Public Comments 2013 (19-40)

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. These are the 22 comments we made in 2013. They are also mentioned in the Annual Reports.

Public Comment 19: January 2013 - to SEC on Public Disclosure
Public Comment 20: March 2013 - EPA Insecticide
Public Comment 21: March 2013 - Michigan Governor Renewable Energy Standards (RES)
Public Comment 22: March 2013 - Pacific NW LNG Project
Public Comment 23: March 2013 - US Department of State on XL Pipeline
Public Comment 24: April 2013 - SEC New Chair on Disclosure
Public Comment 25: April 2013 - Shareholder Protection Act
Public Comment 26: May 2013 - BLM on Fracking on Public land
Public Comment 27: June 2013 - DOE to deny loan Vogtle Nuclear Plant
Public Comment 28: June 2013 - EPA Glyphosate
Public Comment 29: June 2013 - offer NAACP help with North Carolina Moral Majority
Public Comment 30: August 2013 - to BLM on Fracking on Public Lands
Public Comment 31: September 2013 - Commanding General on Manning
Public Comment 32: September 2013 - Joint Letter for No Syrian War
Public Comment 33: September 2013 - USDA Poultry Inspections
Public Comment 34: October 2013 - EPA Fracking investigations
Public Comment 35: November 2013 - Clemency for War Resister
Public Comment 36: November 2013 - EPA Carbon Pollution
Public Comment 37: December 2013 - DOT on Oil Trains
Public Comment 38: December 2013 - Minnesota DNR to reject sulfide mine
Public Comment 39: December 2013 - Port Metro Vancouver to stop coal terminal expansion
Public Comment 40: December 2013 - Urge SEC to require more disclosure in a joint letter

Public Comment 19: January 2013 - to SEC on Public Disclosure

Below is a public release January 8, 2013, for the Corporate Reform Coalition consisting of the New Progressive Alliance and many other organizations listed below.

SEC Moves to Require That Corporations Disclose All Political Spending

WASHINGTON, D.C. – The Corporate Reform Coalition applauds the Securities and Exchange Commission’s (SEC) commitment to seek disclosure of all corporate political spending in response to a historical demonstration of investor demand for such a rule-making.

In one of the last actions of departing SEC Chair Mary Schapiro’s term, the agency announced that it will consider a proposed rule to require that public companies provide disclosure to shareholders regarding the use of corporate resources for political activities. A petition requesting this rulemaking was filed in 2011 by a bipartisan committee of leading law professors.

In a telephone press conference today, coalition members urged the agency to move swiftly on the rule, now that it is on the agenda.

The SEC has a responsibility to protect investors by regulating the securities markets to ensure that they have the information they need to make investment decisions. Shareholders have a right to know how the companies in their investment portfolio are spending their invested money, especially where these actions are outside the scope of normal business activities, or where the interests of shareholders and management may diverge. This is particularly true with corporate political spending, where certain choices may diverge from a company’s stated values or policies, or may endanger the company’s brand by embroiling it in hot-button issues.

By putting this rule on its agenda, the SEC has responded in part to the Supreme Court’s ruling in Citizens United v. Federal Election Commission, which struck down laws restricting non-coordinated corporate spending to influence elections. In Citizens United, Justice Anthony Kennedy emphasized the importance of disclosure and accountability for corporate political spending, writing that disclosure requirements “provide[] shareholders and citizens with the information needed to hold corporations and elected officials accountable for their positions and supporters.”

Unfortunately, the current public reporting regime does not actually require disclosure of all relevant sources of corporate political spending, and post-Citizens United secret corporate political spending has been on the rise. Corporate funds are frequently funneled through third-party groups such as the U.S. Chamber of Commerce, which refuse to disclose the underlying donors who provide the financial resources for their political activities. The Chamber of Commerce was the single largest outside spender in the 2010 elections, and spent more than $36 million on the 2012 elections.
Americans across the political spectrum strongly support requiring transparency and accountability in corporate political spending. A record number of public comments – more than 322,940 and counting – have been filed with the SEC in support of the petition requesting a rule requiring disclosure of corporate political spending. These comments have come from such diverse sources as a large group of firms managing more than $690 billion in assets, the Maryland State Retirement Agency, U.S. Rep. Gary Ackerman (D-N.Y.) and 42 other members of the House, Sen. Robert Menendez (D-N.J.) and 12 other senators, John Bogle (former CEO of the Vanguard Group), five state treasurers, US SIF: The Forum for Sustainable and Responsible Investment, the Sustainable Investments Institute, and many more.

In a recent poll, eight out of 10 Americans (81%) believe that corporations should only spend money on political campaigns if they disclose their spending immediately (including 77 percent of Republicans and 88 percent of Democrats). Eighty-six percent of Americans agree that prompt disclosure of political spending would help voters, customers, and shareholders hold companies accountable for political behavior (support ranged from 83 percent to 92 percent across all political subgroups). Eighty one percent of Americans agree that the secret flow of corporate political spending is bad for democracy, and 84 percent agree that corporate political spending drowns out the voices of average Americans. Seventy-five percent of respondents said they would sign a petition to the SEC in support of corporate disclosure.

Public Citizen, Demos, CREDO Action, Coalition for Accountability in Political Spending, Common Cause, New Progressive Alliance, Walden Asset Management, Natural Investments LLC, Responsible Endowments Coalition, U.S. Public Interest Research Group, The New School Advisory Committee on Investor Responsibility, the Campaign Legal Center, Green Century Capital Management, Krull and Company, Colorado Sustainable Financial Planning, Effective Assets™, Alliance for a Just Society, Main Street Alliance, Corporate Ethics International/ Business Ethics Network, the AFL-CIO, Friends of the Earth, Democracy 21, Sunlight Foundation, Pax World Mutual Funds, Domini Social Investments LLC, Public Campaign, Citizen Works, NorthStar Asset Management, Inc., the Communications Workers of America, the American Sustainable Business Council, AFSCME, Trillium Asset Management LLC, CREW, Zevin Asset Management, CTW Investment Group, Coffee Party USA, the Social Equity Group, People For the American Way, the League of Conservation Voters, and US SIF: The Forum for Sustainable and Responsible Investment participate in the Corporate Reform Coalition working to increase transparency and accountability for corporate political spending.

QUOTES FROM KEY PLAYERS:

“We congratulate the SEC for listening to investors and the public, in moving forward on a rule that would require publicly traded companies to disclose their political spending. For Mary Schapiro it is an important legacy, and we ask the incoming chair to move the rule forward to completion this year,” said Lisa Gilbert, Director of Public Citizen’s Congress Watch.

“I am delighted that the SEC is carefully considering our petition and the research that convinced us that investors should be given the information they need to assess whether and how their money is spent on politics, said Robert Jackson, law professor at Columbia University and one of the original petition filers. “I hope the SEC will propose rules that will shine light on corporate political spending this year.”

“I am delighted that the Division of Corporation Finance will be considering this year whether to recommend that the SEC issue a proposed rule for corporate political spending as our rulemaking petition urged,” said Lucian Bebchuk, Director of the Program on Corporate Governance at Harvard law School who co-chaired the committee on disclosure of political spending. “The case for such a rule is strong, and the rulemaking petition has attracted exceptional levels of support from the record number of comments filed with the SEC. We very much appreciate the contribution of the Coalition to encouraging the submission of comments to the file.”

