Public Comments 2018 (147-

The New Progressive Alliance periodically makes Public Comments by itself or with other organizations to federal agencies and legislative bodies in the United States and Canada in support of the Unified Platform. They are reproduced here in full and also briefly mentioned with our other activities in the Annual Reports and on our website under "News." 

 

  • Public Comment 147: January 2018 - Congress-Clean Budget
  • Public Comment 148: February 2018 - Minnesota Public Utilities Commission - Stop Pipeline
  • Public Comment 149: February 2018 - Gov. Inslee - Stop Methanol Refinery
  • Public Comment 150: February 2018 - Port Kalama - Stop Methanol Refinery
  • Public Comment 151: March 2018 - Congress Oppose Poison Pill Riders
  • Public Comment 152: March 2018 - Congress Oppose Attacks on Clean Water
  • Public Comment 153: May 2018 - Idaho Dept. of Lands - Stop 3 Rail Bridges
  • Public Comment 154: May 2018 - USCG - Stop 3 Rail Bridges
  • Public Comment 155: May 2018 - Support CA Disclosure AB2188
  • Public Comment 156: May 2018 - Congress Oppose Ideological Extreme Riders
  • Public Comment 157: May 2018 - Canada Stop Kinder Morgan Pipeline
  • Public Comment 158: May 2018 - Congress Oppose Recessions and 15.3 Billion Dollar Cuts
  • Public Comment 159: June 2018 - Washington, D.C. Actions
  • Public Comment 160: June 2018 - FERC Pipeline Review Process
  • Public Comment 161: June 2018 - US Senate - SEC and FDIC Appointees
  • Public Comment 162: June 2018 - US HOR Leaders - Don't Weaken FSGG
  • Public Comment 163: July 2018 - US HOR - Oppose Irrelevant Riders
  • Public Comment 164: July 2018 - US HOR Rules Committee - Don't Limit SEC
  • Public Comment 165: July 2018 – Oregon DEQ and Army Corps of Engineers – Oppose Jordan Cove LNG
  • Public Comment 166: July 2018 – Washington Ecology – Stop Coal Expansion
  • Public Comment 167: July 2018 – US DOE - Clean Up Hanford Nuclear
  • Public Comment 168: July 2018 – US Senate – Oppose Irrelevant Riders
  • Public Comment 169: July 2018 - Congress - Don't Allow Adoption Discrimination
  • Public Comment 170: August 2018 – US Senate – No to Ms. Kraninger for CFPB
  • Public Comment 171: August 2018 – US Senate – No to non-experienced nominee for CFPB

 

 

 

Public Comment 147: January 2018 - Congress-Clean Budget

January 11, 2018

Dear Members of Congress,

We, the undersigned organizations as a part of the Clean Budget Coalition, write to ask you to oppose any FY 2018 omnibus or other spending measure which includes ideological poison pill policy riders.

The majority in Congress are quietly trying to slip in special interest wish list items via poison pill riders into the year-end funding packages.

Appropriations bills continue to be misused to undermine essential safeguards through partisan poison pill “policy riders” – provisions that address extraneous and unpopular policy issues. Slipping unrelated and damaging issues into must-pass appropriations bills as a means to win approval is a dangerous strategy for the public.

Poison pill riders are unpopular as standalone legislation, and the public opposes using them to roll back public protections. The American people support policies to:

• Restrain Wall Street abuses;
• Ensure safe and healthy food and products;
• Secure our air, land, water and wildlife;
• Safeguard fair and safe workplaces;
• Guard against consumer rip-offs and corporate wrongdoing;
• Defend our campaign finance and election systems;
• Provide access to justice and fair housing;
• Protect civil rights; and
• Guarantee continued access to vital health care services including reproductive health care, and more.

The Majority budget is rigged for billionaires and big business and could be especially dangerous when combined with their tax plan which features deep cuts that endanger our health and safety, our workplaces and wallets, as well as, our environment and our economy. In addition, any omnibus passed through Congress must go far beyond the obviously inadequate sequester funding levels, to robustly fund agencies and programs to protect the public.

There is an indisputable difference between partisan policy riders that hurt the public and popular policy solutions that are necessary and will help many. Policy solutions with broad bipartisan support are not only appropriate; they are necessary to address urgent situations or to extend essential services. Examples include extending the Children’s Health Insurance Program (CHIP), providing disaster funding to deal with catastrophic storms and wildfires, and protecting Dreamers.

We urge Members of Congress to support increasing the spending caps to fund pivotal programs for the American people with parity between defense and nondefense funds, while opposing any flawed omnibus that includes poison pill policy riders.

Sincerely,

National Groups

9to5, National Association of Working Women

Action on Smoking and Health

AFL-CIO

AFSCME

Alaska Wilderness League

Alliance for Retired Americans

American Association for Justice

American Bird Conservancy

Americans for Financial Reform

Asbestos Disease Awareness Organization

Association of Reproductive Health Professionals

Autistic Self Advocacy Network

Bend the Arc Jewish Action

Black Women’s Health Imperative

Carmelite NGO

Catholics for Choice

Center for Biological Diversity

Center for Justice & Democracy

Center for Progressive Reform

Center for Science in the Public Interest

Clean Water Action

Coalition on Human Needs

Common Cause

Communications Workers of America (CWA)

Consumer Action

Corporate Accountability International

Daily Kos

Defenders of Wildlife

Democracy 21

Earthjustice

Earthworks

Economic Policy Institute Policy Center

Endangered Species Coalition

Environment America

Family Equality Council

Free Press Action Fund

Friends of the Earth

Government Accountability Project

GreenLatinos

Grounded Solutions Network

Hip Hop Caucus

Hispanic Federation

Homeowners Against Deficient Dwellings

ICAST (International Center for Appropriate and Sustainable Technology)

Institute for Agriculture and Trade Policy

Interfaith Power & Light

Jewish Women International

Just Foreign Policy

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

Main Street Alliance

NAACP

NARAL Pro-Choice America

National Abortion Federation

National Asian Pacific American Women’s Forum (NAPAWF)

National Association for College Admission Counseling

National Association of Consumer Advocates

National Association of Social Workers

National Black Justice Coalition

National Center for Lesbian Rights

National Center for Transgender Equality

National Coalition for LGBT Health

National Coalition for the Homeless

National Council for Occupational Safety and Health

National Council of Jewish Women

National Education Association

National Employment Law Project

National Fair Housing Alliance

National Immigration Law Center

National Latina Institute for Reproductive Health

National Low Income Housing Coalition

National Partnership for Women & Families

National WIC Association

National Women’s Health Network

National Women’s Law Center

Natural Resources Defense Council

NETWORK Lobby for Catholic Social Justice

New America’s Open Technology Institute

New Progressive Alliance

Newtown Action Alliance

PAI

People For the American Way

Physicians for Social Responsibility

PLACE

Planned Parenthood Federation of America

PolicyLink

Population Connection Action Fund

Population Institute

Power Shift Network

Progressive Congress Action Fund

Public Citizen

Public Knowledge

Rachel Carson Council

Raising Women’s Voices for the Health Care We Need

Safe Climate Campaign

Service Employees International Union

Sexuality Information and Education Council of the U.S. (SIECUS)

Sierra Club

SiX Action

Stand Up America

States United to Prevent Gun Violence

The Arc of the United States

The Bright Lines Project

The Center for Reproductive Rights

The Impact Fund

The Wilderness Society

U.S. PIRG

UnidosUS (formerly National Council of La Raza)

Union of Concerned Scientists

United Church of Christ, OC Inc.

United Steelworkers

Voces Verdes

Voices for Progress

Woodstock Institute

Workplace Fairness

Young Invincibles

 

State Groups

AIDS Alabama, Inc.

Anti-Poverty Network of New Jersey

Arizona Coalition to End Homelessness

Arizona Housing Alliance

CALPIRG

CASA of Oregon

Church Women United in New York State

ConnPIRG

COPIRG

Earth Action, Inc.

Empower Missouri

Equality California

Florida Alliance for Consumer Protection

Florida PIRG

Georgia PIRG

Habitat for Humanity Virginia

Housing Action Illinois

Housing Community Development Network of NJ

HousingWorks RI

Illinois PIRG

Indiana PIRG

Iowa PIRG

Kentucky Equal Justice Center

Maryland PIRG

Massachusetts Consumers Council

MASSPIRG

Monarch Housing Associates

Montana Environmental Information Center

MontPIRG

MoPIRG

NCPIRG

New Jersey Association on Correction

New Jim Crow Movement – California & Florida

NHPIRG

NJPIRG

NMPIRG

Ohio CDC Association

Ohio PIRG

Oregon PIRG (OSPIRG)

PennPIRG

PeterCares House

PIRG in Michigan (PIRGIM)

Public Justice Center

RIPIRG

TexPIRG

The Interfaith Alliance of Colorado

Vermont Affordable Housing Coalition

Virginia Housing Alliance

Washington Low Income Housing Alliance

WASHPIRG

WISPIRG

 

Local Groups

AFGE Council 238

Alfred E Smirh Resident Association, New York, NY

Antioch Urban Ministries, Inc. DBA Matthew’s Place, Atlanta, GA

Central New York Citizens in Action, Inc., Utica, NY

Clarksburg-Harrison Regional Housing Authority, Harrison County, WV

Family Emergency Shelter Coalition (FESCO), Hayward, Alameda County, CA

Greater Kansas City Coalition to End Homelessness, Kansas City, MO

Harrington Investments, Inc., Napa, CA

Homeless Solutions, Inc., Morris County, NJ

Homestead Affordable Housing, Inc., Holton, KS

Housing Authority of the City of Columbia, MO

Lake County Crisis Center, Lake County, OR

Meals on Wheels of Lehigh County, PA

Plymouth Housing Group, Seattle, WA

ROSE Community Development, Portland, OR

Seattle Human Services Coalition, Seattle, WA

Sitka Community Land Trust, Sitka, AK

South Florida Community Development Coalition, Miami-Dade, FL

South Florida Interfaith Worker Justice

Southern Oregon Climate Action Now

Springfield Housing Authority, Springfield, IL

The Architects Collective, Los Angeles, CA

Toledo Area Jobs with Justice & Interfaith Worker Justice Coalition, Toledo, OH

YWCA-GCR, Inc., New York, NY

Sargent Shriver National Center on Poverty Law, Chicago, IL

 

Public Comment 148: February 2018 - Minnesota Public Utilities Commission - Stop Pipeline

February 25, 2018

Minnesota Public Utilities Commission
121 7th Place E, Suite 350
Saint Paul, MN 55101-2147

The New Progressive Alliance at http://newprogs.org/  urges you to reject the Line 3 tar sands pipeline because it threatens Indigenous rights, makes us more independent on fossil fuels, and threatens our water supply..

While the Minnesota Department of Commerce has completed revisions on the Final Environmental Impact Statement,  it missed the cultural resources survey despite the fact that five Indigenous Nations have repeatedly asked for it to be included.

Tar sands are the most polluting and extreme form of oil extraction. This pipeline would be a catastrophe for Indigenous rights, clean water, and the climate. It would put wild rice, lakes, and rivers at risk and lead to billions of dollars in damages from climate change. When decision day comes, with full information at hand, the PUC should say no to this dangerous project. 

This pipeline threatens our water, climate, and communities. With or without the survey, the PUC has plenty of reasons to reject this pipeline now. It's a catastrophe for Indigenous rights, clean water, and the climate and should not be built.

 

Public Comment 149: February 2018 - Gov. Inslee - Stop Methanol Refinery

February 25, 2018

             

Governor Jay Inslee

Office of the Governor

PO Box 40002

Olympia, WA 98504-0002

The New Progressive Alliance at http://newprogs.org/  urges you to oppose the proposed methanol refinery in Kalama, Washington. The reasons are increased pollution, increased utility costs for both electricity and natural gas, and because it is a bad business plan.

  1. Increased Pollution

Documentation for the below comes from the following sources.

In December 2014, Columbia Riverkeeper and the Northwest Environmental Defense Center submitted 319 pages of comments to the FERC and the state EIS scoping processes at Kalama, urging “the Port to prepare an EIS that fully and accurately discloses the wide reaching impacts of the proposed methanol export facility.”

In April 2016 the New Progressive Alliance urged the Washington state Draft Environmental Impact Statement to be updated to address the Kalama Natural Gas to Methanol Refinery increased dangers and pollution from fracking and natural gas, would use a lot of power which would be reflected in higher electricity rates, water use and contamination, and is founded on a bad business plan.

  • This would be the largest methanol refinery in the world.
  • It would dump up to 53 tons of toxic and hazardous pollutants into the air annually and emit over a million tons of carbon dioxide a year.
  • Methanol is flammable in liquid and gas states, and it is considered highly toxic to humans and animals. Just one gallon of spilled methanol depletes the oxygen from 198,000 gallons in the Columbia River. 
  • A Methanol Plant also produces waste that includes heavy metals, volatile organic compounds, various air pollutants, nickel, copper, and zinc oxide from the catalysts used in the refining process.
  • Air pollution that includes carbon dioxide, carbon monoxide, nitrogen oxide, sulfur dioxide, volatile organic compounds, and fine particulate matter.
  • They will burn 30 percent of the huge amount of natural gas used, adding to local pollution.
  • The Kalama methanol refinery will emit over a million tons of carbon dioxide a year.
  • Kalama methanol refinery’s air pollution risk is massive. They propose to emit up to 53 tons (106,000 pounds) of toxic and hazardous pollutants into the air annually. By comparison, Emerald Kalama Chemical released six tons of toxic and hazardous pollution in 2015, according to the EPA.
  • The plant also could emit up to 62 tons (104,000 pounds) of very fine particulate matter — dust and soot particles — annually. Fine particulate matter can enter into the respiratory system and cause long term health impacts. 
  • The plant would buy gas extracted by fracking. Specifically this plant would use at least 300,000 dekatherms of fracked gas per day (270,000 as raw material plus at least 30,000 for power generation) – one third as much gas as the entire state of Washington. Fracking, a dangerous technique for getting natural gas out of shale, has been linked to serious health risks, groundwater contamination, and other environmental impacts. Fracking companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011. For more documentation on Fracking see “The Environment,” #5, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • The Kalama Refinery would be fed by a new 3.1-mile, 24-inch diameter natural gas pipeline that will divert natural gas from the existing Northwest Pipeline. The New Progressive Alliance in the below documentation shows the danger of transporting fossil fuel, especially by pipes. For documentation on transporting fossil fuels by pipes and other means  see “The Environment,” #12, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • For pollution the Methanol Refinery discharges 200 gallons of wastewater per minute. The Methanol Refinery would also make a huge demand on water resources, using more than 2,500 gallons of water per minute or about 4 million gallons a day for cooling and gas forming, 90 percent of which is consumed during the process or lost as vapor to the atmosphere. It makes no sense that Kalama sell off millions of gallons of its fresh water every day when farmers and fishermen operated under emergency drought restrictions last summer. For more documentation on the dangers to fresh water   see “The Environment,” #14, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

  1. Higher Utility Costs for Electricity and Natural Gas

The Kalama Natural Gas to Methanol Refinery would use a lot of power which would be reflected in higher electricity rates, increased dangers and pollution from fracking and natural gas, water use and contamination, and is a bad business plan.

