
• Bach, L. T., Ferderer, A. J., LaRoche, J., & Schulz, K. G. (2024). Technical note: Ocean Alkalinity Enhancement Pelagic Impact Intercomparison Project (OAEPIIP). Biogeosciences, 21(16), 3665–3676. https://doi.org/10.5194/bg-21-3665-2024
• Bach, L.T., Gill, S.J., Rickaby, R.E., Gore, S. and Renforth, P., 2019. CO₂ removal with enhanced weathering and ocean alkalinity enhancement: potential risks and co-benefits for marine pelagic ecosystems. Frontiers in Climate, 1, p.7.
• Bednaršek, N., van de Mortel, H., Pelletier, G., García-Reyes, M., Feely, R. A., & Dickson, A. G. (2025). Assessment framework to predict sensitivity of marine calcifiers to ocean alkalinity enhancement – identification of biological thresholds and importance of precautionary principle. Biogeosciences, 22(2), 473–498. https://doi.org/10.5194/bg-22-473-2025
• Cripps, G., Widdicombe, S., Spicer, J. I., & Findlay, H. S. (2013). Biological impacts of enhanced alkalinity in Carcinus maenas. Marine Pollution Bulletin, 71(1–2), 190–198. https://doi.org/10.1016/j.marpolbul.2013.03.015
• Delacroix, S., Nystuen, T. J., Tobiesen, A. E. D., King, A. L., & Höglund, E. (2024). Ocean alkalinity enhancement impacts: regrowth of marine microalgae in alkaline mineral concentrations simulating the initial concentrations after ship-based dispersions. Biogeosciences, 21(16), 3677–3690. https://doi.org/10.5194/bg-21-3677-2024
• Fakhraee, M., Li, Z., Planavsky, N., Reinhard, C., 2022. Environmental impacts and carbon capture potential of ocean alkalinity enhancement (preprint). In Review. https://doi.org/10.21203/rs.3.rs-1475007/v1
• Ferderer, A., Schulz, K. G., Riebesell, U., Baker, K. G., Chase, Z., & Bach, L. T. (2024). Investigating the effect of silicate- and calcium-based ocean alkalinity enhancement on diatom silicification. Biogeosciences, 21(11), 2777–2794. https://doi.org/10.5194/bg-21-2777-2024
• Gately, J.A., Kim, S.M., Jin, B., Brzezinski, M.A., Iglesias-Rodriguez, M.D., 2023. Coccolithophores and diatoms resilient to ocean alkalinity enhancement: A glimpse of hope? Sci. Adv. 9, eadg6066. https://doi.org/10.1126/sciadv.adg6066
• Goldenberg, S. U., Riebesell, U., Brüggemann, D., Börner, G., Sswat, M., Folkvord, A., Couret, M., Spjelkavik, S., Sánchez, N., Jaspers, C., & Moyano, M. (2024). Early life stages of fish under ocean alkalinity enhancement in coastal plankton communities. Biogeosciences, 21(20), 4521–4532. https://doi.org/10.5194/bg-21-4521-2024
• González-Santana, D., Segovia, M., González-Dávila, M., Ramírez, L., González, A. G., Pozzo-Pirotta, L. J., Arnone, V., Vázquez, V., Riebesell, U., & Santana-Casiano, J. M. (2024). Ocean alkalinity enhancement using sodium carbonate salts does not lead to measurable changes in Fe dynamics in a mesocosm experiment. Biogeosciences, 21(11), 2705–2715. https://doi.org/10.5194/bg-21-2705-2024
• Gore, S., Renforth, P., Perkins, R., 2019. The potential environmental response to increasing ocean alkalinity for negative emissions. Mitigation and Adaptation Strategies for Global Change 24, 1191–1211. https://doi.org/10.1007/s11027-018-9830-z
