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 Comments on the Council on Environmental Quality's Proposed Climate and Economic Justice Screening Tool

The Center for Progressive Reform joined with partners at the Environmental Justice Health Alliance for Chemical Policy Reform and others to submit comments on the Council on Environmental Quality's climate and economic justice screening tool.

Type: Letters to Agencies (May 25, 2022)
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Joint Letter to CEQ Requesting Comment Period Extension on Carbon Capture Guidance

The Center for Progressive Reform joined dozens of other public interest organizations in a public comment period extension request for the White House Council on Environmental Quality's Carbon Capture, Utilization, and Sequestration Guidance. The groups asked the agency to extend the comment period from 30 days to at least 60 days.

Type: Letters to Agencies (Feb. 25, 2022)
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Testimony to the U.S. Environmental Protection Agency on the Mercury and Air Toxics Standard

Center for Progressive Reform Senior Policy Analyst James Goodwin testified on the importance of reinstating the "necessary and appropriate" finding for the U.S. Environmental Protection Agency's mercury and air toxics rule. The finding, rolled back during the Trump administration's deregulatory frenzy, is essential to ensure the rule stands and continues protecting all Americans — particularly children — from mercury and other dangerous toxins.

Type: Letters to Agencies (Feb. 24, 2022)
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Author(s): James Goodwin
Comments on EPA Environmental Justice Action Plan

The Center for Progressive Reform submitted feedback to the U.S. Environmental Protection Agency's Office of Land and Emergency Management regarding its Draft Environmental Justice Action Plan. The feedback notes that while the draft action plan is a necessary step to ensuring environmental justice impacts and benefits are proactively considered in the office's programs, there are opportunities to strengthen existing strategies. The feedback also urges EPA to consider additional strategies under the office's authority and with environmental justice implications that are currently missing from the draft plan.

Type: Letters to Agencies (Feb. 7, 2022)
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Author(s): Darya Minovi, David Flores, James Goodwin, Katlyn Schmitt
Joint Letter to the White House Office of Management and Budget on Modernizing Regulatory Review

The Center for Progressive Reform joined dozens of other organizations in a letter to the White House Office of Management and Budget, urging it and the Biden administration to get to work on making good on its goals to modernize, improve, and reform the current regulatory review process. That process often results in weaker standards and safeguards than are needed to protect all people and our environment.

Type: Letters to Agencies (Nov. 17, 2021)
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Joint Letter to the U.S. State Department on the Pending Au Pair Rule

The Center for Progressive Reform joined more than 100 workers’ rights organizations, national organizations, and local and community organizations in opposing the U.S. State Department's pending au pair rule. The rule would undermines labor standards and is at odds with the administration’s support for care workers.

Type: Letters to Agencies (Nov. 12, 2021)
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Testimony to the Maryland Occupational Safety and Health Division of Labor and Industry on Heat Stress Protections

CPR Senior Policy Analyst M. Isabelle Chaudry testified to the Maryland Occupational Safety and Health (MOSH) Division of Labor and Industry about heat stress protections for Maryland workers. She provided the agency with recommendations to ensure that its forthcoming standard is effective, strong, and worker-centered.

Type: Letters to Agencies (Sept. 23, 2021)
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Author(s): M. Isabelle Chaudry
Joint Comment to the Virginia Department of Environmental Quality on Updating Public Participation Guidelines

CPR Policy Analyst Katlyn Schmitt joined the Virginia Environmental Justice Collaborative in a public comment urging the Virginia Department of Environmental Quality to update its public participation guidelines. They urged DEQ to ensure meaningful public involvement in the regulatory activities of the state — including the relative state boards that make decisions related to air pollution, water pollution, and waste management.

Type: Letters to Agencies (Aug. 20, 2021)
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Author(s): Katlyn Schmitt
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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