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 under "News."  (We only publish comments after we can confirm them. Some of the comments here were initially submitted in 2015.)

• Public Comment 86: January 2016 - So You Want to Volunteer for the United Nations
• Public Comment 87: January 2016 - Make Your Case with the 2015 United Nations Climate Change Conference, COP 21
• Public Comment 88: January 2016 - Keeping Big Polluters Out of COP21
• Public Comment 89: January 2016 - SEC - FASB on materiality
• Public Comment 90: January 2016 - Postmaster General on Postal Banking
• Public Comment 91: January 2016 - EFSEC Tesoro Savage Proposal
• Public Comment 92: January 2016 - Joint statement in support of moratorium on all oil activities in the wider Virunga, Congo, Africa  area
• Public Comment 93: January 2016 - AB 700, California Disclose Act
• Public Comment 94: February 2016 - Clean Budget Letter
• Public Comment 95: February 2016 - Reynolds Aluminum Clean Up
• Public Comment 96: February 2016 - UN CEPA - World Bank - COP 21
• Public Comment 97: March 2016 - President - EO Requiring Mandatory Disclosure for Political Spending
• Public Comment 98: March 2016 – Welcome Yes on I-732
• Public Comment 99: March 2016 – Welcome Beyond Extreme Energy
• Public Comment 100: March 2016 - US HOR Support STOCK on Disclosure
• Public Comment 101: April 2016 - SEPA - Natural Gas to Methanol Plant
• Public Comment 102: April 2016 - USDA Forest Service - Stop Arch Coal 
• Public Comment 103: April 2016 - Vancouver Port Terminate Lease
• Public Comment 104: April 2016 - Washington State Utilities and Transportation Commission – Retire Colstrip Coal Generating Station
• Public Comment 105: May 2016 - Congress: Free SEC to Require Political Disclosure
• Public Comment 106: June 2016 - Washington state: Stop Millennium Coal Terminal
• Public Comment 107: June 2016 - Washington state Ecology - Oil Train Safety
• Public Comment 108: June 2016 - BOEM - Stop Gulf and Atlantic Off Shore Drilling
• Public Comment 109: July 2016 - Leap Manifesto - Canadian Post Office
• Public Comment 110: August 2016 - BLM - Stop Coal Mining on Public Land
• Public Comment 111: September 2016 - Enterprise out of ALEC

January 2016 - So You Want to Volunteer for the United Nations - Public Comment 86

 

January 2016 - Make Your Case with the 2015 United Nations Climate Change Conference, COP 21 - Public Comment 87

I have read all of the international agreement COP 21 (COP 21 – for Conference Of the Parties #21 – Parties are countries.) signed on 12 December 2015. I have practiced law, though never dealt with international law except peripherally in the Navy. The agreement will become legally binding if joined by at least 55 countries which together represent at least 55 percent of global greenhouse emissions sign and adopt the agreement in New York between 22 April 2016 and 21 April 2017.

This is certainly not a binding agreement with specific requirements which guarantee our safety. Though under Article 2 the parties will "pursue efforts to" limit the temperature increase to 1.5 °C, each country can do whatever it wants to.  Pressure to do the right activity and enough of the right activity must come from its citizens. To say it is worthless goes too far, however, and I believe is too pessimistic. It does give us a point to demand progress, make comparisons between countries, and make public statements. 

Some points:

• More writing is on adaptations than preventing the crisis.
• “Parties aim to reach global peaking of greenhouse gas emissions as soon as possible…” (Article 4, paragraph 1)
• It gives an out (Article 4, paragraph 15) for “concerns…with economies.”
• Each party shall “promote sustainable development and ensure environmental integrity and transparency…” (Article 6 paragraph 2)
• Countries shall share information and make it public. (Article 12)
• Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7)
• The parties will meet starting in 2023 and every five years take stock of the global outcomes. (Article 14 paragraph 2)

Where does this leave us in the United States? Other countries have already surpassed us to a significant degree in the use of renewable energy. Almost all countries pay fossil fuel companies orders of magnitude more than renewable energy. Falling behind other countries in these areas makes us less competitive. The frequency and severity of weather related disasters will continue to increase and it will become more and more obvious how serious climate change is. Link how following the COP 21 will benefit all of us.

Remember including this agreement should be a factor and not a primary argument. There is much animosity against the United Nations, some of it justified. Make your case with benefits of clean energy, better jobs, a more competitive economy, damage of fossil fuels, and cheaper long term costs before mentioning the UN agreement. Then it is good to end with a patriotic appeal that we as a nation can be as competitive as Costa Rica. (or one of the many other countries that have passed us.)

References

1-The actual agreement: 2015 United Nations Climate Change Conference, COP 21 

2-Wikipedia on 2015 United Nations Climate Change Conference 

3-3 New Year’s Resolutions That Will End the World’s Dependency on Fossil Fuels

4-So You Want to Volunteer for the United Nations  

 

January 2016 - Keeping Big Polluters Out of COP21 - Public Comment 88

The fossil fuel industry has incredible influence over the UN climate talks and policymaking around the world – it has been slowing down progress for years. Today, we are facing the prospect of the destruction of life as we know it and irreversible damage to our planet due to climate change. Scientists are telling us with ever more urgency that we must act quickly to stop extracting fossil fuels and reduce greenhouse gas emissions. But the world’s largest polluters have prevented progress on bold climate action for far too long. The fossil fuel industry and other transnational corporations that have a vested interest in stopping progress continue to delay, weaken, and block climate policy at every level. From the World Coal Association hosting a summit on “clean coal” around COP19 to Shell aggressively lobbying in the European Union for weak renewable energy goals while promoting gas, these big polluters are peddling false solutions to protect their profits while driving the climate crisis closer to the brink.

Given the fossil fuel industry’s years of interference intended to block progress, push false solutions, and continue the disastrous status quo, the time has come to stop treating big polluters as legitimate ‘stakeholders’ and to remove them from climate policymaking.” The New Progressive Alliance along with other organizations under the Corporate Accountability International delivered this message to COP21 in December 2015 to protect COP21 and all future negotiations from the influence of big polluters.

See also above January 2016 - Make Your Case with the 2015 United Nations Climate Change Conference, COP 21

 

January 2016 - SEC - FASB on materiality - Public Comment 89

 

December 6, 2015

 

Mary Jo White/Chair

James Schnurr/Office of Chief Accountant

Securities and Exchange Commission

 

Members

Financial Accounting Standards Board

 

Via email

[email protected]

[email protected]

 

Re: “Materiality,” File Reference No. 2015-310

 

We, the undersigned, express our strong opposition to the proposed concept release and notes

to financial statements on Topic 235 regarding materiality.

 

Congress declared that the Securities Exchange Commission would administer disclosures and referee such issues as the definition of materiality. (1) To inform its decisions, the SEC looks to the Financial Accounting Standards Board (FASB). FASB represents itself as a respected repository of thoughtful experts. (2) Because the SEC may ignore FASB’s initiatives, FASB presumably engages in iterative conversation with SEC officials as it proceeds to ensure acceptance of its standards and guidelines. (3) We believe what this means in practice is that what FASB promulgates carries the implicit imprimatur of the SEC. Consequently, our comment to FASB is also a comment to the SEC, as we view the institutions as collegial.

 

Currently, as described by the FASB, materiality means information that “could” influence

investor decisions. Materiality applies to the notes in a financial statement, namely, the

descriptive deconstruction by management of specific items that are part of the aggregate

quantifications in the financial statement (either the income statement or balance sheet). (4)

 

Comes now a proposal to change the definition of materiality from what “could” influence an

investor, to what “would” influence the investor.

 

FASB explains that this new description of materiality stems from a long-term FASB “project”

titled “Disclosure Framework.” FASB states that the “Board hopes that a sharper focus on

important information will result in reduced volume in most cases. (5) We disagree with this

goal. In general, more disclosure is better than less disclosure. (6) Finance-based problems stem

from a lack of disclosure, from “reduced volume,” such as Enron, World Com, the Madoff Ponzi

scheme and many others. The 2008 financial crisis depended on material risk masked from

investors.

 

As to the claim that investors suffer from information overload, we need only point to such

devices as search engines on computers, and the availability of Wall Street industry analysts

who can cut through the chaff of corporate reports. We are unaware of any groundswell of

investors petitioning the SEC for less information.

 

We are concerned that FASB adopted its goal of winnowing corporate reports with the help of

and because of those it recruited to advise it. FASB explains that its “Disclosure Framework”

project results from the advice of a “resource group.” (7) This resource group generally decided

that information that “could be useful to investors …” was considered too broad and too low a

threshold. Participants generally favored using “would be useful” instead of “could be useful.”

Who were these participants? Not one of them could be described primarily as an investor, or

consumers of material information. (8)

 

We believe the proposed change by FASB threatens serious harm. FASB’s proposed change

would lead to less disclosure of material information in two important ways. First, it devalues

the standard of information from what “could” influence a capital provider, to information that

would “substantially alter” the views of the capital provider. By itself, this higher hurdle will

mean that some information currently described in the notes will now go missing.

 

Second, FASB declares that the concept of materiality is a legal concept. A legal concept is one

that can be altered by Congress, by the courts, or by an administrative agency. We believe this

is a momentous retreat from a concept that otherwise exists in multiple venues. (9)

We agree that each of these venues for the expression of law does serve a purpose in shaping the contours of materiality, but we do not concede that they should be the exclusive venue. Indeed, FASB, which is comprised of accountants, might consider itself a body that could help identify the parameters of materiality. (10)

 

Defining materiality as a legal concept also makes a firm’s legal officer the pivotal arbiter of the

issue. Currently an independent auditor might take a contest over whether an item should be

discussed in the notes to the firm’s board audit committee. With this dynamic in force, the

company’s financial officer might tend to accept the auditor’s recommendation instead of

facing board arbitration. Under the new FASB rubric, a dispute between the auditor and in-

house finance official will be settled by the in-house counsel. With this dynamic, the company’s

auditor is less likely to contest the omission of what she might consider material information. In

short, this dynamic will result in less information.

 

Even where the omission does, in fact, involve material information; it is not clear how a

plaintiff will seek a remedy or how a court will weigh the evidence. If a company obtains a legal

opinion from its in-house counsel, a plaintiff may need to establish the legal incompetence of

the in-house counsel. The issue of accounting competency will be irrelevant.

 

We urge FASB to withdraw its proposal. We ask that it reconstitute an advisory panel composed

of financial information users. The concept of materiality is important, and we look forward to a

good faith effort to better help issuers to inform their investors.