Methanol refining requires a lot of electricity. The plant would use 200 megawatts of electricity daily - equal to the amount of electricity used by ALL Cowlitz County residents. The plant would also use 1/3 as much gas as the entire state of Washington. These demands would most likely increase gas and power costs for Washington residents and businesses.

III.      The Kalama Natural Gas to Methanol Refinery is a bad business plan.

Northwest Innovation Works, owned by the Chinese Government and British Petroleum, wants to build this Methanol Refinery even though it has never built or run a methanol refinery. Indeed, the proposed technology has never been used to make methanol commercially.

The plan uses America for cheap energy and to dump pollutants, ships methanol for thousands of miles overseas to China, and then China uses it to make plastics which are then shipped back across the ocean to the United States.

The United States signed the United Nations Agreement COP 21 in 2015. The agreement states “Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7)  This means reporting so we will be compared with other countries. Therefor the United States will be in a poorer position for future bargaining just because of this one Methanol Refinery.

As China’s economy cools, it remains to be seen whether the huge profits that analysts envision for Northwest methanol exports are sustainable. In fact, the world methanol market has been oversupplied as recently as 2008, when many plants were just starting up. While the new proposed refineries would meet a near-term demand for cheap methanol in China, it remains to be seen what the Pacific Northwest will have gained after the gold rush fever abates. What it will have lost because of pollution, water depletion, and electricity usage is clear.

 

Conclusion:

Please consider the total pollution, the higher electricity rates, and this bad business plan and oppose the proposed methanol refinery in Kalama, Washington.

 

Public Comment 150: February 2018 - Port Kalama - Stop Methanol Refinery

Port of Kalama

SEIS@KalamaMfgFacilitySEPA.com

 

February 25, 2018

             

The New Progressive Alliance at http://newprogs.org/  urges you to oppose the proposed methanol refinery in Kalama, Washington. The reasons are increased pollution, increased utility costs for both electricity and natural gas, and because it is a bad business plan.

  1. Increased Pollution

Documentation for the below comes from the following sources.

In December 2014, Columbia Riverkeeper and the Northwest Environmental Defense Center submitted 319 pages of comments to the FERC and the state EIS scoping processes at Kalama, urging “the Port to prepare an EIS that fully and accurately discloses the wide reaching impacts of the proposed methanol export facility.”

In April 2016 the New Progressive Alliance urged the Washington state Draft Environmental Impact Statement to be updated to address the Kalama Natural Gas to Methanol Refinery increased dangers and pollution from fracking and natural gas, would use a lot of power which would be reflected in higher electricity rates, water use and contamination, and is founded on a bad business plan.

  • This would be the largest methanol refinery in the world.
  • It would dump up to 53 tons of toxic and hazardous pollutants into the air annually and emit over a million tons of carbon dioxide a year.
  • Methanol is flammable in liquid and gas states, and it is considered highly toxic to humans and animals. Just one gallon of spilled methanol depletes the oxygen from 198,000 gallons in the Columbia River. 
  • A Methanol Plant also produces waste that includes heavy metals, volatile organic compounds, various air pollutants, nickel, copper, and zinc oxide from the catalysts used in the refining process.
  • Air pollution that includes carbon dioxide, carbon monoxide, nitrogen oxide, sulfur dioxide, volatile organic compounds, and fine particulate matter.
  • They will burn 30 percent of the huge amount of natural gas used, adding to local pollution.
  • The Kalama methanol refinery will emit over a million tons of carbon dioxide a year.
  • Kalama methanol refinery’s air pollution risk is massive. They propose to emit up to 53 tons (106,000 pounds) of toxic and hazardous pollutants into the air annually. By comparison, Emerald Kalama Chemical released six tons of toxic and hazardous pollution in 2015, according to the EPA.
  • The plant also could emit up to 62 tons (104,000 pounds) of very fine particulate matter — dust and soot particles — annually. Fine particulate matter can enter into the respiratory system and cause long term health impacts. 
  • The plant would buy gas extracted by fracking. Specifically this plant would use at least 300,000 dekatherms of fracked gas per day (270,000 as raw material plus at least 30,000 for power generation) – one third as much gas as the entire state of Washington. Fracking, a dangerous technique for getting natural gas out of shale, has been linked to serious health risks, groundwater contamination, and other environmental impacts. Fracking companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011. For more documentation on Fracking see “The Environment,” #5, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • The Kalama Refinery would be fed by a new 3.1-mile, 24-inch diameter natural gas pipeline that will divert natural gas from the existing Northwest Pipeline. The New Progressive Alliance in the below documentation shows the danger of transporting fossil fuel, especially by pipes. For documentation on transporting fossil fuels by pipes and other means  see “The Environment,” #12, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • For pollution the Methanol Refinery discharges 200 gallons of wastewater per minute. The Methanol Refinery would also make a huge demand on water resources, using more than 2,500 gallons of water per minute or about 4 million gallons a day for cooling and gas forming, 90 percent of which is consumed during the process or lost as vapor to the atmosphere. It makes no sense that Kalama sell off millions of gallons of its fresh water every day when farmers and fishermen operated under emergency drought restrictions last summer. For more documentation on the dangers to fresh water   see “The Environment,” #14, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

  1. Higher Utility Costs for Electricity and Natural Gas

The Kalama Natural Gas to Methanol Refinery would use a lot of power which would be reflected in higher electricity rates, increased dangers and pollution from fracking and natural gas, water use and contamination, and is a bad business plan.

Methanol refining requires a lot of electricity. The plant would use 200 megawatts of electricity daily - equal to the amount of electricity used by ALL Cowlitz County residents. The plant would also use 1/3 as much gas as the entire state of Washington. These demands would most likely increase gas and power costs for Washington residents and businesses.

III.      The Kalama Natural Gas to Methanol Refinery is a bad business plan.

Northwest Innovation Works, owned by the Chinese Government and British Petroleum, wants to build this Methanol Refinery even though it has never built or run a methanol refinery. Indeed, the proposed technology has never been used to make methanol commercially.

The plan uses America for cheap energy and to dump pollutants, ships methanol for thousands of miles overseas to China, and then China uses it to make plastics which are then shipped back across the ocean to the United States.

The United States signed the United Nations Agreement COP 21 in 2015. The agreement states “Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7)  This means reporting so we will be compared with other countries. Therefor the United States will be in a poorer position for future bargaining just because of this one Methanol Refinery.

As China’s economy cools, it remains to be seen whether the huge profits that analysts envision for Northwest methanol exports are sustainable. In fact, the world methanol market has been oversupplied as recently as 2008, when many plants were just starting up. While the new proposed refineries would meet a near-term demand for cheap methanol in China, it remains to be seen what the Pacific Northwest will have gained after the gold rush fever abates. What it will have lost because of pollution, water depletion, and electricity usage is clear.

 

Conclusion:

Please consider the total pollution, the higher electricity rates, and this bad business plan and oppose the proposed methanol refinery in Kalama, Washington.

 

 

Public Comment 151: March 2018 - Congress Oppose Poison Pill Riders

OPPOSE POISON PILL CAMPAIGN FINANCE RIDERS IN FY18 OMNIBUS BILL

 

March 1, 2018

 All Members of Congress: 

We strongly urge you to oppose all campaign finance riders from being included in the FY18 Omnibus Appropriations legislation passed by Congress.  

Senate and House leaders have prevented floor consideration of any significant campaign finance reform measures for years. Instead of following regular order in the consideration of such legislation, they have instead attempted to attach riders to appropriations bills that would gut or seriously undermine campaign finance provisions, while not allowing up-or-down votes on the provisions.

One potential rider to the FY18 Omnibus Appropriations bill would gut the prohibition known as the Johnson amendment, which prevents Section 501(c)(3) organizations from engaging in campaign activities. 

A letter signed by more than 5,500 charitable nonprofits, religious organizations, and foundations strongly opposes any proposal to eliminate or weaken the longstanding Johnson amendment. 

In addition, more than 4,300 faith leaders representing every major religion have signed a letter strongly opposing attempts to repeal, amend, or otherwise tamper with the protections in the Johnson amendment.

The letter criticizes proposals that would “politicize the charitable nonprofit and philanthropic community by repealing or weakening current federal tax law protections that prohibit 501(c)(3) organizations from endorsing, opposing, or contributing to political candidates.” 

The letter from charitable groups provides the following explanation for support of the Johnson amendment:

 

Nonpartisanship is a cornerstone principle that has strengthened the public’s trust of the charitable community. In exchange for enjoying tax-exempt status and the ability to receive tax-deductible contributions, 501(c)(3) organizations – charitable nonprofits, including religious congregations, and foundations – agree to not engage in “any political campaign on behalf of (or in opposition to) any candidate for public office.”

 

That provision of law protects the integrity and independence of charitable nonprofits and foundations. It shields the entire 501(c)(3) community against the rancor of partisan politics so the charitable community can be a safe haven where individuals of all beliefs come together to solve community problems free from partisan divisions.

On another matter, a draft Senate Appropriations bill includes a rider that would gut the limit on political party spending coordinated with a candidate. This provision was upheld by the Supreme Court as necessary to prevent donors from using the political parties to massively circumvent the limits on the amount they could give directly to candidates. We strongly oppose including this provision in the FY18 Omnibus Appropriations bill.

In the last Congress, a campaign finance rider was enacted to prevent the SEC from finalizing regulations which would require public corporations to disclose their campaign activities to shareholders. This year’s draft version of the SEC rider would go even further and prevent the SEC from even studying such a rule.

The SEC has a vital role to play in ensuring corporate transparency for shareholders. More than 1.2 million investors and members of the public petitioned the SEC to create a rule requiring uniform corporate political disclosure – the most signers to a petition in SEC history. 

The last Congress also enacted a rider to prevent the IRS from implementing new regulations that would provide clear guidance to non-profit groups about the regulation of their campaign activities. This IRS rider would prevent nonprofit groups from obtaining a clear definition of campaign activities to assist them in complying with the law. The rider would also prevent the public from obtaining information about secret contributions spent in support of campaigns – information that citizens have a right to know. In preventing new IRS regulations, Congress is leaving in place a chronically broken IRS definition of “political campaign intervention” that allows those willing to game the system to pour secret money into our elections. 

The IRS and SEC campaign finance riders currently in the law keep the American people in the dark about the hundreds of millions of dollars in secret contributions that have flooded our elections in recent years. Secret contributions prevent citizens from holding officeholders and big donors accountable for corrupt practices. We strongly oppose including the IRS and SEC riders in the FY18 Omnibus Appropriations bill.

Another damaging campaign finance rider would prevent any requirement for federal contractors to disclose their political spending. Requiring federal contractors to disclose their political spending protects the federal contracting process by assuring the public that their tax dollars are not being used to reward contractors in return for campaign finance support.

Any effort to rewrite the nation’s campaign finance laws or to restrict related campaign finance measures should be done by regular order through the legislative process. This should not be done through the back-door misuse of the appropriations process that prevents members of Congress from voting on the specific provisions.  

We strongly urge you to oppose the inclusion of any campaign finance riders in the 2018 Omnibus Appropriations bill.

 

Signed,

 

California Clean Money Campaign

Campaign for Accountability

Campaign Legal Center

Center for Media and Democracy

Common Cause

CREW

Democracy 21

Every Voice

Franciscan Action Network

Free Speech for People

Friends of the Earth US

Interfaith Center for Corporate Responsibility.

Issue One

MapLight

New Progressive Alliance

Norman Eisen, former chief White House ethics lawyer, 2009-2011

Public Citizen

People For the American Way

Represent.Us

Revolving Door Project

Richard Painter, former chief White House ethics lawyer, 2005-2007

U.S. PIRG

United to Amend

Voices for Progress

 

 

Public Comment 152: March 2018 - Congress Oppose Attacks on Clean Water

March 1, 2018

 

RE: Over 115 groups oppose attacks on clean water safeguards in spending legislation for FY18

 In this letter to all members of congress:

Our organizations, along with our millions of members and supporters, urge you to oppose the inclusions of damaging ideological riders in any final spending legislation for Fiscal Year 2018, including those that attack much needed clean water protections.

In particular, three damaging policy riders that assault important water safeguards were included in the Department of the Interior, Environment, and Related Agencies appropriations bill that the Senate Appropriations Committee released in November of last year. These include:

 

  • Section 424 creates confusion about exemptions allowing polluters to more easily dump dredged or fill material into our waterways, destroying fish and wildlife habitat and flood storage capacity and degrading water quality downstream.
  • Section 433 would resurrect the Yazoo Backwater Pumps Project in Mississippi, essentially reversing the Bush administration's “veto” of this project and would lead to the unacceptable damage of 200,000 acres of ecologically-rich wetlands.
  • Section 434 would set a damaging precedent by exempting the Trump administration’s repeal of the Clean Water Rule from many requirements under the law.

 

Section 434 is especially radical. This provision aims to shield the EPA and Army Corps of Engineers’ repeal of the Clean Water Rule, which provides protections for the sources of drinking water of 117 million people, from public and legal scrutiny. This rider attempts to cut out the public’s ability to have a voice in the actions of their government and prevent court challenges to the Trump administration’s plan to allow polluters to dump into our waterways. If enacted, this rider would encourage the agencies to ignore Clean Water Act and Administrative Procedure Act requirements that they meaningfully consider public comment. It could also interfere with the court's’ ability to review if the repeal is “arbitrary or capricious.” 

 

It is hard to imagine a more undemocratic provision, especially when you consider that the Clean Water Rule was adopted after years of scientific research and public engagement. The water bodies at the center of the Clean Water Rule serve critical functions, including protecting the drinking water sources of one in three Americans, protecting essential fish and wildlife habitat necessary for a robust outdoor recreation economy, and providing critical ecosystem services such as water storage that can aid in protecting communities from flooding and drought. 

 

Additionally, the rider would create significant uncertainty around implementation, compliance, and enforcement of the Clean Water Act itself. It would allow the EPA and Army Corps to withdraw safeguards for waterways that clearly deserve to be protected from pollution, such as tributary streams, and leave many of them in a state of limbo. This would put our precious water bodies at risk of uncontrolled pollution, jeopardizing the clean water our children and grandchildren drink from and swim and play in.

Lastly, Section 434 could allow for numerous activities outside of the law from our governmental agencies by exempting the repeal from “any provision of statute or regulation that establishes a requirement for such withdrawal.” Taken at face value, this sweeping language could even allow the agencies to violate anti-corruption laws while withdrawing the Clean Water Rule.

Ultimately, this rider shows that the Trump administration’s allies in Congress recognize that the administration’s scheme to get rid of the Clean Water Rule and the drinking water protections it provides are unlawful.