“The SEC has taken a step in the right direction by putting disclosure of corporate political spending on its agenda and we will hold them to this promise. We cannot continue to keep our nation's pension funds and investors in the dark about the use of corporate treasury dollars in elections. I urge the incoming SEC Commissioners to act quickly to enact these new rules on disclosure," said Public Advocate Bill de Blasio, trustee of the New York City Employee Retirement System and founder of the Coalition for Accountability in Political Spending (CAPS).

“Undisclosed corporate political spending is a risk factor for investors, and now, with the SEC’s willingness to consider a disclosure rule, investors will have a fighting chance to ensure that such spending is only made in their interests,” said Brandon Rees, Acting Director of the AFL-CIO Office of Investment.

“The SEC should be commended for taking this first concrete step to prevent further secret corporate political spending. Our democratic system of self-government works when we are all political equals. If corporate managers choose to spend money to influence elections, they must do so transparently so they can be held accountable for their positions” said Liz Kennedy, Counsel at Demos.

“Over 150,000 CREDO members took time out of their busy schedules to submit a public comment to the SEC to help end the corrosive flood of anonymous corporate money into our political system. People care deeply about this -- it's not just a wonky regulatory issue -- and it's a small but important first step toward undoing the damaging impact of Citizens United and restoring a measure of sanity to our political system,“ said Becky Bond, Political Director of CREDO Action.

“We are pleased that we are one step closer to ending the days where public corporations can secretly give to political campaigns without any accountability to the public or their shareholders,” said Bob Edgar, President of Common Cause.

“Fortunately, the SEC is reasserting its historical role as the guardian of market integrity in the face of increasing corporate money in politics. This new rule making follows in the footsteps of the SEC’s investigations post-Watergate that uncovered illegal corporate political spending, and the SEC’s recent rules addressing pay to play in the municipal bond market and pay to play for investment advisors to public pension funds,” added Assistant Professor of Law at Stetson University College of Law Ciara Torres-Spelliscy.

“We are heartened that the SEC has taken a step in the right direction in addressing one of the most pressing issues facing our country: anonymous corporate money in our democracy,” said Marge Baker, Executive Vice President of People For the American Way. “Poll after poll shows that this is an issue about which Americans care deeply. Without increased transparency, accountability, and a new approach to addressing corporate political spending, wealthy special interests will continue to undermine our democracy.”

“Full disclosure of all political spending is the only way in which shareholders can evaluate risk. Corporate spending for political purposes should be focused solely on creating shareholder value and should be done in a completely transparent manner. I applaud the SEC for taking up the petition to mandate disclosure of political spending and urge them to protect shareholder rights by ruling in favor of more transparency,” said New York State Comptroller Thomas P. DiNapoli, trustee of the $150.1 billion New York State Common Retirement Fund.

Public Comment 20: March 2013 - EPA Insecticide

March 12, 2013

Bob Perciasepe,
Deputy Administrator
Environmental Protection Agency
1200 Pennsylvania Ave. NW.
Washington, DC 20460-0001

Re: Docket # EPA-HQ-OPP-2008-0850

The New Progressive Alliance at http://newprogs.org/ is very pleased that EPA is evaluating the health risks of the widely used organophosphate insecticide, chlorpyrifos. We are concerned, however, that your current assessment is overlooking recent science.

In 2001, it was banned from home use because exposure puts children’s developing nervous systems at risk. Since that time evidence has shown that it may be even worse than we thought in 2001.

It shows up in most bodies – even those who are not near fields.
It can be very damaging to children or babies even in low levels. In utero exposure has been linked to changes in brain architecture that can last a lifetime. These effects are not even considered in EPA’s current review.
By using it on apples, strawberries, and broccoli caretakers may be under the mistaken impression that they are giving youngsters nutritious food when in fact they are not.
Your review does provide some proof of the damaging effects of chlorpyrifos (such as volatilization drift), but it fails to consider harm to children through biological mechanisms, direct damage to the nervous system enzyme, cholinesterase, and long-term effects on developing children’s nervous systems, such as effects on brain architecture from "in utero" exposure and thyroid effects linked to a range of developmental harms

Please do the right thing and ban chlorpyrifos.

Public Comment 21: March 2013 - Michigan Governor Renewable Energy Standards (RES)

March 12, 2013

The Honorable Governor Rick Snyder
P.O. Box 30013
Lansing, Michigan 48909

Dear Governor Snyder,

Currently, Michigan is on track to meet its goal of 10 percent renewable energy by 2015. Continuing Michigan's momentum towards a cleaner, safer, and more affordable energy future requires policy action to increase and extend the state's current renewable electricity standard. This affects our nationwide economic strength as well as those New Progressive Alliance members who live in Michigan.

Independent science and rigorous analysis show that supporting policies to boost Michigan's use of clean energy resources, such as renewable energy and energy efficiency, will help grow Michigan's economy by creating jobs, lowering costs, and improving public health and the environment. This has been shown repeatedly in other states and other countries.

Without policy action, Michigan's investment in clean energy will drop off significantly when the state's current renewable energy and energy efficiency requirements are fulfilled in 2015. We urge you to include an increase of both renewable energy and energy efficiency in our state's energy plan and to work to implement these clean energy policies starting in early 2014.

Public Comment 22: March 2013 - Pacific NW LNG Project

March 8, 2013

Pacific Northwest LNG Project
Canadian Environmental Assessment Agency
410-701 West Georgia Street
Vancouver, BC V7Y 1C6
Tel.: 604-666-2431
Fax: 604-666-6990
[email protected]

The New Progressive Alliance is an organization with members in Canada, Australia, and the United States. We respectfully request you disapprove the LNG Project for the following reasons.

The record on Pipeline Safety both in Canada and the United States is poor.
Locating it on Lelu Island means a potential of greater environmental damage.
Japex, which now owns at least 10% of this project, is in the tar sands business which will be under increasing scrutiny because of the environmental damage it does.
Economic benefits in Australia, Canada, and the United States on energy export businesses tend not to go to the exporting country. Liabilities, however, for accidents – which are predictable and routine – are paid for by the exporting country.

Please use the science based approach to this that Canada is known for.

Public Comment 23: March 2013 - US Department of State on XL Pipeline

March 12, 2013

United States Department of State

[email protected]

The New Progressive Alliance urges you to reconsider the recent draft Supplemental Environmental Impact Statement (SEIS) on the XL Pipeline for the following reasons.