 

Sincerely,

 

Public Citizen,

Pax World Management LLC

Greenpeace

New Progressive Alliance

Harrington Investments, Inc

CREDO

International Brotherhood of Teamsters

Center for Effective Government

Global Witness

US PIRG

 

1-http://www.huffingtonpost.com/barbara-roper/sec-turns-disclosure-into_b_8462482.html--Bulletin 99, Materiality, SEC (1999), available at: https://www.sec.gov/interps/account/sab99.htm

2-On its website, FASB explains: “The FASB accomplishes its mission through a comprehensive and independent process that encourages broad participation, objectively considers all stakeholder views, and is subject to oversight by the Financial Accounting Foundation’s Board of Trustees.” See http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1351027215692

3-Tom Selling, a professor and former SEC staffer with the Office of Chief Accountant, explains, “The probability that [SEC Chief Accountant James] Schnurr isn’t fully supportive of the FASB proposals is essentially zero. Hence, it strains credibility that Mr. Schnurr didn’t provide at least some initial direction to the FASB. Otherwise, why would the FASB want to be sticking its nose in the PCAOB’s business?” The Accounting Onion, by Tom Selling (2015), available at: available at: http://accountingonion.com/2015/10/fasbs-proposed-materiality-clarifications-are-backfiring.html

4-One imagines that the accounting industry might have developed a manual that establishes numerical metrics. The question of materiality is undoubtedly informed by the hundreds of independent auditor hours expended each year at many thousands of public companies, a ritual that has taken place for many decades. Further, the stock market provides a minute-by-minute evaluation of information that changes stock prices. Given this one might hope that a concept so basic as materiality would enjoy a more muscular description than what seems little beyond a tautology, namely, that which could change an investor’s view.

5-See FASB Project Update, (website visited October 2015), Available at: http://www.fasb.org/cs/ContentServer?c=FASBContent_C&pagename=FASB%2FFASBContent_C%2FProjectUpdatePage&cid=1176156344894

6-See press release, Univ of Tennessee, available at: http://tntoday.utk.edu/2015/10/29/carcello-speaks-proposedrules-limiting-disclosure/

7-FASB Resource group: http://www.fasb.org/cs/ContentServer?c=Document_C&pagename=FASB%2FDocument_C%2FDocumentPage&cid=1176160567809

8-In response to Public Citizen inquiry, FASB representatives pointed to three “stakeholders” that were not “issuers” or accountants. These are representatives from a. the Center for Financial Research and Analysis; b.Standard & Poors; and c. Lazard Freres. The first is a group that specializes in forensic accounting, a businessmodel that profits from finding what’s not transparent. The other two cannot be considered independent consumers of financial information, as their clients are issuers. Email from FASB available upon request

9-These venues include the law, facts, and markets, which can be influence by emotion. Information contained in print may have a different impact than video. For example, it may be immaterial that a CEO is arrested for DUI. However, if this arrest is captured on video, this may lead to a different impression of the same information. See discussion, available at: http://www.theconglomerate.org/2010/10/is-your-ceo-beingarrested-for-dwidui-material.html. In another case, a CEO was caught on a surveillance camera abusing his dog. This became public, and the company was forced to issue a statement condemning its CEO. See San Diego Union, available at: http://www.sandiegouniontribune.com/news/2014/aug/25/centerplate-ceo-dogkicking-san-diego-contracts/

10-DELETE OR REWRITE

 

January 2016 - Postmaster General on Postal Banking - Public Comment 90

The New Progressive Alliance with other organizations such as the Alliance for Retired Americans, the American Postal Workers Unions, and Daily Kos urged Postmaster General Brennan to expand the postal service’s offerings by implementing postal banking. By doing so, the USPS will be offering a non-profit banking option to millions of Americans including those who are currently forced to rely on payday lenders, check cashers and other financial predators who charge approximately 10% on fees and services.

 

Nearly 28% of U.S. households are underserved by traditional banks and turn instead to payday lenders, check cashers and other financial predators, spending nearly 10 percent of their income on fees and services, on average. These services are part of an industry that rakes in $103 billion a year at the expense of the most financially vulnerable.

 

The simple solution is Postal Banking. The more than 30,000 branches of the U.S. Postal Service can provide affordable, non-profit, consumer-driven financial services ranging from paycheck cashing and bill payment to savings accounts and small dollar loans.

 

The USPS is a well-trusted public institution that currently provides limited financial services such as money orders. The USPS can act now to:

 

*Install surcharge-free ATMs making it possible for recipients of public benefits to access funds without paying a fee;

* Expand services to include payroll check cashing; and

* Provide bill paying and electronic funds transfers.

* Paycheck Cashing,

* Surcharge free ATMs,

* Bill Paying Services, and

* Electronic Money Transfers

 

For those without access to traditional banks as well as those looking for an alternative to the Big Banks, Postal Banking is a real solution that serves the public, not Wall Street.

 

January 2016 - EFSEC Tesoro Savage Proposal - Public Comment 91

January 14, 2016

Energy Facility Site Evaluation Council (EFSEC)

P.O. Box 43172

Olympia, WA 98504

 

Re: Tesoro Savage Proposal

            The New Progressive Alliance at http://newprogs.org/  urges you to reject the Tesoro Savage Vancouver Energy Distribution Terminal Facility Proposal for the following three reasons.

I. There is no need.

Nobody is suggesting closing down refineries or suddenly doing without oil. There is just no need for building the largest oil by rail refinery in North America. Oil prices have dropped below 30 dollars a barrel for the first time since December 2003.  The latest wave of selling leaves crude oil down 19% this year alone. It represents an incredible 72% plunge from crude's June 2014 peak of almost $108.  See:   http://www.tomdispatch.com/post/176089/tomgram%3A_michael_klare%2C_the_look_of_a_badly_oiled_planet/

II. The proposal, though detailed, is flawed.

       The proposal is not so much an analysis as a brief of best possible outcomes and most optimistic predictions should the terminal be built. It is also based upon the least possible actions to prepare for or mitigate damages and the minimization of environmental effects which defy both common sense and reason. For examples, consider the following points.

• Chapter 4 on Crude Oil Safety Considerations says, “Additionally, Washington and Oregon laws have instituted financial liability to owners for operation of vessels carrying crude oil. Operators of vessels carrying crude oil from the proposed Facility and the owner of the crude oil would be strictly liable for any damage and the cleanup in the event of a spill and would be required to maintain adequate financial resources (including insurance) to respond to a potential oil spill regardless of fault. These liabilities create significant financial incentives for compliance with all required and any self-imposed risk mitigation measures that are available. In addition to civil liabilities there are also significant criminal liabilities. For example, 33 USC 309(c)(1) authorizes imprisonment and up to $25,000 per day fines for oil spills.” This ignores the long held fossil fuel practice of declaring bankruptcy or simply getting away with pleading they can’t afford it after large spills. Ultimately, the tax payer and government are responsible.
• On ES-9 under 6.2.1 the Draft EIS  says, “No significant (moderate to major) cumulative impacts were identified for the proposed facility in combination with past, present, and reasonably foreseeable future actions.”  This is incredible and ignores the many rail and sea disasters that keep happening despite reassurances after each disaster. The delay to transportation of many mile plus long trains is not even considered. To look at this proposal in isolation without considering other pollution sources - as the Draft EIS does - seems to suggest unfamiliarity with the word “cumulative.”
• Most of our rail infrastructure is over a century old.
• The dangers are illustrated by the 47 people who died in the Quebec explosion of 2013. Since then there have been 12 train explosions so far and about 15 derailments a year, including on the newer supposedly safer CPC-1232 rail cars.
• On ES-14 using wildly optimistic and undocumented assumptions, the Draft EIS said that there would be a derailment of one loaded railroad car spilling up to 700 barrels of crude oil every 27 years, a vessel loading spill of up to 1 barrel every 14 years, and a grounding or collision with a spill of up to 1,000 barrels every 34 years. Even using these unrealistic optimistic estimates show building this facility is a bad idea.
• On ES-14 and ES-15 Emergency Response Preparedness is discussed. The Vancouver firefighters union opposes the oil terminal because of the unacceptable risk to our first responders, port workers and the public. Its protocol for responding to oil train and terminal fires is “nonintervention,” meaning the fire department would evacuate the area and let the oil burn. That’s all we can do. In an urban or industrial area, that leaves too many lives and properties in danger. ES-15 describes how most fire departments are woefully unaware of even where to call for advice.
• ES-16 says all tank rail cars will meet the newer DOT-117 specifications. This is no comfort at all.  The CPC-1232 rail cars (designed to replace the older DOT-111 cars of 1970s design) have still exploded and burned and are only designed to withstand impacts of 12 to 18 miles per hour. Further railroads have until May 1, 2025 to meet even this small improvement. Since 47 people died in the Quebec explosion of 2013 there have been 12 train explosions and about 15 train derailments a year. This is an unacceptable risk.
• ES-17 says the applicant will “conduct a study  to identify an appropriate level of financial responsibility for the potential costs for response and cleanup of oil spills, natural resource damages, and costs to state and affected counties and cities for their response actions to reduce the risks and impacts from an oil spill.” It is difficult to imagine a statement more naïve or unfamiliar with what repeatedly happens in fossil fuel spills and accidents. Fossil fuel companies say they will be responsible and then leave the jurisdiction or declare bankruptcy resulting in leaving tax payers and the government to clean up their messes after they have absconded with the profits.

III.  If approved this will hurt United States interests because of the 2015  United Nations Agreement COP21.

Even if COP 21 is not adopted by the United States, the amount of oil exported from the United States will be reported. The biggest oil terminal in North America would of course play a major role. If enacted, this proposal would create an estimated 54 metric tons of carbon dioxide – an amount that is significant on a global scale. This will surely put us in a poorer position with other countries when it is time for continued negotiations.

 

            For all the above three reasons, the New Progressive Alliance urges the Energy Facility Site Evaluation Council  to deny the Tesoro Savage Proposal.

 

January 2016 - Joint statement in support of moratorium on all oil activities in the wider Virunga, Congo, Africa  area - Public Comment 92

Signatories ACADHOSHA	Descartes Mponge Malasi
Action Coalition for Climate Change	Enock Nimpamya
Advocates Coalition for Development and Environment (ACODE)	Dr. Arthur Bainomugisha
Advocates for Natural Resource Governance and Development (ANARDE)	Frank Tumusiime
Africa Institute for Energy Governance (AFIEGO)	Dickens Kamugisha
African Wildlife Foundation	Kaddu Sebunya - President
Association Pour Le Developpement Des Initives Paysannes	Janvier Murairi
Asyanut Safaris	Babra Adoso Vanhelleputte
Australian Rainforest Conservation Society	Dr Aila Keto. AO - President
Biosphere Expeditions	Dr. Matthias Hammer - Executive Director
Bob Brown Foundation	Jenny Weber
Buliisa Initiative for Rural Development Organisation (BIRUDO)	Paolyel MP Onencan
Civic Response On Environment & Development (CRED)	Bashir Twesigye - Executive Director
CJDH-RDC	Fortunat Maronga
Community Development and Conservation Agency (CODECA)	Asiku Micah
Conservation Action Trust	Francis Garrard - Director
CREDDHO	Semakuba Corneille
Earthworks	Jennifer Krill
Ecological Christian Organisation (ECO Uganda)	Charles Kabiswa
eCountability	Bill Butcher- Director
Elephants Alive	Marlene McCay - Founder and Chairperson
EST	Jean Marie Mangaya
Fauna & Flora International	Mark Rose - Chief Executive Officer
FECOPEILE	Josué Mukura
Gaia Foundation	Liz Hosken
Global Rights Alert	Winnie Ngabiirwe
Global Witness	Patrick Alley - Founder
Greenpeace	Victorine Sirri Che Thöner
Greenwatch	Irene Ssekyana
IDPE	Bantu LUKAMBO
Jeunesse du Monde République Démocratique du Congo	Mr Tibère Kajemba Dunia
Lake Albert Biodiversity Conservation Alert (LABCA)	Mugume Michael
Matoke Tours	Willem Johannes Kok - Managing director
Mid-western region Centre for Democracy & human rights (MICOUD)	Lawrence Kangula
Mutanda Lake Resort	Willem Johannes Kok - Managing director
Nature Uganda	Archilles Byaruhanga
New Eden Christian Foundation	Canon Baluku
New Progressive Alliance	Ed Griffith
Pro-Biodiversity Conservationists in Uganda (PROBICOU)	Robert Tumwesigye
Rainforest Action Network	Lindsey Allen - Executive Director
Rainforest Foundation Norway	Lars Løvold - Director
Rainforest Foundation UK	Simon Counsell
RCGW	Kisuba Muliro Rousseau
Real Agency for Community Development(RACD)	Banturaki Benard
Road Free	Kriton Arsenis - Founder
Save the Elephants	Iain Douglas-Hamilton - Founder & CEO
Save Virunga	Save Virunga Team
SEA DRC	Paul Kasereka
SORADEC	Espoir Shekihumi
South Western Institute for Policy & Advocacy (SOWIPA)	Ben Tumwesigye
SVAN	Mme Masika Tulinabo
Synchronicity Earth	Laura Miller - CEO
The Wild Foundation	Vance G. Martin
Transparency International Uganda	Peter Wandera
UECN	Jonas Pandasi
UFAREP	Janvier Kaikolo
Voluntary Initiative Support Organisation (VISO)	Daniel Abowe
Water Governance Institute	Henry M Bazira
World Heritage International	Tony Sadownichik - Chair of Board of Directors
Zevin Asset Management	Sonia Kowal
ZSL	Jonathan Baillie - Conservation Programmes Director

