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

Updating the Weather Modification Reporting Act of 1972 to include Solar Radiation Management!

Oct 21, 2024

UPDATE: My public comment has been posted:

Comment from Lee Jr., James
Posted by the National Oceanic and Atmospheric Administration on Nov 13, 2024 https://www.regulations.gov/comment/NOAA-OAR-2024-0091-0075 • PDF MIRROR

VIDEO UPDATE: My wife was diagnosed with Basal Cell Carcinoma, and after a follow-up doctor’s visit: we have great news: Kelly is cancer free. Thank you all for your prayers, messages, and suggestions!

TLDR: Comments due November 19, 2024

Be sure to add: “Comments on NOAA’s Petition for Rulemaking on Weather Modification Reporting Docket Number: NOAA-OAR-2024-0091” to your submission here:

https://www.regulations.gov/document/NOAA-OAR-2024-0091-0002

Background and Guidelines, Federal Register:

National Oceanic and Atmospheric Administration - 15 CFR Part 908 - Notice of Receipt and Request for Public Comment on Petition for Rulemaking Regarding Maintaining Records and Submitting Reports on Weather Modification Activities

Request for Information:
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
how NOAA should update 15 CFR part 908 reporting requirements to account for solar radiation modification experiments,
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,
the spatial scale of weather modification experiments and their intended effects for which NOAA should request in submitted reports, and
whether, under existing statutory authorities, NOAA should pursue a broader regulatory strategy for solar radiation modification research and experimentation.
NOAA will consider public comments received in determining whether to proceed with the petition’s requested revisions. Upon determining whether to initiate the requested rulemaking, NOAA will publish in the Federal Register the Agency’s notice of proposed rulemaking with a request for public comment.

My Suggested Responses to these points:

Solar Radiation Management (SRM) Stratospheric aerosol injection (SAI), marine cloud brightening (MCB), and cirrus cloud thinning (CCT), field experiments should not be allowed Weather Modification Reporting Act of 1972, due to their controversial nature, danger to human health, and unknown implications of geoengineering field experiments.
Due to the nature of geoengineering chemical processes in the atmosphere, the area of impact is unknown and the ability to detect manufactured changes in albedo are undetectable with current state of the art atmospheric sensors. More Info.
Solar Geoengineering SAI, MCB, and CCT field experiments should be banned based on the concerns of trans-national effects from these experiments, it is my belief that there is no scale small enough that may not lead to international conflict over experimentation by “private Solar Radiation Modification (SRM) activities.” Allowing for-profit companies or individuals to legally experiment with temperature altering solar geoengineering is a slippery slope that should not be allowed under this petition.
NOAA should pursue a permanent ban on “private, institutional, and federal Solar Radiation Modification (SRM) activities” as this is not a “local weather modification” issue. SRM by definition would be a violation of Environmental Modification Convention (ENMOD) Treaty: “Each State Party to this Convention undertakes not to engage in military or any other hostile use of environmental modification techniques having widespread, long-lasting or severe effects as the means of destruction, damage or injury to any other State Party.” We can say with certainty that stratospheric aerosol injection is long lasting, will change rainfall patterns worldwide, and international governance of geoengineering is currently stalled at the United Nations Environmental Assembly (UNEA) due to concerns from the international community.

Original Petition, March 2024:

PETITION FOR RULEMAKING TO AMEND THE NATIONAL OCEANOGRAPHIC AND ATMOSPHERIC ADMINISTRATION’S REPORTING REGULATIONS UNDER THE WEATHER MODIFICATION REPORTING ACT

Reasons to Oppose Geoengineering:

Solar Radiation Management: 3 good reasons versus 27 bad reasons
Robock, Alan. "Stratospheric Sulfur Geoengineering - Benefits and Risks." 21st Conference on Planned and Inadvertent Weather Modification, American Meteorological Society 98th Annual Meeting (2018).

