It’s a matter of justice – Submission to the Nuffield Council on Bioethics
This submission was sent in response to the call for evidence by the Nuffield Council on Bioethics to assist in their ethical exploration of Solar Radiation Modification.
Introduction
Interest in Solar Radiation Modification (SRM) has accelerated in recent years, driven by growing concern that emissions reductions alone may be insufficient to prevent the most severe climate impacts.[1] The current debate, however, struggles to build on the awareness that has matured in the climate community in recent years: climate change is not only a matter of science, but also a matter of justice.[2]
The current polarised debate operates with critical blind spots: the interests of future generations, non-human species, and the environment are treated as peripheral considerations rather than key elements to take into account. This is not a niche concern. The absence of these perspectives means decision-makers lack the analytical tools to assess long-horizon trade-offs. Given deep uncertainty about SRM’s effects, a comprehensive understanding of risks and opportunities (across time, species, and ecosystems) is a prerequisite for responsible decision-making, not a supplement to it.[3]
Without a structural shift, the SRM debate will default to a human-centric, short-term risk-risk trade-off that may foreclose the well-being of future generations and the survival of ecosystems.
Throughout this submission, ‘future generations’ refers to people born in the future, not to young people alive today. While youth participation in governance is valuable and necessary, young people have their own present interests and needs. Conflating them with those born in the future narrows the intergenerational frame and creates a representational gap that dedicated institutional mechanisms must fill.
This submission focuses on questions 1, 2, 3, 4, and 7 of the call for evidence, drawing on the work of the Center for Future Generations (CFG) and the Jesuit European Social Centre (JESC) on intergenerational fairness, strategic foresight, ecology, and SRM.
Current challenges
Political short-terminism
Political systems are structurally geared toward the urgent. Short electoral cycles make it genuinely difficult to act in the interest of people who do not yet exist, even though the Paris Agreement noted intergenerational equity as a core pillar[4]. SRM involves technologies with deep-time consequences, yet, political systems are not geared toward integrating long-term, forward-looking perspectives into policymaking.
Knowledge gaps and the cost of action vs inaction
Policy-making tends to focus on the costs of action. It rarely considers the equally fundamental costs of inaction – particularly relevant for future generations, the environment, and non-human species.
Such a cost is not only economic, but also social and democratic. Current debates on SRM often focus on the risks of deployment, forsaking the risk of not researching it, a gap that could leave future generations without critical knowledge or tools in an overshoot scenario[5]. The risk-risk framework that is usually used in the SRM debate would also benefit from integrating these perspectives, enabling better-informed decisions in conditions of high uncertainty[6].
Failure to act now risks leaving future generations, and the ecosystems in which they are, without the knowledge they need to make informed choices about their own survival, fundamental rights, and well-being[7].
The Anthropocentric Trap
Most policy and law-making remain anthropocentric in practice. Human exceptionalism and a utilitarian understanding of nature predominate[8]. Thus, nature is treated as a backdrop to human activity, an object, rather than a subject with standing of its own.
The recent push to establish a new crime of ecocide illustrates this tension.[9] While an ecocentric framing is essential in this case, it is structurally difficult to incorporate within legal systems built on human-centred foundations.
Given that SRM as a technology has the potential to impact not only humans but also nature and ecosystems, a merely human-centric perspective is risky and incomplete.[10]
The false growth vs nature trade-off
The prevailing human-centric framing is particularly counterproductive when it positions economic growth and environmental protection as opposing forces.
Once that either-or framing takes hold, trade-offs against nature become structurally easy to justify. Economic growth is often invoked as necessary for the prosperity of future generations. However, a development model that depletes the natural systems it depends on ultimately undermines that very goal it claims to serve.