 

 

January 2016 - AB 700, California Disclose Act - Public Comment 93

 

The New Progressive Alliance along with 13 other organizations recently signed a joint statement supporting AB 700, the California Disclose Act which dramatically increases transparency and disclosure for political ads. This fits well with the Unified Platform on election reform.

The new language in AB 700 is taken from the on-ad disclosure portions of the Voters Right to Know Act initiative. This means the two fit together and AB 700 now requires the type of clear and prominent disclosure on both ballot measure ads AND ads about candidates by outside groups that the California Clean Money Campaign has always advocated.

Television and video ads will have to display the names of the top 3 true funders on a solid black background on the bottom third of the screen for a full 5 seconds. Each name must be displayed on a separate line in a large clear font and using regular capitalization. No more fine print. There are similar rules for radio ads, print ads, online ads, and robocalls.
Equally important, there are new rules for earmarking and tracking to identify true funders when they try to hide behind shell groups with misleading names.

More than 13,500 people contacted their Assemblymember in the four days heading up to the vote and more than 54,000 Californians signed petitions for AB 700.

The AB 700, the California DISCLOSE Act (Gomez-Levine) passed the Assembly to move to the Senate on a bipartisan vote of 60-15.

 

January 27, 2016

 

The Honorable Jimmy Gomez

Assemblymember 51^st District

State Capitol, Room 2114

Sacramento, CA 95814

 

The Honorable Marc Levine

Assemblymember 10^th District

State Capitol Room 2141

Sacramento, CA 95814

 

FROM:

California Clean Money Campaign

California League of Conservation Voters

California Church

IMPACT

Consumer Federation of California

Courage Campaign

Endangered habitats League

JERICHO: A Voice for Justice

Maplight

Lutheran Office of Public Policy-California

Money Out Voters In

New Progressive Alliance

People Demanding Action

Public Citizen

 

Bob Stern, Principal co-author of the Political Reform Act of 1974

 

cc:  Honorable Members of the California Assembly

 

RE: AB 700 (Gomez and Levine) - Support

 

Dear Assemblymembers:

The above listed organizations are pleased to support AB 700, the California DISCLOSE Act.

A message is rightly evaluated based in part on the identity of the messenger. Just as a lobbyist looking for your vote on a bill would never mislead you about the identity of their client, neither should the voters be misled as to who is asking for our votes, whether we are voting for candidates or when we are, like you, being asked to vote on proposed legislation on the

Campaign spending on ballot measures has reached unprecedented levels. More than $640 million was spent in California on ballot measures in 2012 and 2014, almost all of it by donors whose true identities were obscured on ads by misleading names buried in fine print. Although it is essential for individuals  and organizations to be able to communicate effectively with voters, it’s equally important that voters not be deceived about who paid for the ads they see; about who is asking for their vote.

AB 700 requires the true, three largest funders of ads about ballot measures or candidates to be shown clearly and unambiguously on the ad. It applies with appropriate nuances to all major forms of political advertising (radio, television, electronic, print).

And, while there a few drafting refinements that need to be addressed to guarantee that voters are no longer deceived, we are closer than ever before to seeing an end to the time when voters are on ads routinely and legally mislead.

For the right to vote to be meaningful it must be a right exercised free from deception.

Achieving this goal is essential in the era of Citizens United in which billionaires and special interests can kill any legislation you pass with a simple – and, for them, inexpensive-- referendum, all the while keeping their identities and, hence, the specially interested motivation behind the referenda, hidden.

A March 2013 poll by the Public Policy Institute of California found that 84% of California voters  favored “Increasing public disclosure of funding sources for signature gathering and initiative campaigns”. This support was across the board with at least 80% of voters from each political party in favor, a rare example of near-unanimity in an otherwise divided electorate.

Indeed, underscoring the vast and bi-partisan support for disclosure, Justices of the Supreme Court no less than five times have touted the kind of disclosure in AB 700, the most famous of which is this, from Justice Scalia:

“There are laws against threats and intimidation; and harsh criticism, short of unlawful action, is a price our people have traditionally been willing to pay for self-governance. Requiring people to stand up in public for their political acts fosters civic courage, without which democracy is doomed. For my part, I do not look forward to a society which, thanks to the Supreme Court, campaigns anonymously and even exercises the direct democracy of initiative and referendum hidden from public scrutiny and protected from the accountability of criticism. This does not resemble the Home of the Brave.”1

Chief Justice Roberts agrees:

“[D]isclosure of contributions minimizes the potential for abuse of the campaign finance system.…With modern technology, disclosure now offers a particularly effective means of arming the voting public with information[.]”2

So, too, does Justice Kennedy:

“[D]isclosure requirements offer a powerful, speech-enhancing method of deterring corruption—one that does not impose limits on how and when people can speak,”3

Californians are crying out for the specific disclosures of the California DISCLOSE Act, with more than 50,000 signing petitions urging the legislature to pass AB 700. We therefore respectfully ask for your support of AB 700. Just as you would never tolerate a lobbyist who hid the identity of his or her client so, too, should your constituents be afforded the same transparency when they are asked for their votes.

For these reasons, the organizations listed above respectfully SUPPORT AB 700 and request your AYE vote.

 

1 Doe v. Reed, 561 U.S. 186 (2010)

2 McCutcheon v. FEC, 572 U.S.      (2014)

3 Williams-Yulee v. Florida Bar, 575 U.S.      (2015) (dissenting opinion)

 

February 2016 - Clean Budget Letter - Public Comment 94

In September 2015 the New Progressive Alliance and other organizations issued a Public Comment to keep the Congressional  budget  free of many of the hundreds of proposed ideological policy riders from the majority that threatened to undermine health, safety, the environment, and our financial system. This year the process is starting even earlier so in February 2016  we again issued a Public Comment to the same effect.

 

 

February 4, 2016

 

Dear President Obama and Members of Congress,

We, the undersigned organizations, write to ask you to oppose any FY 2017 appropriations bills which include inappropriate ideological policy riders.

Appropriations bills have been used before to undermine essential safeguards through “policy riders” – provisions that address extraneous policy issues, and are slipped into appropriations bills to win approval as part of must-pass funding legislation. Last year, hundreds of these policy provisions were proposed as a part of the omnibus process, and in this year’s budget process some members of Congress have already started to insist on inappropriate riders.

Ideological riders are measures that the public opposes, and that the President would likely veto as standalone legislation. The American people support policies to restrain Wall Street abuses and ensure safe and healthy food and products, to protect our air, land, water and wildlife, to ensure safe and fair workplaces, to prevent consumer rip-offs and corporate wrongdoing, to create fair rules of the road for our campaign finance system, to provide access to justice, and to ensure continued access to vital health care services.

Inappropriate riders are intended to advance the priorities of special interest donors and supporters, and they have become the “new earmarks.” However, in many ways, they are actually far worse than the old district-specific earmarks, because they have vastly greater reach and nationwide consequence for the American people.

We urge Members of Congress to oppose flawed funding proposals that include ideological policy riders. We further urge the administration in the strongest possible terms to oppose any funding bills that have such riders, whether moving via regular order or as part of a funding package.

Sincerely,

Advocates for Better Children’s Diets

American Association for Justice

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

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

Americans for Financial Reform

Breast Cancer Action

Center for Biological Diversity

Center for Effective Government

Center for Justice & Democracy

Center for Progressive Reform

Center for Responsible Lending

Center for Science in the Public Interest

Chicago Consumer Coalition

Citizens for Responsibility and Ethics in Washington (CREW)

Coalition on Human Needs

Common Cause

Communications Workers of America

Consumer Action

Consumer Federation of America

Consumers for Auto Reliability and Safety

Daily Kos

Defenders of Wildlife

Democracy 21

Demos

Earthjustice

Economic Policy Institute

Empire, State Consumer Project, Inc.

Endangered Species Coalition

Environment America

Epic-Environmental Protection Information Center

Everyvoice

Free Press Action Fund

Green America

Homeowners Against Deficient Dwellings

Klamath Forest Alliance

Main Street Alliance

Massachusetts Consumers Council

NARAL

National Alliance of State and Territorial AIDS Directors (NASTAD)

National Association of Consumer Advocates

National Association of Social Workers (NASW)

National Center for Health Research

National Consumers LeagueNational Council for Occupational Safety and Health (National COSH)

National Education Association

National Employment Law Project

National Employment Lawyers Association

National Health Care for the Homeless Council

National Organization for Women

Natural Resources Defense Council

NETWORK, A National Catholic Social Justice Lobby

New Progressive Alliance

People For the American Way

Planned Parenthood Federation of America

Public Citizen

Public Investors Arbitration Bar Association (PIABA)

Service Employees International Union (SEIU)

Texas Consumer Association

The Arc

The Leadership Conference on Civil and Human Rights

The Wilderness Society

Union of Concerned Scientists

Voices for Progress

WildEarth Guardians

Wildlands Network

Wildlife Conservation Society

Workplace Fairness

 

February 2016 - Reynolds Aluminum Clean Up - Public Comment 95

The New Progressive Alliance joined Columbia Riverkeeper, the Sierra Club, and Landowners and Citizens for a Safe Community in advocating before the Washington state Department of Ecology for a full, level six clean up of toxic pollution of Reynolds Aluminum smelter and mill on the Columbia River in Longview, WA. The pollution in the ground and water is flouride, cyanide, polycyclic aromatic hydrocarbons, and total petroleum hydrocarbons.

 

February 20, 2016

 

Department of Ecology – Industrial Section

P.O. Box 47600

Olympia, WA 98504

 

The New Progressive Alliance at http://newprogs.org/  joins Columbia Riverkeeper, the Sierra Club, and Landowners and Citizens for a Safe Community in urging the Department of Ecology for a level six clean up of toxic pollution for Reynold Aluminum in Longview, Washington.