• Guo, J. A., Strzepek, R. F., Swadling, K. M., Townsend, A. T., & Bach, L. T. (2024). Influence of ocean alkalinity enhancement with olivine or steel slag on a coastal plankton community in Tasmania. Biogeosciences, 21(9), 2335–2354. https://doi.org/10.5194/bg-21-2335-2024
• Hutchins, D. A., Fu, F.-X., Yang, S.-C., John, S. G., Romaniello, S. J., Andrews, M. G., & Walworth, N. G. (2023). Responses of globally important phytoplankton species to olivine dissolution products and implications for carbon dioxide removal via ocean alkalinity enhancement. Biogeosciences, 20(22), 4669–4682. https://doi.org/10.5194/bg-20-4669-2023
• Jones, K., Hemery, L. G., Ward, N. D., Regier, P. J., Ringham, M. C., & Eisaman, M. D. (2025). Biological response of eelgrass epifauna, Taylor’s Sea hare (Phyllaplysia taylori) and eelgrass isopod (Idotea resecata), to elevated ocean alkalinity. Biogeosciences, 22(6), 1615–1630. https://doi.org/10.5194/bg-22-1615-2025
• Marín-Samper, L., Arístegui, J., Hernández-Hernández, N., Ortiz, J., Archer, S. D., Ludwig, A., & Riebesell, U. (2024). Assessing the impact of CO₂-equilibrated ocean alkalinity enhancement on microbial metabolic rates in an oligotrophic system. Biogeosciences, 21(11), 2859–2876. https://doi.org/10.5194/bg-21-2859-2024
• Oberlander, J. L., Burke, M. E., London, C. A., & MacIntyre, H. L. (2025). Assessing the impacts of simulated ocean alkalinity enhancement on viability and growth of nearshore species of phytoplankton. Biogeosciences, 22(2), 499–512. https://doi.org/10.5194/bg-22-499-2025
• Paul, A. J., Haunost, M., Goldenberg, S. U., Hartmann, J., Sánchez, N., Schneider, J., Suitner, N., & Riebesell, U. (2024). Ocean alkalinity enhancement in an open ocean ecosystem: Biogeochemical responses and carbon storage durability. EGUsphere, 2024, 1–31. https://doi.org/10.5194/egusphere-2024-417
• Ramírez, L., Pozzo-Pirotta, L. J., Trebec, A., Manzanares-Vázquez, V., Díez, J. L., Arístegui, J., Riebesell, U., Archer, S. D., & Segovia, M. (2024). Ocean Alkalinity Enhancement (OAE) does not cause cellular stress in a phytoplankton community of the sub-tropical Atlantic Ocean. EGUsphere, 2024, 1–34. https://doi.org/10.5194/egusphere-2024-847
• Ries, J.B., 2010. Review: Geological and experimental evidence for secular variation in seawater Mg/Ca (calcite-aragonite seas) and its effects on marine biological calcification. Biogeosciences 7, 2795–2849. https://doi.org/10.5194/bg-7-2795-2010
• Rønning, J., Kofoed, Z. J., Jacobsen, M., & Löscher, C. R. (2024). Response of Marine Primary Producers to Olivine Additions. EGUsphere, 2024, 1–36. https://doi.org/10.5194/egusphere-2023-2884
• Santinelli, C., Valsecchi, S., Retelletti Brogi, S., Bachi, G., Checcucci, G., Guerrazzi, M., Camatti, E., Caserini, S., Azzellino, A., & Basso, D. (2024). Ocean liming effects on dissolved organic matter dynamics. Biogeosciences, 21(22), 5131–5141. https://doi.org/10.5194/bg-21-5131-2024
• Xin, X., Faucher, G., & Riebesell, U. (2024). Phytoplankton response to increased nickel in the context of ocean alkalinity enhancement. Biogeosciences, 21(3), 761–772. https://doi.org/10.5194/bg-21-761-2024