The earlier objections to the equally misleading EIS remain unanswered.
The assumption that this ecologically destructive and carbon-intensive extraction and processing of highly corrosive oil would develop at roughly the same pace regardless of whether the United States issues a permit for this pipeline is completely unsupported. No other avenues for oil sands transport are of similar scale or in this advanced stage of development.
Safety considerations have not been addressed at all, especially the demonstrated higher risk of pipeline failure due to external corrosion in high temperature pipelines like Keystone XL. The 2010 spill of 1.2 million gallons of oil-sands into the Kalamazoo River demonstrates the expense ($800 million) and unprecedented difficulty in cleaning up this kind of oil.
TransCanada, which would construct the Keystone XL pipeline, is currently under a sweeping audit for systematic violations of minimum safety regulations in the construction of its pipelines.
Standing out as a danger is the complete failure to protect our county's aquifiers which endangers our water supply. There is also a real question if there will be enough water left for drinking and farming after the fossil fuel and nuclear energy get top priority. (references happily furnished upon request)
Also ignored is the stability of our oceans, sometimes called the basis for life. The State Department Bureau of Oceans surely knows the oceans absorb heat and carbon dioxide which makes them warmer and more acidic. In addition to coral reefs, oysters, salmon, and fisheries, there is an alarming drop in plankton, the basis of other sea life and photosynthesis for oxygen both in the sea and over land. (references happily furnished upon request)
American taxpayers, not oil-sands refiners, foot the bill for spills of tar sands oil on US soil.
An recent IRS decision exempts tar sands refiners from paying the 8-cents-per-barrel excise tax applied to other crude oil and petroleum products that funds the Oil Spill Liability Trust Fund.
Job claims are simply false. The SEIS - based on TransCanada’s own numbers - shows that most jobs are temporary, only 35 permanent jobs will be created by the pipeline, and that only 10% of the total workforce will be hired locally.
Most of the oil-sands is destined for export and will improve the US’s energy independence.
Based on the increasing occurrence of extreme weather events and projections supported by a near consensus of the scientific community, the world needs to wean itself off of fossil fuels quickly and dramatically, not continue its development.
Fossil fuels are a finite source, thus this industry will inevitably be a failed business model. Wind, solar, and geothermal are infinite sources which we must rely on in the future, and therefore must point ourselves in that direction.
Also unaddressed are the more immediate environmental effects. These oil sands lie under approximately 140,000 square kilometers of the boreal forest in northern Alberta, which is being destroyed for its extraction. The development is the largest source of GHG emissions in Canada, and is sickening the peoples and ecology around it.

Please do the right thing for future generations. This, more than anything else, is what the Obama administration will be remembered for.

Public Comment 24: April 2013 - SEC New Chair on Disclosure

EMBARGOED UNTIL: Contact: Lauren Strayer, Demos (212) 389-1413

10 am EST April 16, 2013 Lisa Gilbert, Public Citizen (202) 454-5188

500,000 Americans Urge SEC to Require Disclosure of Corporate Political Spending

WASHINGTON, D.C. – The Corporate Reform Coalition calls on newly confirmed SEC Chair Mary Jo White to act now to require disclosure of corporate political spending. A record-breaking 500,000 investors and members of the public have submitted comments supporting the rule, demonstrating the importance of this issue. Chair White should seize this pivotal opportunity to safeguard shareholders by providing them with information necessary for their investing decisions.

In a telephone press conference today, coalition members urged the agency to move swiftly on the rule in response to the overwhelming investor concern.

In December, the agency announced that it would consider the proposed rule to require that public companies provide disclosure to shareholders regarding the use of corporate resources for political activities. A petition requesting this rulemaking was filed in 2011 by a bipartisan committee of leading law professors. The SEC has a responsibility to protect investors by regulating the securities markets to ensure that they have the information they need to make investment decisions.

Investors and members of the public have deluged the SEC with half a million comments urging the agency to act to protect their investments. These comments have come from such diverse sources as John Bogle (former CEO of the Vanguard Group), U.S. Representatives Chris Van Hollen (D-MD), Mike Capuano (D-MA) and 70 other members of the House, more than a dozen U.S. Senators, five state treasurers, the Maryland State Retirement Agency, over 200,000 CREDO activists, US SIF: The Forum for Sustainable and Responsible Investment, the Sustainable Investments Institute, a large group of firms managing more than $690 billion in assets, and many, many more.

“The fact that the SEC has received over 490,000 public comments asking for disclosure of political spending from corporations shows there is wide demand from both shareholders and the public for greater transparency. It seems that some opponents of transparency have forgotten who owns any corporations – the shareholders, not the hired executives. I continue to urge the SEC to move forward with its rulemaking as Congress also explores avenues to address shareholder demands legislatively” said Congressman Michael E. Capuano (MA-07).

“Shareholders have a right to know how companies in their investment portfolio are spending corporate money and that their political expenditures are advancing proper corporate purposes. The SEC should act now to protect investors,” stated New York State Comptroller Thomas P. DiNapoli, trustee of the state’s $152.9 billion Common Retirement Fund.

This area requires particular investor protections because certain corporate political spending choices may diverge from a company’s stated values or policies, or may endanger the company’s brand or shareholder value by embroiling it in hot-button issues.

Trevor Potter, President of the Campaign Legal Center and general counsel to John McCain’s 2008 and 2000 presidential campaigns said, “The proposed rule is a logical response from the SEC to address the changed landscape in the wake of the Supreme Court’s ruling in Citizens United v. Federal Election Commission, striking down laws restricting corporate spending to influence elections. That decision has exposed investors to significant new risks and the SEC is in the right in moving forward to issue this rule in order to require disclosure of corporate political spending in order to allow investors to make informed decisions in the markets.”

In Citizens United, Justice Kennedy emphasized the importance of disclosure and accountability for corporate political spending, writing that disclosure requirements “provide[] shareholders and citizens with the information needed to hold corporations and elected officials accountable for their positions and supporters.”

“America should be a place where everyone has an equal say and an equal chance. But right now, investors don’t have a chance to say anything about the political spending that public corporations may be engaged in because they don’t even know about it. If corporate managers choose to spend corporate money to influence elections, there must be rules that ensure transparency and accountability” said Liz Kennedy, Counsel at Demos.

“As the nation’s pioneer coalition of active investors, the Interfaith Center on Corporate Responsibility has more than four decades of experience identifying areas where corporate transparency leads to good investment decisions for our members. We know that transparency undergirds policies promoting value creation as well as justice and sustainability,” said Laura Berry, executive director of ICCR. “Time and time again we’ve seen the catastrophes wrought by opacity in corporate spending. The SEC must adopt investor protections to ensure transparency in the post-Citizens United environment.”

"Political spending disclosure is critical to ensure honest competition and a strong economy that rewards transparency and innovation, not secrecy and pay-to-play politics," said Tim Christiansen, owner of vino per tutti in Bozeman, Montana and a leader with the Montana Small Business Alliance. "When the U.S. Chamber and other big trade groups defend secrecy in political spending, they're defending a system that stacks the deck against small businesses. Secrecy may be part of the U.S. Chamber's business model, but it's not part of mine."

“The American public believes in this reform, and the American investor demands it. Both polling of the general public and the influx of shareholder comments to the SEC demonstrates that fact,” stated Lisa Gilbert, Director of Public Citizen’s Congress Watch.

Americans across the political spectrum strongly support requiring transparency and accountability in corporate political spending. Polling shows that eight out of 10 Americans (81%) believe that corporations should only spend money on political campaigns if they disclose their spending immediately (including 77 percent of Republicans and 88 percent of Democrats). Eighty-six percent of Americans agree that prompt disclosure of political spending would help voters, customers, and shareholders hold companies accountable for political behavior (support ranged from 83 percent to 92 percent across all political subgroups).

"It's hard to believe there are people who object to this," said Common Cause President Bob Edgar. "Every shareholder is a part owner. When management decides to spend an owner's money on influencing elections, surely the owner ought to at least be able to find out about it."

Lisa Woll, CEO of US SIF said “Representing the only US association of professionals engaged in sustainable and responsible investing, we strongly believe that corporate political spending transparency is in the best interests of investors, companies and the general public. The Securities and Exchange Commission should require this disclosure so that investors can fully understand the actions and risks being taken by companies.”

