Center for Progressive Reform

Letters & Comments to Agencies (Page Two)

The Member Scholars and staff of the Center for Progressive Reform often communicate with federal and state agencies, testifying, filing comments on proposed regulations, or bringing important matters to their attention by way of letters. In addition, Member Scholars often testify before congressional committees on a range of topics related to the organization’s core issues.  Letters and other communications with agencies follow from 2003 - 2010 follow. For more recent communications with agencies, visit this page. Or browse Member Scholars' congressional testimony.
Communication with Agencies (Letters, Comments and Testimony) from CPR Member Scholars and staff:
  • Coal Ash Rulemaking. On November 19, 2010, CPR President Rena Steinzor and UMaryland Law Clerk Michael Patoka submitted comments to the EPA on the agency's proposed rulemaking on coal ash. News release.
  • Chesapeake Bay Watershed Implementation Plans. On November 4, 2010, CPR President Rena Steinzor and CPR Policy Analyst Yee Huang submitted comments to the EPA and to the governors of the states in the Chesapeake Bay region on the states' Watershed Implenetation Plans.
  • Coal Ash. Rena Steinzor's Testimony on Coal Ash, before an EPA panel conducting regional hearings on its proposed rule, August 30, 2010, Washington, DC.
  • OMB Report to Congress on Costs and Benefits of Regulation. Each year, the White House Office of Management and Budget submits a report to Congress on the costs and benefits of federal regulation.  And each year, CPR Member Scholars critique the report.  In their 2010 comments, Sidney Shapiro, Amy Sinden, Rena Steinzor, and James Goodwin make several points: 1) aggregating costs and benefits of regulations is unproductive; OMB has signaled its intent to continue micro-managing agency regulating; and OMB's call for transparency should apply to OMB itself.
  • Letter to White House Counsel re OIRA.  On March 17, 2010, CPR Board Members Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden and Rena Steinzor wrote a letter to White House Counsel Robert Bauer requesting a review of "ongoing violations of presidential executive orders by the Office of Information and Regulatory Affairs," specifically, OIRA's routine assertion of jurisdiction over "guidance documents" from regulatory agencies despite EO 13,497 despite a revocation of that authority by the President; OIRA's exceeding deadlines for completing reviews under the terms of EO 12,866; and OIRA's failure to disclose "before and after" documents allowing the public to determine what changes were made to regulatory actions after OIRA's review (again, a violation of EO 12,866).
  • OSHA Hearing on HazCom standard. On March 9, 2010, CPR Policy Analyst James Goodwin made a presentation from Member Scholar Sid Shapiro and himself commenting on a proposed rule modifying OSHA's Hazard Communication (HazCom) Standard, which establishes a system for communicating hazards about dangerous chemicals to the workers who use them. Read the testimony.
  • OSHA Listens Presentation.  On March 4, 2010, CPR Policy Analyst Matt Shudtz made a presentation from Member Scholar Rena Steinzor and himself to an "OSHA Listens" session, chaired by OSHA Administrator David Michaels.  The presentation drew on Workers at Risk: Regulatory Dysfunction at OSHA (700 kb download), CPR White Paper #1003, by CPR Member Scholars Thomas McGarity, Rena Steinzor, and Sidney Shapiro, and CPR Policy Analyst Matthew Shudtz.  Read the presentation.
  • Toyota Safety Letter.  On February 9, 2010, CPR Member Scholars Rena Steinzor and Sidney Shapiro sent a letter to the House Oversight and Government Reform Committee outlining important questions it should put to the National Highway Traffic Safety Administration, in the wake of its failure to force speedy action on safety problems with several Toyota models.  Read the letter.
  • Comments on Draft Water Quality Report for the Chesapeake Bay.  CPR Policy Analyst Yee Huang's comments on EPA's draft 202a Water Quality Report & 203 Strategy for the Chesapeake Bay, January 8, 2010.


  • Letter to OIRA on Coal Ash Regulation.  On December 22, 2009, CPR President Rena Steinzor sent a letter to OIRA Administrator Cass Sunstein concerning OIRA involvement in EPA's announcement that it was delaying potential action on regulation of coal ash. The announcement came after OIRA had held a series of meetings with industry interests.
  • Letter to OIRA on 2009 OMB Report to Congress.  On November 5, 2009, CPR Member Scholars Rena Steinzor and Amy Sinden, with CPR Policy Analyst James Goodwin filed comments with the OMB Office of Information and Regulatory Affairs on OMB's annual report to Congress on the costs and benefits of regulation.
  • Letter to White House Science Adviser and OIRA Administrator.  On October 22, 2009, CPR President Rena Steinzor and Board Member Robert Glicksman sent a letter to White House Science Advisor John Holdren and OIRA Administrator Cass Sunstein regarding OMB interventions in EPA science programs. The letter examined two incidents involving OMB meddling in IRIS and EDSP.
  • Comments on ESA Consultation Rules.  On August 3, 2009, CPR Member Scholars Mary Jane Angelo, Holly Doremus, and Daniel J. Rohlf, and CPR Policy Analyst James Goodwin submitted comments to the U.S. Fish and Wildlife Service (FWS) proposing several ways to improve regulations for implementing interagency consultations under the Endangered Species Act.  Read James Goodwin's blog entry on the comments.
  • Letter to White House Science Advisor.  On April 3, 2009, CPR Member Scholars Rena Steinzor and Wendy Wagner sent a letter to White House Science Advisor John Holdren with several recommendations for protecting science from politics in the Obama Administration.  Read the letter and the news release. On May 13, 2009, after the White House formally opened the science policy development process up for public comment, CPR Member Scholar Reina Steinzor and Policy Analyst Matthew Shudtz submitted formal comments, expanding on some points in the April 3 letter.
  • Letter on Endangered Species Act Consultation Regulation.  April 1, 2009 letter to Interior Secretary Salazar and Commerce Secretary Locke from CPR Member Scholars Holly Doremus, Robert Glicksman, Alejandro Camacho, Daniel Rohlf, and Policy Analyst Margaret Clune Giblin, urging the Secretaries to take advantage of a 60-day window for withdrawing a Bush Administration midnight regulation weaking a requirement that agencies consult on actions that would harm endangered or threatened species.
  • Final Comments on Obama Regulatory Review Process.  Comments from John Applegate, Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden, Rena Steinzor, Robert Verchick (collectively the CPR board), Comments Regarding Executive Order on OMB Regulatory Review, March 16, 2009.  Read the web article.
  • Preliminary Comments on Obama Regulatory Process Memo.  Rena Steinzor's February 20, 2009 letter to OMB chief Peter Orszag submitting preliminary comments for OMB consideration as it prepares recommendations for President Obama on ways to reform the regulatory process.  The letter also called for a formal review period for OMB's proposal once a draft was prepared.


  • Risk Assessment Bulletin.  Member Scholar Rena Steinzor's June 15, 2006 letter to OMB urging it to withdraw its proposed risk assessment bulletin. 

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