From 1941 – 2000 Reynolds Metals constructed and operated an aluminum smelter and cable mill on the Columbia River in Longview, WA. Their operations permanently closed in February 2001. The Reynolds smelter and cable mill left a toxic legacy on the Longview waterfront. Portions of the site show elevated levels of flouride, cyanide and polycyclic aromatic hydrocarbons (PAHs) and total petroleum hydrocarbons (TPHs). The groundwater contains fluoride, cyanide and PAHs.

This should have already been decided.  Cleanup at the highly contaminated Reynolds Aluminum site in Longview is years behind schedule. While other aluminum smelters along the Columbia were cleaned up and converted to new industrial operations, Alcoa—owner of the Reynolds site—hasn’t finished investigating the site to understand the extent of pollution or proposed a cleanup plan for the Longview site.

On June 1, 2014, Ecology released a report stating the six levels of clean up that the site could receive. Citizens from Cowlitz County and throughout the Columbia River packed a hearing room on July 16, 2014 on the clean up at the old Reynolds site. Not a single person who testified asked for anything less than a level six clean up. At this level, the most toxic pollution leftover from decades of aluminum production would be excavated and taken to a certified landfill.

Unfortunately by only listening to current site owner Chinook Ventures and site operator Millennium Bulk Terminals, Ecology is recommending only a level four clean up.

This is clearly inadequate for the following reasons.

• There is a long record throughout the United States of companies escaping the consequences of their pollution and leaving local governments responsible for the clean up.
• Leaving Alcoa to monitor its own clean up contains an obvious conflict of interest and is a recipe for disaster.
• Chinook Ventures—the company that leased the property before Millennium—promised to clean up the site and produce jobs. Instead, Chinook made matters worse by polluting the site further and covering up contamination it discovered.
• Millennium has no experience cleaning up a Hazardous Waste Site.
• To further confuse matters, Millennium coal wants permission to build one of the nation’s largest coal export terminals at the site which would further delay this process.

There have already been major delays in the clean up process and Ecology is right to push for closure, but wrong to ask for a level four instead of a level 6 clean up. At the very least, Ecology should charge Alcoa to pay for a contractor to monitor sampling results, oversee cleanup operations, and review cleanup plans.

 

 

 February 2016 - UN CEPA - World Bank - COP 21 - Public Comment 96

 

The United Nations Division for Public Administration and Development Management announced an open call for written statements for the 15th session of CEPA for NGOs in ECOSOC consultative status. It will be held April 18-22, 2016. As a qualified NGO, the New Progressive Alliance commented to restrict fossil fuels by requiring countries to provide full information as per the requirements of the 2015 United Nations COP 21. The NPA also advocated promoting access to water by restricting privatization funding by the UN World Bank.  The NPA also requested the World Bank cease funding fossil fuel development.

 

February 24, 2016

The 15th session of CEPA called for papers on the implementation and monitoring of the sustainable development goals (SDGs). The two SDGs the New Progressive Alliance would like to comment on are numbers 6 on water and 13 on climate. The two UN agents we would like to act are the World Bank and those monitoring the 2015 United Nations COP 21.

The World Bank's official goal is the reduction of poverty. The World Bank can aid in two areas. Financing projects that privatize water for profit instead of using water as a common resource make poverty worse and contradicts UN Sustainable Development Goal #6 on water. Water privatization, backed by the World Bank, has been devastating for the city of Nagpur, India. Residents face everything from contaminated water to irregular access to skyrocketing rate hikes. Despite this, the World Bank is promoting Nagpur’s privatization as a success story -- to replicate in as many as 600 cities across India. In 2015 hundreds of thousands of people around the world rallied to protest the impending privatization of the water in Lagos, Nigeria. Fortunately, the World Bank’s private investment arm dropped its water advisory contract with the Lagos government.

The second area the World Bank can help in is to stop financing fossil fuel projects. Previous U.N. reports have demonstrated this not only impedes progress on COP21, it also worsens poverty.

Those monitoring the 2015 United Nations COP 21can help by collecting two pieces of information.

2015 United Nations COP 21 provides, “Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7) The first piece of information is an honest appraisal which should include subsidies to fossil fuels which are orders of magnitude greater than for renewable energy. Fossil fuels should include those which do not help the environment such as natural gas and nuclear in addition to coal, natural gas, and other fossil fuels which produce methane, carbon dioxide, and other greenhouse gases.

There is a huge cost to using fossil fuels quite apart from climate change.   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. 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. That cost would be completely eliminated by eventually transitioning instead to 100% renewable energy. 100% renewable energy is technically feasible.

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 far greater than the cost of stopping global warming at this stage.

Those monitoring the 2015 United Nations COP 21can also help by giving a second piece of information. Giving the  fossil fuel used by the militaries of the world would also help make an honest appraisal required by the 2015 United Nations COP 21. Certainly the United States uses the most because of its size and activities, but a significant amount is used by other nations as well.

Documentation about the above on the World Bank and COP21 can be found here: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

March 2016 - President - EO Requiring Mandatory Disclosure for Political Spending - Public Comment 97

 

The Hon. President Barack Obama

The White House

1600 Pennsylvania Avenue, NW

Washington, D.C.  20500 

Subj: Fix American Democracy, Audacious Actions Needed 

 

March 11, 2016

Dear President Obama:

Seven years into your presidency, and six years after the Supreme Court issued its tragically misguided ruling in Citizens United v. FEC, we’re living in damaged democracy. The campaign spending world is out of control and the obstruction and partisanship of government has gotten worse as a result. We have been thrilled to see your strong rhetoric around fixing our process and an avowed commitment to do something about it.  In this year’s state of the union you said: “We have to reduce the influence of money in our politics, so that a handful of families or hidden interests can't bankroll our elections.” Money in politics, disenfranchisement of voters, and a vacancy on the highest court of the land (with partisanship threatening to block efforts to fill the seat), all point to a need for action from the executive.

The system needs a course correction and the people know it. Three-quarters of the American people believe their government is corrupt, according to Gallup, and we need bold action by our leaders to show them that change is possible and engagement in democracy matters.

We need a democracy that works for all Americans, one in which everyone has an equal voice, we have a functioning court, and elected officials are accountable to the people, not the wealthy. The nation needs a Supreme Court that defends our democracy. With the Shelby County and Citizens United decisions in recent years, the Supreme Court has eviscerated crucial voting rights protections and enabled a narrow group of the superrich and giant corporations to dominate our elections.

Fixing our democracy and creating a better politics means dealing with many parts of the problem, inclusive of pushing back on the mockery being made of the majority opinion reaffirming disclosure in Citizens United, with hundreds of millions of dollars being invested in our elections by donors who remain anonymous, leaving voters in the dark about the people and interests to whom candidates are beholden.

The staggering sums raised and spent are empowering a very narrow class of super-rich donors, with a self-interested agenda. They have undue power to affect who runs for office, who wins elections, and what winning candidates do. And as you acknowledged in The Audacity of Hope – in the pre-Citizens United world – these individuals, across party, have a different worldview and different policy preferences than average Americans. Economic inequality and political inequality are now reinforcing each other – and choking democracy and causing government obstructionism in the process.

Against this backdrop, it is imperative that you act. There is no silver bullet to solve the problems with our democracy, but there are many desperately needed solutions. Today, we stand behind you as you work to fill the vacancy on the Supreme Court, and urge you to complement this with a policy package to improve democracy-- including tackling the issue of corruption in government contracting.

As the dominance of Big Money continues to corrupt our democracy, the incentives are too great for federal contractors to spend money on elections in exchange for favors with contracts, service deals, leases and more.

We urge you in the strongest terms to issue immediately an executive order requiring full disclosure of political spending by business entities receiving federal government contracts, and furthermore require federal contractors to affirmatively certify that they are in compliance with 52 U.S.C. 30119 ban on direct or indirect political contributions. 

An executive order shining a light on political spending by contractors would attack the perception and the reality of such “pay-to-play” arrangements. It need simply require that every federal contractor disclose its political spending and that of its senior management and affiliated political action committees post-contract award. By requiring this, the public may judge for themselves whether contracts are being awarded and administered based on merit rather than political favors.

This kind of transparency in government contracting is nothing new at the state level. In response to numerous contracting scandals, more than a dozen states have imposed specific campaign finance disclosure requirements on government contractors.  

As the current Congressional obstruction to filling the Supreme Court vacancy demonstrates, a bought Congress is a broken Congress, and we need real fixes coming from the highest level to make the case to the American people that democracy is still worth participating in.

We the People desperately need your leadership to preserve our democracy. Please act now to fill the court vacancy, and create real changes to our democracy through this executive order to cause transparency and other reforms of our process.

Sincerely,

 

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

American Postal Workers Union (APWU) Brennan Center for Justice

California Clean Money Campaign Center for American Progress

Center for Biological Diversity Center for Media and Democracy Center for Science and Democracy at the Union of Concerned Scientists

Citizens for Responsibility and Ethics in Washington (CREW)

Common Cause

Communications Workers of America

CPD Action

DailyKos

Demand Progress

Democracy 21

Democracy for America

Democracy Matters

Demos

Every Voice

Franciscan Action Network

Friends of the Earth Governmental Accountability Project

Greenpeace USA Harrington Investments, Inc.

Institute for Agriculture and Trade Policy

Interfaith Center on Corporate Responsibility Issue One

League of Conservation Voters Merey Investment Services, Inc.

Money Out, Voters In

New Progressive Alliance

Newground Social Investment, Inc

Northstar Asset Management, Inc

Pay 2 Play

People for the American Way

Public Citizen

Represent.Us

Rootstrikers

Sierra Club Sonen Capital SumOfUs

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

Voices for Progress Zevin Asset Management

 

March 2016 – Welcome Yes on I-732 - Public Comment 98

 

March 10, 2016

There is a huge cost to using fossil fuels quite apart from climate change.   World wide 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. 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 far greater than the cost of stopping global warming at this stage.

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.

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 of this article: The Environment.  

What to do to cover these great costs? One obvious solution the New Progressive Alliance strongly supports is to stop subsidizing fossil fuels.

Another solution is to put a tax on carbon. That is why we support Yes on I-732.  which is fighting to do just that in the state of Washington. This follows the recommendation of many policy makers and economists

British Columbia’s economy did well when they enacted a similar carbon tax. Emissions were reduced with negligible results on the economy. A carbon tax created  a clear incentive for businesses and consumers to use less fuel, invest in efficiency and switch to cleaner energy. It was acceptable because it insured every single carbon tax dollar would be returned to families and businesses.

 

 

March 2016 – Welcome Beyond Extreme Energy - Public Comment 99

 

March 10, 2016

There is a huge cost to using fossil fuels quite apart from climate change.   World wide 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. 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 far greater than the cost of stopping global warming at this stage.

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.

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 of this article: The Environment.

What to do to cover these great costs? One obvious solution the New Progressive Alliance strongly supports is to stop subsidizing fossil fuels.

Another solution is to leave the majority of the fossil fuels in the ground. That is why we support Beyond Extreme Energy.      Beyond Extreme Energy has recommended the below changes to the Federal Energy Regulatory Commission (FERC).

