SOS Submits NOAA Public Comment
On November 19th, 2024, GenSeven's Save Our Sky Campaign submitted its public comment to the National Oceanic and Atmospheric Administration (NOAA) regarding Weather Modification Reporting Act regulations. NOAA was soliciting public comment on the petition for rulemaking to amend their reporting regulations under this Act. This marks the first time since the Act's implementation in 1972 that the public has had the opportunity to influence the report and advocate for an outright ban on all geoengineering-related activities, including Solar Radiation Management (SRM), which Bill Gates has promoted.
The public comment included 216 co-signers and all organizations, including the National Health Federation (NHF) and Children's Health Defense CA. This significant number of organizational co-signers demonstrates a strong collective voice in addressing concerns about weather modification and geoengineering activities.
HISTORICAL CONTEXT
The Weather Modification Reporting Act of 1972 requires anyone intending to engage in weather modification activities in the United States to report such activities to the Secretary of Commerce[5]. This Act has been the primary source of information on attempts to influence weather in the United States for decades[4].
IMPLICATIONS
This public comment period represents a crucial moment for organizations and individuals concerned about the potential impacts of weather modification and geoengineering. It provides an opportunity to influence policy and potentially advocate for stricter regulations or even bans on certain practices that may have far-reaching environmental consequences.
This is our public comment and co-signers:
November 19, 2024
National Oceanic and Atmospheric Administration
Attn: Document No. NOAA-OAR-2024-0091
1401 Constitution Avenue NW, Room 5128
Washington, DC 20230
https://www.federalregister.gov/documents/2024/09/20/2024-21567/notice-of-receipt-and- request-for-public-comment-on-petition-for-rulemaking-regarding-maintaining#open-comment
Re: Document No. NOAA-OAR-2024-0091, Request for Public Comment on
Petition for Rulemaking to Amend NOAA’s Reporting Regulations under
the Weather Modification Reporting Act
To the NOAA Public Comment Review Team,
This public comment is submitted on behalf of GenSeven's Save Our Skies (SOS) campaign, with co-signatories including the National Health Federation (NHF) and other concerned organizations and individuals who share our deep concerns about weather modification, climate intervention and SRM activities.
We submit the following comment to the National Oceanic and Atmospheric Administration (NOAA) regarding the Request for Public Comment dated July 30, 2024, on the petition for rule-making to amend NOAA's reporting regulations under the Weather Modification Reporting Act, document No. NOAA-OAR-2024-0091.
Save Our Skies is a non-profit initiative dedicated to raising public awareness about the dangers of geoengineering and holding regulators accountable for protecting our environment. We strongly oppose any amendments that would normalize or facilitate (SRM), Stratospheric aerosol injection (SAI), marine cloud brightening (MCB), and cirrus cloud thinning (CCT), as such actions pose significant risks to our climate and ecosystems. This amendment, if granted, would be a dangerous step towards normalizing geoengineering practices that pose severe risks to our planet's climate, ecosystems, and human health.
First and foremost, I urge NOAA to pursue a permanent ban on all private, institutional, and federal SRM, SAI, MCB, and CCT activities, outdoor field experiments, and cloud seeding.
Prohibit excessive electromagnetic radio frequency, microwave radiation, or other forms of weather engineering involve the release of hazardous chemicals and/or xenobiotics (foreign-to-life) and provide enforcement and penalties for violations.
SRM, by its very nature, is not a "local weather modification" issue but a global concern with far-reaching consequences. The proposed amendment falls woefully short of addressing the gravity of these interventions and instead risks legitimizing them through mere reporting requirements.
The Weather Modification Reporting Act of 1972 is entirely inadequate to address the scale and complexity of modern geoengineering proposals such as stratospheric aerosol injection SAI, MCB, and CCT. These technologies are not only controversial but potentially catastrophic in their impacts on human health, global climate, and political systems.