In conclusion, we urge you to reject all policy riders attacking safeguards for the streams, wetlands, lakes, rivers, and other waters that our families, communities, and economy depend on, as well as broader attacks on our environment and public health. We want to reiterate our disappointment at seeing such politically-motivated attacks on important clean water safeguards in the underlying appropriations bill and urge you to remove these and all damaging, ideological provisions from any final spending legislation for Fiscal Year 2018.  

 

Thank you for your consideration.

 

Sincerely,

 

National Groups

Alaska Wilderness League

Alliance of Nurses for Healthy Environments

American Rivers

American Sustainable Business Council

Center for Environmental Health

Clean Water Action

Defenders of Wildlife

Earthjustice

Earthworks

Elders Climate Action

Endangered Species Coalition

Environment America

Environmental Protection Network

Green For All

GreenLatinos

Greenpeace

Hip Hop Caucus

Homeowners Against Deficient Dwellings

League of Conservation Voters

National Latino Farmers & Ranchers Trade Association

National Medical Association

National Parks Conservation Association

National Wildlife Federation

Natural Heritage Institute

Natural Resources Defense Council

Nature Abounds

New Progressive Alliance

Ocean River Institute

Physicians for Social Responsibility

PolicyLink

Power Shift Network

Progressive Congress Action Fund

Rachel Carson Council

River Network

Rural Coalition

Save EPA

Sierra Club

Upstream Policy

Waterkeeper Alliance

WE ACT for Environmental Justice

 

Regional Groups

Columbia Riverkeeper, Washington state and Oregon 

Environmental Law & Policy Center, Midwest

The Wetlands Initiative, Midwest

Freshwater Future, Great Lakes 

Healing Our Waters-Great Lakes Coalition, Great Lakes

Friends of the St. Joe River Association, Southwest Michigan and Northern Indiana

Gulf Restoration Network, Gulf Region

Lower Mississippi River Foundation, Lower Mississippi Region

Mississippi River Collaborative, states bordering Mississippi River

Southern Environmental Law Center, Southeastern US

Winyah Rivers Foundation, North and South Carolina

Citizens Campaign for the Environment, New York State and Connecticut

 

Local & State-based Groups

Alabama Rivers Alliance, Alabama 

Cahaba River Society, Birmingham, Alabama

Arkansas Wildlife Federation, Arkansas

Friends of the North Fork and White Rivers, Arkansas

California Coastkeeper Alliance, California

Community Water Center, Sacramento, California

Endangered Habitats League, Southern California

Erin Brockovich Foundation, Claremont, California

Friends of Harbors, Beaches, and Parks, Orange County, California

Friends of the River, California

Parents for a Safer Environment, California

Physicians for Social Responsibility, San Francisco Bay Area Chapter, San Francisco, California San Francisco Baykeeper, Oakland, California

Save The Bay, Oakland, California

San Juan Citizens Alliance, Colorado

Tampa Bay Waterkeeper, Tampa Bay, Florida

Center for a Sustainable Coast, Saint Simons Island, Georgia

Bluestem Communications - Mississippi River Network, Chicago, Illinois

Committee on the Middle Fork Vermilion River, Urbana, Illinois

Illinois Council of Trout Unlimited, Illinois

Prairie Rivers Network, Illinois

Hoosier Environmental Council, Indiana

Indiana Wildlife Federation, Indianapolis, Indiana

Kentucky Waterways Alliance, Louisville, Kentucky

Louisiana Audubon Council, New Orleans, Louisiana

Friends of Casco Bay, South Portland, Maine

Natural Resources Council of Maine, Augusta, Maine

Maryland Chapter Latino Farmers & Ranchers Trade Association, Maryland

Public Justice Center, Baltimore, Maryland

Charles River Watershed Association, Weston, Massachusetts 

Massachusetts Audubon, Lincoln, Massachusetts

Massachusetts Rivers Alliance, Massachusetts

Mystic River Watershed Association, Arlington, Massachusetts

Dwight Lydell Chapter of the Izaak Walton League of America , Grand Rapids, Michigan

Pearl Riverkeeper, Madison, Mississippi

Minnesota Environnental Partnership, St. Paul, Minnesota

Great Rivers Environmental Law Center, Saint Louis, Missouri

Great Rivers Habitat Alliance, Saint Louis, Missouri

Clark Fork Coalition, Missoula, Montana

Montana Audubon, Helena, Montana

Montana Conservation Voters Education Fund, Montana

Montana Trout Unlimited, Montana

Montana Wildlife Federation, Montana

Nebraska Chapter - Sierra Club, Omaha, Nebraska

Save The River / Upper St. Lawrence Waterkeeper, Clayton, New York

Izaak Walton League Central Ohio, Central Ohio

Oregon Environmental Council, Oregon

PennEnvironment, Philadelphia, Pennsylvania

PennFuture, Harrisburg, Pennsylvania

Pennsylvania Council of Churches, Harrisburg, Pennsylvania

Congaree Riverkeeper, Columbia, South Carolina

Edisto Riverkeeper, Aiken, South Carolina

Harpeth Conservancy, Brentwood, Tennessee

Tennessee Clean Water Network, Tennessee

Utah Rivers Council, Salt Lake City, Utah

Virginia Conservation Network, Richmond, Virginia

Virginia League of Conservation Voters, Richmond, Virginia

Puget Soundkeeper Alliance, Seattle, Washington

A.D. Sutherland Chapter-Izaak Walton League of America, Fond du Lac, Wisconsin

Milwaukee Riverkeeper, Milwaukee, Wisconsin

Superior Rivers Watershed Association, Ashland, Wisconsin

Wisconsin Division of the Izaak Walton League of America, Amherst Junction, Wisconsin Wisconsin Wildlife Federation, Madison, Wisconsin

OVEC-Ohio Valley Environmental Coalition, Huntington, West Virginia

 

Public Comment 153: May 2018 - Idaho Dept. of Lands - Stop 3 Rail Bridges

May 9, 2018

Subj: Burlington Northern Santa Fe (BNSF) railroad bridge expansion project (USACE Application No. NWW-2007-01202)

 

The New Progressive Alliance at http://www.newprogs.org/     urges you to reject BNSF’s proposal to build three new rail bridges in the Sand Creek/Lake Pend Oreille watershed.

Please consider the following adverse effects:

  • Lake Pend Oreille is the biggest fresh water Lake in Idaho. Lake Pend Oreille is Idaho’s largest and deepest lake. It is home to threatened bull trout and an entire ecosystem of aquatic life; the lake provides a regional drinking water source and is a major tourism asset. In 2017 alone, four trains derailed in this area near waterways. Just a single fossil fuel train derailment could damage and change Lake Pend Oreille forever.
  • Water quality – increased transport of hazardous materials through the watershed and the possibility of derailment into our local waterways threatens water quality.
  • Wildlife habitat – filling wetland and nearshore areas of the lake for additional bridge construction damages sensitive wildlife habitat beyond repair. The proposed project is within the range of bull trout and its critical habitat.
  • Traffic – increased train traffic flow through at-grade rail crossings may cause more traffic congestion, not less, as proposed by BNSF. Rail traffic is expected to increase to 114 trains per day (from 58 per day now) by 2025.
  • Emergency response – increased train traffic flow through at-grade rail crossings may cause emergency response delays.
  • Noise – increased train traffic may result in more whistle-related noise pollution at and around rail crossings.
  • Economy – increased train traffic may impact local businesses, property values, aesthetics and the tourism industry.

 

The proposal is to build three new rail bridges in the Sand Creek/Lake Pend Oreille watershed and the record on transportation of fossil fuels is not good. We should not be expanding unsafe fuel transportation with pipelines, trains, and other devices. (See reference 536. For a list of pipeline accidents since 2000 see reference 3296.) There has been a huge expansion in pipelines and dangerous fuel transportation by rail and truck.

For verification see  references 7, 8, 11, 13, 18, 19, 24, 31, 47, 55, 57, 62, 138, 154, 165, 214, 304, 310, 319, 331, 335, 337, 338, 341, 381, 383, 384, 395, 427, 447, 457, 487, 501, 508, 510, 512, 530, 536, 538, 539, 543, 548, 549, 566, 567, 568 - 574, 577, 578, 586 - 588, 596 - 598, 605, 606, 640, 721 - 724, 734 - 736, 778 - 780, 784, 849 - 855, 891, 974 - 981, 1081, 1082 - 1093, 1120, 1204 - 1212, 1354, 1389 - 1430, 1564-1565, 1603-1619, 1695-1697, 1734-1737, 1742, 1743, 1775, 1792-1809, 1978-1986, 2155-2175, 2242, 2251, 2320, 2459-2468, 2575-2579, 2812, 2825-2834, 2987-2989, 3175, 3189, 3231, 3284-3315, 3494-3496, 3882-3887, 3916, 3917 of this article “The Environment” located at: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

The proposed project involving three bridges encourages rail activity with cumulative impacts that affect communities far beyond Sandpoint, Bonner County and North Idaho.  The New Progressive Alliance urges you to reject BNSF’s proposal to build three new rail bridges in the Sand Creek/Lake Pend Oreille watershed.

 

Public Comment 154: May 2018 - USCG - Stop 3 Rail Bridges

May 8, 2018

The Honorable Steven M. Fischer

Thirteenth Coast Guard District

915 2nd Ave., Rm 3510

Seattle, WA 98174

 

Email: D13-PF-D13BRIDGES@uscg.mil

 

Subj: needed Environmental Impact Statement for Burlington Northern Santa Fe (BNSF) railroad bridge expansion project (USACE Application No. NWW-2007-01202)

Dear Mr. Fischer:

The New Progressive Alliance at http://newprogs.org/  urges you to require an Environmental Impact Statement rather than merely an Environmental Assessment for BNSF’s proposal to build three new rail bridges in the Sand Creek/Lake Pend Oreille watershed.

The National Environmental Policy Act requires an Environmental Impact Statement for actions "significantly affecting the quality of the human environment." An Environmental Assessment usually finds that no significant impact is likely and approves the action.

Clearly this calls for an Environmental Impact Statement.  Lake Pend Oreille is the biggest fresh water Lake in Idaho. Lake Pend Oreille is Idaho’s largest and deepest lake. It is home to threatened bull trout and an entire ecosystem of aquatic life; the lake provides a regional drinking water source and is a major tourism asset. In 2017 alone, four trains derailed in this area near waterways. Just a single fossil fuel train derailment could damage and change Lake Pend Oreille forever.

The proposal is to build three new rail bridges in the Sand Creek/Lake Pend Oreille watershed and the record on transportation of fossil fuels is not good. We should not be expanding  unsafe fuel transportation with pipelines, trains, and other devices. (See reference 536. For a list of pipeline accidents since 2000 see reference 3296.) There has been a huge expansion in pipelines and dangerous fuel transportation by rail and truck.

For verification see  references 7, 8, 11, 13, 18, 19, 24, 31, 47, 55, 57, 62, 138, 154, 165, 214, 304, 310, 319, 331, 335, 337, 338, 341, 381, 383, 384, 395, 427, 447, 457, 487, 501, 508, 510, 512, 530, 536, 538, 539, 543, 548, 549, 566, 567, 568 - 574, 577, 578, 586 - 588, 596 - 598, 605, 606, 640, 721 - 724, 734 - 736, 778 - 780, 784, 849 - 855, 891, 974 - 981, 1081, 1082 - 1093, 1120, 1204 - 1212, 1354, 1389 - 1430, 1564-1565, 1603-1619, 1695-1697, 1734-1737, 1742, 1743, 1775, 1792-1809, 1978-1986, 2155-2175, 2242, 2251, 2320, 2459-2468, 2575-2579, 2812, 2825-2834, 2987-2989, 3175, 3189, 3231, 3284-3315, 3494-3496, 3882-3887, 3916, 3917 of this article “The Environment” located at: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

The following adverse effects should also be considered.

  • Water quality – increased transport of hazardous materials through the watershed and the possibility of derailment into our local waterways threatens water quality.
  • Wildlife habitat – filling wetland and nearshore areas of the lake for additional bridge construction damages sensitive wildlife habitat beyond repair. The proposed project is within the range of bull trout and its critical habitat.
  • Traffic – increased train traffic flow through at-grade rail crossings may cause more traffic congestion, not less, as proposed by BNSF. Rail traffic is expected to increase to 114 trains per day (from 58 per day now) by 2025.
  • Emergency response – increased train traffic flow through at-grade rail crossings may cause emergency response delays.
  • Noise – increased train traffic may result in more whistle-related noise pollution at and around rail crossings.
  • Economy – increased train traffic may impact local businesses, property values, aesthetics and the tourism industry.

 

The proposed project involving three bridges encourages rail activity with cumulative impacts that affect communities far beyond Sandpoint, Bonner County and North Idaho. All of these adverse impacts need to be thoroughly evaluated through an Environmental Impact Statement. The New Progressive Alliance urges you to follow the National Environmental Policy Act and require an Environmental Impact Statement.

 

Public Comment 155: May 2018 - Support CA Disclosure AB2188

May 2018

The Honorable Marc Berman Chair, Assembly Elections and Redistricting Committee State Capitol, Room 5135 Sacramento, CA 95814

 

Cc: The Honorable Kevin Mullin and other Members of the Assembly Elections and Redistricting Committee

 

RE:  AB 2188, the Social Media DISCLOSE Act (Mullin) – Support

Dear Assemblymember Berman:

The organizations listed below are pleased to support AB 2188, the Social Media DISCLOSE Act.

An estimated $1.4 billion was spent on online political advertising nationally in 2016 (per Borrell Associates), an astounding 789% increase from 2012.  Nearly $600 million of it went to social media ads.  Virtually none of them disclosed who paid for them, including at least $100,000 in Facebook ads by Russian entities.

The congressional Honest Ads Act (S. 1989), introduced with bipartisan support and endorsed by both Facebook and Twitter, is an important response to this threat and lack of transparency because it requires online platforms to display disclosures on political ads and to provide a publicly available database of all such ads.  But it applies to only federal elections and requires only the name of the committee or person paying for the ad, not any of its top funders.

AB 2188 is a California version of the Honest Ads Act that applies to California elections and that will have a significantly greater impact because it leverages last year's California DISCLOSE Act (AB 249), now law, by requiring the paying committee to clearly list its top three funders.

AB 2188 will:

 Require online platforms such as Facebook, Google, and Twitter to include a “Who funded this ad?” or “Paid for by” link, next to their “Promoted” or “Sponsored” label, that will take viewers to the committee’s profile page on the platform or to a website with AB 249’s required disclosure information.

 Require committee profile pages on social media platforms to display their AB 249 top three contributor disclosure in the top cover photo where viewers can easily see it after clicking “Who funded this ad?”

 Require social media platforms to keep a publicly accessible database of the political ads that committees pay for, and to include a link or tab on the profile page of any committee that pays for an ad on the platform for voters to view, similar to the Honest Ads Act’s requirements.