A proposal to transform FERC into a leader
in the urgent, civilizational task
of reducing greenhouse gas emissions
as rapidly as possible

We have an urgent crisis on our hands. An extensive number of people and organizations — including scientists and scientific organizations, government and international agencies, NGO’s worldwide, organizations like the World Bank, our own Department of Defense, grassroots and community organizations — agree that if we do not reduce greenhouse gas emissions substantially, civilization as we know it faces severe threats. We must start immediately, with the objective of bringing these emissions close to zero as soon as possible.

The United States, as the largest greenhouse gas emitter historically, can and must be a leader in this work.  That other countries are partly responsible cannot be an excuse for U.S. inaction. In fact, our overconsumption of products created cheaply in other countries has fueled this crisis. Without U.S. leadership and example, solutions will remain out of reach.

FERC is uniquely positioned, given its key role in the energy system, to help bring about this change. And because of the world’s focus on developing a strong climate treaty at the United Nations Climate Conference in Paris in December, the opportunity for progress is RIGHT NOW.

Toward these ends, Beyond Extreme Energy proposes and will advocate and fight for these changes to the mission and practices of the Federal Energy Regulatory Commission (FERC):

1. Enact a moratorium on new gas infrastructure and export terminals until FERC has been reorganized with independent funding and a clearly defined mission of playing a leading role in reducing greenhouse gas emissions, and shifting to renewables and an energy efficient power grid. Permitted gas infrastructure and gas export terminals that are not yet operating must cease construction until the new FERC has emerged, new priorities are in place, and a reassessment has been made about whether the project should go forward.

2. Transform FERC’s approval process and mission. No community wants these disruptive projects because we don’t want toxic chemicals in our air, land and water. We don’t want exploding pipelines and liquefaction factories in our towns and under our farms. We can no longer sacrifice so many for the wealth of a few. We are ready for an economy fired on clean, safe energy. A new FERC can help make that transition.

3. We call for an investigation into the extent to which FERC is influenced or corrupted by the funding it receives from the industries it is regulating.

4. FERC must fully and comprehensively assess the environmental, health and climate effects of a proposed project and of the clean-energy alternatives. Segmentation of projects that obscures the cumulative effects of infrastructure expansion must end immediately. FERC’s claims that an increase in fracking is not “reasonably foreseeable” from its permitted projects is disingenuous and unacceptable.

5. FERC must be guided by a conscious policy of supporting wind, solar and energy efficiency first, with proposals for dirty, climate-heating energy sources scrutinized as to why renewables and/or efficiency should not be required.

6. FERC’s governing body must include members of the public to represent consumers and the environment. In addition, an advisory board of climate and environmental scientists must have a seat at the table during permit considerations.

7. FERC monthly meetings must include time for public comments.

8. FERC must make its website easier to navigate.

9. Congressional hearings should be held on how to transform FERC’s mission and procedures for a world under severe threat from global warming.

 

 

 

We strongly urge Congress to support the bipartisan “Political Intelligence Transparency Act” with the same enthusiasm in which Congress embraced the STOCK Act.

 

Signed,

 

American Family Voices

Campaign for Accountability

Center for Media and Democracy

Citizens for Responsibility and Ethics in Washington (CREW)

Common Cause

Government Accountability Project

New Progressive Alliance

Public Citizen

Sunlight Foundation

Zevin Asset Management, LLC

 

April 2016 - SEPA - Natural Gas to Methanol Plant - Public Comment 101

Washington State Department of Ecology

State Environmental Policy Act (SEPA)

Ann Farr

Port of Kalama

110 W. Marine Drive

Kalama, WA 98625

April 7, 2016

            The New Progressive Alliance at http://newprogs.org/   urges the DEIS to be updated to address the following concerns.  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. Documentation and Conclusion follows a description of these four concerns.

I.  Excessive Power Demands for both electricity and natural gas will probably increase utility rates.

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.

II.  Increased Dangers and Pollution from Fracking, Natural Gas, and the Methanol Refinery.

The plant would buy gas extracted by fracking. 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.

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.

The New Progressive Alliance in the below documentation shows the danger of transporting fossil fuel, especially by pipes. 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 DEIS downplays or ignores the pollution of a Methanol Refinery. 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 Columbis 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; and roughly 200 gallons of wastewater per minute. They will burn 30 percent of the huge amount of natural gas used, adding to local pollution.

III.    Water Contamination and Water Demands

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.

IV.    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. It 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. The DEIS falsely claims this will reduce climate change without taking into account the carbon involved in fracking for natural gas, the huge amounts of electricity required, or the fossil fuels used by ships hauling methanol to China and the manufactured plastics back to the United States.

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.

V.                Documentation:

Columbia Riverkeeper and the Northwest Environmental Defense Center. In December 2014, these NGOs 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.” They also distributed published a list of five landscape-changing impacts associated with the construction of Northwest Innovation Works’ methanol plant at Kalama.

The New Progressive Alliance documents the dangers of fracking and natural gas at   http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

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. (Fracking is also used for uranium mining.) 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 - 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

The New Progressive Alliance also documents the dangers to our water supply at   http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Standing out as a danger is the complete failure to protect our county's aquifers 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. There is a similar world wide danger. A profit making model has replaced the commons model on clean water.

See references 41, 46, 79, 114, 249, 261, 263, 268, 278 - 281, 288, 303, 312, 317, 359, 364, 367, 370, 378, 381, 382, 400, 401, 411 - 413, 416, 436 - 439, 456, 475, 488 - 493, 521 - 524, 545, 574 - 576, 607 - 609, 725 - 734, 736, 789 - 796, 821 - 824, 858 - 863, 940, 941, 961, 987 - 1005, 1097 - 1109, 1172, 1202, 1217 - 1222, 1350, 1354, 1360, 1361, 1432 - 1451, 1472, 1530, 1575, 1578, 1582-1583, 1590, 1623-1650, 1698-1702, 1765, 1771, 1787, 1810, 1811, 1953-1957, 1989-2014, 2102, 2146-2147, 2181-2192, 2245-2247, 2252, 2300, 2305, 2321-2324, 2377, 2439, 2451, 2452, 2453, 2466, 2469-2486, 2488-2505, 2549, 2550, 2561, 2571, 2583-2594.

The New Progressive Alliance documents the dangers of pipeline transportation of fossil fuels at   http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

We are undergoing a great expansion of unsafe fuel transportation with pipelines, trains, and other devices. See reference 536. The XL Pipeline may have just been a diversion as there has been a huge expansion in other pipelines and dangerous fuel transportation by rail and truck. Even more than transportation, the problem is we are not leaving fossil fuels and  dirty Tar Sands oil in the ground in the first place.  As noted above under "Nuclear Energy is Not the Answer" above, there is no agreed upon way to transport nuclear waste either and it must remain close to the nuclear power facility as it has for decades.

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.

VI. Conclusion

Please look at the DEIS and consider  the amount of power used 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.

 

April 2016 - USDA Forest Service - Stop Arch Coal - Public Comment 102

USDA Forest Service

1400 Independence Ave., SW

Washington, D.C. 20250-1111

April 11, 2016

            The New Progressive Alliance at http://newprogs.org/  urges you to stop Arch Coal from mining Colorado coal. To allow the mining would mean significant widespread pollution, go against the recent Presidential order forbidding coal mining on public lands, and is based on a bad business plan.

I.                   Significant Widespread Pollution

 

• First look at Colorado. The US Forest Service (USFS) is proposing lease modifications that would allow Arch Coal to bulldoze through thousands of acres of public lands in order to build more roads, nearly 50 drill pads, and climate-polluting methane vents in Colorado’s Sunset Roadless Area.

 

• Now look at the Pacific Northwest, specifically Longview, Washington, which is fighting the Millennium Project to use Arch Coal because of the health hazards of coal dust, the hazards involved, and the traffic impairment caused by many mile plus long coal trains. Medical professionals have attributed an increase in asthma, chronic bronchitis, heart attacks, and premature death from heart and lung disease for transporting and burning coal.

 

• Next look at China. Burning this coal will release millions of tons of carbon into the air. There is no such thing as “clean coal.” Smog forming nitrogen oxides, mercury, lead, arsenic, and soot forming sulfur dioxide make coal the dirtiest power by far.

 

• Finally consider that the United States signed the United Nations Agreement COP 21 in 2015. We agreed that “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. Take into account the fossil fuels used by trains to Washington and ships sailing to China.  Consider also that coal produces more greenhouse gases than any other form of energy.

 

 II.                Letting Arch Coal mine goes against the clear intent Of Presidential Executive Order

The Obama administration has stopped issuing new coal leases on federal lands as the administration weighs a programmatic overhaul. Clearly they have determined that Arch Coal is on the wrong track.

 

III.             Arch Coal is based upon a bad business plan unlikely to succeed.

Arch coal has declared bankruptcy. China – the proposed buyer of the coal – faces a huge oversupply causing a suspension of any new coal mines. Arch Coal increased CEO and executive pay so much that the SEC noticed. Their CEO pay went from 3.9 million to 4.3 million in 2013 and 7.3 million in 2014. Why increased pay for a failing company? Asians are not investing heavily in coal plants. The price of coal has dropped from 132 to 43 dollars. Coal companies have a long history of leaving behind retirement pay, jobs, and devastated landscapes after fleeing with obscene profits.

Conclusion:

For the sake of Americans today and future generations around the world, we urge you to preserve the Colorado Roadless Rule, close the Arch Coal loophole, and withdraw the proposed Arch Coal lease modifications.  Please withdraw the proposal to approve Arch Coal’s coal lease modifications and exploration plan.

 

 April 2016 - Vancouver Port Terminate Lease - Public Comment 103

 

April 17, 2016

 

Port of Vancouver USA  

The Honorable Eric LaBrant, Jerry Oliver, and Brian Wolfe

3103 NW Lower River Road

Vancouver, WA 98660 USA

 

The New Progressive Alliance at http://newprogs.org/  urges you to terminate the lease between the Port and the Tesoro Savage oil terminal.

Wisely, the lease signed by the Commission in 2013 affords the Port an opportunity to terminate it before August 1, 2016. It is now clear that the State’s review process will not be complete by then, and appeals over any potential decision will likely drag on for years. The Port should cut its ties to this project now and seek new businesses and tenants for its property.

The New Progressive Alliance previously urged the Energy Facility Site Evaluation Council to deny the Tesoro Savage Proposal for the following three reasons.

I.                   There is no need.

Nobody is suggesting closing down refineries or suddenly doing without oil. There is just no need for building the largest oil by rail refinery in North America. Oil prices have dropped below 30 dollars a barrel for the first time since December 2003.  The latest wave of selling leaves crude oil down 19% this year alone. It represents an incredible 72% plunge from crude's June 2014 peak of almost $108.  See:   http://www.tomdispatch.com/post/176089/tomgram%3A_michael_klare%2C_the_look_of_a_badly_oiled_planet/

 

II.                   The Proposal, though detailed, is flawed.

       The proposal is not so much an analysis as a brief of best possible outcomes and most optimistic predictions should the terminal be built. It is also based upon the least possible actions to prepare for or mitigate damages and the minimization of environmental effects which defy both common sense and reason. For examples, consider the following points.

