Comments, Letters, & Testimony to Agencies

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 with letters or other means of communication.

All such communications since 2011 are listed on this page. For testimony or other communications with Congress, visit this page
 
Communication with Agencies (Letters, Comments and Testimony) from CPR Member Scholars and staff:
Joint Letter to Maryland Department of Environment on Phase I MS4 Permits

CPR joined with the Members of the Choose Clean Water Coalition in comments on the draft Phase I MS4 permits for several Maryland jurisdictions, highlighting strengths and weaknesses.

Type: Letters to Agencies (Sept. 10, 2020)
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Second Joint Letter to Ben Grumbles on Transparency During COVID

In May 2020, CPR joined with other organizations from the Chesapeake Accountability Project in a letter to Maryland Secretary of the Environment Ben Grumbles urging increased transparency during the pandemic. Having received no response, the group wrote again to urge that all compliance waivers granted/denied & claims of force majeure related to COVID-19 be made public. The letter also reiterates the importance of MDE providing strong and clear notice to permit holders of its expectations during the pandemic.

Type: Letters to Agencies (Aug. 26, 2020)
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Author(s): Matt Shudtz
Joint Letter to Governor Hogan re MOSH standard for COVID-19

CPR joined unions, public health professionals, advocates, workers, faith leaders, and Maryland residents across the state calling on Governor Hogan to issue an executive order requiring the Maryland Occupational Safety and Health (MOSH) division of the Department of Labor, Licensing and Regulation to adopt an emergency standard to protect workers from the novel coronavirus.

Type: Letters to Agencies (Aug. 11, 2020)
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Joint Letter to Virginia DEQ re Wegmans Distribution Center

CPR joined a group of 20 organizations in a public comment on a Draft Virginia Water Protection Permit for a proposed Wegmans Distribution Center that would have a permanent and destructive impact on several acres of wetlands in the vicinity of Hanover, Virginia.

Type: Letters to Agencies (Aug. 11, 2020)
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Author(s): Matt Shudtz
CPR Comments on EPA's 'Benefits-Busting' Rule

On August 3, 2020, several CPR Member Scholars and staff joined in submitting comments on the Environmental Protection Agency’s (EPA) “benefits-busting” proposal, designed to drastically overhaul how the agency performs cost-benefit analysis on its biggest Clean Air Act rules. The proposal is a thinly veiled effort to rig the results of those analyses – more so than they already are – to make it harder to issue appropriately strong safeguards, thereby sabotaging the effective and timely implementation of the Clean Air Act.

Type: Letters to Agencies (Aug. 3, 2020)
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Author(s): Catherine O'Neill, Sidney Shapiro, Amy Sinden, James Goodwin, Darya Minovi
Joint Letter on EPA's 'Benefits-Busting' Proposal

Led by the Center for Progressive Reform, a number of public interest organizations submitted comments to the EPA on August 3, 2020, opposing the agency's efforts to rewrite its cost-benefit analysis methodology as it applies to the Clean Air Act. The "benefits-busting" proposal would tilt the playing field even further than it already is toward industry's profit-making interests at the expense of Americans' health.

Type: Letters to Agencies (Aug. 3, 2020)
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Author(s): James Goodwin
Joint letter with Choose Clean Water Coalition to Maryland Department of the Environment re the State Highway Administration and pollution reduction

CPR joined with other members of the Choose Clean Water Coalition in a letter urging the Maryland Department of the Environment to reconsider its proposal to award nutrient credits to the State Highway Administration that it can use toward its pollution reduction requirements under its Municipal Separate Storm Sewer Systems (MS4) permit.

Type: Letters to Agencies (June 16, 2020)
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Author(s): Katlyn Schmitt
Joint Letter with Chesapeake Accountability Project to Maryland Department of the Environment on Compliance During COVID-19 Pandemic

CPR joined with other members of the Chespeake Accountability Project, urging the Maryland Department of the Environment to gather and share information about polluters' alleged inability to comply with permit requirements because of the coronavirus pandemic, and to ensure strong whistleblower protections.

Type: Letters to Agencies (May 21, 2020)
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Author(s): Matt Shudtz
Comments on EPA 'Censored Science' Rule

In comments to the EPA on its proposed 'Censored Science' rule, CPR's Goodwin and Minovi write, "EPA’s rulemaking rejects widely accepted scientific standards and will allow the agency to cherry-pick studies that align with the administration’s agenda ... [and] will be prohibitively costly to the agency, both in terms of taxpayer dollars and the unnecessary and avoidable harms to public health and the environment. Furthermore, the EPA has incorrectly identified ... the legal authority for this rulemaking."

Type: Letters to Agencies (May 18, 2020)
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Author(s): James Goodwin, Darya Minovi
Remarks of Katie Tracy at OSHA Whistleblower Stakeholder Meeting

Katie Tracy’s testimony to OSHA, delivered virtually, during a Whistleblower Stakeholder Meeting, recommending several improvements the agency should make to its Whistleblower Protection Program.

Type: Letters to Agencies (May 12, 2020)
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Author(s): Katie Tracy

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