AB 2188 is a simple yet powerful extension of last year’s AB 249.  AB 249 already requires electronic media ads to include a “Who funded this ad?” link to a website with the required top three contributor disclosure. Technically, however, ads on social media and some online platforms like Google ads do not make this possible.  

AB 2188 is a direct analog of the bipartisan Honest Ads Act for California elections, and also provides significantly more information to voters because it links to existing AB 249 requirements that social media profile pages clearly list their top 3 funders, with ballot measure ads required to use AB 249’s nation-leading earmarking rules to show the true funders even if they try to hide behind front groups.

Californians are crying out for this kind of disclosure.  More than 100,000 Californians signed petitions for the California DISCLOSE Act last year.  AB 249 passed with overwhelming bipartisan support in both houses.

This strong support for disclosure extends to political ads on social media platforms.  A February 2018 poll of 617 likely California voters by the California Clean Money Campaign found that 73% of California voters favored “requiring social media sites like Facebook and Twitter to provide on political advertisements a clear link to a page with their top true funders”.  Support was overwhelming across the board, with 81% of Democrats, 68% of Republicans, and 76% of independents in support.

AB 2188 closes the current disclosure loophole for online platforms to provide Californians the information they want and need about who's funding social media political ads which skyrocket in importance every election.

For these reasons, the organizations listed below respectfully SUPPORT AB 2188 and request your AYE vote.

 

Public Comment 156: May 2018 - Congress Oppose Ideological Extreme Riders

May 17, 2018

Dear Members of Congress,

As a part of the Clean Budget Coalition, we, the undersigned organizations write to ask you to oppose any FY 2019 appropriations measures which include ideological poison pill policy riders.

Time and time again, members of Congress attempt to quietly slip in special interest wish list items that couldn’t pass as standalone legislation into must-pass funding packages as poison pill riders.

Appropriations bills must not be misused to undermine essential safeguards. Slipping unrelated and damaging issues into must-pass appropriations bills as a means to win approval is a dangerous strategy for the public.

Poison pill riders are unpopular and damaging, and the public opposes using them to roll back public protections. The American people support policies to:

  • Restrain Wall Street abuses;
  • Ensure safe and healthy food and products;
  • Secure our air, land, water and wildlife;
  • Safeguard fair and safe workplaces;
  • Guard against consumer rip-offs and corporate wrongdoing;
  • Defend our campaign finance and election systems;
  • Provide access to justice and fair housing;
  • Protect civil rights; and
  • Guarantee continued access to vital health care services including reproductive health care, and more.

This year, in addition to threatening the budget process with harmful riders, the White House proposed rescissions that would claw back funds already appropriated in past spending packages — reneging on bipartisan agreements, where the latest took more than 15 months to pass. Like poison pill riders, rescissions cater to ideological extremists, represent a breach of regular order and threaten Congress’ ability to reach bipartisan spending agreements.

We urge Members of Congress to oppose the White House rescissions package, to abide by the funding numbers agreed upon in that deal to fund the essential programs our nation needs for FY19, and to reject any flawed spending measures that includes poison pill policy riders.

Sincerely,

National Groups
Action on Smoking and Health
AFL-CIO
AFSCME
Alaska Wilderness League
American Association for Justice
American Federation of Teachers
Americans for Financial Reform
Association of Farmworker Opportunity Programs
Autistic Self Advocacy Network
Bend the Arc Jewish Action
Black Women’s Health Imperative
Center for Reproductive Rights
Clean Water Action
Coalition on Human Needs
Common Cause
Communications Workers of America (CWA)
Compassion & Choices
Consumer Federation of America
Center for Science in the Public Interest
Democracy 21
Earthjustice
Endangered Species Coalition
Farmworker Justice
Friends of the Earth – US
Hip Hop Caucus
Hispanic Federation
Homeowners Against Deficient Dwellings
Impact Fund
Institute for Agriculture and Trade Policy
International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America, UAW
Jewish Women International
The Leadership Conference on Civil and Human Rights
League of Conservation Voters
League of Women Voters of the United States
Main Street Alliance
NARAL Pro-Choice America
National Association for College Admission Counseling
National Association of Consumer Advocates
National Coalition for the Homeless
National Council of Jewish Women
National Education Association
National Employment Law Project
National Health Care for the Homeless Council
National Low Income Housing Coalition
National Women’s Health Network
National Women’s Law Center
Natural Resources Defense Council
New Progressive Alliance
Oceana
PAI
People For the American Way
PLACE
Planned Parenthood Federation of America
Population Institute
Power Shift Network
Protect All Children’s Environment
Public Citizen
Public Knowledge
Rachel Carson Council
Restore America’s Estuaries
Safe Climate Campaign
Service Employees International Union (SEIU)
Sierra Club
The Arc of the United States
The Wilderness Society
U.S. PIRG
Union of Concerned Scientists
Voices for Progress
Workplace Fairness
Young Invincibles

State Groups
Hispanic Federation, Connecticut
Hispanic Federation, Florida
New Jersey Association on Correction, New Jersey
Public Justice Center, Maryland
Save Our Sky Blue Waters, Minnesota

 

Public Comment 157: May 2018 - Canada Stop Kinder Morgan Pipeline

May 19, 2018

 

Canadian Consulate General
1501 Fourth Avenue, Suite 600
Seattle, WA 98101-4328
United States

seatl@international.gc.ca 

Dear Honorable Ambassador,

The New Progressive Alliance with members in both Canada and the United States at http://newprogs.org/  urges the Canadian government immediately withdraw support for the Kinder Morgan pipeline in British Columbia. With the very unfortunate current policies of the United States, it is more important than ever for Canada to set a good example for us.

The Canadian tar sands are one of the largest and dirtiest pools of carbon on the planet. New pipelines like Kinder Morgan would allow for massive expansion of tar sands. This is an unacceptable risk for most of the world.

Climate Change and results already being felt are not a matter for controversy among the overwhelming majority of published credentialed scientists in the field. The danger is if we reach certain tipping points then we will not be able to recover. This will be disastrous for future generations. Climate Change is a matter of weather and physics. Politicians, rich people, the failure of people to believe, or government charades pretending to do something will have no effect. If we fail then future generations will likely judge us by this issue more than any other.

There is a huge cost to using fossil fuels because of climate change and the resulting damage to the economy, increased health costs, and environmental damage which is paid for by the government rather than fossil fuel industries. 

There is also a huge cost to using fossil fuels because of fossil fuel subsidies which far exceed renewable energy subsidies.   Worldwide global subsidies are $5.3 trillion dollars (£3.4tn) a year, equivalent to 10 million dollars a minute, according to a startling new estimate by the International Monetary Fund. The $5.3 trillion dollar subsidy estimated for 2015 is greater than the total health spending of all the world’s governments. (see reference 2507 and those below) The costs to the United States alone is between ten and fifty two billion dollars a year and does not include health costs mentioned below as externalities.

These subsidies include tax breaks, incentives for production on federal lands (such as royalty fees that haven't been adjusted in 25 years) and tax deductions for clean-up costs. If state subsidies for oil, gas and coal production are also included, the total value climbs to $21.6 billion for 2013. It is estimated that the world will spend an extra $8 trillion over the next 25 years to prolong the use of non-renewable resources, an estimate that may be way too conservative in light of the IMF's estimate of 5.3 trillion dollars in 2015 alone mentioned above. One study showed the world wide costs for fossil fuel subsidies to be 5 trillion dollars a year and 6.5% of the Global Domestic Product. (See reference 3796.) That cost would be completely eliminated by eventually transitioning instead to 100% renewable energy. (100% renewable energy is technically feasible. See below "We Can Do It If We Want To.")

More than just the costs of massively subsidizing the failed fossil fuel business model is involved. There are also externalities - such as healthcare costs due to pollution, government guaranteed loans, environmental destruction through mountaintop removal for coal, tar sands oil drilling, fracking for natural gas, and wars for oil and uranium.  Also consistently ignored is the price for adjusting to the effects of global climate change - even if possible - is far greater than the cost of stopping global warming at this stage. What we have now is private profit and public risk with the tax payers picking up the tab.

Unlike the climbing costs of fossil fuels, the cost of renewable energy is declining and has been for decades. One should compare the total costs of fossil fuels with the total costs of renewable energy. Documentation for both the costs of using fossil fuels, externalities, and fossil fuel subsidies are below.

Documentation of climate change and the world wide costs are below. The New Progressive Alliance hopes that Canada will do the right thing by denying the Kinder Morgan pipeline and continue to provide the good example the United States needs.

 

Sincerely,

 

New Progressive Alliance

 

The below references are all in the article “The Environment” at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

For documentation of climate change see references 10, 17, 32, 64, 78, 79, 81, 85, 88, 93 - 95, 102, 105, 107, 110, 113, 119, 122, 127, 128, 130, 144, 146, 152, 164, 170 - 172, 176, 177, 182, 185, 186, 204 - 206, 208 - 210, 221, 225, 228, 234, 246, 255, 272, 297, 311, 312, 317, 318, 322, 333, 335, 336, 343, 349, 357, 362, 368, 387, 391, 392, 394, 399, 400, 403, 413, 415, 417 - 419, 426, 440, 441 - 444, 455, 460, 464 - 467, 499, 502, 503, 505, 509, 511, 527, 532, 537, 550, 577, 578, 581, 592, 594, 600, 601, 634, 635, 650 - 652, 653 - 664, 666, 667, 690, 707 - 710, 750 - 760, 776, 801 - 808, 829, 840 - 842, 883 - 899, 1009 - 1023, 1122, 1123, 1124, 1125 - 1155, 1174, 1198, 1199, 1200 - 1202, 1213, 1215, 1238 - 1290, 1472-1524, 1652, 1664-1665, 1671-1682, 1715-1721, 1746-1771, 1851-1896, 2015, 2043-2089, 2123, 2152-2154, 2177, 2193, 2205-2223, 2250, 2267, 2302, 2325-2381, 2419, 2224-2539, 2574, 2598, 2626, 2636-2700, 2741, 2998-3142, 3179, 3210, 3274, 3350-3359, 3378-3435, 3450, 3451, 3516-3519, 3539, 3578, 3611-3772, 3895, 3897, 3898, 3902-3905, 3907, 3908, 3909, and 3915.

For documentation of the costs we face by not responding to climate change see references 146, 725, 762, 771 - 775, 809 - 812, 832, 875, 900 - 904, 1013, 1037 - 1039, 1128, 1157, 1158, 1201, 1313 - 1325, 1479, 1480, 1530, 1533-1551, 1585, 1631, 1666, 1683-1684, 1725-1727, 1752, 1772-1778, 1788, 1813-1824, 1833-1834, 1836-1837, 1906-1907, 1961, 1966-1968, 2053, 2104-2121, 2140, 2180, 2222, 2227-2234, 2248, 2309,2329, 2335, 2336, 2389-2392, 2394, 2395, 2399-2412, 2420, 2425, 2460, 2487, 2506-2512, 2526-2529, 2551-2554, 2598, 2600, 2642-2653, 2679, 2688, 2695, 2717-2719, 2739-2753, 2762, 2901-2905, 2939, 2944, 2964, 3001, 3030-3051, 3087, 3088, 3143, 3145, 3152, 3153, 3159, 3161, 3176, 3180-3208, 3316, 3352-3355, 3378-3402, 3437-3449, 3461, 3503, 3519, 3520, 3545-3547, 3599, 3633-3710, 3780-3846, 3875, 3896, 3897, 3902, 3903, and 3908.

 

Public Comment 158: May 2018 - Congress Oppose Recessions and 15.3 Billion Dollar Cuts

May 22, 2018

 

Dear Representative/Senator:

 

The undersigned 151 national organizations strongly urge you to reject the $15.3 billion rescissions package proposed by the Trump Administration as well as other rescissions messages that may be

subsequently offered. These cuts would violate the agreement enacted in the Bipartisan Budget Act by eliminating funds that make fairer levels of domestic appropriations possible, so that unmet needs in public health, education, job training, housing, and other essential areas may be addressed.

 

The Children’s Health Insurance Program (CHIP) is targeted for nearly half the cuts in the rescissions package. Nearly $2 billion of the rescinded funds could reduce CHIP’s capacity to respond if enrollment unexpectedly rises, as in the aftermath of a disaster, large layoffs due to plant closures, or an overall economic slowdown. Congress just enacted a long-overdue 10-year reauthorization of CHIP; it should not undermine that bipartisan agreement by tampering with CHIP in this package.

 

Another $5 billion would renege on the two-year Bipartisan Budget Act agreement, which in part counted on the availability of unspent CHIP funds to pay for needed increases in other services of importance to children and families.

 

The rescissions package also includes an $800 million cut to the Center for Medicare and Medicaid Innovation, a program which according to the Congressional Budget Office will save $3 for every $1 spent between 2017 and 2026. It makes no sense to end such a cost-effective investment. Nor does it make sense to describe this package of cuts as putting “...our Nation on a sustainable fiscal path” when the recently enacted tax cuts, mainly for the wealthy and corporations, impose a $2 trillion cost.

 

Congress made important progress in the FY 2018 Omnibus appropriations bill because its bipartisan agreement allowed for increases in child care, opioid treatment, and other services. Congress should now turn its attention to building on this progress in FY 2019. Reneging on these hard-won bipartisan agreements now will make further gains extremely difficult. With the limited number of legislative days before you, please do not be distracted by undoing past progress.

 

We cannot emphasize enough that basic needs programs have lost ground after years of reductions, making it extremely important that you do not undermine the agreement to start to reverse these downward trends. Adult and youth job training has been cut nearly 15 percent since FY 2010, adjusted for inflation. If we are serious about helping people to get good jobs, we must undo these cuts. Many other services need rebuilding, such as home heating and cooling assistance (cut nearly 38 percent since FY 2010), juvenile justice programs (cut more than 40 percent), maternal and child health programs (cut 14 percent), and special education funding (cut between 7and 11 percent since FY 2010). In an analysis of more than 180 human needs programs, the Coalition on Human Needs found that nearly 70 percent are still at lower levels than in FY 2010.

 

Please reject this rescissions package, and turn instead to your real responsibility: to provide adequate resources to address the unmet needs for education and training, child care, housing, health care, and other essential services.