"The American people have waited long enough. We need an overhaul of political spending to be at the top of Ms. White's agenda. With a vote, she can force the kind of disclosure we've been sorely lacking since the Citizens United ruling, and shed light on the millions in shadowy spending distorting our elections," said Public Advocate Bill de Blasio, trustee of the New York City Employee Retirement System and founder of the Coalition for Accountability in Political Spending (CAPS).

“Hundreds of thousands of Americans have asked the SEC to move forward with a rule requiring the disclosure of political spending by publicly traded corporations,” said Marge Baker, Executive Vice President of People For the American Way. “There is tremendous momentum around this issue. With a newly-confirmed SEC chairman, now is the time to pull back the corporate curtain on election spending. Without the increased transparency and accountability that comes with public disclosure, unchecked corporate spending on our elections will continue to threaten our democracy.”

“College students benefit from the $400 billion in endowments at this country's institutions of higher education. These students are fighting for real policy change on issues from climate change to student loans, and support disclosure of corporate political spending because they want to know how the companies their colleges and universities invest in are spending their money,” said Dan Apfel, Executive Director of the Responsible Endowments Coalition.

Public Citizen, Demos, Coalition for Accountability in Political Spending, Trillium Asset Management LLC, Walden Asset Management, Sunlight Foundation, People for the American Way, the Campaign Legal Center, Democracy 21, New Progressive Alliance, Main Street Alliance, Alliance for a Just Society, U. S. PIRG, Responsible Endowments Coalition, the Coffee Party, Harrington Investments, Inc., CREDO, Social Equity Group, and US SIF: The Forum for Sustainable and Responsible Investment participate in the Corporate Reform Coalition working to increase transparency and accountability for corporate political spending.

Public Comment 25: April 2013 - Shareholder Protection Act

April 25, 2013

Diverse Coalition of 39 Civic Groups Call on Congress to Pass the Shareholder Protection Act

Corporate Political Spending Must Be Subject to Scrutiny by Shareholders, Open to the Public

Today a diverse coalition of groups sent a letter to Congress endorsing the Shareholder Protection Act, sponsored by Sen. Robert Menendez (D-N.J.) in the Senate and Rep. Michael Capuano (D-Mass.) in the House.

In response to the onslaught of corporate spending in federal, state and judicial elections caused by the Supreme Court’s Citizens United ruling, the groups called upon Congress to establish procedures of corporate governance that would involve shareholders in corporate political spending decisions and inform the public of corporate spending in elections.

The call for approval of the Shareholder Protection Act was made by 39 organizations and individuals representing very diverse backgrounds, ranging from environmental and religious groups to institutional investors and labor unions.

“Our organizations come from diverse backgrounds, with concerns ranging from constitutional rights to corporate governance to protecting our air and water,” notes the letter. “We have many different priorities, but we all agree that the unprecedented 2010 Supreme Court decision, Citizens United v. Federal Election Commission, requires a strong response.”

The Shareholder Protection Act would:

Require shareholders to authorize, on an annual basis, a political activities budget of up to a certain amount of money to be set by the corporation.
Mandate that fiduciaries voting on behalf of their investors disclose that vote to investors.
Require the Board of directors to authorize each political expenditure over $50,000 within the overall budget approved by shareholders.
Disclose specific corporate political expenditures online within 48 hours and to shareholders and the SEC on a quarterly basis.

The letter concludes: “Responsible corporate governance requires the involvement of informed shareholders and is not a partisan issue. We believe that holding management accountable and ensuring that political spending decisions are made transparently and in pursuit of sound business is important for both the market and for democracy.”

The complete letter is posted below.

April 25, 2013

U.S. House of Representatives

Washington, D.C. 20515

United States Senate

Washington, D.C. 20510

RE: Support the Shareholder Protection Act

Dear Member of Congress:

We write to you to encourage your support of the Shareholder Protection Act, sponsored by Rep. Michael Capuano (D-MA) and Sen. Robert Menendez (D-NJ).

Our organizations come from diverse backgrounds, with concerns ranging from constitutional rights to corporate governance to protecting our air and water. We have many different priorities, but we all agree that the unprecedented 2010 Supreme Court decision, Citizens United v. Federal Election Commission, requires a strong response.

We are troubled for several reasons by 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.

In the electoral arena, this decision has brought a flood of new and secretive money into elections, ratcheting up the cost of campaigns and increasing the time and resources needed for fundraising. Spending by outside groups funded largely by corporate interests and intended to influence the 2010 elections was more than four times as high than in 2006, the last mid-term cycle. Outside spending increased another four-fold again in the 2012 election cycle. The sources of much of this new money swamping our elections remains undisclosed, as corporations and other special interests launder their campaign funds through non-profit groups, such as the Chamber of Commerce, which are not required to disclose their donors. The ads funded by unaccountable corporate interests fueled massive attacks that compounded the negative tone of campaigns and added to the public cynicism of our elections.

In the legislative arena, the mere threat of unlimited corporate political spending gives corporate lobbyists a large new club to wield when lobbying lawmakers, and makes it harder for legislators to vote their conscience.

In corporate governance, unless a company sets its own internal policies otherwise, 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.

The Shareholder Protection Act provides a framework to rein in some of the damage in this troubling, new political landscape.

Specifically, the Act would:

Mandate prior approval by shareholders for an annual political expenditure budget chosen by the management for a publicly held corporation.
Require that each specific corporate political expenditure over a certain dollar threshold be approved by the Board of Directors and promptly disclosed to shareholders and the public.
Require that institutional investors inform all persons in their investment funds how they voted on corporate political expenditures.
Post on the Securities Exchange Commission web page how much each corporation is spending on elections and which candidates or issues they support or oppose.

American business leaders are concerned about the pressure on business to donate to political campaigns, and the influx of large, undisclosed donations to third party political organizations that are not required to disclose their sources of funding. In a Zogby International poll commissioned by the business-led Committee for Economic Development (CED), two-thirds of business leaders polled agreed with the statement: “the lack of transparency and oversight in corporate political activity encourages behavior that puts corporations at legal risk and endangers corporate reputations.”

In addition to business leaders, the general public at large believes in transparency and giving shareholders a voice. A 2012 survey conducted by Bannon Communications for the Corporate Reform Coalition found that more than 8 in 10 Americans (81%) believe that the secret flow of campaign spending is bad for democracy, and 87 percent agree that prompt disclosure of political spending would help voters, customers and shareholders hold companies accountable for political behavior. Huge majorities of Americans across the political spectrum condemn corporate political spending and support strong reforms. For example, requiring corporations to get shareholder approval before spending money on politics is supported by 73 percent of both Republicans and Democrats, and 71 percent of Independents. About 84 percent of Americans agree that corporate political spending drowns out the voices of average Americans, and 83 percent believe that corporations and corporate CEOs have too much political power and influence.

Responsible corporate governance requires the involvement of informed shareholders and is not a partisan issue. We believe that holding management accountable and ensuring that political spending decisions are made transparently and in pursuit of sound business is important for both the market and for democracy.

We urge you to support the reasoned response that is the Shareholder Protection Act.

