Public Comments 2017 (112-146)

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

Public Comment 112: January 2017 - WA state SW Clean Air Agency on proposed Methanol Refinery
Public Comment 113: January 2017 - WA state Cowlitz County deny local land use permits to Northwest Innovation Works’ Kalama proposed methanol refinery
Public Comment 114: February 2017 - BLM on Spring Creek Coal EIS
Public Comment 115: February 2017 - Senate Banking Committee on SEC Nominee Walter Clayton
Public Comment 116: February 2017 - Beyond Extreme Energy FERC Appointments
Public Comment 117: March 2017 - HOR FERC Appointments
Public Comment 118: March 2017 - U.S. Senate on Supreme Court Nominee
Public Comment 119: March 2017 - Postal Concerns
Public Comment 120: May 2017 - Open Call for NGOs to help United Nations
Public Comment 121: May 2017 - NPA Welcomes ACT NOW
Public Comment 122: May 2017 - Rover Pipeline FERC
Public Comment 123: June 2017 - CA Disclose ACT (AB14)
Public Comment 124: June 2017 - U.S. Withdrawal from United Nations COP 21
Public Comment 125: June 2017 - Political Intelligence Transparency Act
Public Comment 126: July 2017 - Congress oppose ideological irrelevant riders
Public Comment 127: July 2017 - Nebraska PSC - Stop Keystone XL Pipeline
Public Comment 128: July 2017 - Governor Jay Inslee should not approve Methanol Refinery
Public Comment 129: July 2017 - 50 Secretaries of State Should Oppose the Pence-Kobach Request
Public Comment 130: July 2017 - Congress - Stop FERC Abuse of Authority on Pipelines
Public Comment 131: July 2017 - Washington State Ecology - Stop Millennium
Public Comment 132: September 2017 - Seattle Disability Commission - end sub-minimum wage for disabled people
Public Comment 133: September 2017 - Congress Stop Idealogical Irrelevant Riders
Public Comment 134: September 2017 - DRBC Stop Penn East Pipeline
Public Comment 135: September 2017 - Organizations Oppose FERC
Public Comment 136: September 2017 - Congress Letter Opposing FERC
Public Comment 137: September 2017 - CA Disclose Act AB 249 Governor Sign
Public Comment 138: October 2017 - World Bank - Stop Financing Fossil Fuels
Public Comment 139: October 2017 – Cowlitz County Stop Millennium
Public Comment 140: October 2017 – Washington State Ecology – Stop Millennium
Public Comment 141: December 2017 - Congress - Don't Strip the SEC of its Power
Public Comment 142: December 2017 - Congress- Legislative Priorities
Public Comment 143: December 2017 - Congress - Net Neutrality
Public Comment 144: December 2017 – Congress – Challenge Trump on Environment
Public Comment 145: December 2017 – State Attorney Generals – FERC Abuses
Public Comment 146: December 2017 – Health and Human Services – CDC Forbidden Words

Public Comment 112: January 2017 - WA state SW Clean Air Agency on proposed Methanol Refinery

January 4, 2017

Washington state

SW Clean Air Agency

Subj: Air Discharge Permit 16-3204

The New Progressive Alliance at http://newprogs.org/ urge you to deny Northwest Innovation Works’ Air Discharge Permit for the proposed methanol refinery in Kalama, Washington.

The primary reason to deny Air Discharge Permit 16-3204 is the pollution it would cause. Other reasons are utility costs for both electricity and natural gas would increase and it is a bad business plan.

1. Increased Pollution

Documentation for the below comes from the following sources.

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

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

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

2. Higher Utility Costs for Electricity and Natural Gas

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

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

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

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

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

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

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

Conclusion:

Please consider the total pollution, the higher electricity rates, and this bad business plan and reject Air Discharge Permit 16-3204.

Public Comment 113: January 2017 WA state Cowlitz County deny local land use permits to Northwest Innovation Works’ Kalama proposed methanol refinery

January 16, 2017

Hearing Examiner The Honorable Scheibmeir

The Honorable Ron Melin

Cowlitz County

[email protected]

The New Progressive Alliance at http://newprogs.org/ urges you to not issue local land use permits to Northwest Innovation Works’ Kalama methanol refinery because of increased pollution, higher utility costs, it would support a bad business plan, and it will hurt U.S. interests because of United Nations commitments.

1. Increased Pollution

Documentation for the below comes from the following sources.

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

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

The acute health and air impacts from high-concentration short-term exposure to pollutants through refinery flaring, are not worth the risk to our communities. The EIS estimates flare operations will involve six shutdowns (requiring 2 hours of flaring each), six start-ups (requiring 12 hours of flaring each), and four process upsets (requiring 4 hours of flaring each) per year. In addition, the facility plans to flare between 48 to 60 hours while the catalysts are prepared for initial use and every few years thereafter. Flaring can cause acute impacts (e.g. respiratory and eye ear and nose irritation) when people are exposed to very high levels of pollutants over a short period of time (a few minutes or hours).

The methanol refinery would emit over a million tons of greenhouse gases each year. NWIW admits that the technology exists to reduce greenhouse gas emissions by about 86%, but NWIW does not want to spend the money.

2. Higher Utility Costs for Electricity and Natural Gas

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

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. Foreign corporations and government shouldn’t be allowed to take over private land, pollute our air, and exploit our water and natural resources.
Northwest Innovation Works has never built or run a methanol refinery and the proposed technology has never been used to make methanol commercially, yet NWIW proposes to build the largest methanol refinery in the world.

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

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

Conclusion:

Please do not issue local land use permits to Northwest Innovation Works’ Kalama methanol refinery because of increased pollution, higher utility costs, it would support a bad business plan, and it will hurt U.S. interests because of United Nations commitments.

Public Comment 114: February 2017 - BLM on Spring Creek Coal EIS

February 13, 2017

The Honorable Irma Nansal

Bureau of Land Management

The New Progressive Alliance at http://newprogs.org/ urges you to reconsider the Spring Creek Coal Environmental Impact Statement.

Coal and fracking companies do not deserve a continuing series of good deals at the expense of the American taxpayers. The New Progressive Alliance has written the BLM in June 2012, May 2013, August 2013, June 2015, and August 2016 on this matter and now we are writing again.

Last month, a new report from the Bureau of Land Management found major problems with the federal coal leasing program, including massive taxpayer losses through sweetheart deals for coal companies. The report also showed how coal companies have failed in their legal duty to reclaim mined farms, ranches, and public lands; and how federal coal management has failed to account for the climate impacts of coal leasing.

Interior Secretary Sally Jewell said at the time: “We have a responsibility to ensure the public – including state governments – get a fair return from the sale of America's coal, operate the program efficiently and in a way that meets the needs of our neighbors in coal communities, and minimize the impact coal production has on the planet that our children and grandchildren will inherit. The only responsible next step is to undertake further review and implement these commonsense measures.”

But at the same time that the BLM pointed out these major problems and called for taking a step back to institute reforms, the bureau was moving forward with leasing an additional 205 million tons of coal to Cloud Peak Energy’s Spring Creek Mine for export to Asia. Cloud Peak does not even need this coal right now—it already has more than 13 years of stockpiled coal reserves. Cloud Peak Energy currently has years of leased reserves at Spring Creek. And though they've been operating for decades, they've fully reclaimed less than 10% of mined lands. The BLM has no business giving coal to a company that doesn’t need it any time soon—especially under a system everyone knows is broken.

