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 Biden Administration and Congress on Strengthening Federal Whistleblower Protections

CPR joined the Government Accountability Project and 263 other organizations in calling on the Biden-Harris administration and Congress to improve federal whistleblower protections for public-sector workers.

Type: Letters to Agencies (April 1, 2021)
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Joint Letter to the Maryland Department of the Environment on Fenceline Ammonia Monitoring

CPR joined the Environmental Integrity Project, Assateague Coastal Trust, Waterkeepers Chesapeake, and Chesapeake Legal Alliance to provide the Maryland Department of the Environment with information on ammonia pollution monitoring near concentrated animal feeding operations (CAFOs) for poultry. Those CAFOs are often located near and can pollute fenceline communities on Maryland's Eastern Shore.

Type: Letters to Agencies (March 29, 2021)
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Joint Letter to Incoming Biden-Harris Administration on Regulatory Process Reform

CPR joined the Coalition for Sensible Safeguards and 94 other organizations in calling on the incoming Biden-Harris administration to direct the White House Office of Information and Regulatory Affairs (OIRA) to take on the mission of advancing a strong, proactive agenda for safeguarding the public, workers, and the environment. The groups offered a set of recommendations to help ensure that our regulatory system protects workers, consumers, our environment, and our economy.

Type: Letters to Agencies (Dec. 9, 2020)
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Joint Comments on the Army Corps of Engineers' Modifications to Nationwide Water Pollution Permits

CPR joined comments opposing nationwide water pollution permits proposed by the Army Corps of Engineers. These permits would result in significant, widespread harm to our nation’s waters and would violate the Clean Water Act, the National Environmental Policy Act, the Endangered Species Act, and the Administrative Procedure Act.

Type: Letters to Agencies (Nov. 16, 2020)
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CPR Comments on DEQ Air Permit for Norfolk Naval Shipyard Power Plant

CPR analysts Darya Minovi and David Flores submitted a public comment on Virginia's draft air pollution permit for a proposed natural gas and diesel-burning power plant at the Norfolk Naval Shipyard in Portsmouth. Citing CPR's Toxic Floodwaters study of the James River Watershed, the letter explores the risks of harm that the facility and others in the area pose to the low-income and minority fenceline communities already disproportionately burdened by industrial pollution.

Type: Letters to Agencies (Oct. 7, 2020)
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Author(s): Darya Minovi, David Flores
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

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