Addressing this requires moving beyond damage-limitation. Some frameworks propose recognising nature as a subject of rights, emphasising that humans hold a specific responsibility for the flourishing of life rather than the pursuit of progress alone. Incorporating non-human interests into governance, however, demands more than a legal adjustment. It requires a shift in how we perceive the relationship between human activity and the natural world, thus shifting the human role from progress pursuer to steward of (all) life.
Unclear definitions about future generations
A further challenge is the conceptual confusion around the term itself. The term “future generations” is often used to mean young people alive today. This narrows the frame, making it harder to think beyond existing generations and leaving a significant gap in incorporating the rights and well-being of generations not yet alive.[11]
Proposed solutions toward integrating future generations and nature into SRM discussions
To address the unique challenges of SRM, we propose a 4-pillar approach. The pillars are sequential as well as complementary: without the first (foresight), the second (representation) lacks legitimacy; without the third (ecological shift), the fourth (operational reform) lacks evidence.
Pillar 1 – Temporal Governance: Foresight, Scenarios and Time Horizons
Foresight and Scenario Planning
Anticipatory governance and strategic foresight offer practical frameworks to feed and inform decisions on emerging technologies’ long-term impacts.
Scenario planning can make the needs of future generations and non-human systems legible within policy deliberation: not as abstract ethical obligations but as concrete variables shaping how different futures unfold. It creates space to ask: under what conditions do ecosystems recover or collapse? Which futures protect biodiversity? Who bears the costs? These questions surface trade-offs that conventional cost-benefit analysis tends to obscure or defer.
Anticipatory governance builds on this by embedding foresight into institutional processes early enough to shape decisions before technological trajectories lock in. This enables deliberation while decisions can still be shaped.
For example, the Centre for Future Generations SAFEGEOGOV project applies this logic directly to solar radiation modification governance[12]. It develops scenarios set in 2035, stress-tested against social, geopolitical, and ecological dimensions, building an evidence base that allows policymakers to consider long-range impacts under a range of plausible futures.
Layered Time Horizons
The 10–15 year horizon that tends to be used in foresight practice has real merit. It is long enough to explore structural shifts and transformative change beyond the current policy cycle, while remaining actionable for decision-makers. However, for present and future generations, this window is not enough.
Layered time horizons may offer a more adequate approach. Near-term frames anchor decisions in practical relevance while longer views force consideration of intergenerational consequences. The two are not in competition: the short term informs the long, and the long disciplines the short.
Canada’s Horizons Foresight Method, one of the leading government foresight frameworks, explicitly frames its approach around a 10–15 year horizon, on the basis that this window identifies real issues that current policies and institutions are not ready to address, while giving government sufficient time to prepare for disruptive changes.[13]
Adaptive perspectives
The resilience science framework, as understood by the Stockholm Resilience Centre, and its core management framework, “adaptive (co-)management”[14] provides a framework for managing functional biodiversity and thresholds of change across different timescales and under conditions of high uncertainties.
Nature and ecosystems continually change. Adaptive (co-)management addresses this directly. Rather than seeking a fixed optimal outcome, it institutionalises iterative decision-making: setting thresholds of acceptable change, monitoring against them, and adjusting course when those thresholds are approached or crossed. It is a design principle: governance built for reversibility and adaptation.
Recommendations
- Embed foresight and scenario planning into SRM governance processes. Decision-making on SRM must be stress-tested against a range of plausible futures, covering both the risks of deployment and the risks of failing to research it, to ensure future generations retain meaningful options.
- Adopt layered time horizons in policy and impact assessment. Near-term policy cycles (10–15 years) should be paired with longer-horizon assessments that make the needs of future generations and ecosystems legible as concrete policy variables, not abstract obligations.
Pillar 2 – Representing the Unrepresented
Structural representation for future generations
A key question is not only what decisions are made, but on whose behalf, and by whom. Youth forums and youth participation mechanisms are valuable, but young people and generations born in the future have distinct interests and needs. Conflating these two groups together is both conceptually imprecise and unfair to young people themselves.