In addition to environmental concerns, coal makes less and less sense economically. China is cancelling coal orders and building new coal plants. More than 15 independent and governmental reviews of federal coal leasing have found massive taxpayer losses due to the undervaluing of publicly-owned coal. This problem was significant enough to warrant a full-scale national review, which to date has also found issues with reclamation and the way coal leasing is dealing with climate change.

BLM should factor these things into its consideration, and shouldn't lease more coal at Spring Creek until the broken coal leasing system is fixed and Spring Creek steps up reclamation efforts.

Thank you for your consideration.

Public Comment 115: February 2017 - Senate Banking Committee on SEC Nominee Walter Clayton

February 15, 2017

To: Members of the Senate Banking Committee

Dear Senators:

You face crucial issues in your consideration of the nominee for Chair of the Securities and Exchange Commission (SEC), Walter “Jay” Clayton. As the primary agency regulating U.S. securities trading markets, the SEC’s actions have far-reaching implications for Main Street Americans who deserve strong investor protection and a growing real economy supported by stable and reliable markets.

Mr. Clayton’s background is as a Wall Street corporate lawyer and dealmaker representing many of the largest financial institutions in our society. Such a corporate background is not unique among past SEC chairs and commissioners, and the wisdom of a seasoned practitioner could be useful in the position. But Mr. Clayton’s decades of service to Wall Street raises serious questions about his ability to lead an agency dedicated to investor protection and the public interest. Accordingly, it is particularly urgent that you thoroughly question Mr. Clayton as to whether his background may bias him toward the interests of Wall Street insiders such as those he has worked with for many years. These interests often conflict with those of ordinary investors, and indeed, all those who depend on fair and well-functioning capital markets (including our state and local governments).

Our economy is still recovering from the devastating effects of the 2008 financial crisis. The inadequate oversight of SEC-regulated institutions and markets was a major contributor to that crisis. While the SEC has made progress to reform and re-vitalize itself, it still has not fully addressed the serious issues revealed in the crisis. New challenges are also emerging as financial markets continue to evolve toward more complex investment products and trading technologies.

The response of the new Administration to this unfinished business has been to call on regulatory agencies to tear down even those improvements that have been made since 2008. As the head of an independent regulatory agency, Mr. Clayton will still have the freedom to act to protect the public when the evidence shows that uncontrolled Wall Street practices endanger economic security, capital formation, and the savings of ordinary investors. But it is crucial that you thoroughly question and examine him to find out whether he will be willing to do so.

Such questioning should be guided by the mission of the SEC, which is to “protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation,” as well as to promote a market environment that is worthy of the public's trust.”[1] Based on this directive, the American public and its representatives in Congress justifiably expect the SEC and its leadership to hold corporations accountable, to ensure those financial services under the jurisdiction of the SEC operate under fair and robust rules, and afford no special treatment to any entity or person.

The SEC is also charged with ensuring that shareholders have access to timely and complete disclosure of not only financial information but also a company’s policies and activities. The underlying premise of the agency is that markets function better as investor confidence improves and that part of that confidence is built on providing investors with information that they, and not just industry, deem material. Additionally, shareholders are increasingly calling for more information on environmental, social, and governance (ESG) issues like climate change, human rights, tax, political spending and lobbying activity, CEO pay, and workforce matters. The SEC Chair must be responsive to these demands and utilize increased technological capabilities to make this information readily available to shareholders and to the public.

Disclosure is far from the only pressing challenge facing the SEC. Critical rules responding to the weaknesses in oversight revealed in the financial crisis remain unwritten or unimplemented. Unfinished rules should be prioritized and those rules that have been put in place should not be rolled back unless there is broad consensus on a better way to manage the risks they are intended to address. In addition, there is an important regulatory agenda to improve investor protections in a variety of areas marked by rapid growth and technological change.

While rulemaking is central to the agency’s mandate, rules are only effective insofar as they are enforced. It is essential that the Chair of the SEC be willing to take all steps necessary to enforce the law and the rules regardless of how wealthy, powerful or well-connected a firm or person might be. While using all of the Commission’s powers to enforce the law civilly, the Chair of the SEC must also be willing to refer lawbreakers to the Justice Department whenever appropriate for criminal prosecution. This is how a fair, serious, and ardent regulator sends the critically important message that no one is above the law.

Among other issues, you should press Mr. Clayton on whether:

1) He will implement and enforce the law as currently written including systemic risk provisions such as the Volcker Rule and derivatives regulation, reporting of “CEO to worker pay ratios,” whistleblower protections and rewards programs, risk-retention requirements, and reforms to proxy access rules.

2) He will continue and build on the examinations of private funds that revealed significant fraud and expand the Commission’s registration and oversight of those funds to protect investors as required by current law.

3) He will defend the rights of investors and asset owners through the shareholder resolution process laid out by Rule 14a-8.

4) He will uphold the definition of materiality as information that investors find relevant, rather than the management of the issuers.

5) He will take action in cases where new financial products and activities pose risks to investors and the broader financial system.

6) He will maintain the long SEC tradition of prioritizing strong and effective disclosure for investors.

In questioning Mr. Clayton, you must critically assess his capacity for impartial dedication to and prioritization of the public interest given his long history as a Wall Street lawyer whose sole duty was to act as a zealous advocate for his clients’ narrow, private sector interests. In particular, Mr. Clayton has spent a significant portion of his career representing the nation’s biggest banks as a lawyer at Sullivan & Cromwell - the law firm The New York Times referred to as Goldman Sachs “go-to law firm for more than a century.”[2]

His resume includes:

Advising Goldman Sachs on the $5 billion investment it received from Warren Buffett’s Berkshire Hathaway during the financial crisis.[3]
Advising Bear Stearns during its sale to JPMorgan Chase.[4]
Advising Barclays Capital in buying up assets left by the Lehman Brothers bankruptcy during the financial crisis.[5]
Representing Ally Financial[6] in connection with the $25 billion settlement related to robo-signing and other foreclosure abuses with the federal government and state attorneys general.[7]
Advising the Chinese e-commerce company Alibaba Group on its $25 billion initial public offering, the largest ever IPO.[8]

While this experience has the potential to inform a regulator’s perspective, it can also embed a belief that what is best for Wall Street is best for America. The 2008 financial crash proved this belief to be objectively false. Congress needs and the American people deserve a Chair of the SEC who advocates for the needs of Main Street over the interests of Wall Street.

Moreover, Mr. Clayton’s long list of former clients opens up the possibility of significant conflicts of interest if he becomes Chair of the SEC. He will almost certainly need to recuse himself from significant decision-making processes at the agency. His wife’s ties to Goldman Sachs further complicate the matter. As a result, Mr. Clayton needs to demonstrate beyond any doubt that he will be able to be objective, fair, and willing to hold Wall Street accountable (including his former clients), and not favor policies that allow anyone to profit at the expense of the American people.