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Appendix D.
High-level checklist for regulators assessing OAE field trials

Table 10: Quality elements for ecological baselining showing the definition for high and good status taken from the Water Framework Directive (WFD) (2000)

Quality Element for Ecological Baselining	Definition for High Status as per WFD	Definition for Good Status as per WFD
Composition, abundance, and biomass of phytoplankton	The taxonomic composition of phytoplankton corresponds totally or nearly totally to undisturbed conditions. The average phytoplankton abundance is wholly consistent with the type-specific physicochemical conditions and is not such as to significantly alter the type-specific transparency conditions. Planktonic blooms occur at a frequency and intensity that is consistent with the type-specific physicochemical conditions.	There are slight changes in the composition and abundance of planktonic taxa compared to the type-specific communities. Such changes do not indicate any accelerated growth of algae resulting in undesirable disturbances to the balance of organisms present in the water body or to the physicochemical quality of the water or sediment. A slight increase in the frequency and intensity of the type-specific planktonic blooms may occur.
Composition and abundance of other aquatic flora, including macrophytes and phytobenthos	The taxonomic composition corresponds totally or nearly totally to undisturbed conditions. There are no detectable changes in the average macrophytic and the average phytobenthic abundance.	There are slight changes in the composition and abundance of macrophytic and phytobenthic taxa compared to the type-specific communities. Such changes do not indicate any accelerated growth of phytobenthos or higher forms of plant life, resulting in undesirable disturbances to the balance of organisms present in the water body or to the physicochemical quality of the water or sediment. The phytobenthic community is not adversely affected by bacterial tufts and coats present due to anthropogenic activity.
Composition and abundance of benthic invertebrate fauna	The taxonomic composition and abundance correspond totally or nearly totally to undisturbed conditions. The ratio of disturbance-sensitive taxa to insensitive taxa shows no signs of alteration from undisturbed levels. The level of diversity of invertebrate taxa shows no sign of alteration from undisturbed levels.	There are slight changes in the composition and abundance of invertebrate taxa from the type-specific communities.The ratio of disturbance-sensitive taxa to insensitive taxa shows slight alteration from type-specific levels. The level of diversity of invertebrate taxa shows slight signs of alteration from type-specific levels.
Composition, abundance, and age structure of fish fauna	Species composition and abundance correspond totally or nearly totally to undisturbed conditions. All the type-specific disturbance-sensitive species are present. The age structures of the fish communities show little sign of anthropogenic disturbance and are not indicative of a failure in the reproduction or development of any particular species.	There are slight changes in species composition and abundance from the type-specific communities attributable to anthropogenic impacts on physicochemical and hydromorphological quality elements. The age structures of the fish communities show signs of disturbance attributable to anthropogenic impacts on physicochemical or hydromorphological quality elements, and, in a few instances, are indicative of a failure in the reproduction or development of a particular species, to the extent that some age classes may be missing.
Hydromorphological elements supporting the biological elements	The quantity and dynamics of flow, and the resultant connection to groundwater, reflect totally or nearly totally undisturbed conditions. The continuity of the river is not disturbed by anthropogenic activities and allows the undisturbed migration of aquatic organisms and sediment transport. Channel patterns, width and depth variations, flow velocities, substrate conditions, and both the structure and condition of the riparian zones correspond totally or nearly totally to undisturbed conditions.	Conditions consistent with the achievement of the values specified above for the biological quality elements.
Chemical and physicochemical elements supporting the biological elements	The values of the physicochemical elements correspond totally or nearly totally to undisturbed conditions. Nutrient concentrations remain within the range normally associated with undisturbed conditions. Levels of salinity, pH, oxygen balance, acid neutralising capacity, and temperature do not show signs of anthropogenic disturbance and remain within the range normally associated with undisturbed conditions.	Temperature, oxygen balance, pH, acid neutralising capacity, and salinity do not reach levels outside the range established to ensure the functioning of the type of specific ecosystem and the achievement of the values specified above for the biological quality elements. Nutrient concentrations do not exceed the levels established so as to ensure the functioning of the ecosystem and the achievement of the values specified above for the biological quality elements.

Table 11: UK Estuaries and coastal waters specific pollutants and operational environmental quality standards (EQS)¹⁶⁷

“95 percentile standard” means a standard that is failed if the measured value of the parameter (for example, the concentration of a pollutant) is greater than the threshold for 5% or more of the time.

Substance	Annual average EQS [μg/L]	Maximum allowable concentration EQS [μg/L]
Ammonia – un-ionised	21	Not applicable
Arsenic	25	Not applicable
Boron	7,000	Not applicable
Bromine -total residual oxidant	Not applicable	10
Chloride	Not applicable	Not applicable
Chlorine	Not applicable	10 (95th percentile standard, concentration of total residual oxidant)
Chromium (III) – dissolved	Not applicable	Not applicable
Chromium (VI) – dissolved	0.6	32 (95th percentile standard)
Cobalt – dissolved	3	100
Copper – dissolved (Dissolved organic carbon (DOC) less than or equal to 1 milligram per litre (mg/l))	3.76	Not applicable
Copper – dissolved (Dissolved organic carbon (DOC) greater than 1mg/l)	3.76 + (2.677 x ((DOC/2) –0.5)) μg/l	Not applicable
Cyanide	1	5 (95th percentile standard)
Fluoride – dissolved	5,000	15,000
Hydrogen sulphide	Not applicable	10
Iron – dissolved	1,000	Not applicable
Manganese	Not applicable	Not applicable
pH	Not applicable	6 – 8.5 (95th percentile standard)
Silver – dissolved	0.5	1
Sulphate	Not applicable	Not applicable
Tin (inorganic) – dissolved	10	Not applicable
Total anions	Not applicable	Not applicable
Vanadium	100	Not applicable
Zinc – dissolved plus ambient background concentration. For saltwater, an Ambient Background Concentration of 1.1 µg/l is recommended.	6.8	Not applicable

Table 12: Environmental Quality Standards (EQS) table for heavy metals used in Europe, taken from Environmental Quality Standards Directive (EQSD)¹⁸⁵