Future generations need dedicated structural representation: through commissioners, ombudspersons, or other institutional mechanisms (e.g., citizens’ assemblies) designed to properly represent their interests.
The Wellbeing of Future Generations (Wales) Act 2015 offers the most developed real-world model: it places a statutory obligation on public bodies to act in the interests of future generations, supported by a Future Generations Commissioner with investigative and advisory powers.[15]
Addressing the impact, consequences and possible governance framework of SRM in the right venues would ensure future generations’ interests are represented on this upcoming and inevitable topic.
Advancements to represent non-human interests
The advisory opinion of the International Court of Justice of 23 July 2025 marked a significant step forward toward a more ecological perspective. The Court identified intergenerational equity as a guiding norm for interpreting the UN Charter and environmental treaties (paras. 155–157)[16]. This can be used as an example to pave the way to more inclusive frameworks in this direction.
At the domestic level, examples like the constitutional rights of nature in Ecuador or the legal personhood of the Mar Menor lagoon in Spain shift nature from a legal “object” to a “subject of rights”, a key actor to be considered in decision-making. Emerging technologies are also opening genuinely new possibilities for representing non-human interests.
For instance, researchers are currently using AI to decode sperm whale communication – early work that may ultimately support legal personhood claims and stronger protections for non-human species.[17] This is an active area of legal and scientific inquiry and also a practical example linked to broader ethical questions mirroring those we are trying to address in this response.
Shared definitions and participatory governance
Developing a clear, shared definition of intergenerational equity would eliminate the semantic friction that currently prevents substantive policy progress.
Recentering future generations and nature as fundamentally democratic questions, about whose interests count, allows for a broader political deliberation beyond traditional silos.
Recommendations
- Establish dedicated structural representations for future generations and non-human species.
Youth participation mechanisms cannot adequately represent generations born in the future. Dedicated institutions (commissioners, ombudspersons, or mandated citizens’ assemblies) are needed to represent those not yet born in SRM governance. This should also apply to non-human species.
Pillar 3 – An ecological shift: from anthropocentric to ecocentric governance
Ecosystems as a general approach
SRM could affect rainfall patterns, ocean currents, and sunlight distribution at planetary scale, for decades. At the same time, climate change will fundamentally destabilise ecosystems, with potentially cascading and irreversible consequences especially once tipping points are crossed.[18] These changes would affect not only humans but entire living systems – forests, oceans, soils, and the countless species within them. Yet current debates about SRM treat nature largely as a side effect, not as a subject in its own right.
Under the UN Convention on Biological Diversity, governments have made two recommendations: 1. to abstain from deploying risky interventions (sometimes referred to as a de-facto moratorium) and 2. To pursue more transdisciplinary research that studies the implications of SRM (and CO2-removal methods) “to better understand the impacts of climate-related geoengineering on biodiversity and ecosystem functions and services, socio-economic, cultural and ethical issues and regulatory options.” Neither of the two recommendations has yet been fully operationalised.[19]
An ecological perspective offers a way to fill this gap, and to overcome many of the obstacles outlined above. It means treating the environment as a living entity with its own needs and rights, not merely as a resource whose value is defined by its relationship to humans.[20] Rather than asking only “what does this mean for people?”, it asks “what does this mean for the living systems we are part of?”
In practice, this means evaluating SRM through the lens of ecosystems and habitats (oceans, forests, watersheds) as whole, functioning systems with their own integrity. This framing also sidesteps one of the hardest legal and political obstacles: the difficulty of defining rights for each individual species or entity. Protecting an ecosystem as a whole delivers for everything within it, without requiring that every subject be named and defined. Existing legal tools (e.g., biodiversity treaties, water protection laws, soil frameworks) already point in this direction, providing a ready foundation to bring nature into the SRM debate not as a resource to be protected for human benefit, but as a living world with its own stake in the outcome.