We hope and expect you will press Mr. Clayton concerning his willingness to support tough rules and enforcement for Wall Street giants when such action is necessary to protect the broader public. The shortest path to economic growth and job creation is to put Main Street investors’ interests first and ensure that rule of law on Wall Street is enforced and strengthened.

Sincerely,

AFL- CIO

American Family Voices

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

Americans for Financial Reform

Better Markets

Center for Popular Democracy

Clean Yield Asset Management

Communication Workers of America

Democracy Matters

Harrington Investments, Inc.

Money Out Voters In (MOVI)

New Progressive Alliance

Public Citizen

WV Citizen Action Group

Zevin Asset Management, LLC

[1] https://www.sec.gov/about.shtml

2 https://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html?_r=0

3 http://www.wsj.com/articles/SB122220798359168765

4 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

5 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

6 https://www.sullcrom.com/lawyers/Jay-Clayton

7 https://www.justice.gov/opa/pr/federal-government-and-state-attorneys-general-reach-25-billion-agreement-five-largest

8 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

Public Comment 116: February 2017 - Beyond Extreme Energy FERC Appointments

February 17, 2017

Beyond Extreme Energy is proposing to transform the Federal Energy Regulatory Commission (FERC) with the following nine steps.

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.

To achieve this, Beyond Extreme Energy is banding together with the New Progressive Alliance and other organizations around the country to fight Trump's upcoming appointments to the Federal Energy Regulatory Commission (FERC).

Right now, FERC is down to two commissioners and can no longer approve fossil fuel infrastructure.

FERC has traditionally ignored and dismissed community and climate concerns when reviewing industry permits for fracked-gas pipelines and other infrastructure. Research indicates that the agency has rejected ONLY ONE such application, in 2016, in 30 years. FERC is in essence a rubber-stamp agency for the fracked-gas industry.

Donald Trump will be able to nominate three Republican commissioners and one other commissioner to the five-member panel over the next six months, one of whom will be a new chair. There are now three vacancies, given the resignation of former chair Norman Bay in the last week of January, and one sitting commissioner’s term expires in June.

Within just weeks, FERC could be controlled by Trump. All FERC-sponsored, open community meetings on proposed fracked-gas infrastructure projects could become one-person-at-a-time, behind-closed-door meetings, as has happened already under the current regime in Ohio, New York, New Jersey and Virginia. FERC could institute rigid, compressed timelines for action on permit applications. Landowners fighting eminent domain abuse could face greater pressure from pipeline companies anxious to take their land. FERC staff could be ordered to do even worse jobs on Environmental Assessments and Environmental Impact Statements that deal with threats to community health, safety and climate. The FERC public relations department could actively attempt to portray communities that oppose proposed pipelines in the most negative light. The FERC building security in DC could become more repressive against those who protest there.

Trump’s nominations need to be approved by the full Senate. We call upon members of the Senate, especially those on the Senate Energy and Natural Resources committee which has to review those nominations, to speak out about the myriad problems with FERC and press Trump’s nominees about its rubber-stamp history for gas industry expansion.

We pledge that when Trump makes his first FERC nomination we will work actively against it and the other nominations, as best and as much as we can, in collaboration with other organizations doing the same.

Signed,

Advocates for Springfield, NY
Allegheny Defense Project
American Medical Student Association
The AMP Creeks Council
Athens County [Ohio] Fracking Action Network
Aquashicola/ Pohopoco Watershed Conservancy
Berks Gas Truth
Berkshire Environmental Action Team (BEAT)
Beyond Extreme Energy
Buckeye Environmental Network
Catskill Citizens For Safe Energy
Catskill Mountainkeeper
The Center And Library for the Bible and Social Justice
Center for Biological Diversity
Chesapeake Climate Action Network
Citizen Coalition for Wildlife and Environment
Citizens Against the Rehoboth Compressor Station (CARCS)
Citizens For Water
Clean Air Council
Climate 911
CODEPINK for Peace
Columbus Community Bill of Rights
Compressor Free Franklin
Concerned Citizens of Otego, NY
Delaware Riverkeeper Network
Damascus Citizens for Sustainability
Earth Action, Inc.
ECHO Action NH: #FossilFree603
Exact Solar
The FANG Collective
Food and Water Watch
Fore River Residents Against the Compressor Station (FRRACS)
Fossil Free Rhode Island
FreshWater Accountability Project
Friends for Environmental Justice
Friends of the Harmed
Gas Free Seneca
Glenville Environmental Organization
glofernartstudio.org
Greenbelt Climate Action Network
Guernsey County Citizens Support on Drilling Issues
Green America
Health Professionals for a Healthy Climate
Howard County (MD) Climate Action
Keeper of the Mountains Foundation
Lancaster Against Pipelines
LEPOCO Peace Center (Lehigh-Pocono Committee of Concern)
Marcellus Outreach Butler
Milford Doers/Residents of Crumhorn Mtn
Milwaukee Riverkeeper
Mountain Lakes Preservation Alliance
NC WARN
New Haven Leon Sister City Project
New Progressive Alliance
North Jersey Pipeline Walkers
Nuclear Age Peace Foundation
NYH2o
OgreOgress Productions
Ohio Valley Environmental Coalition (OVEC)
Otsego 2000, Inc.
Pennsylvania Alliance for Clean Water and Air
Pennsylvania Earth Guardians
People Over Pipelines
Plymouth Friends of Clean Water
Popular Resistance
Preserve Giles County
Preserve Montgomery County, VA
Preserve Roanoke/Bent Mountain
Protectors of the Planet
Renewable Energy Long Island
Resist the Pipeline
ROAR Against Fracking
Rockfish Valley Investments LLC
Rogue Climate
Roseland Against Compressor Station (RACS)
Safe Energy Rights Group (SEnRG)
Sane Energy Project
SEED
Seneca Lake Guardian, a Waterkeeper Affiliate
Sierra Club Niagara Group
South Coast Neighbors United, Inc.
Stop the Algonquin Pipeline Expanson
Stop the Pipeline
Students for a Just and Stable Future
Sullivan Alliance for Sustainable Development
Sullivan Area Citizens for Responsible Energy Development (SACRED)
Sullivan County Residents Against Millennium (SCRAM)
Sunflower Alliance
Sustainable Loudoun
Sustainable Medina County
SustainUS
Underground Scholar Association
Unitarian Universalist Church of Loudoun, Green Team
Valley Watch, Inc
Waterkeepers Chesapeake
We Are Cove Point
Western New York Peace Center
West Roxbury Saves Energy
West Virginia Highlands Conservancy
Williams Township Concerned Citizens Against the Pipeline
Winyah Rivers Foundation
WV Environmental Council
350 CT
350 Eugene
350 Loudoun
350 Massachusetts Berkshire Node
350 Salem, OR

Public Comment 117: March 2017 - HOR FERC Appointments

March 1, 2017

Fourteen Democrats in the House wrote to Trump calling on him to make FERC operational again by putting forward nominees for the open commissioner spots. These representatives don’t understand FERC. (See Public Comment 116.) They think making this rubber stamping agency operational again will be helpful. We know otherwise and wrote these 14 democrats.

