Tracy,

I found your paper comprehensive and informative, and I think it will
serve as a valuable resource going forward.  I also think it serves as
an important reality check for the geoengineering community.  There is
much discussion about research guidelines, experimental protocols, and
even governance arrangements, but to move from modeling to possible
deployment requires overcoming many other obstacles--social, cultural,
economic, business, ethical.  You do a great job of sketching out the
legal landscape that any climate engineering project would encounter
in the US.  Perhaps this will encourage aspiring geoengineers to set
up offshore in less restrictive jurisdictions, as with manufacturing,
finance, etc.

By the way, you've probably already seen it, but there is a similar
though much less thorough discussion of some of these legal issues in
the recent CRS report "Geoengineering: Governance and Technology
Policy" (pp. 23-28) - http://www.fas.org/sgp/crs/misc/R41371.pdf

Josh Horton
[email protected]


On Feb 7, 5:20 pm, Mike MacCracken <[email protected]> wrote:
> Dear Tracy--
>
> I look forward to reading the article. My first thought is that it would
> certainly be nice if all US environmental laws also applied to the decision
> not to take dramatic action to limit greenhouse-induced climate change
> through mitigation. Massachusetts vs. EPA is a start (as are a couple of
> other lawsuit victories) as it has prompted the EPA Endangerment Finding
> (seehttp://www.epa.gov/climatechange/endangerment.html), and the lawsuit
> against the Am-Ex Bank and the Overseas Private Investment Corporation did
> lead to a requirement for NEPA, but it is interesting that it might require
> much more legal consideration for taking action to keep the climate near to
> what it is than to decide not to take and let the climate keep changing
> without control. Indeed, starting to try to make sense of all this sounds
> appropriate.
>
> Mike MacCracken
>
> On 2/7/11 4:48 PM, "Tracy" <[email protected]> wrote:
>
>
>
> > I've lurked in this group for quite a while, but I'm now stepping into
> > the light to provide a working paper for your consideration.
>
> > While this group has usually focused on technical and policy issues,
> > you might have an interest in some of the potential legal battles that
> > could affect climate engineering projects.  This working paper
> > discusses how existing U.S. environmental laws can be used to
> > challenge geoengineering research or field tests.  U.S. environmental
> > laws have often served as the first line of legal resistance to new
> > technologies (GMOs, nanomaterials), so it struck me as a likely
> > scenario for geoengineering as well.
>
> > You can access the working paper at tinyurl.com/6e7ejtf .  I'd welcome
> > any comments or suggestions.  Thanks!
>
> > **********
> > Tracy Hester
> > Director, Environment, Energy & Natural Resource Center
> > Assistant Professor
> > University of Houston Law Center
> > 100 Law Center
> > Houston, Texas   77204
> > 713-743-1152 (office)
> > [email protected]
> > web bio:  www.law.uh.edu/faculty/thester

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