Sincerely,

Brennan Center for Justice at N.Y.U. School of Law

Center for Media and Democracy

Chesapeake Climate Action Network

Citizen Works

Citizens for Responsibility and Ethics in Washington (CREW)

Coffee Party USA

Common Cause

Corporate Accountability International

Corporate Ethics International/Business Ethics Network

Democrats.com

Demos

Free Speech for People

Friends of the Earth

Greenpeace

Harrington Investments, Inc.

Holy Cross International Justice Office

Illinois Campaign for Political Reform

Krull and Company, Peter W. Krull, President & Founder

League of Conservation Voters

Maryknoll Office for Global Concerns

National Consumers League

New Progressive Alliance

North Carolina Center for Voter Engagement

NorthStar Asset Management, Inc.

Ohio Citizen Action

People for the American Way

Progressive States Network

Public Campaign

Public Citizen

Service Employees International Union (SEIU)

Social Equity Group, Ron Freund and Duncan Meaney

Strategic Counsel on Corporate Accountability, Sanford Lewis

Sunlight Foundation

Torres-Spelliscy, Ciara

U.S. Public Interest Research Group (US PIRG)

United Food and Commercial Workers

West Virginia Citizen Action

Wisconsin Democracy Campaign

Zevin Asset Management, LLC

Public Comment 26: May 2013 - BLM on Fracking on Public land

May 28, 2013

The New Progressive Alliance at http://newprogs.org/ objects to the ALEC written guidelines for fracking on public lands.

The answer is not natural gas obtained by fracking - "in essence, explode a pipe bomb a few thousand feet beneath the surface, fracturing the surrounding rock." See reference 594 in the below cited article. Unregulated by the EPA because of congressional action combined with the support of President Obama, 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, 375, 376, 377, 404, 410, 414, 434, 456, 475, 483, 521, 542, 543, 544, 594, 602, 639, 683, 684, 685, 686, 687, 688, 689, 712, 713, 715, 716, 717, 718, 734, 735, 736 in the article at http://newprogs.org/blog/2011/11/08/environment-under-democraticrepublican-uni-party.

Fracking endangers our air, water and climate. As the concentration of carbon dioxide in the atmosphere passes 400 parts per million--well beyond what many scientists say is safe--the Obama administration should be working to keep its promise to confront climate change.

Public Comment 27: June 2013 - DOE to deny loan Vogtle Nuclear Plant

June 28, 2013

The Honorable Ernest Moniz

Secretary of Energy
Washington, DC

Fax: (202) 586-4403

The New Progressive Alliance at http://newprogs.org/ urges you to follow the lead of the Office of Management and Budget and deny the 8.3 billion dollar taxpayer loan to Southern Company and its partners for construction of two new nuclear reactors at the Vogtle site in Georgia.

The loan announcement was first made over three years ago. Even though the Department of Energy has extended the deadline for completion of the loan package several times, the loan still has not been granted because the utilities want a sweetheart deal that would put all the risk on the taxpayers. Keep in mind the proposed Vogtle loan would be 15 times larger (and far riskier) than the one given to Solyndra. Also remember that there are many signs of overcharging and incompetence at Vogtle. According to the Georgia Public Service Commission's own watchdog, these reactors are already behind schedule and over budget. (Remember the original Vogtle reactors were 1200% over budget when completed!) The nuclear energy industry has over a fifty year history of being vastly over budget, not to mention having safety or nuclear waste disposal problems.

The loan is now due to be finished by June 30, 2013. If it is not finished on time, please do not extend it again. There are many renewable energy projects that could be on line sooner, cheaper, and with greater reliability.

Public Comment 28: June 2013 - EPA Glyphosate

June 23, 2013

Environmental Protection Agency

docket ID number EPA-HQ-OPP-2012-0132

OPP Docket
Environmental Protection Agency Docket Center (EPA/DC), (28221T)
1200 Pennsylvania Ave. NW.
Washington, DC 20460–0001

The New Progressive Alliance at http://newprogs.org/ objects to the EPA allowing a dramatic increase in glyphosate contamination of food crops, edible oils and waterways at concentrations which are thousands of times higher than the amount needed to cause cancer. The science on this is clear. The false claims of Monsanto are also clear. See below for confirmation.

The stakes in following a science based program as opposed to a corporate enrichment program are huge. Our health and future food production depend on you taking the correct action. Please follow science and the action many other countries have already taken.

Public Comment 29: June 2013 - offer NAACP help with North Carolina Moral Majority

June 27, 2013

Ms. Amina Turner
North Carolina State Conference of the NAACP
P O Box 335

Durham, NC 27702

The New Progressive Alliance at http://newprogs.org/ supports you and Moral Mondays in your struggle to protect the most vulnerable citizens of North Carolina.

As long as our Nation's wealth is being squandered on militarism and wars we will not be able to solve the problems people are experiencing. Government budgets at the national, state and local levels are a reflection of priorities. The needs of the people for living wage jobs, quality public education, adequate housing and health care, food, access to affordable public transportation and recreational programs for youth must take precedence over militarism and wars.

We are in support, and solidarity, with your Moral Monday Movement as you struggle for justice and look forward to working with you on shared concerns. Our North Carolina members will participate with you in your local actions and we wanted you to know the National New Progressive Alliance supports you as well.

(The NAACP replied with a very nice letter.)

Public Comment 30: August 2013 - to BLM on Fracking on Public Lands

August 23, 2013

Bureau of Land Management:

Comment: Document ID BLM-2013-0002-0011 concerning Oil and Gas; Hydraulic Fracturing on Federal and Indian Lands

The New Progressive Alliance at http://newprogs.org/ opposes the Obama Administration recently proposed new rules for oil and gas fracking on federal lands managed by the Bureau of Land Management. The agency's mission is "to sustain the health, diversity, and productivity of America's public lands for the use and enjoyment of present and future generations." Fracking conflicts with this mission.

Fracking and other unconventional methods of extracting oil and natural gas come with intensive drilling and mining, massive amounts of toxic waste, air pollution and pervasive infrastructure that threatens our essential food and water resources.

Drilling and fracking:

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.
Leads to destruction of aquifiers which have already led western communities to face water shortages.
require millions of gallons of water for each well, competing with farmers for local water supplies.
produce massive amounts of toxic and even radioactive waste with no good disposal options.
contaminate sources of drinking water given disposal problems and the thousands of leaks and spills every year.
can lead houses and water wells to explode, due to contamination from methane and other harmful gases.
bring untold costs to local communities, from declines in agriculture, real estate and tourism to road damage, public health problems and increased demand for social services.

The Bureau of Land Management's proposed rules are inadequate.

The regulations would expand “trade secrets” loopholes, allowing well operators to avoid disclosing use of dangerous fracking chemicals.
The rule would require oil and gas companies to report only the chemicals they used that are not claimed to be trade secrets, and only after fracking had already taken place.
The rules provide little regulatory protection for air, water and climate. The regulations do nothing to protect people living near fracked wells from air pollutants that increase risks of cancer and respiratory illness. They do not protect residents from exposure to, or contamination by, the large volume of toxic wastewater that fracking produces.
There is no requirement to collect and disclose baseline data on air and water quality needed for effective regulation.
The rules even ignore the advice of the Obama administration’s own advisory board.

Fracking is a poor practice under any conditions, but especially so on Federal Lands. See references below. The inadequate rules for fracking – many written by the Fracking Companies themselves – make the situation even worse. Please do the right thing and forbid fracking on public lands.

