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:
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
Comments to OSHA on Improving the Whistleblower Protection Program

Comment letter to OSHA ahead of its Whistleblower Stakeholder Meeting on May 12, 2020, providing recommendations on how the agency can address key issues and improve its administration of the Whistleblower Protection Program.

Type: Letters to Agencies (May 5, 2020)
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Author(s): Katie Tracy
Censored Science Rule Virtual Hearing Testimony

Testifying at a virtual hearing hosted by the Union of Concerned Scientists, James Goodwin laid bare the feeble legal underpinnings of EPA's "censored science" rule.

Type: Letters to Agencies (April 14, 2020)
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Author(s): James Goodwin
Joint Letter to CDC on Harmful Coronavirus Guidance for Workplaces

CPR joined more than 500 labor, racial, legal, interfaith, and women’s justice organizations and individuals on a letter demanding that the Centers for Disease Control and Prevention retract its flawed guidance that allows workers exposed to coronavirus to return to work without self-quarantining.

Type: Letters to Agencies (April 9, 2020)
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Author(s): Katie Tracy
Letter to USDA Calling for Aid to Farmers Impacted by COVID-19

CPR joined more than 750 organizations in a letter to USDA Secretary Sonny Perdue urging the agency to allocate $9.5 billion appropriated for farmers in the CARES Act to local producers rather than corporate agribusiness.

Type: Letters to Agencies (April 9, 2020)
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Author(s): Katie Tracy

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