Dear Congressional Representatives,

On behalf of communities across the nation who are being abused by the misuse of power and law by the Federal Energy Regulatory Commission (FERC), we were deeply disturbed by your February 22, 2017 letter urging swift nomination and approval of new FERC Commissioners.

Rather than advocating for the installation of new FERC Commissioners, you should be doing all you can to forestall the nomination and approval process. Without a quorum FERC cannot issue Certificates of Public Convenience and Necessity to natural gas infrastructure projects using its abusive, biased and conflicted review and approval process for which the approval is a foregone conclusion and not the result of objective consideration of facts, impacts and need.

Communities across the nation are being harmed by the indiscriminate, ill-informed and misguided approvals rolling out of FERC for natural gas infrastructure projects. FERC has proven itself to be an agency with unparalleled bias – approving every natural gas interstate transmission line brought before its Commissioners for approval. In 30 years FERC’s Commissioners have said “no” to only one, just one, gas pipeline project brought before it for approval. Not only are communities being harmed by the pipelines themselves, but they are being mistreated by FERC throughout the review process.

Until Congress has investigated the abuses of power and law by FERC, including the biased and self-serving decisionmaking advanced by its Commissioners and staff, and put in place needed reforms you should oppose restoration of a quorum of FERC Commissioners. Among the many reforms that must be undertaken before a quorum is restored are: the removal of eminent domain power; a prohibition on the use of tolling orders that prevent legal challenges to FERC approvals before pipelines go into construction; a prohibition on the stripping and undermining of state legal authority by FERC; a mandatory public participation process that provides for meaningful access and input; a mandatory determination that there is a genuine need for a project that genuinely serves the public interest (as opposed to corporate greed and goals); a prohibition on the use of consultants that have conflicts of interest and/or work for the industry; a prohibition on self-dealing by the pipeline companies in their claims of need; an end to the employee revolving door between FERC staff and the industry; a clear and enforced prohibition on conflicts of interest by FERC Commissioners …. just to name a few.

In order to genuinely serve the public interest you must take a strong stand against approval of any new Commissioners to FERC until such time as the House and Senate have held hearings investigating the bias and misuse of authority demonstrated by FERC, its employees and Commissioners and needed reforms have been identified, proposed and passed.

Signed,

(See list from Public Comment 116)

Public Comment 118: March 2017 - U.S. Senate on Supreme Court Nominee

On March 3, 2017 The New Progressive Alliance joined with many other organizations to express concerns to the United States Senate about Judge Neil Gorsuch nomination to the Supreme Court of the United States.

The full letter can be found here:

https://doc-0c-8c-apps-viewer.googleusercontent.com/viewer/secure/pdf/s395dp07c6l5tn1v8keo204fmnaho743/rdhfh4962rilkr00d3v63hggksqebcg3/1494900300000/lantern/15694384274789180582/ACFrOgCV18EtiySQaXqAWjqHEI7JXIhenBCE3liJNCyjsxsVBVzsrAzwnflbSS-m6RJ5iwUD9LVYgH5PjlZygUYE6b2osLymMMPWC6PhXtxW55isovt8c6M3XaKc9nA=?print=true&nonce=2ukcrej5v4bqg&user=15694384274789180582&hash=vl3an3v8298pi8vb0mn3o1km52kh6p3b

In addition to the New Progressive Alliance, below is a partial list of other organizations that signed the letter.

Act.tv

AFSCME

Alliance for Democracy

American Federation of Teachers

American Association of University Women (AAUW)

Americans for Democratic Action

American Postal Workers Union

Asian Americans Advancing Justice

Berkshire Environmental Action Team

Beyond Nuclear

Brave New Films

Catholics in Alliance for the Common Good

Center for Media and Democracy

Center for Popular Democracy

Center for Science in the Public Interest

Church Women United in New York State

Citizens for Responsibility and Ethics in Washington (CREW)

Class Action

Clean Elections Texas

Coalition for Disability Health Equity

Coalition to Restore Democracy

CODEPINK

Coffee Party Savannah

Common Cause

Concerned Citizens for Change

Communications Workers of America

DC Latino Caucus

Democracy 21

Democracy Initiative

Democracy Matters

Democracy Spring

Demos

Don't Waste Michigan

End Citizens United

EPI Policy Center

Every Voice

Fix Democracy

Free Speech for People

Friends of the Earth

Greenpeace USA

Hightower Lowdown

Indivisible

Institute for Agriculture and Trade Policy

Iowa Citizens for Community Improvement

Jobs with Justice

Just Foreign Policy

Labor Campaign for Single Payer Healthcare

League of Conservation Voters

Maplight

MayDay PAC

NAACP

National Council of Jewish Women

National Education Association

National LGBTQ Task Force Action Fund

National Partnership for Women and Families

National Priorities Project

Northwest Atlantic Marine Alliance

Occupy.com

Occupy Bergen County

Organize Florida

Our Revolution

Participatory Politics Foundation

Patriotic Millionaires

People Demanding Action

People for the American Way

PeopleNOW.org

People's Action

Power Shift Network

Pride at Work

Represent.US

ReThink Media

RootsAction.org

SEIU

Sierra Club

Sierra Student Coalition

Small Planet Institute

Stamp Stampede

Student Debt Crisis

The Rootstrikers Project of Demand Progress

The Workmen's Circle

Union For Reform Judaism

Voices for Progress

West Virginia Citizen Action Group

Wisconsin Democracy Campaign

Public Comment 119: March 2017 - Postal Concerns

March 17, 2017

Before the Postal Regulatory Commission

901 New York Avenue NW, Suite 200

Washington, DC 20268-0001

Statutory Review of the System

For Regulating Rates and Classes

For Market Dominant Products

Docket No. RM 2017-3

COMMENTS OF THE ALLIANCE FOR RETIRED AMERICANS; CATHOLICS IN ALLIANCE FOR THE COMMON GOOD; CENTER FOR COMMUNITY CHANGE ACTION; CENTER FOR MEDIA AND DEMOCRACY’S PR WATCH; CENTER FOR STUDY OF RESPONSIVE LAW; CONSUMER ACTION; FARM AID; IN THE PUBLIC INTEREST; HIGHTOWER LOWDOWN; NATIONAL COALITION ON BLACK CIVIC PARTICIPATION; NATIONAL ORGANIZATION FOR WOMEN; NEW PROGRESSIVE ALLIANCE; PEOPLE DEMANDING ACTION; VOTE VETS ACTION FUND

Dear Commissioners:

This letter is in response to the Postal Regulatory Commission’s (PRC) request for public comment on whether or not the current system for regulating rates and classes for market dominant products is achieving the objectives of the 2006 Postal Accountability and Enhancement Act (PAEA). We, the undersigned, believe in a strong, public Postal Service that collects revenue adequate to provide affordable, universal mail service to all. The Postal Service’s shortage in revenue over the last 10 years has led directly to cuts in service and the threat of privatization.

Under the current system the Postal Service has not had adequate revenues to meet all of its operational and statutory obligations. Tying postal rate increases to the increase in the Consumer Price Index (CPI), while not allowing the Postal Service to expand services and requiring the Postal Service to pre-fund decades of future retiree health benefits, has put the Postal Service into an impossible bind.