The proposed amendment should require NOAA to proactively publish all weather modification research, reports, and related information, ensuring transparent public access with comprehensive advance notice. This disclosure must include detailed information about the purpose, scale, projected environmental impacts, and potential risks of proposed weather modification activities, enabling meaningful public understanding and informed consent. This disclosure must include - details as to all agents to be used in the proposed project including the amount and formulation of each, application rate, delivery method, average altitude, and coordinates of the area of the project.
It's crucial to understand that the effects of geoengineering chemical processes in the atmosphere are not confined to local areas. Climate is dynamic, the area of impact is unpredictable, and our current atmospheric sensors are incapable of accurately detecting manufactured changes in albedo. This uncertainty alone should be enough to halt any field experiments.
Moreover, allowing for-profit companies or individuals such as Bill Gates and David Keith to legally experiment with temperature-altering solar geoengineering is a dangerous precedent. There is no scale small enough for these experiments that wouldn't risk international conflict. The transnational effects of such activities could violate the Environmental Modification Convention (ENMOD) Treaty, which prohibits environmental modification techniques with "widespread, long-lasting or severe effects.”
The potential risks of SRM deployment are alarming and include:
Severe disruptions to weather patterns, including drought and flooding
Increase in catastrophic forest fires
Disruption of monsoon cycles
Increased air pollution and acid rain
Extreme temperature fluctuations
Food shortages due to agricultural disruptions
Ozone layer depletion
Reduction in solar power efficiency
Geopolitical conflicts arising from unilateral climate interventions
Societal disruption, conflicts between nations
Most concerning is the prediction by scientists that once SRM is initiated, we may become dependent on it, unable to cease without triggering rapid and potentially catastrophic warming.
Instead of regulating geoengineering, which NOAA Form 17-4 implicitly allows, NOAA should implement policies that actively discourage research, field experiments, and deployment of any weather modification or climate intervention technologies. At the very least, such activities should not proceed without the fully informed consent of the American people and the global community, include nationwide real-time monitoring stations, and transparent, timely reporting systems for all weather modification programs, outdoor field experiments, and cloud seeding.
ENVIRONMENTAL RISKS
SRM could lead to severe environmental harm, including drought, floods, heat waves, increased fire potential, acid rain, food shortages, ozone layer depletion, and ecosystem disruption. There are too many unknowns and the full environmental impact of SRM cannot be understood without deployment, which itself carries unknown risks. There are serious concerns about the reversibility of SRM effects and the potential for planetary systems to become dependent on ongoing SRM deployment.
PUBLIC HEALTH RISKS
SRM poses potentially grave unintended consequences to public health. The long-term effects of chemicals used to modify weather and climate conditions are insufficiently studied. Potential risks include increased air pollution, UV exposure-related mortality, acid rain, disruption of agriculture and food supply, and health impacts from extreme weather events like droughts, floods, and temperature extremes.
GLOBAL POLITICAL FALLOUT
SRM research and deployment are likely to instigate international and domestic political conflicts. The global community is deeply divided on SRM governance and deployment issues. For example, a recent SRM resolution at UNEA-6 failed due to opposition from African and Global South countries, citing concerns about disruptions to local climate patterns, food production, and biodiversity. Additionally, countries like Russia and China are researching SRM as potential warfare strategies.
DOMESTIC CONFLICT
Domestically, states are divided on weather modification activities. While some western states employ active weather modification programs, others, like Tennessee, have laws prohibiting such activities. SRM deployment in one state could adversely affect neighboring states, potentially leading to interstate conflicts.
Given these risks, NOAA should update its regulations to prohibit SRM research, experimentation, and deployment to protect public health, preserve environmental integrity, and prevent geopolitical conflicts.
SOS PUBLIC RECORDS REQUESTS
As President of GenSeven's Save Our Skies campaign, I must bring to NOAA's attention a critical issue uncovered through our Public Records Requests. We have discovered that several California irrigation districts are relying on environmental impact studies from the 1990s to justify current water management and potential geoengineering projects. This practice is deeply concerning and potentially illegal.
