and 9 of the statue. Article 7 states that all actions carried out by federal agencies must be unlikely to jeopardize the continued existence or result in the destruction of endangered species. Article 9 focuses not just on federal agencies but everybody, banning the taking of any endangered species by any party, be it federal, state, or private. By proving that actions taken by those who are contributing to climate change jeopardize animals listed on the ESA, climate activists are able to use the ESA to stop actions contributing to climate change. The first step for climate change activists is to make sure that species threatened by climate change are listed on the ESA by the Fish and Wildlife Service (FWS). Oftentimes this alone can be a lengthy process. In December 2005 the Center for Biological Diversity joined with two other US NGOs (Greenpeace and the Natural Resources Defense Council) to petition that the Arctic Polar Bear be listed on the ESA. The FWS under the Bush administration stretched the process out for years, missing many key deadlines and listing the species as "threatened" instead of endangered while the science was clearly in favor of an endangered listing. Facing mass public pressure and scientific consensus the FWS officially listed the species as endangered in May 2008. Actions Using the National Environmental Policy Act The National Environmental Policy Act (NEPA) recognizes that actions taken by the US government can have significant environmental impact and requires that all federal agencies consider these environmental implications when doing "major federal actions". This can be done either through an environmental assessment (EA) or a more thorough environmental impact statement (EIS), how thorough the analyzation has to be depends on the nature of the proposed action. NEPA does not require climate change or greenhouse gases be mentioned in all EAs and EISs, but many climate change activists will sue under NEPA claiming that the impacts related to climate change are relevant enough that they should be included. Actions Using the Clear Air Act The Clean Air Act (CAA) regulates air pollutants both from stationary and mobile sources. The Act was passed in the 1970s before there was widespread knowledge about greenhouse gases (GHGs) but in 2007 the Supreme Court decided the EPA did have to regulate GHGs under the CAA due to the famous Massachusetts vs. The EPA case. As a result of this, climate change