The Postal Service has responded to the constraints listed above by slowing mail service, closing community-based Post Offices and mail processing facilities, slashing hours of operations, trying to end six-day service as well as door-to-door delivery, and eliminating hundreds of thousands of living wage jobs. Over the last few years nearly all of Postal Service management’s focus has been on ways to cut more costs, rather than a balanced business approach of improved service, expanded products and services, including basic financial services, and cost efficiency. Should financial pressure from CPI-based rates continue, the Postal Service could be at risk of further service erosion. If service and usage decline significantly, the Postal Service could then become a target for privatization. Under a privatization of the Postal Service, mail users of all types can be sure that shareholders would demand much higher postal prices.

The Postal Service binds the nation together. It provides universal service to people from all walks of life – rich and poor, rural and urban, without regard to age, gender, race or nationality. The current status quo of a pre-funding mandate, restrictions on new products and services, and a lack of flexibility in setting rates puts the Postal Service at risk. In this proceeding, we believe the PRC has the ability to make an important change in the rate setting process in order to support a strong, public Postal Service.

Sincerely,

Katherine E. Isaac on behalf of

Alliance for Retired Americans

Catholics in Alliance for the Common Good

Center for Community Change Action

Center for Media and Democracy’s PR Watch

Center for Study of Responsive Law

Consumer Action

Farm Aid

In the Public Interest

Hightower Lowdown

National Coalition on Black Civic Participation

National Organization for Women

New Progressive Alliance

People Demanding Action

Vote Vets Action Fund

Public Comment 120: May 2017 - Open Call for NGOs to help United Nations

The New Progressive Alliance is proud to be an NGO in consultative status with the United Nations. NGOs interested in applying for ECOSOC consultative status should submit their application and required documents on or before 1 June 2017 in order to be considered by the 2018 NGO Committee. If you submit after that then it will eventually be considered, but not until after 2018.

This link provides background information, some of the benefits, and the instructions how to apply: http://csonet.org/index.php…

If you would like to participate in United Nations activities through the New Progressive Alliance see So You Want to Volunteer for the United Nations - http://www.newprogs.org/so_you_want_to_volunteer_for_the_un…

Public Comment 121: May 2017 - NPA Welcomes ACT NOW

May, 2017

The New Progressive Alliance is proud to welcome ACT NOW as an ally. The ACT NOW coalition supports a price on carbon in Washington state. Taxing polluters could promote renewable energy, help keep our air and water clean, provide tax relief, and fund healthy forests and vital state services.

Climate Change is a moral and economic threat to Washington State. One of the most efficient and effective policies to reduce carbon emissions is a price on carbon pollution. We urge the Washington State legislature to enact a price on pollution as a measure to uphold our obligation to future generations.

Pricing carbon pollution can and must be bipartisan including input from Republicans, Democrats, business leaders, social justice leaders, climate policy experts, and the public.

A price on carbon pollution will generate revenue that could be used to provide tax relief for citizens, in particular, low-income communities, funding for healthy forests and clean water, acceleration of the clean energy economy and vital state services.

The ACT NOW coalition supports the passage of a broad-based price on carbon pollution that efficiently and equitably meets our obligation to reduce pollution and fulfill Washington’s core responsibility to protect our environment and our kids, now and in the future.

ACT NOW (Advocates for a Carbon Tax NOW) is a grassroots non-partisan coalition.

Public Comment 122: May 2017 - Rover Pipeline FERC

May, 2017

TO: Cheryl A. LaFleur, FERC Acting Chair
Colette D. Honorable, FERC Commissioner

CC: Sherrod C. Brown, Senator from OH
Rob J. Portman, Senator from OH
John R. Kasich, Governor of OH

Dear Commissioners,

We write to express our deep concern regarding the extensive environmental harm caused by Energy Transfer Partners in their construction of the Rover gas pipeline, and to demand immediate action to eliminate the ongoing risk posed by this and future gas pipeline construction. This letter has been signed by organizations from across the country including along the pipeline route in Michigan, Ohio, Pennsylvania, and West Virginia.

The spilling of 2 million gallons of drilling waste into wetlands as a result of reckless horizontal drilling activities clearly demonstrates ETP’s poor planning, neglect, and disregard for communities and the environment along the pipeline route. Already, the Ohio Environmental Protection Agency has fined the company over $400,000 in response to numerous incidents during Rover Pipeline construction.

While we welcome the Federal Energy Regulatory Commission’s (FERC’s) recent action to halt new horizontal directional drilling on the project, it is clear that this limited action is not sufficient to ensure the safety of communities along the pipeline route.

Therefore, we write to demand that FERC halt all construction of the Rover Pipeline in order to ensure the safety of communities and ecosystems along the pipeline route. The permit case and environmental impact statement (EIS) should be reopened and supplemented so that horizontal directional drilling plans and procedures can be reviewed and improved. Further construction should be limited to only those actions needed to ensure the safety and stability of the vicinity until such a review is satisfactorily completed. A Supplemental EIS would allow for a more thorough analysis of the greenhouse gas emissions and climate change impacts of the project, which were lacking in the original EIS and Certificate Order.

Further, FERC should initiate an immediate review of horizontal directional drilling plans and procedures on all open pipeline dockets. FERC should put the safety of communities and ecosystems first by halting the permitting for all new pipeline projects while conducting this comprehensive safety review.

FERC has a responsibility to ensure projects it approves do not imperil the public. Immediate action is needed to live up to that standard with respect to the Rover pipeline and all other gas pipelines currently in the FERC docket.

Signed,

Ohio River Citizens’ Alliance (OH)
Friends for Environmental Justice (OH)
FreshWater Accountability Project (OH)
Radioactive Waste Alert (OH)
Sustainable Medina County (OH)
Athens County Fracking Action Network (OH)
Licking County Concerned Citizens for Public Health and Environment (OH)
Cleveland Environmental Action Network (OH)

New Progressive Alliance
Delaware Riverkeeper Network (PA)
Camp White Pine (PA)
Berks Gas Truth (PA)
Lancaster Against Pipelines (PA)
Damascus Citizens for Sustainability (PA)
LNG Opposition Team (PA)
West Virginia Highlands Conservancy (WV)
Protect Our Water, Heritage, Rights (WV)
Mountain Lakes Preservation (WV)
Laurel Mountain Preservation Association (WV)
MelRose Ministries (WV)
Friends of Buckingham (VA)
Delaware Action Group (NY)
Concerned Burlington Neighbors (NY)
Citizens For Water (NY)
Advocates for Cherry Valley (NY)
NYH2O (NY)
Otsego 2000 (NY)
People Over Pipelines (NY)
Advocates for Springfield, NY (NY)
Deep Green Resistance New York City (NY)
Roseland Against Compressor Station (NJ)
SouthEast Communities Against Pollution (MD)
South Coast Neighbors United (MA)
Citizens Against the Rehoboth Compressor Station (MA)
Atchafalaya Basinkeeper (LA)
350 Louisiana – New Orleans (LA)
Idle No More SF Bay (CA)
Oil Change International
Earthworks
Beyond Extreme Energy
Center for Earth Ethics
Great March for Climate Action
Green America

Public Comment 123: June 2017 - CA Disclose ACT (AB14)

June, 2017

The Honorable Marc Berman

Chair, Assembly Elections and Redistricting Committee

State Capitol, Room 5135

Sacramento, CA 95814

Cc: The Honorable Jimmy Gomez and Marc Levine and Members of the Assembly Elections and Redistricting

Committee

RE: AB 14 (Gomez, Quirk-Silva, and Levine) – Support

Dear Assemblymember Low:

The below listed organizations are pleased to support AB 14, 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 ballot.