The use of such outdated studies fails to provide an accurate picture of these projects' potential environmental impacts in today's climate conditions. The 1990s studies do not account for:
1. Significant changes in local and regional ecosystems over the past three decades
2. The cumulative effects of agricultural yields, increased tree mortality rates, disruption of local ecosystems, and alterations to natural precipitation patterns.
3. Advancements in scientific understanding of environmental processes and impacts
4. Changes in land use and population demographics
5. The emergence of new environmental challenges and priorities
Both the U.S. Environmental Protection Agency and the California Environmental Protection Agency have failed in their duty to ensure that the information used in environmental assessments remains relevant and accurate for current projects and environmental conditions. This oversight undermines the entire environmental review process and potentially puts our ecosystems and communities at risk.
The reliance on outdated studies is particularly alarming in the context of potential geoengineering projects, which could have far-reaching and long-lasting impacts on our climate and environment. It is imperative that any consideration of such projects be based on the most current and comprehensive environmental data available.
If NOAA refuses to ban cloud seeding, we urge NOAA to take immediate action to address this issue by:
1. Requiring updated environmental impact studies for all current and proposed water management and geoengineering projects
2. Implementing stricter guidelines on the currency of data used in environmental assessments
3. Conducting a thorough review of existing projects that may have been approved based on outdated information
4. Establishing a comprehensive real-time monitoring system for all weather modification activities, including cloud seeding. This system should:
a) Track the timing, location, and scale of all cloud-seeding operations
b) Monitor immediate and long-term environmental impacts, including effects on precipitation patterns, ecosystem health, and air quality
c) Provide public access to this data through an easily accessible online platform
d) Require prompt reporting of any unexpected outcomes or adverse effects
This situation underscores the critical need for transparency, rigorous scientific standards, and ongoing public oversight in environmental decision-making processes. This information is crucial for NOAA to consider as it evaluates its policies and regulations regarding weather modification and climate intervention activities.
We strongly urge NOAA to:
1. Reject the proposed amendment and encourage stricter guidelines
2. Implement a policy that prohibits all SRM field experiments, including SAI, MCB, CCT, and cloud seeding
4. Advocate for international governance and agreements on the prohibition of geoengineering activities
5. Increase public education on the risks and ethical implications of solar geoengineering.
6. The increased reliance on and dependence on solar energy to power the grid, as opposed to gas and coal, means that any effort to block or dim the sun intentionally will decrease performance and have devastating effects on people dependent on green energy. This could force either blackouts or render these solar products obsolete
7. All companies conducting these operations should be required to be bonded in adequate amounts to cover potential claims
Plain and simple: NOAA should amend its Reporting Act regulations (15 C.F.R. 908) to prohibit Solar Radiation Modification (SRM) research, outdoor experiments, and deployment due to significant risks to human health, the environment, and geopolitical stability.
CONCLUSION
In conclusion, we, the undersigned organizations and individuals, including GenSeven's Save Our Skies campaign and the National Health Federation, along with all the signatories on this public comment, urge NOAA to take immediate action to address the critical issues raised in this submission.
We collectively call for a ban on SRM, cloud seeding and all other weather modification activities, or at the very least, the implementation of stringent regulations, up-to-date environmental impact studies, and real-time monitoring systems. Our shared goal is to protect public health, preserve environmental integrity, and ensure full transparency and accountability in all weather modification and climate intervention activities. We stand ready to engage further with NOAA and other relevant agencies to safeguard our skies and our future.
The escalating use of weather modification, SRM, SAI, and MCB, poses severe threats to all living beings and our environment. These programs are being conducted without public knowledge or consent, violating fundamental principles of transparency and democratic oversight.
The stakes are too high to gamble with the Earth's climate system. NOAA has a responsibility to protect our shared atmosphere and environment. I implore you to take a firm stand against the normalization of geoengineering.
Thank you for your consideration of these critical concerns.