 

Sincerely,

 

Action on Smoking and Health

ADAP Advocacy Association

Advance CTE

African American Health Alliance

AFSCME

AIDS United

Allied Progress

American Association of People with Disabilities

American Association on Health and Disability

American Federation of Teachers

Americans for Democratic Action (ADA)

Asian Americans Advancing Justice -AAJC

Association of American Veterinary Medical Colleges

Association of Farmworker Opportunity Programs

Autism Society of America

Autistic Self Advocacy Network

Bend the Arc Jewish Action

CAEAR Coalition

Campaign for Youth

Justice

Center for Community Change Action

Center for Employment Opportunities (CEO)

Center for Law and Social Policy (CLASP)

Center for Popular Democracy Action

Center for Public Representation

Ceres Policy Research

Child Care Aware of America

Child Welfare League of America

Children's Defense Fund

Children's Leadership Council

Children’s Advocacy Institute

Christopher and Dana Reeve Foundation

Coalition for Health Funding

Coalition for Juvenile Justice

Coalition on Human Needs

Community Access National Network (CANN)

Congregation of Our Lady of Charity of the Good Shepherd, US Provinces

Council on Social Work Education

Disciples Center for Public Witness

Dominican Sisters Conference

Dominican Sisters of Peace

Ecumenical Poverty Initiative

Equal Rights Advocates

Evangelical Lutheran Church in America

Every Child Matters

Faith in Public Life

Families USA

Family Focused Treatment Association

Food & Water Watch

Food Research & Action Center (FRAC)

Forum for Youth Investment

Friends Committee on National Legislation

Friends of the Earth -US

Girls Inc.

Grounded Solutions Network

Health Care for America Now

Healthy Teen Network

HEAR US Inc.

Hispanic Federation

HIV Medicine Association

Holy Spirit Missionary Sisters, USA-JPIC

Housing Works, Inc.

International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America,

UAW

Justice in Aging

Lakeshore Foundation

Leadership Conference of Women Religious

League of Women Voters of the United States

LIFT

Main Street Alliance

Mom2Mom Global

MomsRising

NAACP

NARAL Pro-Choice America

National Action Network

National Advocacy Center of the Sisters of the Good Shepherd

National Alliance of HUD Tenants

National Association of Councils on Developmental Disabilities

National Association of Counsel for Children

National Association of Regional Councils

National Association of Social Workers

National Association of State Head Injury Administrators

National Association for Bilingual Education

National Black Justice Coalition

National Coalitionfor the Homeless

National Coalition of STD Directors

National Consumer Law Center (on behalf of its low income clients)

National Council of Jewish Women

National Crittenton

National Disability Institute

National Domestic Workers Alliance

National Education Association

National Employment Law Project

National Employment Lawyers Association

National Housing Trust

National Indian Education Association

National Juvenile Justice Network

National Low Income Housing Coalition

National Network for Youth

National Network to End Domestic Violence

National Organization for Women

National Urban League

National WIC Association

National Women's Health Network

National Women's Law Center

New Progressive Alliance

North American Passionists, JPIC

People Demanding Action

People For the American Way

Planned Parenthood Federation of America

Poligon Education Fund

Provincial Council Clerics of St. Viator (Viatorians)

Public Advocacy for Kids

Public Citizen

Rachel Carson Council

Racial and Ethnic Health Disparities Coalition

Raising Women's Voices for the Health Care We Need

RESULTS

Ryan White Medical Providers Coalition

Safer Foundation

School Social Work Association of America

Service Employees International Union

Sinsinawa Dominicans

Sisters of Charity of Nazareth Western Province Leadership

Sisters of Charity of the Blessed Virgin Mary

Sisters of Mercy South Central Community

SocioEnergetics Foundation

Somerset Development Company

SparkAction

StoptheDrugWar.org

Strategies for Youth, Inc.

Students for Sensible Drug Policy

The Arc of the United States

The Children’s Partnership

The John Leary Organization

The Leadership Conference on Civil and Human Rights

The United Methodist Church -General Board of Church and Society

Transportation Learning Center

Treatment Action Group

Tuberous Sclerosis Alliance

UnidosUS

United Church of Christ

United Methodist Women

Voices for Progress

  1. Haywood Burns Institute

WildWest Institute

Woodhull Freedom Foundation

Woodstock Institute

Workplace Fairness

Young Invincibles

Youth Service America

YWCA USA

ZERO TO THREE

 

 

Public Comment 159: June 2018 - Washington, D.C. Actions

The New Progressive Alliance endorsed actions in June 23 – 25, 2018 in Washington, D.C.  by Beyond Extreme Energy and the Poor Peoples’ Campaign. Below are other endorsers.

198 methods

350 NJ-Rockland

350NYC (http://world.350.org/nyc/)

350 Loudoun (https://350loudoun.org/)

Alliance to Protect Our People and the Places We Live (www.apppl.org)

AMP Creeks Council

Appalachians Against Pipelines

Berks Gas Truth (gastruth.org)

Better Path Coalition

Center for Biological Diversity (www.biologicaldiversity.org)

Chesapeake Climate Action Network (www.chesapeakeclimate.org)

Climate Mama

Deep Green Resistance New York City (http://dgrnyc.tumblr.com/, https://deepgreenresistance.org/en/)

Earth Defense Coalition

ECHO Action NH: #FossilFree603 ( ECHOaction.org)

Food & Water Watch

FreshWater Accountability Project(www FWAP.org)

IMAC (www.interfaithmoralactiononclimate.org)

Lowell Pipeline Resistance

New HavenLeon SCP

New Progressive Alliance (http://www.newprogs.org/)

NH Pipeline Resistance (PipelineFree603.org)

NYC H2O (http://www.nych2o.org/)

OVEC-Ohio Valley Environmental Coalition (ohvec.org)

www.peopledemandingaction.org

Popular Resistance

Preserve Rockbridge

Protect Orange County

Resist the Pipeline

Roseland (NJ) Against the Compressor Station

Sane Energy Project (www.saneenergy.org)

The Shalom Center (https://theshalomcenter.org)

Shut Down Indian Point Now 

Southern Illinoisans Against Fracturing Our Environment

We Are Cove Point

 

Public Comment 160: June 2018 - FERC Pipeline Review Process

(The New Progressive Alliance joined with other organizations in the following letter.)

 

June 25, 2018

 

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington D.C. 20426

RE: Time for FERC to Represent People over Pipelines: Implementing a Public Interest Pipeline Review Process,

Giving Proper Priority to People, Environment, Climate and

Future Generations

 

Submission to docket PL18-1

 

Dear FERC Commissioners,

 

As a federal agency, the Federal Energy Regulatory Commission (FERC) has a duty to respect the law and respect the people of the United States of America.

 

We The People offer the following comments:

 

1)It is Time that FERC Implement a Pipeline Review Process that Prioritizes the Public Interest Over the Goals of the Pipeline Industry. This Means Giving Proper Priority (i.e. Highest Priority) to

People, the Environment, Protection Against Climate Changing Emissions and Protection of Future Generations in both the FERC Review and Decision-making.

 

2) Review and Reform of FERC’s Pipeline Review Process Must Begin with a Series of No Less than Six Public Hearings Held in Affected Communities, and 90 Days for Written Comment,

So FERC Can Learn How the Current Process Is Failing and the Public Interest Reforms that Are Needed.

To ensure that FERC identifies a full spectrum of truly meaningful fixes to its pipeline review and approval process, FERC’s Commissioners need to hear directly from the communities impacted by pipeline infrastructure and the FERC process. FERC should begin the 1999 Policy Statement review process with no less than six public hearings held in affected communities across the nation that are dedicated to allowing the impacted public to testify directly to the FERC Commissioners about their experiences with the pipeline review and approval process. Testimony should be open to all who are interested and impacted including community members, impacted landowners, environmental advocates, and their representative organizations.

In addition, FERC needs to open a comment period of no less than 90 days to receive written comment, submitted not just via the FERC online portal, but by mail and email as well – in order to ensure the

broadest access possible from all who are impacted and have important information to share for this review.

In addition to the reforms that will be identified and informed by the public process outlined above, VOICES – a coalition of over 200 impacted community organizations representing communities in every

state in the nation –has identified reforms that must be implemented if FERC is earnestly seeking a process that fully, fairly and properly

considers the appropriateness of a proposed pipeline infrastructure

project, and is genuine in it desire to secure complete and

accurate information as well as community engagement.

 

3)FERC Must Mandate a Legitimate Demonstration of “Need” for a Proposed Pipeline/Infrastructure Project that is Verified by Unbiased Experts, Is Not Comprised of Contracts to Supply Gas to the Pipeline Company Itself or Any of Its Business Counterparts, and Is Not/Cannot be Supplied by Renewable or Existing Energy Sources.

FERC must mandate a legitimate demonstration of an end-use need for a proposed infrastructure project as part of any application materials. This assertion of need must be objectively verified by experts who are not tainted by an industry conflict of interest.

This means that a claim of “need” cannot be supported/demonstrated by contracts from the pipeline company itself, or any of its subsidiaries or business counterparts or affiliates. This also means that a

claim of “need” cannot be supported/demonstrated if the geographic region to be served already has gas service from other pipelines that would merely be replaced/displaced by gas delivery from the proposed project. Such illegitimate “need” demonstrations must be prohibited, and cannot be used to fulfill the “public use” requirements needed to support project approval and eminent domain authority. A legitimate demonstration of “need” must include a demonstration that the energy goals to be achieved cannot be fulfilled by renewable energy options, or by existing or proposed energy sources and

infrastructure (e.g. the gas is already being supplied by a pre-existing pipeline supply network).

 

4)There Must Be a Prohibition on FERC Issuing (a) Certificates of Public Convenience or Necessity, (b) Notices to Proceed with Any Aspect of Construction, Including Tree Felling, and/or (c) Approval for Exercise of Eminent Domain, Until Such Time as an Infrastructure

Project Has Secured All State, Federal and/or Regional Permits, Dockets and/or Approvals.

This Includes a Prohibition on Conditional FERC Certificates.

FERC must respect the authority of other state and federal agencies by instituting a regulatory prohibition on (a) issuance of a FERC Certificate approving a project or (b) FERC approvals for projects to proceed with any element of construction or eminent domain authority,

until such time as all state, federal and regional (e.g. from River Basin Commissions) reviews have been finalized and any and all necessary approvals, permits, certificates and/or dockets have been granted. Such a prohibition is essential for ensuring that projects are not allowed to proceed until all government agencies/entities have had the opportunity to fully and fairly evaluate a project and render their own independent determinations regarding necessary approvals, and to avoid the current situation where pipeline companies are allowed by FERC to proceed with eminent domain and/or construction only to find that later they have been denied some key permit and are not able to proceed to completion. This prohibition must include the issuances of conditional FERC Certificates or approvals of any kind, because conditional approvals by FERC have resulted in projects advancing prior to securing all necessary reviews, approvals, permits and/or dockets. This prohibition is imperative and non-negotiable. We

don’t want a repeat of the Constitution Pipeline situation where, as the result of a FERC Certificate and notices to proceed, the property rights of hundreds of property owners were taken, forests were cut, and businesses were harmed only to have the project denied New York state approval thereby preventing full construction. In other words, all the devastation was for naught as the pipeline is never going to be built.

 

5)FERC Must End Its Strategic Practice of Failing to Affirmatively Grant or Deny Rehearing Requests, But Instead Issue

Responses that Provide FERC More Time for Consideration (i.e. a Tolling Order), and as a Result Prevent Pipeline Challengers from Bringing a Legal Challenge in the Courts while FERC Grants the Pipeline Company the Power of Eminent Domain and Approval for Construction. FERC must end the use of tolling orders, which place people in legal limbo and prevent communities from challenging a FERC pipeline approval in the courts before property rights are taken by eminent domain; forests are cut; and irreparable harm is inflicted on communities, farmers, businesses, the environment, public open spaces and our global climate. Because property owners, community groups, business owners and environmental organizations are

unable to challenge a FERC Certificate approving a pipeline project until after they have submitted a rehearing request to FERC and that request has been denied or granted and the rehearing process

completed, FERC has developed a strategy whereby it refuses to grant or deny rehearing requests and instead issues a decision termed a “tolling order” which merely grants FERC unlimited time to consider the rehearing request. Tolling orders are commonly in effect for a year or more, with one recent tolling order lasting 15 months while the pipeline company exercised eminent domain authority and was granted 20 notices to proceed with construction. Without a final decision on the rehearing request, challengers are placed in legal limbo, unable to challenge the project until FERC renders a final yay or nay on the rehearing request. As a result of this strategy, FERC prevents court challenges to its decision in a meaningful time frame.

Meanwhile, it grants the pipeline company the power of eminent domain and the right to begin and continue construction, all the while knowing that challengers are awaiting their ability to challenge the

project in court. The result is that even in those cases where legal challenges to FERC approvals have succeeded, the victories have come too late to genuinely impact the FERC decision already rendered. See, for example, the successful challenge to the TGP North East Upgrade Project where, as the result of a

nearly 12 month tolling order, the court determination that FERC had violated the National Environmental Policy Act by engaging in illegal segmentation and failing to consider cumulative impacts came only

after the pipeline was fully constructed and in operation. There are two potential remedies to this problem:

1.A regulatory prohibition that prevents FERC from granting approval for pipelines to exercise the powerof eminent domain or undertake any element of construction if there is an outstanding rehearing request/tolling order. In this way the status quo is maintained for all, while FERC engages in its supposed consideration of the rehearing request. We say “supposed” because  according to our research,granted a

rehearing request submitted by a challenger to a project;

the requests are always denied signifying that in fact FERC is not engaged in any genuine review process, but instead is

simply buying time for the pipeline company to proceed, unimpeded, with its project.

2.A regulation mandating that FERC respond to rehearing requests with a firm yes or no within 30 days and that the practice of issuing tolling orders is outlawed. In this way it is assured that rehearing requests will be addressed in a timely fashion and legal challenges

can, likewise, proceed in a timely fashion, before it is too late for the property owners, businesses, communities and environments that will be impacted by construction.

 

6)FERC Must Prohibit the Practice of Hiring Third-Party Consultants to Assist in the FERC Review Process who Have Any Business Contracts (Past, Present or Future) with a Pipeline

Company Seeking FERC Approval, and Must Prohibit FERC Commissioners or FERC Staff from Working on or Deciding upon Any Pipeline or Infrastructure Project in which They or a Family

Member Have a Direct or Indirect Financial or Employment Interest.

FERC must commit to removing bias from the decision-making process, by no longer hiring consultants with demonstrated conflicts of interest (i.e., those who are representing a pipeline company seeking

Commission approval), and by prohibiting Commission staff or Commissioners from working on/deciding upon any pipeline infrastructure project in which they, or a member of their family,

have a direct or indirect financial stake or have worked to represent the company within the previous five years or from whom they are seeking future employment. Conflicts of interest are well documented for the consultants FERC hires to support pipeline reviews, in FERC Commissioners reviewing and rendering decisions on projects, and in FERC staff working to advance projects through the review and approval process. Such bias taints the process and must be firmly prohibited.

 

7)FERC Must End the Practice of Using Segmentation, AllowingPipeline Companies to Break Up Projects into Smaller Segments in Order to Undermine a Full and Accurate Review of

Community and Environmental Impacts.FERC must end the practice of using segmentation, whereby larger projects are broken up into smaller pieces for FERC review and approval, as a means to undermine environmental and community impact reviews. FERC’s practice of segmentation has been firmly rejected by the courts and yet the practice continues at the agency. A prohibition on the practice is clearly warranted to make clear to agency staffand Commissioners that this violation of law will no longer be tolerated.