Campaign spending on ballot measures has reached unprecedented levels. Nearly $1 billion was spent in California on ballot measures from 2012 to 2016, almost all of it by donors whose true identities were obscured on ads by misleading names buried in fine print. Hundreds of millions more was spent on independent expenditures supporting or attacking candidates. 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 and therefore who is asking for their vote.

AB 14 requires the true, three largest funders of ads about ballot measures or independent expenditures in support or opposition of 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). Even more importantly, AB 14 includes new earmarking rules for contributions meant for specifically identified

committees or ballot measures or for independent expenditures supporting or opposing specifically identified candidates. These new earmarking rules are completely separate from existing earmarking rules regarding contributions to candidates, but will, for the first time, reveal true funders on ballot measure and independent expenditure ads when the funders attempt to hide behind one or more layers of misleading front groups.

AB 14 would thus stop voters from being routinely and legally misled about funders of political ads. 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 14, 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.”

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.

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.”

Californians are crying out for the specific disclosures of the California DISCLOSE Act, with more than 31,000 signing petitions urging the legislature to pass AB 14. We therefore respectfully ask for your support of AB 14. 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 below respectfully SUPPORT AB 14 and request your AYE vote.

FROM: California Clean Money Campaign (Sponsor)

California Alliance for Retired Americans

California Church IMPACT

California Common Cause

Californians for Disability Rights

California League of Conservation Voters

California Physicians Alliance

California Public Interest Research Group (CALPIRG)

Coalition for Clean Air

Consumer Watchdog

CounterPAC

Courage Campaign

CREDO

Daily Kos

Democracy for America

Endangered Habitats League

Free Speech for People

Friends of the Earth

LegitAction

Lutheran Office of Public Policy

Maplight

Money Out People In

Money Out Voters In

New Progressive Alliance

People for the American Way

People Demanding Action

Public Citizen

Represent.Us

Social Security Works

Voices For Progress Education Fund

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

Public Comment 124: June 2017 - U.S. Withdrawal from United Nations COP 21

It is unfortunate that so many believe following the United Nations Agreement will result in economic deprivation. Already states and cities in the United States have resolved to follow it even as President Trump tries to withdraw.

Climate facts are not enough - http://below2c.org/2017/05/climate-facts-not-enough/#comment-6519

Make Your Case with the 2015 United Nations Climate Change Conference, COP 21 - http://www.newprogs.org/make_your_case_with_the_2015_united_nations_climate_change_conference

Our Responsibility After Trump's Climate Withdrawal - https://popularresistance.org/newsletter-understanding-trumps-climate-withdrawal-our-responsibility/

Thank You For Dropping Out of Paris Agreement and Good Riddance - http://below2c.org/2017/06/thank-you-for-dropping-out-of-paris-agreement-and-good-riddance/

Public Comment 125: June 2017 - Political Intelligence Transparency Act

The New Progressive Alliance joined with other organizations in supporting the Political Intelligence Transparency Act.

June, 2017

Groups Urge Congress to Bring Secret Industry that Taps Congressional Sources for Stock Trading Tips into the Sunlight

Reps. Slaughter, Duncan Introduce Bipartisan

“Political Intelligence Transparency Act”

We applaud Reps. Louise McIntosh Slaughter (D-N.Y.), John Duncan, Jr. (R-Tenn.) and Tim Walz (D-Minn.) for resuming the legislative drive to shine a light on the secret activities of Wall Street consultants and lobbyists who lurk on Capitol Hill seeking valuable information they can use to cash in on the stock market. We urge all of Congress to join in this effort to open the books on the stock market cottage industry known as the “political intelligence industry.”

Our organizations and scholars supporting this transparency legislation include: Center for Media and Democracy, Common Cause, Every Voice, James A. Thurber, New Progressive Alliance, Public Citizen, WV Citizen Action Group,

The political intelligence industry operates largely in secret. It is estimated that there are some 2,000 political intelligence consultants roaming the halls of Congress soaking up trading information for paying clients to the tune of anywhere between $100 million to $400 million in annual profits. But no one knows for sure, since political intelligence activities are not disclosed either to the public or to Congress. Some of this activity could well involve insider trading.

The “Political Intelligence Transparency Act” does not prohibit such activity as long as it is done legally and above board. The legislation would require political intelligence consultants to register under the Lobbying Disclosure Act (LDA) and disclose their clients, income and activities. This bill is a straightforward transparency measure that would enable the public to monitor whether any illegal insider trading is taking place.

This is commonsense transparency legislation. We strongly urge Congress to support the bipartisan ‘Political Intelligence Transparency Act’ with the same enthusiasm in which Congress embraced the STOCK Act.

Public Comment 126: July 2017 - Congress oppose ideological irrelevant riders

July 5, 2017

Dear Members of Congress,

We, the undersigned organizations, write to ask you to oppose any FY 2018 appropriations bills which include 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. Earlier this year, hundreds of these policy provisions were proposed as a part of the omnibus process, and in the FY18 budget process some members of Congress have already started to insist on ideological riders.

Ideological riders are measures that the public opposes and would be unpopular to move 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 fair housing, and to ensure continued access to vital health care services including reproductive health care.

Contentious poison pill riders are intended to advance the priorities of special interest donors and supporters and should not be included in funding bills.

President Trump has proposed a budget rigged for billionaires and big business featuring deep cuts that endanger our health and safety, our workplaces and wallets, as well as, our environment and our economy. In addition to being free from poison pill riders, any budget passed through Congress must go far beyond both this paltry Presidential proposal and the obviously inadequate sequester funding levels, to robustly fund agencies and programs to protect the public.

We urge Members of Congress to support increased spending caps while opposing flawed funding proposals that include ideological policy riders.