Most Sincerely,
GenSeven
Reinette Senum, Founder/President
Johanna Finney, Secretary
Kimberly Carlson, Treasurer
Save Our Skies Campaign
Co-Signer Organizations:
2. National Health Federation
Scott C. Tips, JD, President and General Counsel
3. The El Dorado County Committee of Safety
Kari Hand Benton
Gary Kinghorn
Susanne Colby
Jess Roddy
Jonathan Wacker
Brian DeBerry
Jack Budmark
4. Nisenan Miwok Collective, Citizens Against Geoengineering
Laura Galvan, Chairwoman
5. Children's Health Defense California Chapter
Beverly Raimondo
6. Alameda County Committee of Restoration
Lou Anne McKeefery
7. El Dorado County Geoengineering Awareness
Julie Leconte
8. Health Choice Rhode Island
Deborah H Jennings, RN
9. SYV Common Sense Group
Holly Delaney, Santa Valley, Santa Barbara County
10. Clean Texas Skies
Betsy Dewey
11. SOAAR Global, PMA
Anastasia Sprout
12. Rogue Valley for True Blue Skies, Ashland, Oregon
Karen Potts
13. Health 1st
Gerald Fitzgibbon
14. The REAL Green New Deal Project
Megan K. Seibert
15. Natural-Law Church
Charles Stewart
Co-signer Individuals:
