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Center for Progressive Reform



Letters & Comments 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 by way of letters or other means of communication. 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 from 2011 forward follow. For comments and letters to agencies before 2011, visit this pageOr browse Member Scholars' congressional testimony.
 
Communication with Agencies (Letters, Comments and Testimony) from CPR Member Scholars and staff:
 
2017
2016
2015
  • Letter to Benjamin Grumbles, Secretary Maryland Department of the Environment, December 17, 2015, from CPR Member Scholar Rena Steinzor and others, urging prompt release of 2015 Frosh Report.
  • Letter to DOL on EO 13673 Guidance, August 27, 2015, by Celese Monforton, CPR Executive Director Matthew Shudtz, CPR Policy Analyst Katherine Weatherford, Nebraska Appleseed, Oxfam America, Southern Poverty Law Center urging rigorous standards for federal contractors.
2014
2013
  • 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.
 
2012
  • 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.
2011
  • 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.
 

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