Sincerely,

National Groups

9to5, National Association of Working Women

Action on Smoking and Health

AFL-CIO

AFSCME

Alliance for Retired Americans

American Association for Justice

American Bird Conservancy

Americans for Financial Reform

Asbestos Disease Awareness Organization

Association of Reproductive Health Professionals

Autistic Self Advocacy Network

Bend the Arc Jewish Action

Black Women’s Health Imperative

Carmelite NGO

Catholics for Choice

Center for Biological Diversity

Center for Justice & Democracy

Center for Progressive Reform

Center for Science in the Public Interest

Clean Water Action

Coalition on Human Needs

Common Cause

Communications Workers of America (CWA)

Consumer Action

Corporate Accountability International

Daily Kos

Defenders of Wildlife

Democracy 21

Earthjustice

Earthworks

Economic Policy Institute Policy Center

Endangered Species Coalition

Environment America

Family Equality Council

Franciscan Action Network

Free Press Action Fund

Friends of the Earth

Government Accountability Project

GreenLatinos

Grounded Solutions Network

Hip Hop Caucus

Hispanic Federation

Homeowners Against Deficient Dwellings

ICAST (International Center for Appropriate and Sustainable Technology)

Institute for Agriculture and Trade Policy

Interfaith Power & Light

Jewish Women International

Just Foreign Policy

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

Main Street Alliance

NAACP

NARAL Pro-Choice America

National Abortion Federation

National Asian Pacific American Women’s Forum (NAPAWF)

National Association for College Admission Counseling

National Association of Consumer Advocates

National Association of Social Workers

National Black Justice Coalition

National Center for Lesbian Rights

National Center for Transgender Equality

National Coalition for LGBT Health

National Coalition for the Homeless

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

National Council for Occupational Safety and Health

National Council of Jewish Women

National Council of La Raza

National Education Association

National Employment Law Project

National Fair Housing Alliance

National Immigration Law Center

National Latina Institute for Reproductive Health

National Low Income Housing Coalition

National Partnership for Women & Families

National WIC Association

National Women’s Health Network

National Women’s Law Center

Natural Resources Defense Council

NETWORK Lobby for Catholic Social Justice

New America’s Open Technology Institute

New Progressive Alliance

Newtown Action Alliance

Oceana

PAI

People For the American Way

Physicians for Social Responsibility

PLACE

Planned Parenthood Federation of America

PolicyLink

Population Connection Action Fund

Population Institute

Power Shift Network

Progressive Congress Action Fund

Public Citizen

Public Knowledge

Rachel Carson Council

Raising Women’s Voices for the Health Care We Need

Safe Climate Campaign

Service Employees International Union

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

Sierra Club

SiX Action

Stand Up America

States United to Prevent Gun Violence

The Arc of the United States

The Bright Lines Project

The Center for Reproductive Rights

The Impact Fund

The Wilderness Society

U.S. PIRG

Union of Concerned Scientists

United Church of Christ, OC Inc.

United Steelworkers

Voces Verdes

Voices for Progress

Woodstock Institute

Workplace Fairness

Young Invincibles

State Groups

AIDS Alabama, Inc.

Alaska Wilderness League

Anti-Poverty Network of New Jersey

Arizona Coalition to End Homelessness

Arizona Housing Alliance

CASA of Oregon

Church Women United in New York State

Cornerstone Housing Inc., Florida

Earth Action, Inc., Florida

Empower Missouri

Equality California

Florida Alliance for Consumer Protection

Habitat for Humanity Virginia

Housing Action Illinois

Housing Community Development Network of New Jersey

Housing Works Rhode Island

Kentucky Equal Justice Center

Massachusetts Consumers Council

Monarch Housing Associates, New Jersey

Montana Environmental Information Center

New Jersey Association on Correction

New Jim Crow Movement, Florida and California

Ohio CDC Association

PeterCares House, Maryland

Public Justice Center, Maryland

The Interfaith Alliance of Colorado

Vermont Affordable Housing Coalition

Virginia Housing Alliance

Washington Low Income Housing Alliance

Local Groups

AFGE Council 238

Alfred E Smirh Resident Association, New York, NY

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

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

Clarksburg-Harrison Regional Housing Authority, Harrison County, WV

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

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

Harrington Investments, Inc., Napa, CA

Homeless Solutions, Inc., Morris County, NJ

Homestead Affordable Housing, Inc., Holton, KS

Housing Authority of the City of Columbia, MO

JCTOD Outreach, Inc. (dba) Johnson Park Center (JPC), Utica, NY

Lake County Crisis Center, Lake County, OR

Meals on Wheels of Lehigh County, PA

Plymouth Housing Group, Seattle, WA

ROSE Community Development, Portland, OR

Seattle Human Services Coalition, Seattle, WA

Sitka Community Land Trust, Sitka, AL

South Florida Community Development Coalition, Miami-Dade, FL

South Florida Interfaith Worker Justice

Southern Oregon Climate Action Now

Springfield Housing Authority, Springfield, IL

The Architects Collective, Los Angeles, CA

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

YWCA-GCR, Inc., New York, NY

Sargent Shriver National Center on Poverty Law, Chicago, IL

Public Comment 127: July 2017 - Nebraska PSC - Stop Keystone XL Pipeline

July 13, 2017

The Honorable Nichole Mulcahy

Nebraska Public Service Commission

1200 N Street, Suite 300,

Lincoln, NE 68508

Subj: Application of TransCanada Keystone Pipeline, L.P., Calgary, Alberta, seeking authority for Route Approval of the Keystone XL Pipeline Project Pursuant to the Major Oil Pipeline Siting Act.

The New Progressive Alliance at http://newprogs.org/ urges the Nebraska Public Service Commission to reject the Keystone XL Pipeline permit because of damage to Nebraska, the people of Nebraska, and the United States.

1. Damage to Nebraska

This pipeline would carry 830,000 barrels per day of tar sands oil- the world’s dirtiest oil. We are already seeing the effects of climate change in Nebraska and across the U.S., and this pipeline would only increase our problem. According to the University of Nebraska, the effects of climate change are going to cause increases in temperatures in Nebraska which will lead to more rain, worse flooding, more days over 100 degrees F, and decreased water flow in Nebraska's rivers and streams. This could have devastating impacts on Nebraska’s farms and economy. For the University of Nebraska study on the effects in Nebraska see http://snr.unl.edu/research/projects/climateimpacts/index.aspx

2. Damage to the People of Nebraska

Transportation of fossil fuels has repeatedly proved dangerous. Perhaps the biggest pass we are giving is for tar sands. For a list of pipeline accidents since 2000 see reference 3296 of the below list. This is particularly dangerous to Nebraska because this pipeline would pose the risk of oil spills along the entire route. This includes waterways and the Sandhills region. Even more critical is the Keystone XL crosses the Ogallalla Aquifer, which provides fresh water for Nebraska and seven other states. Tar Sands oil is not easy to clean up and Nebraska’s land and water would be harmed irreparably from a spill.

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

There are dozens of landowners along the proposed route and several Indigenous tribes who do not want this pipeline to cross their land.

We should consider the effects on Tribal lands, burial grounds, sacred sites, and archaeological sites. This would violate Indigenous rights.

The state would also have to invoke eminent domain to take over private land. Eminent domain should never be used for the private gain of a foreign oil company. Giving profits to a Canadian company while keeping the risks mostly in the United States is also not a good business plan.

The climate costs that farmers in Nebraska will pay with continued reliance on fossil fuels and tar sands oil include increased drought, more floods, and lower food production.

3. Damage to the United States

There are dangers to all waterways, but the biggest danger of unreliable pipes such as the Keystone XL is to the Ogallalla Aquifer. In addition to Nebraska, the Ogallalla Aquifer is critical to Wyoming, Kansas, Colorado, South Dakota, Oklahoma, New Mexico, and Texas. 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, 2626, 2629-2635, 2696, 2715, 2736, 2784-2787, 2838-2871, 2993, 2996, 2997, 3032, 3050, 3051, 3133, 3135-3138, 3158, 3172, 3203, 3233-3235, 3268, 3269, 3314, 3322-3340 of this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

NASA scientist James Hansen has said that approving this pipeline and further allowing the tar sands to develop would be “game over for the planet”. See https://thinkprogress.org/james-hansen-slams-keystone-xl-canada-u-s-pipeline-exploitation-of-tar-sands-would-make-it-implausib-bce6d044bb93

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

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. Continuing to build fossil fuel infrastructure such as the Keystone XL Pipeline threatens the economic future of our country.