16. Abreu, Donna B
17. Acken, Janice
18. Adams, Connie (Kings Beach, CA)
19. Andress, Carrie MSc
20. Atwood, Dr. Gwendolyn
21. Ayers, Lauren (Guinda, CA)
22. Baime, Carlene
23. Ballew, David
24. Ballew, Leah
25. Ban, Cheryl
26. Barrett, Mark
27. Barrett, Penny
28. Bates, Christine
29. Beal, Roger D.
30. Bienvenue, Christine
31. Blake, Gavin
32. Blais, Susan M.
33. Blazak Nathan, Bonnie (Boise, Idaho)
34. Bockstahler, Christopher
35. Bostian, Sidney E.
36. Brake, Robin
37. Brann, Joy MPH
38. Brown, Kathleen (California)
39. Bruce, Laura
40. Brunett, Steve
41. Buck, Susan
42. Butterfly, Nola
43. cameron, m
44. Carman, Dave (Colorado)
45. Carper, Travis
46. Castro Hudson, Satori
47. Cavallaro, Josephine
48. Clamer, Marge
49. Colibri, Kathy
50. Collins, Grace
51. Cox, Sidnee
52. Crane, Maggie
53. Cullum, Kathy
54. Cunningham, Vanessa
55. Curlin, Robert (Hicksville TN)
56. Curtis, Penelope
57. Dave M
58. Davies, Howard A
59. Davis, Larissa
60. DeMartini, Susan (Marin County)
61. Dodds, Denise (Virginia)
62. Doll, Joan
63. Donahoe, Carol
64. Donahue, Carol
65. Dow, Georgia
66. Dunne, Elizabeth Catherine
67. Dunne, Timothy J.
68. Dutton-Jones, Diane
69. Dutton-Jones, Keegan
70. Dutton-Jones, Robert
71. Ehrich, Elizabeth (Fredericksburg Virginia)
72. Ekelund, Carol
73. Eldefonso, Greg
74. Ely, Lynn
75. Engelson, James
76. Fabrizio, Rachel (CA)
77. Field, Melinda
78. Folkner, Sonia
79. Franklin, Derek
80. Frans, Wiene
81. Friedman, Lauren
82. Garcia, Shanon
83. Gay, Karen
84. George, Cynthia
85. Gilton, Brian Robert
86. Goodson, Maria
87. Griffin, Donna (Michigan)
88. Gruenke, Jae
89. Guido, Amy
90. Hagerman, Marilyn
91. Haley, Mary
92. Hall, Pamela
93. Hancock, Donna
94. Hannon, Patty
95. Harlib, Amy
96. Haskell, Tess
97. Hazard, Gary
98. Hentschel, Adrienne (Oregon)
99. Hillis, Eric
100. Hodge, Jessica
101. Hofmann, Lynda
102. Holt, Linda (Nevada City, CA)
103. Holt, Mark (Nevada City, CA)
104. Howard, Kara
105. Hughes, Lola
106. Hume, Tiffany Angelique
107. Hunter, Jan
108. Hunter, Liz
109. Huttenhoff, Joanne
110. Iwahashi, Chizuru
111. Jan, Peter
112. Jans, Sylvie
113. Jeff (last name pending)
114. Jennings, Deborah H
115. Jewell, Catherine
116. Jordan, Jess
117. Judd, Ginny (Asheville NC)
118. Keener, Katherine
119. Kelly, Leighton
120. Kim, Alannah L
121. Klein, Barbara
122. Knapp, Maureen
123. Krofina, Kristen
124. LaRocque, Jean Pierre (Westmeath, Ontario)
125. Lawler, Susan
126. Leavens, Gary & Margaret
127. Lee, Berda
128. Leonhardt, Scott and Ashley
129. Lewton, Cami, Zach, and Oliver
130. Lin, Danielle (Des Moines Iowa)
131. Lis, Katherine
132. Lomon, Mia and Kara
133. Luca, Remo
134. Lundberg, Leanne
135. MacBurnie Wakefield, Martha (RI)
136. Mann, Debra
137. Mann, Douglas G MD
138. Mann, Jeff
139. Manesis, Michele Markela
140. Manzo, April
141. Marmor, Loretta
142. Marshall, Andrew
143. Martin, Andi Pigott
144. Mason, Diane
145. May, Gregory
146. McCall, Robin (Berkeley CA)
147. McDonough, Dale
148. McGeary, Megan
149. McIntyre, Judith (Boston, MA)
150. Merrill Proctor, Todd (Ventura, CA)
151. Miller, Donna
152. Mitchell, Sally RNC
153. Moran, Mary Kate
154. Moss, Brad (Idaho)
155. Murphy, Kate (Charlotte, NC)
156. Murphy, Rochelle
157. Nash, Lisa
158. Nathan, Xavier (Boise, Idaho)
159. Neal, Lillian Jane
160. Newton, Julia
161. Nordness, Astrid
162. Northrup, Dr. Christiane
163. O'Shea, Arthur A. (Millis, MA)
164. Olin, Kelly Rose
165. Olin, Timothy R.
166. Ortega, Suzann
167. Palmer, Amy
168. Peace, Lara (Santa Rosa, CA)
169. Pollari, Joseph (NY)
170. Pratini, Randi
171. Pucciariello, Julie
172. Pye, Graham (Herk de Stad, Belgium)
173. Reese, Michelle
174. Regan, Erin
175. Resseger, Sheila
176. Rodriguez, Chase
177. Rodriguez, Courtney
178. Rose, Eric
179. Rosenfeld, Eric
180. Rough, Janis
181. Sansom, Stephen
182. Schappert, Laura
183. Schaffer, Ellen
184. Schrader, Teri
185. Selck, Brandee (Oakland CA)
186. Sima, Gerald
187. Simek, Andrew
188. Sinclair, Barbara (North Sandwich NH)
189. Smith, Nora
190. Smith, Quentin
191. Spencer, Terence
192. Stanton, Renee
193. Stevenson, Terri
194. Stonebrooke, Pamela (Houston Texas)
195. Stottlemyer, Patty
196. Sullivan, Penelope
197. Taylor, LaShon
198. Threet, Julie
199. Toth, Frank
200. Troiano, Pete
201. Tucker, Denise (Austin, TX)
202. Vallaire, Denise
203. Velkoff, Victoria (California)
204. Visher, John (Malibu California)
205. Walker, Doug (AZ)
206. Webb, Betty
207. Webb, Loraine (Nevada County, CA)
208. Webb, Soleil
209. Weich, Erika and Christopher
210. Wels, Gerald
211. Wenger, Andrea
212. White, Joanne
213. Williams, Rachel
214. Williamson, James F D.C.
215. Wilmot, James (Oswestry, Britain)
216. Zerwekh, Shannon (Carlsbad, CA)