8)FERC Must Commit to a Full and Fair Implementation of the National Environmental Policy Act, Including Full and Fair Evaluation of Climate Change Impacts; Induced Fracking/Drilling Operations; Costs of Construction, Operation and Maintenance (not Just

Benefits); Health and Safety Impacts; the Full Array of Community, Business and Environmental Impacts that Will Result; and that All Inaccurate, Missing, False or Misleading Data and/or Information Identified by FERC and/or Public Commenters Are Fully, Completely and Accurately Addressed. FERC must commit to a

full and fair implementation of the National Environmental Policy Act(NEPA), including a complete analysis of the costs and benefits of every aspect of a project (i.e. not just segmented pieces)including, but not limited to, fully evaluating social justice impacts; climate change impacts of pipeline construction and operation; community, environment, and climate change impacts of increased natural gas exploration, fracking, and methane emissions that will result from pipeline infrastructure operations; economic analyses that include costs, not just asserted benefits; alternatives not limited to alternate routes but that also include alternative energy sources and the

no-build option; and robust health-and-safety impact analyses. This reform must mandate that all data gaps be filled before FERC issues a Certificate approval. This reform must mandate that all demonstrated data inaccuracies, misleading information, and/or false information be fully investigated and addressed by the applicant before FERC issues a Certificate approval.  

 

9)FERC Must End the Practice of Allowing Pipeline Companies to

Secure a 14% Rate of Return on Equity on All New Pipeline Projects

In Order to Ensure the Public Does Not Bear the Burden of Flawed Projects and to Ensure that FERC Does not Incentivize Inappropriate

and/or Unwarranted Pipeline/Infrastructure Construction.

FERC must end the practice of allowing pipeline companies to secure a 14% rate of return on equityon all new pipeline projects (what are termed as greenfield projects in that they require constructing a new

right of way through communities and natural resources).

This practiceof granting a 14% rate of return, without adequately examining market need and existing infrastructure,not only incentivizes the construction of more and more pipelines, regardless of whether there is any genuine need, because the projects become a cash cow for the companies, but it also inflicts an unfair economic burden on communities. Our communities have already borne the burden of construction of these projects in the loss of natural

resources, property rights, property values, agricultural production, business revenue and jobs, the sense of safety and well-being, their actual safety and well-being, the cost of emergency and community

services and more. It is neither fair nor right to allow the company to further burden the public with the cost of these projects by guaranteeing the company such a high and unwarranted rate of return, particularly given that an increasing number of these projects are being built to ship gas to foreign

markets, not to U.S. customers.

 

In conclusion, if FERC is serious about wanting a full, fair, and properly informed decision-making process for fracked gas pipelines, compressors, LNG export, storage and related infrastructure

projects, it will commit to the process and substantive

asks laid out in this letter.

 

Public Comment 161: June 2018 - US Senate - SEC and FDIC Appointees

 

June 2018

 

U.S. Senate

Washington, DC 20515

 

Dear Senators,

We are writing to urge you to move quickly to offer the White House strong progressive candidates for open leadership positions at key financial agencies, including the Securities and Exchange Commission (SEC) and the Federal Deposit Insurance Corporation (FDIC).

As the primary regulator of the nation’s capital markets, the SEC is at the center of everything from protecting the retirement savings of ordinary investors to protecting the economy from another disastrous financial crash. Many of the entities and markets at the heart of the 2008 crisis, from broker-dealers to credit rating agencies, are regulated by the SEC. Today, the SEC is responsible for crucial rules determining whether financial market professionals will be required to put the interests of ordinary investors first. The ability of the Commission to protect the public, including when this requires opposing up the interests of the giant Wall Street firms and traders that it regulates, is crucial to the safety of our economy.

At the end of this year, Commissioner Kara Stein’s seat will become open for a Democratic replacement. Commissioner Stein has been a tireless advocate of the public interest and has consistently prioritized the interests of the public and of ordinary investors over the profits of Wall Street firms.  Her independent voice will be sorely missed. It is crucial that you nominate a new SEC Commissioner who will likewise be a strong and independent voice for the public interest.

The FDIC also plays a critical role in safeguarding the stability of our financial system, and assuring that banks effectively serve all communities. As the key prudential regulator overseeing the deposit insurance system, the FDIC acts to protect taxpayers from bankers seeking to take advantage of the public deposit guarantee to make reckless bets that can enrich them but harm the economy. Should a major bank fail, the FDIC will be entrusted with resolving the bank and preserving the integrity of the financial system. The agency also plays a key role in the design and enforcement of rules on fair lending and access to credit.  

It is critical that FDIC board members be proven champions of the public interest. As in the case of the SEC, this regulatory agency is subject to tremendous pressure from big-money interests who can profit by endangering the stability and fairness of the financial system. Americans require nominees to these positions who have proven track records of commitment to the public interest and reform of the financial system. Such a record must include a demonstrated willingness to stand up to Wall Street or banking interests when that is necessary to protect investors, consumers, or borrowers.

The need for strong public interest nominees is even greater today. This Administration has been filling key regulatory positions with people pursuing Wall Street’s agenda at the public’s expense, and the revolving door is spinning faster than ever.  There is an enormous amount at stake at both the SEC and FDIC as the financial industry and their friends in the Trump administration work to undo the progress made in Dodd-Frank and to undermine key investor protection standards.

The next SEC Commissioner and members of the FDIC’s Board of Directors must be ready and willing to shine a bright, public light of scrutiny on misguided deregulation designed to enhance profits at the expense of market safety and public well-being. The leaders you nominate must understand that their duty to the public interest is more important than comity between senior officials.

We urge you and the entire Senate Democratic caucus to move expeditiously and energetically to advance progressives for these openings, and to ensure that there will be no unnecessary delays in filling Democratic Party slots.

 

Sincerely,

 

AFL-CIO

Americans for Financial Reform

Center for Popular Democracy

Communications Workers of America (CWA)

CREDO Action

Demand Progress

Economic Policy Institute Policy Center

Global Witness

Harrington Investments, Inc.

Indivisible

National Consumer Law Center (on behalf of its low income clients)

New Progressive Alliance

OIP Trust, Missionary Oblates

Public Citizen

Presente

Publish What You Pay - US.

Reinvestment Partners

Revolving Door Project

Women's Institute for Freedom of the Press

 

Public Comment 162: June 2018 - US HOR Leaders - Don't Weaken FSGG

June 12, 2018

Dear Chairman Frelinghuysen and Ranking Member Lowey:

On behalf of the undersigned organizations, we are writing to urge you to reject the numerous sweeping financial deregulatory measures that are inappropriately packaged in the Committee’s Financial Services and General Government appropriations bill.

Title IX of this bill – consisting of 125 pages, more than one third of the entire bill – includes a grab bag of deregulatory provisions aimed at assisting banks and financial institutions at the expense of the public interest. Besides the evident absurdity of devoting more than one-third of an appropriations bill to dozens of policy proposals that together would comprise one of the most sweeping Wall Street deregulatory bills passed in decades, most of these policies are ill-considered, harmful, and damaging to consumers and to financial stability. Provisions in this bill would deregulate everything from the nation’s largest banks to high-frequency Wall Street traders to consumer lenders supervised by the Consumer Financial Protection Bureau.

For example, the legislation contains multiple provisions that would be devastating to the independence of the Consumer Financial Protection Bureau. The CFPB has successfully gone to bat for consumers, delivering results that have made markets work more fairly and putting a stop to fraud and abuse. In total, CFPB enforcements have resulted in nearly $12 billion in relief for more than 29 million Americans who have been harmed by illegal, deceptive, and discriminatory practices of various companies. The agency’s rules, supervision, and other activities have saved money, aided understanding, and prevented harm for many millions more.

The following provisions in the bill would gravely undermine the CFPB’s independence and ability to take on abusive consumer practices:

● Section 943 in the FSGG 2019 print eliminates the CFPB’s independent funding, making it the only banking regulator subject to the appropriations process. Permitting the change in Section 943 would leave the CFPB more uniquely vulnerable to industry influence and would make it much less likely that the agency would take action to protect the public interest in the face of opposition from industry profiting from an abusive status quo. It would give Wall Street and the worst elements of the financial services industry endless lobbying opportunities to deny the CFPB the funding to do its job if the regulator took action the industry did not like.

● Section 947 further damages the CFPB’s independence by allowing the president to fire the CFPB director for any reason or no reason, despite a January, 2018 appellate decision upholding the constitutionality and appropriateness of an independent CFPB director. As the judges in that case stated, “Congress’s decision to provide the CFPB Director a degree of insulation reflects its permissible judgment that civil regulation of consumer financial protection should be kept one step removed from political winds and presidential will.”

● Section 948 would impose numerous draconian restrictions on the CFPB’s authority to issue rules, which would dramatically undermine the CFPB’s ability to carry out its duty to protect consumers. For example, this section subjects CFPB’s “major rules” to a congressional veto similar to the likely unconstitutional Regulations In Need Of Scrutiny (REINS) Act. This bill allows inaction by at least one chamber of Congress to block any “major” CFPB rules. Even if both chambers of Congress were to approve a “major” rule, the section would further require the CFPB to adhere to a so-called regulatory budget by offsetting the costs of any “major” rules by in turn repealing other rules, despite whatever harm to consumers and the public interest might be inflicted by that repeal. This misguided standard would create a unique barrier to CFPB rule-making that is faced by no other agencies.

● Subtitle W (Sections 939-942) would unnecessarily establish a separate Inspector General for the CFPB. As a part of the Federal Reserve the CFPB is currently under the jurisdiction of the Federal Reserve Inspector General, who is ably carrying out the job. The new inspector general would be selected by the president, which would further dilute the CFPB’s independence from the White House.

These provisions strike at the independence and effectiveness of the CFPB are only the beginning of the objectionable elements in this bill. Several additional examples are listed below.

Subtitle D of the bill (“The Mortgage Choice Act”) would open a new loophole to permit loans with higher costs to the borrower to improperly qualify for a legal safe harbor. This provision would once again expose borrowers to some of the exploitative fees that the new mortgage rules passed in Dodd-Frank were designed to prevent. Fees exempted by the Mortgage Choice Act include fees paid to title insurance companies affiliated with the lender – lender affiliated title insurance fees are some of the most notoriously inflated fees in housing markets.

Subtitle M of the bill would put unprecedented limits on the ability of securities regulators to do basic oversight of automated high-speed trading, the riskiest and fastest-growing element of trading markets. This provision would severely restrict the ability of the Securities and Exchange Commission to examine the detailed trading strategies of automated traders, even in cases where such traders posed a risk to markets or the financial system. It would prevent regulators from inspecting not only the raw source code used in automated trading, but also any related intellectual property that “forms the basis for the design of” source code. Examination of such intellectual property would only be possible in an enforcement context pursuant to a subpoena. This would mean in practice that the SEC would have to wait until the damage was done through a “flash crash” or similar market disruption before taking any action, rather than being able to take action to prevent abuse.

Subtitle T in the print (“The Financial Institutions Examination Fairness and Reform Act”) would grant regulated banks the right to appeal any supervisory determination made by any banking agency to a new “Office of Independent Examination Review”. Upon appeal by a supervised bank, this new office would be required to undertake a de novo review of the agency’s supervisory decision. No deference to the initial examination findings or the agency’s judgment would be required in this review. This new appeals process is an addition to formal appeals processes and ombudsmen already present at the banking agencies. By layering an entirely new de novo appeals process on top of existing processes, the Exam Fairness Act would enormously increase the ability of banks to resist supervisory decisions. This effect would be most pronounced at the largest banks, who could appeal dozens or hundreds of material findings from every examination, creating enormous barriers to bank oversight. The bank supervision process has been the first line of regulatory defense against threats to bank safety and soundness for a century or more. Subtitle T would create unprecedented roadblocks to bank supervision, making it more likely that banks could get away with dangerous or abusive practices.

These are just a few examples of the dozens of harmful financial deregulatory provisions inappropriately included in this legislation. Other provisions weaken the Volcker Rule ban on speculative gambling with publicly insured deposits (Subtitle R), eliminate requirements for annual examinations of the giant securities rating agencies found guilty of fraudulent activities during the 2008 financial crisis (Subtitle L), weaken risk controls for financial derivatives (Subtitle Z), and more. The list of harmful deregulatory provisions goes on from there.

These financial policy riders are wrongheaded and dangerous in and of themselves, and it is entirely inappropriate to include them in a funding bill. All of the deregulatory provisions should be eliminated from the legislation.

Sincerely,
Americans for Financial Reform
Allied Progress
American Association for Justice
American Federation of State, County and Municipal Employees (AFSCME)
Baltimore Neighborhoods, Inc, MD
California Reinvestment Coalition, CA
Center for Popular Democracy
Center for Responsible Lending
Consumer Federation of America
Consumers Union
Demos
Hispanic Federation
Hispanic Federation - CT
Hispanic Federation - FL
Impact Fund
Indivisible
Institute for Agriculture and Trade Policy
NAACP
National Association of Consumer Advocates
National Community Reinvestment Coalition (NCRC)
National Consumer Law Center (on behalf of its low income clients)
New Progressive Alliance
Prosperity Now
Public Citizen
Service Employees International Union (SEIU)
Strong Economy For All Coalition
Tennessee Citizen Action, TN
U.S. PIRG
Woodstock Institute, IL

 

Public Comment 163: July 2018 - US HOR - Oppose Irrelevant Rider

(This is similar to Public Comment 156 in which we with other organizations asked the congress to oppose ideological extreme riders. This also addresses specifics and addresses the United States House of Representatives.)

 

July 16, 2018

Dear Representative,

As a part of the Clean Budget Coalition, we, the undersigned organizations write to ask you to oppose the House FY 2019 minibus packaging the Financial Services & General Government and Interior & Environment appropriations bills together.

This package is laden with ideological policy riders that are inappropriate for any funding bill. Time and time again, members of Congress attempt to quietly slip in special interest wish list items that couldn’t pass as standalone legislation into must-pass funding packages as poison pill riders. Appropriations bills must not be misused to undermine essential safeguards. Slipping unrelated and damaging issues into must-pass appropriations bills as a means to win approval is a dangerous strategy for the public. Poison pill riders are unpopular and damaging, and the public opposes using them.

The American people oppose rollbacks that would hinder government’s ability to:

  • Restrain Wall Street abuses;
  • Ensure safe and healthy food and products;
  • Secure our air, land, water and wildlife;
  • Safeguard fair and safe workplaces;
  • Guard against consumer rip-offs and corporate wrongdoing;
  • Defend our campaign finance and election systems;
  • Provide access to justice and fair housing;
  • Protect civil rights; and
  • Guarantee continued access to vital health care services including reproductive health care, and more.

We urge Members of Congress to abide by the funding numbers agreed upon in the deal to fund the essential programs our nation needs for FY19, and to reject any flawed spending measures that includes poison pill policy riders.

