I am pleased to announce that, on Thursday, December 23, 2021, we submitted a draft petition with Environmental Protection Agency Administrator Michael S Regan demanding EPA action to halt additional fossil fuel greenhouse gas (GHG) emissions and removal of legacy emissions of carbon dioxide (CO2) and methane (CH4).
We provided the Petition Seeking A Phaseout of New and Removal of Legacy Fossil Fuel Greenhouse Gas Emissions in draft form, in order to trigger a period of pre-filing consultation with EPA.
During this consultation period, we hope to garner any additional information we need that the Agency has on the issue, and to see what additional information the Agency needs from us, in order to render a proper determination.
Formally, the Petition is on behalf of:
- Donn J. Viviani, President of the Board of Directors of CPR Initiative and 30-year EPA scientist (retired),
- John Birks, Chief Scientist at 2B Technologies, Professor Emeritus of the University of Colorado, and Member, CPR Initiative Board of Directors,
- James E. Hansen, Director of Climate Science, Awareness and Solutions (CSAS), former Director of the NASA Goddard Institute of Space Studies, and CPR Initiative Adviser,
- CSAS, a non-profit organization, and
- CPR Initiative, a non-profit organization.
Now, you might ask, just what specific determination does the Agency need to make, in order to undertake the actions that we demand? There are two.
First, the Petition requests that the Agency begin a civil action, in court, to compel the major oil, gas and coal companies to phase-out fossil fuel GHG emissions and remove, or pay to remove, excess atmospheric carbon dioxide (CO2) and methane (CH4).
For this to happen, EPA needs to determine that fossil fuel GHG emissions present an imminent and unreasonable risk of serious or widespread injury to health or the environment. 15 USC 2608(b).
Second, the Petition demands that the Agency commence a rule-making to do the same thing, namely, to compel the major oil, gas and coal companies to phase-out fossil fuel GHG emissions and remove, or pay to remove, excess atmospheric carbon dioxide (CO2) and methane (CH4).
For EPA to commence that rule making, it needs to determine that fossil fuel GHG emissions present an unreasonable risk of injury to health or the environment. 15 USC 2605(a).
We strongly believe that the draft Petition provides overwhelming evidence that continuing and legacy GHG emissions from oil, gas and coal present both an imminent and an unreasonable risk of serious and widespread injury to public health and the environment.
But perhaps, during this interim consultation period, you can be the judge. Please have a look at the Petition draft. And let us know your thoughts by emailing us at info@CPRclimate.org or by submitting a message through our contact us form.
Lastly, for now, in order to aid your consideration of the Petition, and to aid our receipt of your thoughts, we will host a special Zoom conference call for you and other CPR Initiative supporters. It is slated for Thursday, January 13, at 12 noon (pacific time).
For A Redress of Grievances
CPR Initiative — invoking key federal statutes, and with your help — will petition the government to compel the major fossil fuel companies to clean up their mess.