Can YOU stop SRM? Viviani & Galpern

Donn Viviani & Dan Galpern look at how individual petitioners could put an end to US firms' deployment of SRM. Background info provided by guests: Current petition and lawsuit available at cprclimate.org In my 2015 petition I explicitly asked for a section 4 rule to develop data, if EPA lacked the information to make a risk finding. It could serve as a template for a geoengineering information request https://www.epa.gov/sites/default/files/2015-09/documents/petition_oa_tsca_2014_final_2.pdf the denial is here https://www.regulations.gov/document/EPA-HQ-OPPT-2015-0487-0001 Under the Administrative Procedure Act, any person may petition for the issuance, amendment, or repeal of a rule (5 U.S.C. 553(e)). The petition will be addressed to the Secretary of the Interior, U.S. Department of the Interior, Washington, DC 20240. see https://www.ecfr.gov/current/title-43/subtitle-A/part-14 NEPA National Environmental Policy Act: Each Agency has it's out set of NEPA guidelines and policies Here is a good overview from an ngo https://www.epa.gov/sites/default/files/2015-09/documents/petition_oa_tsca_2014_final_2.pdf EPAs NEPA guide is here https://www.epa.gov/nepa/national-environmental-policy-act-policies-and-guidance When does NEPA apply to obligate a private actor to undertake environmental analysis? The US Council on Environmental Quality published a nice little Citizen's Guide to the National Environmental Policy Act (NEPA) in 2007 and on p. 4 it noted, among other things, that: "[]Congress recognized that the Federal Government’s actions may cause significant environmental effects. The range of actions that cause significant environmental effects is broad and includes issuing regulations, providing permits for private actions, funding private actions, making federal land management decisions, constructing publicly-owned facilities, and many other types of actions. Using the NEPA process, agencies are required to determine if their proposed actions have significant environmental effects and to consider the environmental and related social and economic effects of their proposed actions. "NEPA’s procedural requirements apply to a Federal agency’s decisions for actions, including financing, assisting, conducting, or approving projects or programs; agency rules, regulations, plans, policies, or procedures; and legislative proposals.7 "NEPA applies when a Federal agency has discretion to choose among one or more alternative means of accomplishing a particular goal.8 Frequently, private individuals or companies will become involved in the NEPA process when they need a permit issued by a Federal agency. When a company applies for a permit (for example, for crossing federal lands or impacting waters of the United States) the agency that is being asked to issue the permit must evaluate the environmental effects of the permit decision under NEPA. Federal agencies might require the private company or developer to pay for the preparation of analyses, but the agency remains responsible for the scope and accuracy of the analysis."