Summary/Abstract
This paper argues against attempting to commercialize OIF under any emerging market framework. Current standards for globally recognized compliance offset markets require that a recognized activity is permanent, additional, free of leakage, and absent of adverse side effects. At present, there is not adequate scientific evidence that OIF is any. Worse, measurement challenges, unreliable auditing, ambiguous baselines compromised by high-frequency variability, and uncertain externalities could combine to cripple a market-based approach. Fortunately, the UN London Protocol has banned non-scientific iron fertilization, precluding the adoption of OIF into any international, compliance offset markets. However, voluntary offset markets, or those in which offsets are bought and sold without any federally mandated obligation, are not subject to any legitimate regulatory or enforcement mechanisms. The paper makes that case that absent the appropriate oversight OIF activity on voluntary offset markets motivated by a reasonable market opportunity, the relative ease of deployment, and the perception of an ethical imperative, can, and will continue to, emerge. In turn, continued research is necessary to help constrain the public perception that voluntary markets depend on by further clarifying the risks, elaborating the challenges, and delegitimizing the promise of an iron bullet.