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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\n\nIn 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\n\nthe denial is here https://www.regulations.gov/document/EPA-HQ-OPPT-2015-0487-0001\n \nUnder 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\n\nNEPA 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\n\nEPAs 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?\n\nThe US Council on Environmental Quality published a nice little Citizen's Guide to the National Environmental Policy Act (NEPA) in 2007 and \non p. 4 it noted, among other things, that:\n\n"[]Congress recognized that the Federal Government\u2019s actions\nmay cause significant environmental effects. The range of actions that\ncause significant environmental effects is broad and includes issuing\nregulations, providing permits for private actions, funding private\nactions, making federal land management decisions, constructing\npublicly-owned facilities, and many other types of actions. Using the\nNEPA process, agencies are required to determine if their proposed\nactions have significant environmental effects and to consider the\nenvironmental and related social and economic effects of their\nproposed actions.\n\n"NEPA\u2019s procedural requirements apply to a Federal agency\u2019s\ndecisions for actions, including financing, assisting, conducting, or\napproving projects or programs; agency rules, regulations, plans,\npolicies, or procedures; and legislative proposals.7\n\n"NEPA applies when a Federal agency has discretion to choose among one or more\nalternative means of accomplishing a particular goal.8\nFrequently, private individuals or companies will become involved\nin the NEPA process when they need a permit issued by a Federal\nagency. When a company applies for a permit (for example, for\ncrossing federal lands or impacting waters of the United States) the\nagency that is being asked to issue the permit must evaluate the\nenvironmental effects of the permit decision under NEPA. Federal\nagencies might require the private company or developer to pay for\nthe preparation of analyses, but the agency remains responsible for\nthe scope and accuracy of the analysis."