Sincerely,

National groups

2020 Vision

Action on Smoking and Health

AFL-CIO

AFSCME

Alaska Wilderness League

American Association for Justice

American Federation of Teachers

American Rivers

Americans for Financial Reform

Association of Farmworker Opportunity Programs

Autistic Self Advocacy Network

Bend the Arc Jewish Action

Black Women's Health Imperative

Center for Progressive Reform

Center for Reproductive Rights

Center for Responsible Lending

Center for Science in the Public Interest (CSPI)

Clean Water Action

     Coalition on Human Needs

Common Cause

Communications Workers of America (CWA)

Compassion & Choices

Consumer Action

Consumer Federation of America

Democracy 21

Earthjustice

Endangered Species Coalition

Environment America

Farmworker Justice

Food & Water Watch

Friends of the Earth - US

Green Science Policy Institute

Hip Hop Caucus

Hispanic Federation

Homeowners Against Deficient Dwellings

Humane Society Legislative Fund

Impact Fund

Institute for Agriculture and Trade Policy

International Chemical Workers Union Council (ICWUC)

International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America, UAW

Jewish Women International

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

League of Women Voters of the United States

Main Street Alliance

NARAL Pro-Choice America

National Association of Consumer Advocates

National Birth Equity Collaborative

National Center for Lesbian Rights

National Coalition for the Homeless

National Consumer Law Center (on behalf if its low income clients)

National Council of Jewish Women

National Education Association

National Employment Law Project

National Fair Housing Alliance

National Health Care for the Homeless Council

National Low Income Housing Coalition

National Women's Health Network

National Women's Law Center

Natural Resources Defense Council

New Progressive Alliance

PAI

People For the American Way

PLACE

Planned Parenthood Federation of America

Population Institute

Power Shift Network

Protect All Children's Environment

Public Citizen

Public Knowledge

Rachel Carson Council

Restore America's Estuaries

Safe Climate Campaign

Service Employees International Union (SEIU)

Sierra Club

Southern Environmental Law Center

The Arc of the United States

The Wilderness Society

U.S. PIRG

Union of Concerned Scientists

Voices for Progress

Witness to Mass Incarceration

Workplace Fairness

 

State and Local Groups

California Reinvestment Coalition - CA

Citizens' Environmental Coalition - NY

Environmental Advocates of New York - NY

Equality California - CA

Florida Alliance for Consumer Protection - FL

Herd on the Hill - DC

Hispanic Federation - CT

Hispanic Federation - FL

New Jersey Association on Correction - NJ

New Jersey Citizen Action - NJ

New Yorkers for Responsible Lending (NYRL) - NY

Public Justice Center - MD

Save EPA Ann Arbor - MI

Save Our Sky Blue Waters - MN

 

Public Comment 164: July 2018 - US HOR Rules Committee - Don't Limit SE

July 16, 2018

The Honorable Pete Sessions

Chairman House Committee on Rules

Washington, D.C. 20515

 

The Honorable James McGovern

Ranking Member House Committee on Rules

Washington, D.C. 20515

 

Dear Chairman Sessions and Ranking Member McGovern:

The undersigned organizations urge you to rule in order Capuano amendment #35 to strike the language in section 628 of the House 2019 Financial Services and General Government Appropriations bill.

The provision would limit the Securities and Exchange Commission’s (SEC) ability to finalize, issue, or implement a rule requiring public companies to disclose political spending to shareholders.  Since the U.S. Supreme Court’s decision in

Citizens United v. FEC came down in 2010, corporations have been allowed to spend unlimited undisclosed amounts of money to influence American elections and in turn affect policy outcomes. Noting the danger of “dark money” for

both American democracy and the shareholders of the companies that are spending in secret, a strong coalition of diverse allies has been working together since the decision to bring corporate spending in politics into the light.

We, the undersigned organizations, believe the SEC should be allowed to and encouraged to move forward with the rulemaking that would require public companies to disclose to their shareholders and the public how they spend money in politics. This information is material to investors - the constituency the SEC is responsible for protecting.

The Supreme Court’s decision to give corporations the right under the First Amendment to spend unlimited funds from their corporate treasuries to support or attack candidates is troubling for several reasons, and investors concerned about the value of their investments and citizens concerned about the future of American democracy are looking to the SEC to take the action that so many investors have demanded and require disclosure of political spending.

Without direction from the SEC, there are no rules or procedures established in the United States to ensure that shareholders - those who actually own the wealth of corporations – are informed

of, or have the right to approve, decisions on spending their money on politics. Investors want more disclosure in order to make sound investment decisions. That is why 1.2 million comments - the most in the agency’s history - have come into the SEC on this rulemaking petition from diverse stakeholders including the founder of Vanguard, John Bogle, five state treasurers, a bi-partisan group of former SEC chairs and commissioners, and investment professionals representing $690 billion in assets.

We believe that the rider blocking the SEC from making progress on this rulemaking was inappropriately included in the appropriations process and that the budget should be free of any

poison pill policy riders. We urge you to rule in order the Capuano amendment #35 to strike section 628. We are grateful for your leadership and appreciate your consideration of this request to restore transparency and accountability to our democracy.

 

Sincerely,

American Federation of Labor and Congress of Industrial

Organizations(AFL-CIO)

American Federation of State, County and Municipal Employees (AFSCME)

Boston Common Asset Management

Campaign for Accountability

Center for Biological Diversity

Center for Media and Democracy

Citizen Works

Citizens for Responsibility and Ethics in Washington (CREW)

Clean Yield Asset Management

Common Cause

Democracy 21

Dominican Sisters of Hope

End Citizens United

Every Voice

Franciscan Action Network

Free Speech For People

Government Accountability Project

Green Century Capital Management

Greenpeace

Interfaith Center on Corporate Responsibility

International Corporate Accountability Roundtable (ICAR)

New Progressive Alliance

OIP Trust

People For the American Way

Public Citizen

Shareholder Association for Research & Education

Trillium Asset Management, LLC

Unitarian Universalist Association

Ursuline Sisters of Tildonk, U.S. ProvinceU.S.Public Interest Research Group

Voices for Progress

Wisconsin Democracy Campaign

Women's Institute for Freedom of the Press

Zevin Asset Management

 

Public Comment 165: July 2018 – Oregon DEQ and Army Corps of Engineers – Oppose Jordan Cove LNG

July 20, 2018

Department of Environmental Quality
700 NE Multnomah Street, Suite 600
Portland, OR 97232-4100

EQInfo@deq.state.or.us

Headquarters
U.S. Army Corps of Engineers
441 G Street NW
Washington, DC 20314-1000 

 

The New Progressive Alliance at http://newprogs.org/ urge you to reject the Jordan Cove Liquefied Natural Gas (LNG) export terminal in the town of Coos Bay, Oregon.

The future should not be natural gas obtained by fracking - "in essence, explode a pipe bomb a few thousand feet beneath the surface, fracturing the surrounding rock."   Unregulated by the EPA because of congressional action combined with the support of Presidents Obama and Trump, companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011.

See references 60, 63, 150, 183, 194, 220, 244, 280, 288, 296, 301, 303, 345, 355, 359, 370, 374 - 377, 404, 410, 414, 434, 456, 475, 483, 521, 542 - 544, 594, 602, 639, 683 - 689, 712, 713, 715 - 718, 734 - 736, 745, 746, 776, 815 - 824, 845, 846, 929 - 941, 989, 1052 - 1071, 1166 - 1173, 1345-1362, 1557, 1560-1561, 1576-1583, 1668-1669, 1687-1689, 1724, 1731, 1783-1787, 1937-1957, 2133-2139, 2249, 2317, 2421-2436, 2558-2564, 2598, 2667, 2747, 2776-2787, 2980-2982, 3168, 3170, 3171, 3187, 3222-3236, 3347, 3494-3496, 3507, 3853-3860 of the article “The Environment” at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Specifics about the Jordan Cove Liquefied Natural Gas (LNG) export terminal:

-This project would pollute nearly 500 waterways, harm salmon habitat, threaten tribal territories and burial grounds, impact hundreds of landowners, raise energy prices, and become the largest source of climate pollution in Oregon.

-This project would require the 229-mile Pacific Connector pipeline across private and public land, creating a 95-foot wide clearcut through southwest Oregon’s forests and farms to transport fracked gas from Canada and the U.S. Rockies overseas.

-The pipeline would terminate on the coast in an export facility in the Port of Coos Bay, Oregon. -This highly explosive facility would be located in a tsunami hazard zone, subjecting over 16,000 people to hazardous burns in the case of an accident.

-The pipeline would terminate on the coast in an export facility in the Port of Coos Bay, Oregon. This highly explosive facility would be located in a tsunami hazard zone, subjecting over 16,000 people to hazardous burns in the case of an accident.

Senator Jeff Merkley opposed the Jordan Cove LNG terminal and Pacific Connector pipeline in 2017. He stated, “…I cannot turn away from the knowledge that, like other large-scale fossil fuel projects, Jordan Cove will contribute massively to pollution that is profoundly damaging our state and our world. Generations from now, our grandchildren will wonder why we continued to burn fossil fuels when the catastrophic consequences were so evident.” Instead of expanding use of fossil fuels to benefit corporate special interests, we should be investing in a faster transition to clean energy jobs and greater energy efficiency.

The project does not comply with the Clean Water Act because it will significantly degrade rivers and streams in Oregon and northern California, will violate state water quality standards, will impair designated uses, and is not in the public interest. It also does not meet the Department of Environmental Quality mission to be a leader in restoring, maintaining and enhancing the quality of Oregon's air, land and water.

The U.S. Army Corps of Engineers and the Oregon Department of Environmental Quality should deny the Clean Water Act 404 and 401 permits. Similar fracked gas pipelines in Oregon, New York and Maryland have been stopped through the Clean Water Act process because of impacts to rivers, streams and wetlands and the Jordan Cove Liquefied Natural Gas (LNG) export terminal should be stopped for the same reasons.

Public Comment 166: July 2018 – Washington Ecology – Stop Coal Expansion

July 20, 2018

Tricia Miller, Permit Coordinator        
Washington State Department of Ecology
Northwest Regional Office
3190 - 160th Avenue SE
Bellevue, WA  98008-5452
nwropccc@ecy.wa.gov

 

 

 

The New Progressive Alliance at http://newprogs.org/  urges the Washington State Department of Ecology not to grant approval of the Pacific Coast Coal Company’s attempt to re-open a shuttered coal mine in King County, Washington.

Burning coal is one of the highest producers of greenhouse gases and other pollutants. Mountain Top Removal for coal - which destroys mountains forever through explosions and destroys thousands of miles of streams - continues unabated. Coal pollution already worsens air quality resulting in more asthma attacks, heat-related deaths, and respiratory complications. Carbon pollution contributes to warmer temperatures which is speeding the spread of infectious diseases. Coal Plants also emit   mercury, sulfur, arsenic, cyanide, soot, and lead which have a disproportionate impact on vulnerable communities. Coal companies are not responsible for these health effects or for clean up when coal ash spills and destroys water supplies.

See references 52, 82, 97, 98, 101, 133, 159, 174, 207, 308, 421, 498, 814, 830, 906, 1024 - 1036, 1156, 1214, 1216, 1292 - 1312, 1422, 1525-1532, 1666, 1708, 1709, 1722-1725, 1897-1905, 1960, 1963, 2016, 2038 2052, 2091-2103, 2224-2226, 2261, 2287, 2308, 2382-2397, 2540-2550, 2627, 2628, 2703-2738, 2742, 2767, 2845, 2873-2880, 2901, 2904, 2979, 3029, 3090, 3145-3177, 3224, 3349, 3502-3506, 3521, 3773-3779, 3861, 3898, 3908 of this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Re-opening the shuttered John Henry coal mine in King County would cause 250,000 tons of carbon pollution each year. Even worse, Pacific Coast Coal has a track record of pollution in that they are responsible for dumping illegal pollution into local creeks and lakes, illegally disposing of waste, and failing to clean up waste at the mine. This coal mine will cause harmful environmental impacts to local water quality, hydrology, and air quality and would reverse decades of progress towards transitioning Washington away from dirty fossil fuels.

The New Progressive Alliance urges you to do the right thing and deny expansion of coal into this state.

Public Comment 167: July 2018 – US DOE - Clean Up Hanford Nuclear

July 20, 2018

U.S. Department of Energy
1000 Independence Ave., SW
Washington, DC 20585

Mr. Jan Bovier

U.S. Department of Energy, Office of River Protection

P.O. Box 450

MSIN H6-60

Richland, WA 99354

 

WMACDRAFTWIR@rl.gov

 

            The New Progressive Alliance at http://newprogs.org/  urges the Department of Energy (DOE) to abandon its proposal to reclassify high-level nuclear waste and leave it in Hanford’s underground tanks, soils, and groundwater. Renaming High-Level Radioactive and Toxic Waste as low level radioactive waste is both inaccurate and certainly is not clean up.

 

The below information is verified by the Columbia Riverkeeper which is funded through a grant from the Washington state Department of Ecology.

 

DOE proposes to reclassify high-level radioactive waste as low-level radioactive waste in the C Farm, one of Hanford’s tank farms holding high-level nuclear waste. The remaining waste—potentially more than 70,000 gallons of the 1.77 million gallons once stored in the tanks—does not magically change to low-level waste just because it is reclassified. This will leave dangerous waste in Hanford’s tanks, soils, and groundwater, threatening the Columbia River for generations to come.

 

DOE’s also proposal does not address the concerns raised by tribal nations, Washington Senator Maria Cantwell, and many public interest organizations.

  • At least 67 underground tanks have leaked liquid waste into the ground. Some waste has already reached groundwater. And polluted groundwater from Hanford’s 200 Area—where the tanks are located—has already reached the Columbia River.
  • C Farm waste likely includes transuranic waste. Transuranic waste has a high concentration of long-lived, heavy radionuclides, and is not suitable for shallow disposal at Hanford.
  • Waste in the C Farm contains technecium-99, plutonium-239, strontium-90, cesium-137, iodine-129, multiple uranium isotopes, and many other toxic and radioactive contaminants.
  • In 2012, the Washington state Department of Ecology (Ecology) wrote in its forward to the Tank Closure Waste Management Environmental Impact Statement (EIS) that Washington state prefers “retrieval of at least 99 percent of the waste from each tank.” DOE failed to meet this expectation and proposes to leave four percent of the waste in C Farm. DOE has certainly not removed the “maximum technically achievable” amount of waste.
  • Contaminants such as technecium-99 and iodine-129 are long-lived, mobile, and could present a long-term risk if not addressed in the C Farm’s tanks and soils. DOE has certainly
  • Grout lacks durability for immobilizing long-lived and mobile waste. Because Energy will use the Draft WIR Evaluation to justify leaving up to four percent of C Farm’s tank waste cement, Energy’s proposal will ultimately lead to greater soil and groundwater pollution when the grout fails in hundreds or perhaps thousands of years.
  • The cumulative impacts analysis from Energy’s Tank Closure Waste Management Environmental Impact Statement suggests that leaving long-lived, mobile waste in grouted tanks, soils, and groundwater will pose a long-term risk to the Columbia River.
  • Washington state Department of Ecology has questioned Energy’s inventory of waste remaining in the C Farm tanks and raised concerns about how future waste may move through soils and groundwater.

