NOAA request for comments on potential solar radiation modification research regulation (deadline Nov. 19, 2024)

[Hester, Tracy]

We wanted to alert everyone about NOAA’s recent request for comments on federal reporting requirements for solar radiation modification research and field experiments.  NOAA published its request in the Sept. 20, 2024 Federal Register, which we’ve attached.

 

NOAA’s request arises from a rulemaking petition that the University of Houston Law Center, the Institute for Responsible Carbon Management, and several individual scholars filed in March 2024 to clarify reporting requirements for private solar radiation modification activities.  But please do not limit your comments to the scope of our underlying petition.  NOAA’s request throws a considerably broader net – in particular, item (4) opens the door to a broad range of feedback and suggestions (bolded below):

 

NOAA solicits public comment on the petition for rulemaking to amend NOAA’s reporting regulations under the Weather Modification Reporting Act.  NOAA is particularly interested in (1) how NOAA should update 15 CFR part 908 reporting requirements to account for solar radiation modification experiments, (2) what reporting requirements NOAA should include regarding potential and/or measured environmental impacts of weather modification experiments given the state of the science and current detection capabilities, (3) the spatial scale of weather modification experiments and their intended effects for which NOAA should request in submitted reports, and (4) whether, under existing statutory authorities, NOAA should pursue a broader regulatory strategy for solar radiation modification research and experimentation.

 

Comments are due by November 19, 2024.  If you would like to coordinate your comments with us or other groups, or you simply want to join comments filed by another party, please let either of us know and we’ll help if we can.

 

Thanks,

 

Tracy Hester

Co-Director Environment, Energy & Natural Resources Center

UNIVERSITY of HOUSTON | LAW CENTER

 

David Bookbinder

Director of Law and Policy

Environmental Integrity Project

 

[Hester, Tracy]

Just a brief reminder:  if anyone wants to comment on NOAA’s proposal for solar radiation management reporting regulations, the deadline to submit them is two weeks away (November 19, 2024).

 

Yesterday’s election, of course, throws some uncertainty into NOAA’s effort (as well unsettling the future of NOAA itself).  But please comment nonetheless if you have an interest in the potential rules.

 

Best,

 

 

Professor Tracy Hester

University of Houston Law Center

4170 Martin Luther King Blvd, Room 341K

Houston, Texas     77204

713-743-1152 (office)

tdhe...@central.uh.edu 

web bio:  www.law.uh.edu/faculty/cv/Hester-Bio.pdf? 

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[Andrew Song]

While I understand regulations are important and we fully intend to comply with future requirements as we currently do. You know you can just ask us what data and changes you want to see and we'll take them into consideration.

We currently share out deployments on X (https://x.com/MakeSunsets) or YouTube (https://youtube.com/@makesunsets) with SO2 payload amount and altitude of deployment. Current deployment location is Northern California, I'm being vague here because actually release of the aerosol in the stratosphere varies due to delivery method (weather balloons) and wind. We also share historical deployments amounts on our website: https://makesunsets.com/pages/who

Also, if you really want to dig into our progress we share cash on hand, sales figures, cash burn, company runway, wins/losses, and what we're working on next month every month since inception of starting MS on October 2022 in our email newsletter and blog: https://makesunsets.com/blogs/news

Cool regards,

Andrew

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[James Lee]

 Public opposition to geoengineering voiced during NOAA comment period:

NOAA Legalizing Private Geoengineering: Public Comments Due Nov. 19th!

https://climateviewer.substack.com/p/noaa-legalizing-private-geoengineering

My comment: https://www.regulations.gov/comment/NOAA-OAR-2024-0091-0075

Join ICAN in Demanding a Ban on Geoengineering:

https://icandecide.org/press-release/join-ican-in-demanding-a-ban-on-geoengineering/
This week, ICAN, through its attorneys, submitted a powerful public comment to the National Oceanic and Atmospheric Administration (NOAA) taking a strong stand against weather modification and geoengineering. ICAN calls for NOAA, absent a ban on geoengineering, to implement a policy that discourages research, field experiments, and deployment of any weather modification or climate intervention technologies without the informed consent of the American people. Submit your own comment by November 19.

ICAN Comment: https://icandecide.org/wp-content/uploads/2024/11/NOAA-OAR-2024-0091-0099_attachment_1.pdf

Friends of the Earth: Tell NOAA to require reporting of ALL weather modification activities!

https://action.foe.org/page/75758/action/1

James F. Lee Jr.

ClimateViewer News, LLC

https://connect.climateviewer.com/

https://weathermodificationhistory.com/

+1.803.450.4305

[Claudia Wieners]

Dear James Lee, 

I strongly disagree with what Make Sunset are doing.

However, there is a huge difference between, say, small-scale non-commercial scientific outdoor experiments with proper risk assessment, and reckless startups like Make Sunsets who claim to actually implement SRM (even though they are most likely way to small to have an actual climate impact). 

Therefore, using Make Sunsets to call for a ban on all, even small-scale, outdoor experimentation, or even SRM research more generally, lacks nuance in my view. It is also impractical - does "research" include modelling studies? Does it include observations or modelling studies on, for example, climate impacts of explosive volcanic eruptions, because this information could be used also for SAI? 

It is good to have a debate on which SRM research should be permitted, fostered, discouraged, or forbidden. Probably most SRM researchers would agree with a moratorium (potentially temporary) on SRM deployment and large-scale outdoor experiments that are big enough to have a significant climate impact, or something like an updated and expanded "London Protocol" for SRM. 

But a blanket ban on all "SRM research" may be counterproductive, first, because even under ambitious mitigation, it may well be that SRM ends up being the one thing between us and major climate tipping, and second, because an absence of "legitimate, international collaborative research leaves the field to dubious actors, let's say (oil) companies who want to pose as saviours of the world and postpone meaningful mitigation. Fostering critical interdisciplinary research may help to counter overly optimistic claims by parties with conflict of interest, and third, because it can help prevent disastrous panic actions. Note that the idea of using Ocean Iron Fertilisation for extracting CO2 from the atmosphere is now off the table because research showed that OIF may not work. Research on SRM might likewise help to eliminate flawed methods. 

We have argued the case in more detail two years ago, but I believe the arguments are still valid: https://www.call-for-balance.com/letter 

Kind regards

Claudia Wieners

Op ma 18 nov 2024 om 19:06 schreef James Lee <j...@climateviewer.com>:

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