From growth to stewardship
The dominant logic in technology development – optimising for speed, scale, and shareholder value is part of the same paradigm that positions growth and nature as opposing forces. As long as SRM is evaluated purely through this lens, short-term trade-offs against ecosystems and future generations will always seem justified.
Thinkers like Roman Krznaric argue that what we need instead is the orientation of a “good ancestor”: asking not just what a technology enables today, but what kind of future it makes possible or forecloses-[21] Paired with the framework of doughnut economics – which asks us to meet the needs of current and future generations within the means of the planet’s life-supporting systems – this offers a different design brief for technology governance altogether.[22] The question stops being purely about risk and safety, and becomes one about intergenerational responsibility.
Recommendations
- Treating the Environment as a Living Entity with Its Own Rights.
Governance frameworks should treat the environment as a living entity with its own needs, drawing on existing legal innovations — including rights of nature, the ICJ’s July 2025 advisory opinion, and the principle of intergenerational equity — as practical foundations.
Pillar 4 – Making inclusive governance operational
Mandatory, double-sided and long-term impact assessments
The EU’s Better Regulation Framework, as advocated by JESC, offers a concrete and transferable model to include mandatory impact assessments for future generations.[23] This approach is transferable beyond the EU and could inform how a governance framework on SRM could be conceptualized based on a transparent model.
Double-Sided Assessment
The European Commission’s Chief Scientific Advisors’ recommendation pointed out that future decision-makers should be equipped with the knowledge to assess the risks and potential benefits of SRM comprehensively.[24] Impact assessment frameworks should reflect this: weighing not only the costs of action, but equally the costs of inaction.
Multi-scenario discourse in politics and policy-making
Seeing the multifaceted aspects of SRM, decision-making on SRM increasingly requires a multi-scenario approach. Risks exist in the climate system, in the technology itself, and in its governance. No single political actor can choose or enforce a preferred outcome. Responses must therefore be stress-tested against a range of plausible scenarios, covering both action and inaction.
Awareness-raising and capacity building
Awareness-raising is a first and necessary step: the discourse around future generations has yet to enter the mainstream of policy thinking, and decision-makers need more literacy in this area – not as a fringe concern, but as a legitimate and pressing dimension of democratic governance.
The same applies to nature and non-human species. Despite significant legal innovations – such as the constitutional rights of nature in Ecuador and the legal personhood of Spain’s Mar Menor lagoon – these developments have yet to meaningfully inform broader policymaking. These are serious legal and governance innovations that deserve attention as practical models for more inclusive, comprehensive and effective policy-making.
The European Commission’s first Strategy on Intergenerational Fairness, just released on 5 March 2026, is a first attempt to address this knowledge gap.[25] Furthermore, it demonstrates that embedding long-term thinking into governance is both feasible and politically actionable at the highest institutional level. While the Strategy focuses primarily on current young people rather than those born in the future, its institutional model provides a practical template that the SRM debate could adapt and extend.
Recommendations
- Require mandatory, double-sided impact assessments for SRM research and governance. Existing frameworks, such as the EU’s Better Regulation Toolbox, should be adapted to assess both the costs of action and the costs of inaction, explicitly accounting for impacts on future generations, non-human species, and the environment
- Build decision-maker literacy on intergenerational and ecocentric governance. Awareness-raising and capacity building are a necessary precondition for all other recommendations. Policymakers need substantive exposure to these topics and innovations to assess trade-offs related to SRM responsibly and comprehensively (e.g., legal personhood for nature, intergenerational commissioners, resilience-based management).
Conclusion: a call to responsibility for future generations, the environment and non-human species
Ethical considerations must evolve from peripheral discussions into central pillars of decision-making. Although ethical questions and principles may apply differently to the various technologies, it is paramount that all discussion and decision-making take them into account, with specific considerations related to future generations, the environment, and non-human species.