Public Comment 31: September 2013 - Commanding General on Manning

September 17, 2013

Commanding General of the Military District of Washington

Major General Jeffrey S. Buchanan

The New Progressive Alliance at http://newprogs.org/ urges you to use your authority as Convening Authority to reduce Pvt. Manning's sentence. Though I am writing for the New Progressive Alliance, my background is a lawyer and 20 year Navy veteran.

Convening Authorities often see a “big picture” that lawyers operating on technicalities miss and are rightly given the authority to reduce sentences as appropriate. Reasons to reduce Manning’s sentence include the following.

Manning was treated inhumanely in a manner I have never witnessed or heard of in the Navy. (And when I was in the Navy there was such a punishment as three days bread and water!) If someone was in need of psychiatric treatment he was not stripped and awakened every 4 hours. There were tear proof garments that prisoners could not hang themselves with even in the 1980s.
With Wall Street and within the military there is a perception - whether it be true or false – that those who break the law get a pass or a slap on the wrist while those who report the violation are prosecuted to the full extent of the law. Manning’s sentence will go a long way to strengthen or lessen that perception.
Manning did what he thought was right. He may not have been right, but that is an extenuating circumstance that those who raped, for instance, do not have.

Convening Authorities have reduced the sentences of soldiers and sailors who broke military law for conscientious reasons in the past. We think PVT Manning deserves clemency as much as other soldiers and sailors, many of whom had far less extenuating circumstances.

Public Comment 32: September 2013 - Joint Letter for No Syrian War

Progressives, Libertarians, Greens, Conservatives, Independents and Other Persuasions Agree! Launching War on Syria Would Be Unethical, Illegal and Pragmatically Unwise!

Strange political bedfellows seem to have aligned together in the Minnesota congressional delegation on the topic of the (now indefinitely postponed) vote whether to authorize Obama to launch war on Syria. As best we can determine, Keith Ellison and Al Franken consistently favored giving President Barack Obama the authority to bomb Syria while Democratic Congresspersons Colin Peterson, Tim Walz and Rick Nolan and Republicans Michele Bachmann, John Kline and Erik Paulsen all either quickly or eventually indicated they leaned towards opposing authorizing Obama to bomb. And Democrats Amy Klobuchar and Betty McCollum ended up saying they were undecided.

Public opinion polls show large majorities of ordinary U.S. citizens of all political persuasions do not think, for a variety of reasons, that this proposed war should be launched at all! There is a strong bipartisan (and also non-partisan) consensus that nothing good can come of bombing Syria. Calls from the public to elected representatives nationally were reportedly running 100 to 1 against giving Obama new war authority. The undersigned, who represent a variety of different political ideologies in Minnesota all therefore opposed the authorization requested by President Obama for use of military force and U.S. intervention in Syria's civil strife. Now that Obama has announced that the U.S. would work with Russia to implement a plan to put Syria’s stockpile of chemical weapons under control of international authorities and then remove or eliminate them, the congressional vote has been indefinitely postponed. However, there was still some talk in Congress to ensure a “credible threat” of warfare remains on the table by passing new legislation that would “pre-authorize” Obama to bomb Syria if the Russian plan does not work out.

Our consensus, at a minimum, is that military force should only be used by the U.S. and other nations in self-defense, as a last resort or when confronted with imminent risk of danger, and certainly only when Congress declares war according to the U.S. Constitution. We support those Congresspersons and Senators elected in Minnesota who will listen to their constituents, follow the law and not vote to endorse the U.S. entering into another terrible, costly war, and one with inherent, dangerous "mission creep" that risks spreading to other countries, as occurred with the wars on Afghanistan and Iraq. Furthermore, a war launched in violation of the U.N. Charter and the Kellogg-Briand Pact is not only an illegal war of aggression, but is considered the "supreme crime" under international law that carries the seeds of other war crimes. What good will it do to commit such a serious war crime under the pretense of punishing a prior war crime? The whole notion of "humanitarian war" is like the old "bomb the village to save it" notion uttered during the Vietnam War. We thought more of our Minnesota politicians would have learned by now, as the military has, that wars are never "cake walks." And wars are never humanitarian.

Politicians often say, “we have to do something” but there is plenty that can and should be done instead of bombing. Besides implementation of the plan to destroy Syria’s chemical weapons, the U.S. and other countries should also stop arming all fighters in that country as well as push for the few remaining countries in the world which have not previously agreed or ratified the Chemical Weapons Ban to do so.

Our hearts go out to the Syrian civilian victims. These war crimes are deplorable and should be adjudicated and punished but evidence must first be produced for international judicial process and the International Criminal Court. The United States simply does not have "policeman of the world" authority to act unilaterally on its own secret, disputed evidence. (We note that some of the rebel factions are associated with al Qaeda, known to have possessed such dangerous chemical weapons in the past.) If the U.S. Government does possess sufficient evidence, it needs to present this evidence to the United Nations Security Council, the International Criminal Court and/or other international bodies as soon as possible and share it with the public.

Residents of Minnesota:

Todd E. Pierce, Major, U.S. Army (Ret.), Roseville

Coleen Rowley, retired FBI Agent and former DFL-endorsed candidate in 2006 for Congress in MN 02, Apple Valley

Marianne Stebbins, former MN Chair for the Ron Paul 2012 presidential campaign

Phil Willkie, political organizer, Minneapolis

Jack Nelson-Pallmeyer, Professor, former Democratic candidate for US Senate in 2008, and founder of the Minnesota Alternative Spending Priorities (MN-ASAP)

Annie Young, Green Party, Minneapolis Park Board Commissioner

Mike Whelan, peace activist, St. Paul, MN

Bill Rood, peace activist, BA University of Michigan 1969, MA Wayne State University 1973, Rochester

Darlene M. Coffman, peace activist, Rochester

M. J. Lavigne, Do Peace Minnesota, White Bear Lake

Patty Guerrero, peace activist, St. Paul

Pat Jordan,

Richard Segers, peace activist, Savage

Camille Lenling, peace activist, Burnsville

Suzan Koch, peace and human rights activist, Mendota Heights

Alan L. Maki, member of the National Steering Committee of the New Progressive Alliance, Warroad

Mike Madden, St. Paul

John Hazard, Minneapolis

Lydia Howell, Journalist-Premack award winner, Host Catalyst, KFAI Radio

Ben Wiechman, Melrose

Joan C. Wells, St. Paul

Bill McGrath, Northfield

Ross Rowley, Apple Valley

Steve McKeown, Richfield

Georganne Krause, Minneapolis

David Givers, President Red River Veterans for Peace, chap;ter 154, Moorhead

Andrew M. Hine, St. Paul

Tim Hansen

Tim Wulling, US Army (1969-1971), retired electrical engineer, St. Paul

Bruce Brummitt, Carsonville Township, Becker County

Robert Haarman, Emily

Bob and Joy Johnson, members Southeast MN Alliance of Peacemakers, Harmony

Jean Chovan, member Southeast MN Alliance of Peacemakers, Rochester

Hilary Ziols, St. Paul

Henry W. Kliewer, Rochester

Susu Jeffrey, whose Vietnam husband died aged 33 of unknown causes, peace and environmental activist, retired professor and founder of Friends of Coldwater, Minneapolis

Greg Hagen, member of Veterans for Peace, Woodbury

Fredric Markus, independent geographer, Minneapolis

Barbara Vaile, grandmother of ROTC scholar whose body is now dedication to the Navy, Minneapolis