• Chapter 4 on Crude Oil Safety Considerations says, “Additionally, Washington and Oregon laws have instituted financial liability to owners for operation of vessels carrying crude oil. Operators of vessels carrying crude oil from the proposed Facility and the owner of the crude oil would be strictly liable for any damage and the cleanup in the event of a spill and would be required to maintain adequate financial resources (including insurance) to respond to a potential oil spill regardless of fault. These liabilities create significant financial incentives for compliance with all required and any self-imposed risk mitigation measures that are available. In addition to civil liabilities there are also significant criminal liabilities. For example, 33 USC 309(c)(1) authorizes imprisonment and up to $25,000 per day fines for oil spills.” This ignores the long held fossil fuel practice of declaring bankruptcy or simply getting away with pleading they can’t afford it after large spills. Ultimately, the tax payer and government are responsible.
• On ES-9 under 6.2.1 the Draft EIS  says, “No significant (moderate to major) cumulative impacts were identified for the proposed facility in combination with past, present, and reasonably foreseeable future actions.”  This is incredible and ignores the many rail and sea disasters that keep happening despite reassurances after each disaster. The delay to transportation of many mile plus long trains is not even considered. To look at this proposal in isolation without considering other pollution sources - as the Draft EIS does - seems to suggest unfamiliarity with the word “cumulative.”
• Most of our rail infrastructure is over a century old.
• The dangers are illustrated by the 47 people who died in the Quebec explosion of 2013. Since then there have been 12 train explosions so far and about 15 derailments a year, including on the newer supposedly safer CPC-1232 rail cars.
• On ES-14 using wildly optimistic and undocumented assumptions, the Draft EIS said that there would be a derailment of one loaded railroad car spilling up to 700 barrels of crude oil every 27 years, a vessel loading spill of up to 1 barrel every 14 years, and a grounding or collision with a spill of up to 1,000 barrels every 34 years. Even using these unrealistic optimistic estimates show building this facility is a bad idea.
• On ES-14 and ES-15 Emergency Response Preparedness is discussed. The Vancouver firefighters union opposes the oil terminal because of the unacceptable risk to our first responders, port workers and the public. Its protocol for responding to oil train and terminal fires is “nonintervention,” meaning the fire department would evacuate the area and let the oil burn. That’s all we can do. In an urban or industrial area, that leaves too many lives and properties in danger. ES-15 describes how most fire departments are woefully unaware of even where to call for advice.
• ES-16 says all tank rail cars will meet the newer DOT-117 specifications. This is no comfort at all.  The CPC-1232 rail cars (designed to replace the older DOT-111 cars of 1970s design) have still exploded and burned and are only designed to withstand impacts of 12 to 18 miles per hour. Further railroads have until May 1, 2025 to meet even this small improvement. Since 47 people died in the Quebec explosion of 2013 there have been 12 train explosions and about 15 train derailments a year. This is an unacceptable risk.
• ES-17 says the applicant will “conduct a study to identify an appropriate level of financial responsibility for the potential costs for response and cleanup of oil spills, natural resource damages, and costs to state and affected counties and cities for their response actions to reduce the risks and impacts from an oil spill.” It is difficult to imagine a statement more naïve or unfamiliar with what repeatedly happens in fossil fuel spills and accidents. Fossil fuel companies say they will be responsible and then leave the jurisdiction or declare bankruptcy resulting in leaving tax payers and the government to clean up their messes after they have absconded with the profits.

 

III.             If approved this will hurt United States interests because of the 2015  United Nations Agreement COP21.

Even if COP 21 is not adopted by the United States, the amount of oil exported from the United States will be reported. The biggest oil terminal in North America would of course play a major role. If enacted, this proposal would create an estimated 54 metric tons of carbon dioxide – an amount that is significant on a global scale. This will surely put us in a poorer position with other countries when it is time for continued negotiations.

 

Since 2013, hundreds of thousands of people have asked the State of Washington’s Energy Facility Site Evaluation Council (EFSEC) to turn down the Tesoro Savage project and for opening up our Port to safer, cleaner opportunities than oil-by-rail. The New Progressive Alliance joins with the following coalition.

 

• Cities of Vancouver, Portland, Washougal, and Spokane;
• Vancouver and Spokane Firefighters Unions;
• 12 Vancouver-area neighborhood associations;
• 100+ Vancouver business interests of all sizes – from small local shops to the proposed Columbia Waterfront Development group;
• International Longshore and Warehouse Union Local 4;
• Outdoor recreation company Patagonia’s founder Yvon Chouinard;
• Columbia River Inter-Tribal Fish Commission;
• Columbia Riverkeeper
• Landowners and Citizens for a Safe Community

 

You will find broad support and appreciation in our community for opening up our Port to safer, cleaner opportunities than oil-by-rail.

 

April 2016 - Washington State Utilities and Transportation Commission – Retire Colstrip Coal Generating Station - Public Comment 104

April 18, 2016

Utilities and Transportation Commission

PO Box 47250

Olympia, WA 98504-7250

Puget Sound Energy Integrating Resource Plan says it will keep using its Rosebud County, Montana, Colstrip coal generating station    for at least 20 years. The New Progressive Alliance at http://newprogs.org/  urges the UTC to consider alternatives because it is bad business, significantly increases pollution, and will reflect badly upon the United States because of the 2015 United Nations Agreement COP21.

I.                   It is bad business.

Peabody Coal and Arch Coal have declared bankruptcy because of bad business practices, not because of regulatory interference. The economics will just get worse for coal as more and more coal plants are retired and pollution regulatory burdens increase. The price of coal has dropped from 132 to 43 dollars. Arch Coal increased CEO and executive pay so much that the SEC noticed. Their CEO pay went from 3.9 million to 4.3 million in 2013 and 7.3 million in 2014. Why increased pay for a failing company? Coal companies have a long history of leaving behind retirement pay, jobs, and devastated landscapes after fleeing with obscene profits. Relying on a plant in Montana for Washington power operating on a declining fossil fuel whose costs are increasing is simply not wise.

The choice is stark. Either we dump hundreds of millions of dollars in an outdated, out-of-state coal plant or invest that money right here in Washington building energy efficiency and renewable energy solutions that will create thousands of well-paying jobs, improve public health, and significantly cut carbon pollution.

 II.                It significantly increases pollution.

• There is no such thing as “clean coal.” Smog forming nitrogen oxides, mercury, lead, arsenic, and soot forming sulfur dioxide make coal the dirtiest power by far.
• Medical professionals have attributed an increase in asthma, chronic bronchitis, heart attacks, and premature death from heart and lung disease for transporting and burning coal. Coal also produces more greenhouse gases than any other form of energy.
• Coal is an outdated form of energy that is polluting our air and water, increasing global warming and jeopardizing our children’s future.
• Despite all of this, Puget Sound Energy still gets around 30% of its electricity from coal — mostly from an aging coal plant in Colstrip, Montana. Retiring Colstrip is the single largest carbon pollution reduction available in the entire Northwest. 
• 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 of this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 III.             This will hurt United States interests because of the 2015 United Nations Agreement COP21.

Even if COP 21 is not adopted by the United States, the increased carbon output from coal for the United States will be reported. This will surely put us in a poorer position with other countries when it is time for continued negotiations.

Conclusion:

Please take another look at being stuck with Colstrip for two decades because it is a bad business, increases pollution, and will hurt United States interests because of the 2015 United Nations Agreement COP21.

 

 

May 2016 - Congress: Free SEC to Require Political Disclosure - Public Comment 105

May 23, 2016

 

We, the undersigned organizations, ask you to oppose harmful riders to the Financial Services and General Government (FSGG) fiscal year 2017 appropriations that would hinder the Securities and Exchange Commission’s (SEC) ability to protect investors. In particular, we urge you to oppose language mirroring an inappropriate rider included in the FY16 omnibus budget deal which limited the Securities and Exchange Commission’s (SEC) ability to develop, propose, issue, finalize, or implement a rule requiring public companies to disclose political spending to shareholders in fiscal year 2016. While this rider does not foreclose preliminary work on the issue at the agency, such a policy rider does halt rule completion in 2016 and is an impediment to this important policy.

 

Disclosure of corporate political spending has immense value for investors and serves as a key tool to promote transparency for shareholders and the public-at-large. It gives potential investors a better understanding of how companies operate and promotes a truly free market. Shareholders have a legitimate interest in knowing how their money is being spent and how those expenditures may impact the value of their investments. The ability of companies, their management, and their boards to spend resources for political purposes without shareholders’ knowledge gives rise to significant investor protection and corporate governance concerns.

 

Stakeholders have expressed overwhelming support for such disclosure. To date, more than 1.2 million securities experts, institutional and individual investors, and members of the public have pressed the SEC for a rule requiring public companies to disclose their political spending. Furthermore, in May of last year bipartisan support for this effort was expressed by former SEC Chairmen Arthur Levitt and William Donaldson and former Commissioner Bevis Longstreth. They urged the Commission to take action, noting that a rule on corporate political spending disclosure fits squarely within the primary mission of the SEC, which is to protect investors.

 

The Supreme Court’s 2010 Citizens United v. FEC decision fundamentally changed our nation’s campaign finance laws. Spending by organizations that do not disclose their donors has increased dramatically from less than $5.2 million in 2006 to over $300 million in the 2012 presidential cycle and more than $174 million in the 2014 midterm elections. The result is that investor demand for this information has only increased, as the magnitude of the problem and the potential for abuse has skyrocketed. 

 

For the above reasons, we urge you to protect the integrity of the SEC and reject efforts to insert such a policy rider. Poison pill riders are inappropriate and should have no part in any budget bill.

Sincerely,

 

Agenda Project Action Fund

American Family Voices   Americans for Financial Reform

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

Brennan Center for Justice

California Clean Money Campaign

Campaign for Accountability

Campaign Legal Center

Center for Biological Diversity

Center for Media and Democracy

Center for Science and Democracy at the Union of Concerned Scientists

Citizens for Responsibility and Ethics in Washington (CREW)

Common Cause

Communications Workers of America (CWA)

Courage Campaign

Daily Kos

Democracy 21

Demos

Greenpeace

Harrington Investments, Inc

Interfaith Center on Corporate Responsibility (ICCR)

International Brotherhood of Teamsters (IBT)

Issue One

Main Street Alliance

New Progressive Alliance

Newground Social Investment

NorthStar Asset Management, Inc

PaxWorld Management, LLC

Public Citizen

Represent.Us

Rootstrikers Project at Demand Progress

Sierra Club

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

Union for Reform Judaism

Voices for Progress

West Virginia Citizen Action

Women’s Donors Network

Zevin Asset Management, LLC

 

June 2016 - Washington state: Stop Millennium Coal Terminal - Public Comment 106

June 3, 2016

            The New Progressive Alliance at http://newprogs.org/  urges that the “no action” course mentioned by the Draft Environmental Impact Statement (DEIS) be followed in the proposed Millennium Bulk Terminals. References are at the end of this comment.

1.      This is a Bad Business Plan

S6 of the DEIS says Millennium will be good for the local economy because it will cause increased jobs and increased taxes. This is based on false assumptions.   

Only someone with little or no knowledge of jobs could think that exporting fossil fuels from Longview will ever help us with jobs or a tax base. To begin with, companies relocate to pleasant rather than polluted environments. Secondly, there are more jobs in renewable energy than in the fossil fuel industry, a trend that is only increasing.

