Letters & Comments to Agencies

• Letter to Maryland Department of the Environment urging it to stop waiving pollution permit application fees for Concentrated Animal Feeding Operations, by CPR President Rena Steinzor and Policy Analyst Anne Havemann.
• Comments to the FDA on food safety rules for raw produce on November 15, 2013, by CPR Member Scholars Lisa Heinzerling, Thomas O. McGarity, Sidney Shapiro, and Rena Steinzor, and CPR Policy Analyst Michael Patoka.
• Comments to the FDA on preventive controls for human food production, November 15, 2013, by CPR Member Scholars Lisa Heinzerling, Thomas O. McGarity, Sidney Shapiro, and Rena Steinzor, and CPR Policy Analyst Michael Patoka
• Letter to OIRA re USDA proposal to “modernize” the poultry inspection system.  On April 9, 2013, CPR Member Scholar Rena Steinzor and CPR Policy Analyst Michael Patoka sent a letter to the Acting Head of the Office of Information and Regulatory Affairs about the unexamined environmental implications of a USDA proposal to replace government inspectors on poultry processing lines with company employees, while speeding up the processing line to 175 birds per minute.
• Letter to ACUS on bias toward industry on international regulatory cooperation. On March 21, 2013, CPR Member Scholars Thomas McGarity and Rena Steinzor, and Policy Analyst Michael Patoka, wrote a letter to Paul Verkuil, Chairman of the Administrative Conference of the United States (ACUS), expressing concern that the independent federal agency has elevated business and trade concerns over health, safety, and environmental protections in its ongoing work on international regulatory cooperation.

• Letter to EPA on industry efforts to stall IRIS toxicological assessment through non-germane comments. On November 1, 2012, CPR Member Scholar Rena Steinzor and Policy Analysts Wayland Radin and Matthew Shudtz wrote a letter to EPA Administrator Lisa Jackson calling on the agency to put reasonable limits on the length of comments submitted on IRIS assessments in order to prevent industry from further stalling the process.
• Letter to ACUS on bias toward industry. On October 18, 2012, CPR Member Scholars Thomas McGarity and Rena Steinzor wrote a letter to Paul Verkuil, Chairman of the Administrative Conference of the United States (ACUS), criticizing the independent federal agency for its increasingly apparent bias toward the agendas of industry groups.  
• Letter to ACUS on science in the administrative process. On August 21, 2012, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz wrote a letter to Dr. Anne-Marie Mazza, Director of the National Academies' Committee on Science, Technology and Law, and H. Russell Frisby, Chair of the Administrative Conference of the United States (ACUS) Committee on Regulation. The letter asked them to carefully consider recommendations regarding the influece of the Office of Information and Regulatory Affairs on science matters in the rulemaking process.
• Letter to EPA Nominating Bisphenol A (BPA) for Fourth Contaminant Candidate List. On June 22, 2012, CPR Member Scholar Noah Sachs and Policy Analys Aimee Simpson wrote a letter nominating BPA to be considered for regulation under the Safe Drinking Water Act.
• Letter to EPA Administrator Lisa Jackson regarding review of IRIS profiles. On June 15, 2012, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz wrote a letter regarding potential conflict of interests for SAB Chemical Assessment Advisory Committee nominees who would review IRIS profiles, and recommending that the CAAC review process be melded into existing IRIS review steps.
• Letter to USTR Ron Kirk on environmental provisions in trade promotion authority legislation. On May 4, 2012, CPR Member Scholars Carmen Gonzalez, David Hunter, John Knox, and Chris Wold sent a letter to U.S. Trade Representative Ron Kind, recommending a series of environmental policy elements his office should include in the trade promotion authority legislation it is expected to submit to Congress.
• Letter to ACUS on collaboration with the Chamber of Commerce. On April 27, 2012, CPR Member Scholars Thomas McGarity and Rena Steinzor wrote to Paul Verkuil, Chairman of the Administrative Conference of the United States (ACUS), to express dismay that ACUS was holding an event together with the anti-regulatory Chamber of Commerce regarding "incorporation by reference" regulatory policy.
• Comments to FDA on BPA. On April 17, 2012, CPR Member Scholar Noah Sachs and Policy Analyst Aimee Simpson submitted comments to FDA regarding a petition from the American Chemistry Council to remove approval of the use of BPA in infant feeding bottles and certain spill-proof cups.
• Letter to EPA on North American Commission for Environmental Cooperation. On March 29, 2012, CPR Member Scholars Rebecca Bratspies, Carmen  Gonzalez, David Hunter, John Knox, Noah Sachs, Dan Tarlock, and Chris Wold sent a letter to EPA Administrator Lisa Jackson expressing concern over threats to the viability of the North American Commission on Environmental Cooperation's citizen submission procedure.
• Comments to EPA Science Advisory Board (SAB). On January 24, 2012, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz submitted comments on a draft report by the SAB's Committee on Science Integration for Decision Making.