Larry Johnson, President, Veterans for Peace, Chapter 27, Golden Valley

Tom Garry, Mounds View

Kevin Ray Smith, peace activist and member of Veterans for Peace Chapter 127, Minnetonka

Evangelos Kalambokidis, member of Veterans for Peace, Chapter 127, Minneapolis

Molly Johanna Culligan, St. Paul

Bill Tilton, St. Paul

Endorsing Organizations:

Come Home America http://comehomeamerica.wordpress.com/

Minnesota Arms Spending Alternatives Project http://www.mnasap.org/

4th CD/St. Paul Green Party

Antiwar.com

Green Party of Minnesota

Southeast MN Alliance of Peacemakers

Veterans for Peace, Chapter 27

New Progressive Alliance

Public Comment 33: September 2013 - USDA Poultry Inspection

September 17, 2013

Food Safety and Inspection Service
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250-3700

The New Progressive Alliance at http://newprogs.org/ urges you to withdraw the so-called "Modernization of Poultry Slaughter Inspection." Turning most of poultry inspection over to poultry companies so that they can police themselves would have predictably disastrous results.

Specific concerns we have follow.

The proposed rule would make one USDA inspector responsible for inspecting an impossible number of birds, up to 175 birds per minute or three birds per second.
In order to compensate for missed fecal contamination, the proposed rule would permit companies to use more anti-microbial chemicals to clean the poultry carcasses which would in turn encourage the use of dangerous chemical cocktails to compensate for increased line speeds.
Poultry plants that receive traditional USDA inspection had lower salmonella rates than pilot plants using the privatized inspection model. Two of these pilot plants FAILED salmonella testing in recent testing conducted by USDA.
This rule would put the safety of our food at risk, as well as the health of the workers who are using increased amounts of hazardous chemicals to decontaminate the poultry.

We urge you to withdraw this rule for privatizing poultry inspection.

Public Comment 34: October 2013 - EPA Fracking investigations

October 9, 2013

Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

The New Progressive Alliance at http://newprogs.org/ urges the Environmental Protection Agency to re-open and continue the following three fracking investigations.

1. Parker County, TX – The EPA began an investigation after a homeowner reported that his drinking water was bubbling like champagne. But after fracking company Range Resources threatened not to participate in another study in March 2012, the EPA set aside the "smoking gun" report connecting methane migration to fracking.

2. Dimock, PA – The mid-Atlantic EPA began testing water in Dimock, PA after residents complained that their drinking water was contaminated from nearby fracking operations. But the federal EPA closed the investigation in July 2012 even after the staff members who had been testing the water warned of methane, manganese and arsenic contamination.

3. Pavilion, WY – The EPA released a draft report in 2011 linking fracking to contamination of an underground aquifer. After drawing criticism from the oil and gas industry, the EPA handed the investigation over to the state of Wyoming in June 2013 to be completed with funding from EnCana, the drilling company charged with contaminating the water wells in the first place.

Already unregulated because of congressional action combined with the support of President Obama, 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. Further discontinuing even investigating pollution and health damage related to fracking gives industry far too much of an advantage and goes against the EPA Charter.

Public Comment 35: November 2013 - Clemency for War Resister

November 19, 2013

Brigadier General Michael A. Bills

c/o Fort Carson Public Affairs Office
1626 Ellis Street
Suite 200, Building 1118
Fort Carson, CO 80913

Subj: clemency for Private First Class Kimberly Rivera

The New Progressive Alliance at http://newprogs.org/ respectfully urges clemency for Private First Class Kimberly Rivera such that she be allowed to give birth and then discharged with a bad conduct discharge without serving the remainder of her sentence.

As a retired Commander in the Navy I do not claim or pretend she is innocent or not deserving of punishment. The less than honorable BCD will remain with her for the rest of her life as will her sentence. This is an appropriate time for limited clemency.

Public Comment 36: November 2013 - EPA Carbon Pollution

November 20, 2013

Docket ID: EPA-HQ-OAR-2013-0495

Carbon Pollution Standards for New Power Plants

The New Progressive Alliance at http://newprogs.org/ urges the EPA to move forward with the proposed safeguards for new power plants.

Your agency has already determined the debilitating effects of carbon dioxide pollution (plus the many other pollutants involved in mining and burning of coal) and the deadly and expensive costs of climate change. These changes, though modest and late, are a necessary first step. In the face of mounting costs caused by climate change the Environmental Protection Agency should raise the limits on new power plants and apply limits on old power plants.

Public Comment 37: December 2013 - DOT on Oil Trains

December 5, 2013

Docket No. PHMSA-2012-0082 (HM-251)

U.S. Department of Transportation

The New Progressive Alliance at http://newprogs.org/ urges the Department of Transportation to protect our communities from the risks associated with transporting crude oil and tar sands by rail by enacting the following recommendations.

Old and outdated tank cars (e.g. the DOT-111 that carry crude oil and tar sands) should be removed from the rails before it’s too late. An immediate ban on the use of DOT-111 cars, or other inferior cars, is preferable to a lengthy phase-out that leaves communities at risk. DOT-111s puncture even during slow speed accidents. If you accept the increased risk, then at the very least there should be sensible speed limits for any train that uses them.

Emergency responders, local governments, and the public deserve to know when we are being put at risk. Please notify rail communities that are likely to see major increases in crude transport because of the many new proposed terminals around the United States.

Volatile tanker cars should not transit population centers during peak times for train/automobile interactions or when potentially impacted parties (schools, churches, concert venues) are likely to host large numbers of people within a potential blast zone.

Trains should have automatic brakes (dead-man switches) to prevent roll away accidents.

Thank you for your consideration on a matter of importance for the safety of our citizens.

Public Comment 38: December 2013 - Minnesota DNR to reject sulfide mine

December 16, 2013

Minnesota Department of Natural Resources

500 Lafayette Road
St. Paul, MN 55155-4040

[email protected]

The New Progressive Alliance at http://newprogs.org/ urges the Minnesota Department of Natural Resources to reject the PolyMet proposed sulfide mine described in their Supplemental Draft Environmental Impact Statement.

In the summer of 2013 over 24,000 people signed the Mining Truth petition asking Governor Dayton to use four basic criteria to evaluate sulfide mining proposals. Not one of those criteria has been met by PolyMet’s Supplemental Draft Environmental Impact Statement.