The coal industry is dying thanks to natural gas, environmental regulation and shrinking global demand. A string of coal companies have filed for bankruptcies in recent months, including Peabody Energy, the world’s largest coal company and Arch Coal,  the world’s second largest coal company and former Millennium partner. Over 26 companies have filed for Chapter 11 bankruptcy in the past two years leaving workers and retirees penniless. Faced with collapsing price of thermal coal and export markets caused by slumping demand and too much supply, Wall Street has no appetite to finance new infrastructure. Arch Coal, which is restructuring itself after filing for bankruptcy, saw Millennium as a financial drain rather than cash-making investment and pulled out.

The Obama administration announced Friday April 8, 2016 that it will halt issuing new coal leases on federal lands as the administration weighs a programmatic overhaul. 

"The bringing in of low-production-cost natural gas into the North American
energy space has been absolutely game-changing for coal," said James
Stevenson, director of North American coal at IHS Energy. "I rank that
bigger than regulatory impact."

Even worse, the strong U.S. dollar is driving buyers to other countries.
Russia's ruble fell about 20 percent last year, and the Australian dollar
some 10 percent, according to Capital Economics.

"These falls have shielded Russian and Australian exporters from the full
impact of weakening demand for coal," analysts Oliver Jones and Tom Pugh
wrote last month.

In February, a report from a global research firm Wood Mackenzie, concluded that weak demand and plummeting prices made any new coal docks in the Northwest economically unviable. That same month, Cloud Peak Energy’s accountants wrote off its rights to access Millennium’s docks as essentially worthless.

The principals of this proposed Millenium deal while at TransMessis fired all workers without warning and are presently defending a lawsuit saying they lied on credit applications while owing 1.6 million dollars in outstanding debts. Waterside Energy LLC has also held secret meetings for over a year with the Port of Longview trying to hide this from the public eye. With Arch gone, Millennium no longer has a backer with a balance sheet to finance a major infrastructure expansion

Recall how Millenium deceived us about the volume of coal they wanted to ship through our community. It is also worth noting Arch Coal increased CEO and executive pay so much that the SEC noticed. Their CEO pay went from 3.9 million to 4.3 million in 2013 and to 7.3 million in 2014. Why increased pay for a failing company?

The Port of Vancouver’s Operation Manager, Mike Schiller wrote: “Coal is the most risky bulk mineral market. Consuming markets have no loyalty and will quickly shift to the cheapest market. Prices and markets can change before a facility is completed. . . . Because this is a fickle market, there is real danger in losing investment – both in construction capital and lost opportunity in a poorly performing asset (i.e. a single commodity terminal handling lower than expected volumes).”

Coal export requires a small workforce and wastes hundreds of acres of waterfront property to store raw coal. Millennium displaced 50 employees when it bought the waterfront property and they plan to produce just 20 additional jobs. It’s not worth the risk. The proposed 460-acre coal export site has tremendous potential for thousands of jobs in light industrial and smart-tech growth, instead of being mired in a single commodity dirty export trade.

In addition to woes in the United States, export prospects look very poor. DEIS was wrong to just blindly take Millennium’s numbers without further investigation.

Asians are just not investing heavily in coal plants. China – the proposed buyer of the coal and by far the world's largest coal consumer – faces a huge oversupply causing a suspension of any new coal mines. Because of this China raised up its domestic supply last year, throwing into question how much it will ultimately buy from America. Chinese coal imports in 2015 were almost a third lower than they were in 2014, according to Capital Economics. China has been trying to reform its domestic coal producers so it can be more self-reliant, said Stevenson of IHS. In Paris, the climate talks were bolstered by a joint agreement between the United States and China to cut greenhouse gases. China has said it will transition the economy from a manufacturing-led one to a consumer-led one which necessarily means less reliance on coal.

Coal companies have a long history of leaving behind retirement pay, jobs, and devastated landscapes after fleeing with obscene profits. See references at the end of this paper for documentation.

2.      Millennium will be Disastrous for Health

S6 of the DEIS says “The analysis determined the estimated maximum concentrations for each criteria air pollutant would be below the National Ambient Air Quality Standards established by the U.S. Environmental Protection Agency.”

The DEIS has ignored the testimony of expert medical professionals and said perhaps a health report will come later. This is a fatal mistake. National Ambient Air Quality Standards established by the U.S. Environmental Protection Agency are completely irrelevant. The question is Millennium’s effect on health.

There is no such thing as “clean coal.” Smog forming nitrogen oxides, toxic heavy metals, mercury, polyaromatic hydrocarbons, sulfur, lead, arsenic, cyanide, and soot forming sulfur dioxide make coal the dirtiest power by far. The pollution in both the transportation and the burning come with a predictable result. Medical professionals have attributed an increase in asthma attacks, heat-related deaths, emphysema, respiratory complications, chronic bronchitis, heart attacks, and premature death from heart and lung disease to the coal transportation being proposed. Children and senior citizens are especially vulnerable.

These adverse health effects also have a disproportionate impact on vulnerable communities such as the poor and working class neighborhood of the Highlands of Longview. This affects the lives of the folks who not only live on the wrong side of the tracks, but all along the tracks. Our area already is significantly worse off in terms of these health issues than most of the rest of the state.

The University of Washington reported coal trains emit nearly double the amount of pollution compared to freight trains. Consideration needs to be given to the extra diesel exhaust which causes deleterious effects to health.

Burlington Northern Santa Fe (BNSF) acknowledges that coal trains spill a lot of dust.  BNSF’s studies show that 500 pounds of coal can be lost in the form of dust from each rail car. Each 100-car train, therefore, may spill 50,000 pounds of coal dust into our rivers and towns. BNSF’s website stated that “the amount of dust that escapes from PRB [Powder River Basin] trains is surprisingly large.” BNSF has removed this page from its website, but our allies at the Sightline Institute captured the image.

Coal dust blowing from the coal terminal will foul the air and water, as well as homes, boats, and businesses up to several miles away. The Westshore coal terminal in British Columbia is located three miles from residences, yet homes are still covered with coal dust.

S6 This Draft EIS uses this New Zealand study to identify a threshold for nuisance level dust deposition. Coal dust nuisance impacts refer to coal dust that affects the aesthetics, look, or cleanliness of surfaces but not the health of humans and the environment.” This is not only without proof, it is palpable nonsense! Science clearly comes down on verifying coal dust is toxic and not a mere legal nuisance as verified by the references at the end of this paper.

3.      Rail Traffic will slow Traffic and Emergency Vehicles

S6 of the DEIS says, “Proposed Action…related rail traffic would not affect land use because existing land uses currently coexist with rail traffic.” This misses the larger point. Sixteen trains each having a length of over one mile means of necessity traffic will be significantly delayed. More critical are emergency vehicles that will be delayed likely resulting in loss of property and lives.   

4.     Greenhouse Gas Emissions

S.7.9 of the DEIS says, “Implementation of the Proposed Action would result in increased greenhouse gas pollution.” This is certainly true. Coal also produces more greenhouse gases than any other form of energy and 44 million tons of coal a year is a lot. Raising carbon dioxide levels in any country raises it worldwide. The immediate effect of exporting coal to Asian nations encourages them to burn more dirty coal and prolongs the world’s transition to cleaner alternatives. The result would be more global warming pollution resulting in more forest fires, more flooding and lost agriculture, more violent storms, more droughts, and greater loss of forestry and fishery revenues, and greater numbers of climate refugees. Unfortunately all these ill effects have already started.

This will hurt United States interests because of the 2015 United Nations Agreement COP21. Even if COP 21 is not adopted by the United States, the increased carbon output from coal for the United States will be reported and compared with other countries. This will surely put us in a poorer position with other countries when it is time for continued negotiations.

“If you make peaceful revolution impossible you make violent revolution inevitable.”

John F. Kennedy

            If the State of Washington chooses to go against both the majority of people and the overwhelming preponderance of evidence to build the largest coal terminal in North America then it will face more than the displeased people of Longview. We will rightly be the focal point for environmental action for this continent and perhaps even worldwide at the loss of our reputation as a state formerly known for protecting its environment.

Conclusion

A proposal to export 44 million metric tons of coal annually from a site on the Columbia River, Millennium Bulk Terminals would be the biggest coal terminal in North America. So far the government agencies reviewing the project were swamped with 215,000 public comments during the “scoping” phase of the review. This is the last major fossil fuel project remaining – all the others have been turned down. Let us not make a bad decision that we will be stuck with for half a century or more.

Coal companies are not responsible for these health effects or for clean up when coal ash spills and destroys water supplies. Unlike students who can’t declare bankruptcy if there are no jobs after student loans, companies have the cost to clean up the environment and health costs paid for by taxpayers. Property damage, lost lives, environmental damage, and health costs are never paid for with cities and towns picking up the tab while companies keep the profits. Washington should not fall for this Millennium scam that will cost both jobs and money. 

S-7 says despite S6 mitigation measures, “Unavoidable and significant adverse environmental impacts could remain for nine environmental resource areas: social and community resources; cultural resources; tribal resources; rail transportation; rail safety; vehicle transportation; vessel transportation; noise and vibration; and greenhouse gas emissions.”

Given the above, the no action course is the best one to follow.

References:

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 of the article located here: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

 

June 2016 - Washington state Ecology - Oil Train Safety - Public Comment 107

 

June 12, 2016

 

Department of Ecology

Washington state

PO Box 47600

Olympia, WA 98504-7600

Subj: Chapter 173-185 WAC Oil Movement by Rail and Pipeline Notification and Chapter 173-186 WAC Oil Spill Contingency Plan – Railroad.

 

The dangers of most of our rail infrastructure being over a century old are illustrated by the 47 people who died in the Quebec explosion of 2013. Since then there have been 12 train explosions so far and about 15 derailments a year, including on the newer supposedly safer CPC-1232 rail cars. Most recently, a crude oil train derailed and caught fire in Mosier, Oregon. The New Progressive Alliance at http://newprogs.org/    urges the Washington state Department of Ecology to adopt increased safety rules to deal with this danger.

There has been a huge expansion in other pipelines and dangerous fuel transportation by rail and truck. Even more than transportation, the problem is we are not leaving fossil fuels and dirty Tar Sands oil in the ground in the first place.

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 of the document at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

It is also worth looking at the objections to the Tesoro Savage Vancouver Energy Distribution Terminal Facility Proposal. The same considerations apply.