• Comments to NIOSH. On December 22, 2011, CPR Member Scholars Thomas McGarity, Sidney Shapiro, and Wendy Wagner, and Senior Policy Analyst Matthew Shudtz submitted comments to the National Institute for Occupational Safety and Health (NIOSH) recommending NIOSH develop a multi-‘bin’ system for classifying carcinogens, and set Recommended Exposure Limits (REL) based on a risk target of 1-in-1,000,000 in order to ensure workers are protected from air toxics as well as the public is.
• Letter to EPA re IRIS toxics database. On December 22, 2011, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz wrote to EPA Administrator Lisa Jackson responding to a letter the American Chemistry Council (ACC) had sent to EPA. The ACC’s letter had included an erroneous interpretation of IRIS-related riders to an omnibus spending bill, and ACC claimed they necessitated EPA sending an ongoing IRIS assessment of dioxin back to the drawing board.
• Letter to OMB re EPA's IRIS toxics database. On July 8, 2011, CPR Member Scholars Rena Steinzor and Wendy Wager wrote to OMB Director Jacob Lew, responding to a letter the American Chemistry Council (ACC) had sent to OMB regarding the EPA's Integrated Risk Information System (IRIS) database. Steinzor and Wagner rebutted ACC's arguments that OMB should become further involved in the review of IRIS chemical assessments, and that the National Academy of Sciences should review IRIS assessments.
• Letter to Cass Sunstein re Chemicals of Concern listings. On June 20, 2011, CPR Member Scholars Rena Steinzor, Noah Sachs, and Wendy Wagner wrote to OIRA Administrator Cass Sunstein, responding to a request from the U.S. Chamber of Commerce that Sunstein block EPA from listing several toxic chemicals, including BPA, from a chemicals of concern list.
• SBA's Crain and Crain Study. On February 8, 2011, CPR Member Scholar Sidney Shapiro wrote to the Small Business Administration and its Office of Advocacy Office requesting that SBA withdraw its sponsorship from a report issued by the Office of Advocacy that trumpeted inflated estimates of the economic costs of regulation.

• Comments to the Environmental Protection Agency on priorities for the IRIS database, Setting Priorities for IRIS: 47 Chemicals that Should Move to the Head of the Risk-Assessment Line, CPR White Paper 1010, by CPR Member Scholar Rena Steinzor and CPR Policy Analysts Matthew Shudtz and Lena Pons, December 2010.  Read the related blog post.
• 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.
• 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.

2009

• 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.

2008

• Endangered Species Act Interagency Cooperation.  CPR's Holly Doremus, Robert Glicksman, Alejandro Camacho, Daniel Rohlf and Margaret Clune Giblin, joined by Mark Schwartz (UC Davis), October 10, 2008, Comments on the U.S. Fish & Wildlife Service and National Marine Fisheries Service's Proposed Rule on Interagency Cooperation under the Endangered Species Act.
• DOL Risk Assessment Comments.  Rena Steinzor and Policy Analyst Matt Shudtz's September 29, 2008 comments on DOL's Risk Assessment proposal. 
• Risk Assessment Request to Extend Comment Period.  Rena Steinzor's September 5, 2008 joint letter (with 38 other experts in regulatory and labor safety matters) to the Department of Labor requesting an extension of the 30-day comment period for its risk assessment guidelines.
• IRIS Letter.  Member Scholar Rena Steinzor and CPR Policy Analyst Matt Shudtz’s April 27, 2008 letter to EPA Administrator Stephen L. Johnson, expressing concerns about proposed “Integrated Risk Information System Assessment Development Procedures” that would slow the process of filling significant gaps in the database’s toxicological profiles for many chemicals EPA is responsible for regulating under the Clean Air, Safe Drinking Water, and Emergency Planning and Community Right to Know Acts.

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

• Mercury Credit-Trading. Catherine O'Neill's January 3, 2005 comments on EPA's proposed mercury pollution credit-trading scheme.
• Comments and Testimony on Mercury Pollution Credit-Trading.  Catherine O'Neill's January 3, 2005 comments to EPA on its mercury pollution credit-trading proposal.

• Comments on VOCs via IQA.  CPR's Sidney Shapiro and Rena Steinzor's August 3, 2004 response to the paint industry's Information Quality Act challenge to state rules on volatile organic compounds (VOCs) in paint.
• Steinzor CII Comments for DHS.  Rena Steinzor’s May 2004 comments on the Department of Homeland Security’s Procedures for Handling Critical Infrastructure Information (Interim Rule). 

• Comments on Peer Review Proposal.  CPR's Sidney Shapiro’s December 7, 2003 comments on OMB's Proposed Bulletin on Peer Review and Information Quality.
• Steinzor CII Comments for DHS.  Rena Steinzor’s June 16, 2003 comments on the Department of Homeland Security's proposed rule for handling Critical Infrastructure Information, in which she writes that "DHS needs to go back to the drawing board."
• Letter to EPA/OMB on IQA-related Effort to Censor NRDC.  Read a May 21, 2003 letter to EPA and OMB from Rena Steinzor and Sidney Shapiro, responding to an attempt by the Center for Regulatory Effectiveness' to use the Information Quality Act as a weapon to censor NRDC comments on a proposed rule regulating disposal of biosolids. And read CPR's news release. 

• Comments on Cooling Water Intake Standards.  Read August 2002 comments from a number of CPR Member Scholars on EPA's proposal to incorporate Cost-Benefit Principles into the Technology Based Standards for Cooling Water Intake Structures.
• Comments on IQA Guidelines. Read Thomas McGarity’s May 2002 Comments on OMB's Draft Information Quality Guidelines.