Will Minnesota’s water stay safe and clean? Absolutely not! PolyMet would create polluted water requiring expensive treatment for hundreds of years after they stop mining, and millions of gallons of untreated, polluted water would seep from the site every year into groundwater and nearby rivers. There is a national failure to protect our county's aquifiers which endangers our water supply. There is a real question if there will be enough water left for drinking and farming after fossil fuel and nuclear energy get top priority. See references 41, 46, 79, 114, 249, 261, 263, 268, 278, 279, 280, 281, 288, 303, 312, 317, 359, 364, 367, 370, 378, 381, 382, 400, 401, 411, 412, 413, 416, 436, 437, 438, 439, 456, 475, 488, 489, 490, 491, 492, 493, 521, 522, 523, 524, 545, 574, 575, 576, 607, 608, 609, 725, 726, 727, 728, 729, 730, 731, 732, 733, 734, 736, 789, 790, 791, 792, 793, 794, 795, 796, 821, 822, 823, 824, 858, 859, 860, 861, 862, 863, 940, 941, 961, 987, 988, 989, 990, 991, 992, 993, 994, 995, 996, 997, 998, 999, 1000, 1002, 1003, 1004, 1005, 1097, 1098, 1099, 1100, 1101, 1102, 1103, 1104, 1105, 1106, 1107, 1108, 1109 in this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
Are there strong safeguards in place for when things go wrong? PolyMet’s plan fails to plan for contingencies like pipeline breakages and extreme weather events. Experience has proven these are inevitable. 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, 569, 570, 571, 572, 573, 574, 577, 578, 586, 587, 588, 596, 597, 598, 605, 606, 640, 721, 722, 723, 724, 734, 735, 736, 778, 779, 780, 784, 849, 850, 851, 852, 853, 854, 855, 891, 974, 975, 976, 977, 978, 979, 980, 981, 1081, 1082, 1083, 1084, 1085, 1086, 1087, 1088, 1089, 1090, 1091, 1092, 1093 in this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
Will the company leave the site clean and maintenance free? Again, absolutely not. See the above references.
Will Minnesota taxpayers be protected? Again, absolutely not! This involves a trade of 20 years of mining for perhaps centuries of monitoring, treatment of polluted water, and site maintenance.

Due to the problems with the Supplemental Draft Environmental Impact Statement, we believe the mine should not be built as described.

Public Comment 39: December 2013 - Port Metro Vancouver to stop coal terminal expansion

December 15, 2013

The New Progressive Alliance at http://newprogs.org/ urges Port Metro Vancouver to perform a new valid Environmental Impact Assessment before expanding the Fraser Surrey Docks coal terminal. A new valid Environmental Impact Assessment should include the following.

they must involve key stakeholders such as Health Authorities from the start;
they must include an assessment of the risks of the proposed coal export expansion at Neptune Terminals;
they must be open and transparent and incorporate public hearings;
they must consider all local impacts from the time the coal enters our region by rail to the time it enters international waters by ocean going vessel;
they must consider climate change impacts of the end use of that coal;

If the project to massively expand Fraser Surrey Docks coal terminal at Port Metro Vancouver (PMV) is approved then Vancouver would become the biggest coal exporter in North America. Not only would the associated carbon emissions be greater than BC’s current total annual carbon output, this coal export project is just the tip of the iceberg to make BC a gateway to profits for the fossil fuel industry. While a coal terminal may be all that is under consideration for now, you are facing a juggernaut of fossil fuel development that puts your climate, water and health at risk for the sake of corporate profit. Stricter regulations and fierce community resistance has American coal producers looking to BC ports for a way to ship their dirty coal overseas. Is this what you want for beautiful Vancouver? To become the dumping ground for North American coal exports?

If the Port Metro Vancouver cannot properly assess the potential impacts of coal exports, it should deny the Fraser Surrey Docks permit and suspend any further expansion of coal exports.

Public Comment 40: December 2013 - Urge SEC to require more disclosure in a joint letter

Political contributions by corporations used to be strictly controlled. Now they do not even have to be reported to the government or even the shareholders of the company. Despite over three quarters of a million comments (including those of the NPA) urging more disclosure, the Securities and Exchange Commission recently submitted an agenda with nothing on disclosure. It was submitted over Thanksgiving in hopes it would go unnoticed. In December 2013 the NPA joined with 51 other organizations in protesting the outrageous decision with the below press release from the Corporate Reform Coalition.

The Corporate Reform Coalition is deeply disappointed by and demands an explanation for the removal from its agenda of the most widely supported rulemaking in the Securities and Exchange Commission’s history. The agency chose to put the political spending disclosure rule on their docket for consideration based on its strong support from investors and the potential risks to companies from secret political spending. The decision to drop this rule and others from the 2014 Commission agenda is a step back from the SEC’s proactive agenda to protect investors.

There is an urgent need for a new disclosure rule to address political spending since the U.S. Supreme Court’s Citizens United decision allowed companies to directly spend their money in politics. Citizens United also affirmed the constitutionality of disclosure requirements and, in fact, assumed that new corporate political spending would be transparent to shareholders. Justice Kennedy said in the opinion that “shareholder objections raised through the procedures of corporate democracy” would provide accountability for the new political spending. Without a mandatory disclosure rule shareholders do not have the ability to raise those objections.

Resolutions calling for company disclosure of political spending have topped the shareholder agenda for the last five years, and this year will be no exception. For the 2014 proxy season, this will remain a priority as more investors will be urging companies to disclose their political spending. Shareholders and other securities experts see an SEC rule as critical to achieving uniform political disclosure.

More than 100 leading companies have taken the initiative to publicly disclose their political spending. This demonstrates the ease with which these disclosures can be accomplished. It also demonstrates the acceptance of disclosure by many prominent and large corporations. Unfortunately, however, other companies keep their shareholders in the dark, unaware if their money is funding political campaigns and even political attack ads.

The SEC has received nearly 700,000 comments – a record breaking number -- urging disclosure of political spending. In addition, surveys commissioned by the Committee for Economic Development and the Center for Political Accountability found a strong majority of business leaders endorsing corporate disclosure of direct and indirect political spending. The SEC had taken the public and investor demand for greater disclosure into account and was considering a rulemaking in response to this demonstrated need.

The context has not changed. This rule is still necessary. We look forward to an explanation from SEC chairman Mary Jo White as to why the investor demand for this updated regulation is being rebuffed. We urge that this decision be reversed and that the rulemaking returned to the SEC’s agenda. In the meantime, the agency should publicly explain the questions it needs answered in order to move forward with the rulemaking in a concept release.. The rights of shareholders must be protected, and the SEC has the means and the mandate to do so. The commission must renew its political disclosure rulemaking. This is critical both for democracy and the rights of investors in the marketplace. The agency owes investors – and the public -- nothing less.

Alliance for a Just Society

American Federation of Labor-Congress of Industrial Organizations (AFLCIO)

As You Sow

Amazon Watch

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

Americans for Campaign Reform

Boston Common Asset Management

Brennan Center for Justice

Campaign Legal Center

Center for Political Accountability

Center for Responsive Politics

Change to Win

Citizens for Responsibility and Ethics in Washington (CREW)

Citizen Works

Clean Yield Asset Management

Common Cause

Communications Workers of America (CWA)

Credo Mobile

Democracy 21

Demos

Domini Social Investments

Dominican Sisters of Hope

Friends of the Earth

Green Century Fund

Greenpeace

Harrington Investments

HIP Investor, Inc.

International Brotherhood of Teamsters (IBT)

Investor Voice, SPC

League of Conservation Voters

Main Street Alliance

National Consumers League (NCL)

New Progressive Alliance

Newground Social Investment, SPC

People for the American Way (PFAW)

Progressives United

Public Citizen

Responsible Endowments Coalition

Responsible Wealth

Social Equity Group

SumOfUs

Sunlight Foundation

The Sustainability Group of Loring, Wolcott and Coolidge

U.S. Public Interest Research Group (U.S.PIRG)

Union of Concerned Scientists

United Food and Commercial Workers (UFCW)

United for a Fair Economy

Ursuline Sisters of Tildonk

US SIF: The Forum for Sustainable and Responsible Investment

Walden Asset Management

Wisconsin Democracy Campaign

WV Citizen Action Group

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