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."

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