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:
Comment to the U.S. EPA on Preventing Chemical Disasters and Cost-Benefit Analysis

In a comment to the U.S. Environmental Protection Agency (EPA), CPR Senior Policy Analyst James Goodwin urges the agency to use any eventual rulemaking within the Risk Management Program to rework how cost-benefit analysis is used to evaluate rules. Goodwin encourages EPA to work with the White House Office of Management and Budget (OMB) and the Office of Information and Regulatory Affairs (OIRA) to take otherwise unquantifiable benefits into account and maximize protections from chemical disasters.

Type: Letters to Agencies (July 15, 2021)
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Author(s): James Goodwin
Joint Letter Proposing Recommendations to the U.S. Chemical Safety and Hazard Investigation Board

The Center for Progressive Reform joined 21 other public interest organizations in a letter proposing reforms and improvements to the U.S. Chemical Safety and Hazard Investigation Board. The recommendations are aimed at improving the functionality of the agency and better protecting communities from chemical disasters.

Type: Letters to Agencies (July 8, 2021)
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Joint Letter to President Biden and the EPA on Strengthening Select Air Pollution Standards

CPR joined dozens of public health, environmental, and other public interest organizations in urging the Biden White House and the EPA to strengthen air pollution standards for ozone and particulate matter. Both substances can cause or worsen a wide range of serious health problems, including asthma, other lung diseases, and cardiovascular conditions.

Type: Letters to Agencies (June 10, 2021)
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Author(s): James Goodwin
Joint Letter to Biden Administration on an Emergency Temporary Standard for COVID-19

CPR joined workers' rights, occupational safety and health, academic, and faith organizations and leaders in a letter to President Joe Biden, the White House Office of Management and Budget (OMB), and the Occupational Safety and Health Administration (OSHA) urging approval of OSHA's long overdue Emergency Temporary Standard to protect frontline workers from COVID-19.

Type: Letters to Agencies (April 28, 2021)
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Author(s): Minor Sinclair
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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