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)
[email protected]
web bio:  
www.law.uh.edu/faculty/cv/Hester-Bio.pdf?<http://www.law.uh.edu/faculty/cv/Hester-Bio.pdf?>



From: [email protected] <[email protected]> On 
Behalf Of Hester, Tracy
Sent: Monday, September 30, 2024 9:47 AM
To: [email protected]
Subject: [geo] NOAA request for comments on potential solar radiation 
modification research regulation (deadline Nov. 19, 2024)

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

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