Surprise, Kevin, and J. P. Sapinski. "Economic interests and ideologies behind solar geoengineering research in the United States." Solar Geoengineering Non-Use Agreement (2022).
Necheles, Ella, Lizzie Burns, Amy Chang, and David Keith. "Funding for Solar Geoengineering from 2008-2018." Harvard’s Solar Geoengineering Research Program (2018). • DOWNLOAD PDF

Stilgoe, Jack. “Experiment Earth: Responsible innovation in geoengineering.” Routledge, 2015. (pg 162) https://doi.org/10.4324/9781315849195 • DOWNLOAD PDF

The Rest of the Story (How we got here)

I bookmarked a story about David Bookbinder back in March because he was the reason I testified at an EPA Hearing on jet pollution (an attempt to regulate green house gases under the Clean Air Act) and I knew this article would lead to something major. He proposed updating the Weather Modification Reporting Act of 1972 to include Geoengineering Solar Radiation Management (SRM), or sunlight blocking Stratospheric Aerosol Injection (SAI) and Marine Cloud Brightening (MCB) due to private entities like Make Sunsets getting involved in climate engineering FOR PROFIT.

Click here to view current weather modification reports from the official NOAA website (bottom of the page).

NOAA gets dire warning about solar geoengineering

https://www.eenews.net/articles/noaa-gets-dire-warning-about-solar-geoengineering/

Bookbinder is agnostic on whether geoengineering technologies should be deployed, he said, but he’s worried it could be done without proper oversight and that the United States and international governments aren’t prepared to keep it in check.
It’s been on his mind for a few years, Bookbinder said, since he started wondering about “the next big problem that we’re not thinking about yet.”
“I said, ‘Holy shit, it’s not the climate change.’ We know what that is. We know how it’s proceeding,” Bookbinder said. “It’s going to be the solutions that people start offering up.”

The article from E&E News discusses how NOAA (National Oceanic and Atmospheric Administration) has received what's described as a "dire warning" regarding solar geoengineering, particularly focusing on the practice of solar radiation modification (SRM). Here's a summary based on the context provided:

Regulation and Reporting: Currently, there's a minimal regulatory framework in place for weather modification activities, including solar geoengineering. A U.S. law from the 1970s requires only a simple notification to the Commerce Department (under which NOAA operates) ten days before any such activity. This regulation is considered weak, essentially a "toothless rule" that does not adequately cover the scope and potential impact of geoengineering efforts like SRM.
Petition for Stronger Oversight: There has been a push, as of early 2024, for NOAA to strengthen these regulations. Advocates for change, including academics and environmental law experts, argue that the current system fails to require all necessary information to assess the risks of geoengineering. This comes in light of potential large-scale implementation of technologies like stratospheric aerosol injection (SAI), which could have significant global effects.
Potential Risks and termination shock: The discussion around SRM includes concerns about "termination shock," a scenario where if SRM were to be suddenly stopped, it could lead to rapid warming with potentially catastrophic effects. This underscores the long-term commitment and risks associated with starting such geoengineering projects.
Research and Political Context: NOAA has been funded to research these "Plan B" options for climate intervention due to the failure of reducing greenhouse gas emissions sufficiently. However, the Biden administration has clarified that its focus remains on reducing emissions rather than endorsing geoengineering as a solution.
Public and Scientific Concern: The sentiment on social media indicates a mix of skepticism, environmental concern, and criticism over the practicality and safety of deploying solar panels in hurricane-prone areas, which could be seen as tangentially related to the broader discussion on geoengineering and its unintended consequences.

The Problem

By including solar radiation management in the reporting requirements of public law 92-205, NOAA and the Department of Commerce are effectively “legalizing” private companies and entities to conduct geoengineering field trials and deployment.

The Weather Modification Reporting Act of 1972 needs to be updated, but not in this way. At a minimum, the law should require the standard forms to be submitted, however with modern technology there should be REAL-TIME reporting of every single chemical or electrical intervention in natural weather systems.

Though I agree with Bookbinder that the law is outdated and needs an overhaul, allowing solar radiation management to simply be reported is not a solution, it’s permission.

I will expand on this subject with my own petition to overhaul this law in the future.

For now, oppose geoengineering for all the reasons listed at the top of this article and make your voice heard!