Name of substance	CAS number	AA-EQS *1Inland surface waters *2 [μg/l]	AA-EQS *1Other surface waters [μg/l]	MAC-EQS *3  Inland surface waters *2 [μg/l]	MAC-EQS *3 Other surface waters [μg/l]	EQSBiota *4 [μg/kg wet weight]
Cadmium and its compounds(depending on water hardness classes) *5	7440-43-9	≤ 0,08 (Class 1)0,08 (Class 2)0,09 (Class 3)0,15 (Class 4)0,25 (Class 5)	0,2	≤ 0,45 (Class 1)0,45 (Class 2)0,6 (Class 3)0,9 (Class 4)1,5 (Class 5)	≤ 0,45 (Class 1)0,45 (Class 2)0,6 (Class 3)0,9 (Class 4)1,5 (Class 5)
Lead and its compounds	7439-92-1	1,2 *6	1,3	14	14
Mercury and its compounds	7439-97-6			0,07	0,07	20
Nickel and its compounds	7440-02-0	4 *6	8,6	34	34

*¹ The annual average value (AA-EQS) applies to the total concentration of all isomers.

*² Inland surface waters encompass rivers and lakes and related artificial or heavily modified water bodies.

*³ This parameter is the EQS expressed as a maximum allowable concentration (MAC-EQS). 

*⁴ Unless otherwise indicated, the biota EQS relates to fish. An alternative biota taxon, or another matrix, may be monitored instead, as long as the   EQS applied provides an equivalent level of protection. 

*⁵ For Cadmium and its compounds the EQS values vary depending on the hardness of the water as specified in five class categories (Class 1: < 40 mg CaCO₃/l, Class 2: 40 to < 50 mg CaCO₃/l, Class 3: 50 to < 100 mg CaCO₃/l, Class 4: 100 to < 200 mg CaCO₃/l and Class 5: ≥ 200 mg CaCO₃/l).

*⁶ These EQS refer to bioavailable concentrations of the substances.

Table 13:  U.S. EPA’s recommended aquatic life criteria for discharge measured within a pipeline.

Pollutant(P = Priority Pollutant)	SaltwaterCMC1(acute)(µg/L)	SaltwaterCCC2(chronic)(µg/L)
Arsenic	69	36
Cadmium (P)	33	7.9
Chlorine	13	7.5
Chromium (VI) (P)	1,100	50
Copper (P)	4.8	3.1
Cyanide (P)	1	1
Lead (P)	210	8.1
Mercury (P)	1.8	0.94
Nickel (P)	74	8.2
pH	—	6.5 – 8.5
Selenium (P)	290	71
Silver (P)	1.9	—
Sulphide-Hydrogen Sulphide	—	2
Zinc (P)	90	81
1/ CMC: Criterion Maximum Concentration
2/ CCC: Criterion Continuous Concentration

Table 14: Nova Scotia EQSs for Surface Water and Groundwater Discharging to Surface Water. Information amalgamated from ^{186, 187}.

Parameter	Surface Water (<10m from surface water body)[µg/L]		Groundwater (>10m from surface water body)[µg/L]
	FW	Marine	FW	Marine
Aluminium	5		50	–
Antimony	9	250	90	2500
Arsenic	5	12.5	50	125
Barium	1000	500	10,000	5000
Beryllium	0.15	100	1.5	1000
Boron	1500	1200	15,000	12,000
Cadmium	0.09	0.12	0.9	1.2
Chromium(hexavalent)	1	1.5	10	15
Chromium(total)	8.9	56	89	560
Cobalt	1	4	10	40
Copper	2	2	20	20
Cyanide	5	1	50	10
Iron	300	–	3000	–
Lead	1	2	10	20
Manganese	430	–	4300	–
Mercury(total)	0.026	0.016	0.26	0.16
Methylmercury	0.004	0.004	0.04	0.04
Molybdenum	73	1000	730	10,000
Nickel	25	8.3	250	83
Selenium	1	2	10	20
Silver	0.25	1.5	2.5	15
Strontium	21,000	2008	210,000	–
Thallium	0.8	0.3	8	3
Tin	–	–	–	–
Uranium	15	8.5	150	85
Vanadium	120	5	1200	50
Zinc	7	10	70	100
pH	6.5 to 9	7 to 8.7	–	–

Figure 7: USA’s Marine Protection, Research, and Sanctuaries Act (MPRSA – 40 CFR Part 222) permitting process to meet the USA’s obligations under the London Convention

Figure 8: Major steps for the U.S. EPA to develop and issue permits under the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES)

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