We cannot eliminate the risks inherent to SRM, but we can reduce them by addressing the knowledge gaps that may leave future generations and non-human species vulnerable. Recentering these items as fundamentally democratic questions – about who gets a voice, whose interests count, and over what timeframe – opens up a broader conversation and a broader coalition for more aware, stronger, and more effective policy-making.
Policymakers must move toward an ecological understanding of policy-making where the environment is treated as a living entity with its own needs. This requires a shift from “command-and-control” legal paradigms to adaptive, intergenerational governance that prioritizes the flourishing of all life, both present and future.
The discussions on SRM currently lack a space that adequately accounts for those who cannot speak for themselves yet. The decisions made now will determine whether future generations inherit options or foreclosures.
[1] For example, opinions from the European Commission’s Chief Scientific Advisors, the European Group on Ethics, and the UN Secretary-General’s Scientific Advisory Board.
[2] Lazard, O., Bissett, M. and Dyke, J. (2025). Geoengineering: Assessing Risks in the Era of Planetary Security. Carnegie Endowment for International Peace.
[3] European Commission Group of Chief Scientific Advisors & European Group on Ethics in Science and New Technologies. (2024). Solar Radiation Modification, Scientific Opinion No. 17. Scientific Advice Mechanism.
[5] Kabbej, S. (2026). How SRM Intersects with Geopolitics and Security. DSG Fellow, Alliance for Just Deliberation on Solar Geoengineering.
[6] McLaren, D.P. (2025). Reconstructing Risk–Risk Analysis to Support Effective Governance of High-Risk Climate Interventions. European Journal of Risk Regulation. Cambridge University Press.
[7] Science Advice for Policy by European Academies. (2024, December). Solar Radiation Modification: Evidence Review Report. Scientific Advice Mechanism.
[8] Boyd, David R., The Rights of Nature: A Legal Revolution That Could Save the World. ECW Press.
[9] Killean, R. & Newton, E. (2025). From ecocide to ecocentrism: Conceptualising environmental victimhood at the ICC. Punishment & Society.
[10] UNESCO World Commission on the Ethics of Scientific Knowledge and Technology. (2023). Report of the World Commission on the Ethics of Scientific Knowledge and Technology (COMEST) on the Ethics of Climate Engineering. UNESCO.
[11] Botto et al. (2023). Solar Radiation Modification and youth perspectives on its governance, UN SDG submission.
[12] Centre for Future Generations. 2025. https://cfg.eu/introducing-safegeogov/
[13] Policy Horizons Canada. Introduction to Foresight. Government of Canada.
[14] Walker, B. and Salt, D. (2006). Resilience Thinking: Sustaining Ecosystems and People in a Changing World. Island Press.
[15] Welsh Government. (2015). Well-being of Future Generations (Wales) Act 2015.
[16] International Court of Justice (2025). Obligations of States in Respect of Climate Change, Advisory Opinion, ICJ Case No. 187, paras. 155–157.
[17] Keim, B. (2025, April 24). Whales could one day be heard in court – and in their own words. National Geographic.
[18] Lenton, T.M. et al. (2023). Global Tipping Points Report. University of Exeter.
[19]Convention on Biological Diversity. (2016, December 9). Climate-Related Geoengineering, Decision XIII/14, para. 5.
[20] Pelizzon, A. (2025). Ecological Jurisprudence: The Law of Nature and the Nature of Law. Springer Nature.
[21] Krznaric, R. (2020). The Good Ancestor: How to Think Long Term in a Short-Term World. W.H. Allen.
[22] Raworth, K. (2017). Doughnut Economics: Seven Ways to Think Like a 21st-Century Economist. Chelsea Green Publishing.
[23] Jesuit European Social Centre. (2024). jesc.eu/wp-content/uploads/2024/06/Conference-Booklet.pdf
[24] European Commission Group of Chief Scientific Advisors. (2024). Solar Radiation Modification. European Commission.
[25] European Commission.(2026). Strategy on Intergenerational Fairness.