• Chapter 4 on Crude Oil Safety Considerations says, “Additionally, Washington and Oregon laws have instituted financial liability to owners for operation of vessels carrying crude oil. Operators of vessels carrying crude oil from the proposed Facility and the owner of the crude oil would be strictly liable for any damage and the cleanup in the event of a spill and would be required to maintain adequate financial resources (including insurance) to respond to a potential oil spill regardless of fault. These liabilities create significant financial incentives for compliance with all required and any self-imposed risk mitigation measures that are available. In addition to civil liabilities there are also significant criminal liabilities. For example, 33 USC 309(c)(1) authorizes imprisonment and up to $25,000 per day fines for oil spills.” This ignores the long held fossil fuel practice of declaring bankruptcy or simply getting away with pleading they can’t afford it after large spills. Ultimately, the tax payer and government are responsible.
• On ES-9 under 6.2.1 the Draft EIS  says, “No significant (moderate to major) cumulative impacts were identified for the proposed facility in combination with past, present, and reasonably foreseeable future actions.”  This is incredible and ignores the many rail and sea disasters that keep happening despite reassurances after each disaster. The delay to transportation of many mile plus long trains is not even considered. To look at this proposal in isolation without considering other pollution sources - as the Draft EIS does - seems to suggest unfamiliarity with the word “cumulative.”
• Most of our rail infrastructure is over a century old.
• The dangers are illustrated by the 47 people who died in the Quebec explosion of 2013. Since then there have been 12 train explosions so far and about 15 derailments a year, including on the newer supposedly safer CPC-1232 rail cars.
• On ES-14 using wildly optimistic and undocumented assumptions, the Draft EIS said that there would be a derailment of one loaded railroad car spilling up to 700 barrels of crude oil every 27 years, a vessel loading spill of up to 1 barrel every 14 years, and a grounding or collision with a spill of up to 1,000 barrels every 34 years. Even using these unrealistic optimistic estimates show building this facility is a bad idea.
• On ES-14 and ES-15 Emergency Response Preparedness is discussed. The Vancouver firefighters union opposes the oil terminal because of the unacceptable risk to our first responders, port workers and the public. Its protocol for responding to oil train and terminal fires is “nonintervention,” meaning the fire department would evacuate the area and let the oil burn. That’s all we can do. In an urban or industrial area, that leaves too many lives and properties in danger. ES-15 describes how most fire departments are woefully unaware of even where to call for advice.
• ES-16 says all tank rail cars will meet the newer DOT-117 specifications. This is no comfort at all.  The CPC-1232 rail cars (designed to replace the older DOT-111 cars of 1970s design) have still exploded and burned and are only designed to withstand impacts of 12 to 18 miles per hour. Further railroads have until May 1, 2025 to meet even this small improvement. Since 47 people died in the Quebec explosion of 2013 there have been 12 train explosions and about 15 train derailments a year. This is an unacceptable risk.
• ES-17 says the applicant will “conduct a study to identify an appropriate level of financial responsibility for the potential costs for response and cleanup of oil spills, natural resource damages, and costs to state and affected counties and cities for their response actions to reduce the risks and impacts from an oil spill.” It is difficult to imagine a statement more naïve or unfamiliar with what repeatedly happens in fossil fuel spills and accidents. Fossil fuel companies say they will be responsible and then leave the jurisdiction or declare bankruptcy resulting in leaving tax payers and the government to clean up their messes after they have absconded with the profits.

Recommendations:

We join other organizations in making the following recommendations.

 

For the Rail and Pipeline Notification rule (Chapter 173-185 WAC):

(1)        Provide more detailed information on the types of oil, volume of different types of oil, oil spills, etc. consistent with the route segments to understand areas where unique risks or problems exist.

(2)        Incorporate language in the final rule that makes it clear that the agency will assume that the route is known and the burden is on the facility to show that they do not know the route taken by an oil-by-rail shipment through documentation. This will prevent the facilities from cutting corners in reporting requirements.

(3)        Centralize information for rail, pipeline, and vessel reporting systems so we can have a one stop shop for public information. This includes the TYPE of oil as well as how much oil and how the oil is traveling.

(4)        Continue to require facilities to report all oil shipments scheduled to arrive at their facility.

For Railroad Contingency Plan rule (Chapter 173-186 WAC):

(1)        Contingency plan requirements for railroads should be comparable with the most rigorous contingency plan requirements for pipelines and vessels. This includes the 1-, 2-, and 4-hour planning standards and aerial surveillance capabilities.

(2)        Require planning standards for diluted bitumen that include the recommendations from the National Academy of Sciences’ Spill of Diluted Bitumen from Pipelines: A Comparative Study of Environmental Fate, Effects and Response

(3)        Retain the definition of a ‘worse case spill.’

(4)        Ensure safety of first responders through adequate protective gear.

(5)        Update the cost-benefit analysis to include the analysis of insurance expert Robert J. Blackburn, hired by the City of Vancouver, that indicates a worse-case scenario in Vancouver could cost $6 billion.

(6)        Establish a prioritization process for processing and/or paying damage claims if they exceed the money available for compensation.

(7)        Identify adequate planning points for the distribution of oil spill response equipment and trained personnel.

(8)        Require a public notice, review, and commenting opportunity when there is a significant change of the plans in order to approve the plan.

 

June 2016 - BOEM - Stop Gulf and Atlantic Off Shore Drilling - Public Comment 108

June 15, 2016

Bureau of Ocean Energy Management (BOEM)

The New Progressive Alliance at http://newprogs.org/   thanks the  Bureau of Ocean Energy Management for cancelling the plan to lease areas off the Atlantic coast to oil companies. It is a good but insufficient first step.

The full extent of damage in the Gulf of Mexico is still being discovered. See references 1, 71, 151, 166, 187, 199, 224, 244, 250, 269, 329, 371 - 373, 397, 405, 470 - 473, 487, 553 - 556, 593, 636, 637, 669 - 676, 833, 843, 882, 891, 911 - 923, 971, 1040 - 1047, 1160 - 1164, 1329 - 1339, 1556-1557, 1572-1573, 1739, 1779-1782, 1909-1932, 2126-2127, 2413, 2555, 2757-2766, and 2881-2884 of the document located here: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Because of the extensive damage to the Gulf and other disasters the BOEM should also  cancel plans for seismic blasting, place a moratorium on offshore drilling in the Atlantic,  phase out of Gulf leasing, and eventually stop all drilling in the Artic and Gulf of Mexico. This would be a good faith effort to comply with the recent United Nations climate treaty and make a needed change to minimize global warming for future generations.

 

July 2016 - Leap Manifesto - Canadian Post Office - Public Comment 109

July 28, 2016

The New Progressive Alliance recently joined with the Leap Manifesto in urging Canada to retain and expand their postal service and resist privatization drives. The Leap Manifesto is a coalition of Canadians calling for a restructuring of the Canadian economy and an end to the use of fossil fuels. As in the United States, there has been a call for privatization of the Post Office despite that it has been both efficient and profitable for decades.  The New Progressive Alliance’s Unified Platform emphasizes the importance of public investment in infrastructure.

Canada Post has been profitable for 19 out of the past 21 years, and last year netted almost $100 million in profits. With profits like these, it doesn’t break the bank to restore home delivery to households that should never have lost it.  Canada Post should restore home delivery, and add new services that will make it viable for years to come.

Canada Post is the country’s largest retail and logistics network, and should be put to use to address Canada’s economic and climate challenges. Canada's postal service could include a made-in Canada electric delivery fleet, postal banking that finances green energy, services for seniors, coast-to-coast charging stations for electric cars, and much more.

We encourage the task force to adopt the Delivering Community Power proposal to expand Canada Post with services like affordable banking, local food delivery, and community digital access. In the United States there is a similar push to add community banking to the Post Offices.

 

August 2016 - BLM - Stop Coal Mining on Public Land - Public Comment 110

August 1, 2016

Director: The Honorable Neil Kornze
Bureau of Land Management - Washington Office
1849 C Street NW, Rm. 5665
Washington DC 20240

Secretary of the Interior Sally Jewell has launched a major review of how the Bureau of Land Management manages coal. This is an excellent opportunity to take into account the true costs of coal on our air, our health, our land, and our climate. The New Progressive Alliance at http://newprogs.org/  urges the BLM to stop coal mining on public land.

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 of the article “The Environment” located here: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

In addition to environmental concerns, coal makes less and less sense economically. The New Progressive Alliance encourages you do the right thing for future generations and stop coal mining on public land.      

 

September 2016 - Enterprise out of ALEC - Public Comment 111

September 13, 2016

 

Enterprise Holdings, Inc.

600 Corporate Park Drive

Clayton, MO 63105

 

To: Pamela Nicholson, President and CEO

 

Your company has long said, “At Enterprise, our doors are open.” We, the undersigned, would like to take you up on that open-door policy and implore you to rescind your membership in the American Legislative Exchange Council (ALEC).

 

Your company prides itself on important global sustainability programs, including reducing greenhouse gas emissions with climate change in mind. In stark contrast, ALEC promotes climate change denial to policymakers and in school textbooks, and has fought against clean energy initiatives across the country while advocating against climate solutions such as cleaner power plants and carbon pricing.

 

ALEC has also pushed legislation that would dismantle your workers’ retirement security, risk their lives by deregulating their workplaces, and make it more difficult for them to vote. Although ALEC has tried to distance itself from Voter ID restrictions, for years it pushed for those measures to become binding law and has done nothing to get them repealed.

 

Enterprise is well-known for its support of our troops, yet ALEC’s pay-to-play operations enable its legislators to advance the wish list of the predatory lending industry, which preys on military families at four times the rate of other Americans. ALEC has also aggressively attacked Medicaid expansion measures in the states that could help up to 300,000 veterans and their families access badly-needed healthcare services if they are not near a VA hospital or are not eligible for the full set of VA benefits. ALEC works to limit eligibility for welfare and other safety net benefits, even though nearly a quarter of enlisted service members need access to food assistance due to the low pay provided to too many of our military families. ALEC even advocates strongly for an Article V convention to enact a federal balanced budget amendment that would gut necessary programs and provisions for our troops like the purchasing of protective gear and treatment for wounded veterans.

 

As a member of ALEC, you are underwriting an undemocratic process by which lobbyists  and politicians come together under the cover of darkness to write and vote on “model” write legislation that harms American families. ALEC’s legislation stands in conflict with the values of your company and its customers. Enterprise continues to be one of the leaders in the industry in terms of charitable giving. We know how important to your company giving back is, and you may be surprised to learn that ALEC calls its lobbying operation a “charitable” endeavor, insulting organizations that have a philosophy of giving. This has generated at least three separate complaints by public interest groups to the Internal Revenue Service that contributions to ALEC should not be treated as tax-deductible. ALEC even opposes socially responsible investing.

 

The undersigned organizations have varying opinions on these issues, but we all know that Enterprise’s membership in ALEC undermines your publicly stated corporate values and cultural compass, especially around climate change. We urge you, as a responsible corporate citizen, to leave ALEC.

 

Sincerely,

350 Seattle

Alliance for Retired Americans

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

American Federation of Teachers (AFT)

American Postal Workers Union (APWU)

Americans for Democratic Action

Asian Pacific American Labor Alliance (APALA)

Center for Media and Democracy/ALEC Exposed

Christopher Reynolds Foundation

ClimateTruth.org

Color of Change

Common Cause

Communications Workers of America (CWA)

Daughters of Charity, Province of St. Louise

Demand Progress

Democracy for America

Dominican Sisters of Hope

Food & Water Watch

International Brotherhood of Teamsters

Mercy Investment Services, Inc.

MoveOn.org

New Progressive Alliance

Northwest Coalition for Responsible Investment

People For the American Way

Progress Florida

ProgressNow

Sierra Club

Social Security Works

Stand Up to ALEC

Students for a Just & Stable Future

SustainUS: U.S. Youth for Justice & Sustainability

Ursuline Sisters of Tildonk, U.S. Province

We Act Radio

West Virginia Citizen Action Group

Zevin Asset Management

cc:

Andrew C. Taylor, Executive Chairman

Patrick Farrell, Senior Vice President and Chief Marketing and Communications Officer

Ray Wagner, VP of Government & Public Affairs for Enterprise Holdings