The DOE should and must label waste based on its dangerous nature, not on whether Energy has plans to dispose the waste. The New Progressive Alliance urges the Department of Energy to do the right thing and abandon its proposal to reclassify high-level nuclear waste.

 

Public Comment 168: July 2018 – US Senate – Oppose Irrelevant Riders

(This is similar to Public Comment 163 except it is aimed specifically at the US Senate instead of the US House of Representatives.)

July 23, 2018

 

Dear Senator,

As a part of the Clean Budget Coalition, we, the undersigned organizations write to ask you to oppose adding ideological poison pill policy riders to the Senate FY 2019 minibus II made up of the Financial Services & General Government, Interior, Agriculture, and Transportation, Housing & Urban Development appropriations bills.

 

Time and time again, members of Congress attempt to quietly slip in special interest wish list items that couldn’t pass as standalone legislation into must-pass funding packages as poison pill riders. Appropriations bills must not be misused to undermine essential safeguards. Slipping unrelated and damaging issues into must-pass appropriations bills as a means to win approval is a dangerous strategy for the public.

 

Poison pill riders are unpopular and damaging, and the public opposes using them to roll back public protections. The American people support policies to:

 

  • Restrain Wall Street abuses;
  • Ensure safe and healthy food and products;
  • Secure our air, land, water and wildlife;
  • Safeguard fair and safe workplaces;
  • Guard against consumer rip-offs and corporate wrongdoing;
  • Defend our campaign finance and election systems;
  • Provide access to justice and fair housing;
  • Protect civil rights; and
  • Guarantee continued access to vital health care services including reproductive health care, and more.

 

We urge Senators to abide by the funding numbers agreed upon in the deal to fund the essential programs our nation needs for FY19 and to reject any flawed spending measures that includes poison pill policy riders.

 

Sincerely,

 

National Groups

2020 Vision

Action on Smoking and Health

AFL-CIO

AFSCME

Alaska Wilderness League

American Association for Justice

American Federation of Teachers

American Rivers

Americans for Financial Reform

Association of Farmworker Opportunity Programs

Autistic Self Advocacy Network

Bend the Arc Jewish Action

Black Women's Health Imperative

Center for Progressive Reform

Center for Reproductive Rights

Center for Responsible Lending

Center for Science in the Public Interest (CSPI)

Clean Water Action

      Coalition on Human Needs

Common Cause

Communications Workers of America (CWA)

Compassion & Choices

Consumer Action

Consumer Federation of America

Democracy 21

Earthjustice

Endangered Species Coalition

Environment America

Farmworker Justice

Food & Water Watch

Friends of the Earth - US

Green Science Policy Institute

Grounded Solutions Network

Hip Hop Caucus

Hispanic Federation

Homeowners Against Deficient Dwellings

Humane Society Legislative Fund

Impact Fund

Institute for Agriculture and Trade Policy

International Chemical Workers Union Council (ICWUC)

International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America, UAW

Jewish Women International

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

League of Women Voters of the United States

Main Street Alliance

NARAL Pro-Choice America

National Association of Consumer Advocates

National Birth Equity Collaborative

National Center for Lesbian Rights

National Coalition for the Homeless

National Consumer Law Center (on behalf of its low income clients)

National Council of Jewish Women

National Education Association

National Employment Law Project

National Fair Housing Alliance

National Health Care for the Homeless Council

National Low Income Housing Coalition

National Women's Health Network

National Women's Law Center

Natural Resources Defense Council

New Progressive Alliance

PAI

People For the American Way

PLACE

Planned Parenthood Federation of America

PolicyLink

Population Institute

Power Shift Network

Protect All Children's Environment

Public Citizen

Public Knowledge

Rachel Carson Council

Restore America's Estuaries

Safe Climate Campaign

Service Employees International Union (SEIU)

Sierra Club

Southern Environmental Law Center

The Arc of the United States

The Wilderness Society

U.S. PIRG

Union of Concerned Scientists

United Church of Christ, OC Inc.

Voices for Progress

Witness to Mass Incarceration

Workplace Fairness

State and Local Groups

California Reinvestment Coalition - CA

Citizens' Environmental Coalition - NY

Environmental Advocates of New York NY

Equality California - CA

Florida Alliance for Consumer Protection - FL

Hispanic Federation - CT

Hispanic Federation - FL

New Jersey Association on Correction - NJ

New Jersey Citizen Action - NJ

New Yorkers for Responsible Lending (NYRL) - NY

Public Justice Center - MD

Save Our Sky Blue Waters - MN

Herd on the Hill Washington, D.C.

Save EPA Ann Arbor Ann Arbor, MI

 

 

Public Comment 169: July 2018 - Congress - Don't Allow Adoption Discrimination

July 26, 2018

 

The Honorable Richard Shelby                     The Honorable Patrick Leahy   

The Honorable Rodney P. Frelinghuysen                  The Honorable Nita M. Lowey

The Honorable Roy Blunt                The Honorable Patty Murray       

The Honorable Tom Cole                The Honorable Rosa DeLauro

               

Dear Senators and Representatives:

 

The 205 undersigned religious, child welfare, civil rights, and other organizations write to voice our strong opposition to the Aderholt Amendment to the House Labor-HHS-Education Appropriations Bill for FY 2019. We urge you to reject this provision because it would harm children in the child welfare system and authorize taxpayer-funded discrimination.

 

In violation of state and federal nondiscrimination policies, the Aderholt Amendment would allow child welfare providers receiving taxpayer dollars to decide which families and children to serve. The amendment would affect a wide variety of child welfare services, including family preservation services; foster care, counseling and other services for children; and adoption services.

 

Taxpayer dollars should not be used to discriminate and no family should be told they are not qualified to serve as foster or adoptive parents because they are LGBTQ or the “wrong” religion by a taxpayer-funded provider.  This amendment would allow agencies to use a religious litmus test to determine which families or children to serve, and which services to provide, while still receiving taxpayer dollars.

 

Moreover, because the amendment conflicts with other federal laws including Title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, and national origin in federally funded programs, it could open the door to discrimination against children and prospective families on the basis of race and national origin by taxpayer-funded agencies.

 

Children who have been separated from their birth families are entrusted to the state for care, stability, and safety. When the state contracts with child welfare service providers to serve these children, following professional standards to ensure the children’s safety, permanency, and wellbeing, the providers stand in the place of the state and have a duty to act in the best interests of each child. Yet, the Aderholt Amendment places the religious and moral beliefs of some state contractors above the needs of children in state care. This is unacceptable.

 

The United States has nearly 440,000 children in foster care, more than 117,000 of whom are waiting to be adopted. Yet, each year, less than half of the children waiting to be adopted find forever homes, and tens of thousands of foster youth age out of the system without finding a loving, forever family. This places them at higher risk of involvement with the criminal justice system, homelessness, unemployment, and being trafficked. For LGBTQ youth in care risk for these negative outcomes is even greater.

 

The Aderholt Amendment could exacerbate these challenges. Forty-six states and the District of Columbia have laws and policies that protect children and families against discrimination in the child welfare system. But under this amendment, states that enforce their own policies could be penalized and face a 15% cut of federal funding for child welfare services--a potential cumulative cut of more than $1.04 billion, further straining the system.

 

We value religious freedom, and the only way to protect religious freedom for all people is to ensure that taxpayer-funded agencies do not place a religious test on the services they provide or the people they serve.  Moreover, we appreciate the important role religiously affiliated institutions historically have played in providing child welfare services.  Effective government collaboration with faith-based groups, however, does not require the sanctioning of taxpayer-funded discrimination.

 

In closing, because the Aderholt Amendment undermines the principle that child welfare providers should operate in the best interests of the children in their care and because it is inconsistent with the longstanding principle that federal dollars must not be used to discriminate, we urge you to reject the Aderholt Amendment.

 

National Organizations

 

African American Ministers In Action

American Association of University Women

American Atheists

American Conference of Cantors

American Federation of Teachers

American Humanist Association

Americans United for Separation of Church and State

American Unity Fund

Anti-Defamation League

Atticus Circle

AIDS United

American Civil Liberties Union

American Psychological Association

Athlete Ally

Baptist Joint Committee for Religious Liberty

The Bassuk Center on Homeless and Vulnerable Children & Youth

Bend the Arc Jewish Action

Center for American Progress

Center for Children's Law and Policy

Center for Children & Youth Justice

Center for Inquiry

Center for Public Interest Law

Center for Social Innovation

CenterLink: The Community of LGBT Centers

Ceres Policy Research

Children's Advocacy Institute

Children's Defense Fund

Children’s Rights

Child Welfare League of America

COLAGE

DignityUSA

Disciples Justice Action Network

Equality Federation

Faith in Public Life

Family Values @ Work

Family Equality Council

FORGE, Inc.

Foster Care to Success

FosterClub

Freedom for All Americans

Global Justice Institute

Hadassah, The Women's Zionist Organization of America, Inc.

Harm Reduction Coalition

Hispanic Federation

Human Rights Campaign

Human Rights Watch

Keshet

Impact Fund

Interfaith Alliance

Intersections International

Juvenile Law Center

Lambda Legal

Log Cabin Republicans

Men of Reform Judaism

Methodist Federation For Social Action

Metropolitan Community Churches

Movement Advancement Project

NAACP

NARAL Pro-Choice America

National Adoption Center

National Asian Pacific American Women's Forum (NAPAWF)

National Association of County and City Health Officials

National Association of Social Workers

National Black Justice Coalition

National Center for Lesbian Rights

National Center for Transgender Equality

National Center on Adoption and Permanency

National Coalition for the Homeless

National Council of Jewish Women

National Crittenton

National Education Association

National Equality Action Team (NEAT)

National Health Law Program

National Juvenile Justice Network

National LGBT Chamber of Commerce

National LGBTQ Task Force Action Fund

National Network of Abortion Funds

National Network for Youth

National Organization for Women

National Women's Law Center

Nebraska Appleseed

New Progressive Alliance

New Ways Ministry

North American Council on Adoptable Children

Partnership For America's Children

People For the American Way

PFLAG National

Planned Parenthood Federation of America

Population Connection Action Fund

Presbyterian Church (U.S.A.)

Religious Institute

RESOLVE: The National Infertility Association

SAGE

SchoolHouse Connection

Secular Coalition for America

Sexuality Information and Education Council of the United States (SIECUS)

SisterLove, Inc.

SparkAction

The Trevor Project

Transgender Law Center

True Colors Fund

Union for Reform Judaism

United Church of Christ, Justice and Local Church Ministries

Unitarian Universalist Association

URGE: Unite for Reproductive & Gender Equity

Uri L'Tzedek

Voices for Progress

Witness to Mass Incarceration

Women of Reform Judaism

Youth Law Center

 

State and Local Organizations

 

Alabama

AIDS Alabama

AIDS Alabama South, LLC

Equality Alabama

Rainbow Mobile

 

Arizona

Children’s Action Alliance (Arizona)

 

California

Children's Law Center of California

County Welfare Directors Association of California

The Diversity Center

Equality California

Family Builders by Adoption

Los Angeles LGBT Center

LYRIC

North County LGBTQ Resource Center

Resource Center for Nonviolence

Sacramento LGBT Community Center

San Gabriel Valley LGBTQ Center

The Spahr Center

The Source LGBT+ Center

 

Connecticut

Connecticut Alliance of Foster and Adoptive Families

Connecticut Voices for Children

Hispanic Federation - Connecticut

True Colors, Inc. Sexual Minority Youth and Family Services of Connecticut

 

Colorado

GLBT Community Center of Colorado

Inside Out Youth Services

One Colorado

 

Florida

Equality Florida

Hispanic Federation - Florida

Pridelines

Safe Schools South Florida

 

Georgia

Georgia Equality

Georgia Safe Schools Coalition

TRANScending Barriers

Trans(forming)

 

Illinois

Center on Halsted

Equality Illinois

 

Kansas

Children's Alliance of Kansas

Kansas Appleseed

 

Kentucky

Louisville Youth Group Inc.

 

Louisiana

Louisiana Trans Advocates

 

Maine

EqualityMaine

Maine Children's Alliance

Maine Women’s Lobby

 

Maryland

FreeState Justice

GLCCB - Gay, Lesbian, Bisexual & Transgender Community Center in Baltimore, MD

Public Justice Center

 

Massachusetts

Child and Family Services, New Bedford

Jewish Alliance for Law and Social Action

MassEquality

 

Michigan

Grand Rapids Pride Center

OutCenter of Southwest Michigan

 

Minnesota

Gender Justice

 

Missouri

OutFront Kalamazoo

PROMO

 

Montana

Kynexions

Youth Dynamics

 

Nebraska

Voices for Children in Nebraska

 

Nevada

Gay and Lesbian Community Center of Southern Nevada

Purple W.I.N.G.S. Organization

 

New Jersey

New Jersey Parents Caucus, Inc

The Pride Center of New Jersey, Inc.

 

New Mexico

Equality New Mexico

 

New York

Adoptive and Foster Family Coalition of New York

The Children's Agenda

Dignity Buffalo

Fairness Alliance and Information Resources of New York, Inc.

Hamptons LGBT Center

LGBT Network (Long Island/Queens)

Long Island LGBT Community Center

Long Island Gay and Lesbian Youth

Pride Center of the Capital Region

Queens LGBT Community Center

Services and Advocacy for LGBT Elders - Long Island (SAGE-LI)

 

North Carolina

Equality North Carolina

Youth OUTright, WNC

 

Ohio

Equality Ohio

LGBT Community Center of Greater Cleveland

 

Pennsylvania

Bradbury-Sullivan LGBT Community Center

Equality Pennsylvania

Women's Law Project

 

Rhode Island

Adoption Rhode Island

 

South Carolina

SC Equality

South Carolina Appleseed Legal Justice Center

 

South Dakota

Equality South Dakota

 

Tennessee

CCYS

OUTMemphis

Tennessee Equality Project

Tennessee Commission on Children and Youth

 

Texas

DFW Foster Parent Association

Equality Texas

Resource Center

Texas Freedom Network

 

Washington

Gay City: Seattle's LGBTQ Center

Legal Voice

 

Wisconsin

Our Lives Magazine

Wisconsin LGBT Chamber of Commerce

 

District of Columbia

Whitman-Walker Health



cc:      The Honorable Mitch McConnell, Senate Majority Leader

    The Honorable Charles Schumer, Senate Minority Leaders

    The Honorable Paul Ryan, Speaker of the House

    The Honorable Nancy Pelosi, Democratic Leader

 

Public Comment 170: August 2018 – US Senate – No to Ms. Kraninger for CFPB

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Public Comment 171: August 2018 – US Senate – No to non-experienced nominee for CFPB

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