See references 146, 725, 762, 771 - 775, 809 - 812, 832, 875, 900 - 904, 1013, 1037 - 1039, 1128, 1157, 1158, 1201, 1313 - 1325, 1479, 1480, 1530, 1533-1551, 1585, 1631, 1666, 1683-1684, 1725-1727, 1752, 1772-1778, 1788, 1813-1824, 1833-1834, 1836-1837, 1906-1907, 1961, 1966-1968, 2053, 2104-2121, 2140, 2180, 2222, 2227-2234, 2248, 2309,2329, 2335, 2336, 2389-2392, 2394, 2395, 2399-2412, 2420, 2425, 2460, 2487, 2506-2512, 2526-2529, 2551-2554, 2598, 2600, 2642-2653, 2679, 2688, 2695, 2717-2719, 2739-2753, 2762, 2901-2905, 2939, 2944, 2964, 3001, 3030-3051, 3087, 3088, 3143, 3145, 3152, 3153, 3159, 3161, 3176, 3180-3208, 3316, 3352-3355 of this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

We do not need to expand fossil fuel infrastructure with projects such as the Keystone XL Pipeline. There is no scientific barrier that restricts 100% use of renewable energy. There is nothing preventing greatly expanding the use of renewable energy. This is not theory, it has been accomplished in other countries. As renewable energy provides a bigger portion of the energy pie, costs go down. With fossil fuels, costs go up. We know this because it has been demonstrated repeatedly in countries which are wisely encouraging renewable energy and thus becoming more competitive than the United States. It is estimated that the world will spend an extra $8 trillion over the next 25 years in a wide variety of fossil fuel subsidies to prolong the use of non-renewable resources, a cost that would be eliminated by transitioning instead to 100% renewable energy. Simply leveling the playing field would make renewable energy competitive right now.

See references 132, 137, 141, 200, 230, 284, 295, 299, 300, 332, 337, 353, 461, 468, 496, 506, 514, 534, 546, 547, 551, 552, 557, 579, 580, 591, 599, 631 - 633, 642 - 648, 728, 743, 744, 797 - 799, 827, 828, 864 - 874, 925, 983, 1006, 1037, 1094, 1110, 1111 - 1119, 1197, 1201, 1223-1237, 1454-1471, 1534, 1651-1663, 1703-1706, 1738, 1835-1849, 1958-1959, 2019-2036, 2090, 2122, 2176, 2180, 2194-2204, 2206, 2253-2283, 2306, 2421, 2429, 2431, 2433, 2514-2523, 2595-2625, 2885-2970, 3001, 3143, 3178, 3272, 3361-3375 of this article: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Conclusion

This pipeline is bad for the climate, poses risks to our water and land, infringes on indigenous rights, and is not wanted by landowners in Nebraska. Please consider the climate and economic impacts of this pipeline when evaluating whether it's in the public interest of Nebraskans. Please show your leadership by stopping this harmful project.

Public Comment 128: July 2017 - Governor Jay Inslee should not approve Methanol Refinery

July 14, 2017

Governor Jay Inslee

Office of the Governor

PO Box 40002

Olympia, WA 98504-0002

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

I. Increased Pollution

Documentation for the below comes from the following sources.

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

II. Higher Utility Costs for Electricity and Natural Gas

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

Conclusion:

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

Public Comment 129: July 2017 - 50 Secretaries of State Should Oppose the Pence-Kobach Request

In July 2017 the New Progressive Alliance joined with the Leadership Conference on Civil and Human Rights - a diverse coalition of more than 200 national organizations committed to protecting civil rights - to oppose the Pence-Kobach data request by President Trump. The reasons are the potential for voter suppression and privacy concerns. The Public Comment made to the 50 U.S. Secretaries of State.

July, 2017

To 50 U.S. Secretaries of State:

On behalf of The Leadership Conference on Civil and Human Rights (“The Leadership Conference”), a diverse coalition of more than 200 national organizations committed to promoting and protecting the civil and human rights of all persons in the United States, we write to express our profound outrage and opposition to the data request by President Trump’s advisory commission (the “commission”). The Leadership Conference strongly believes that the commission’s request is an unprecedented overreach by the Trump administration and a brazen assault on the founding principles of our democracy. We have three overarching concerns. First, we are concerned that this commission is laying the groundwork for potential voter suppression by the wrongful removal of eligible voters, including Black, Hispanic, elderly, and student voters, from the rolls through the problematic process known as Crosscheck. Second, the creation of a national database of voters’ detailed information raises serious privacy concerns. And finally, at a time when the focus should be addressing the possibility of Russian interference including cyberattacks, the creation of a national database raises significant security concerns. We applaud the principled actions that many Secretaries of State have taken to reject the commission’s request for sensitive information about voters in your state, and we urge the rest of you to carefully consider any future responses to the commission.

The right to vote is our most sacred right. It is the right that protects all other rights and ensures that our elected leaders are accountable to the citizens they represent. Our country has made great strides to increase access to the ballot throughout its history, and as Secretary of State, you play a fundamental role in the free and fair administration of our electoral process.

As reported, Vice President Pence and Kansas Secretary of State Kobach sent you a letter last week requesting that you provide sensitive voter roll data, including the names, addresses, dates of birth, political party affiliation, past voter history, and even partial social security numbers of registered voters in your state. This letter is merely a request and given the fact there are no guarantees about how this data would be used or even secured, no one should feel compelled to cooperate. We were heartened that this request rightly drew swift and bipartisan condemnation across the country in large part because of serious questions about the legality of releasing this personal information. Member organizations of The Leadership Conference, and others, have filed multiple legal challenges to this request, alleging possible violations of numerous federal laws, and constitutional violations. Depending on how states respond to the commission’s request, additional legal challenges could be pursued under state laws as well.

Although disgraceful, the commission’s actions are unfortunately not surprising given the individuals leading the effort and their longstanding pursuits of voter suppression in the name of phantom voter fraud. Vice President Pence has a history of supporting voter suppression tactics, including undermining voter registration drives and pushing extreme voter ID laws. Secretary Kobach also has a long record of discriminatory and regressive actions on voting rights. His unrepentant attempts to suppress voting has led to thousands of voters being wrongly removed

from the rolls and barred from exercising their democratic right. And just last week, President Trump appointed Hans von Spakovsky to the commission. Von Spakovsky’s troubling reputation for voter suppression led not only to a public rebuke from career Justice Department attorneys but also to the U.S. Senate refusing to confirm his nomination to the Federal Election Commission.

Many Secretaries of State have rightly characterized the commission’s data request as “disingenuous,” “repugnant,” a “waste of taxpayer money,” and “a tool to commit large-scale voter suppression.” As you prepare to join your fellow Secretaries of State later this week at the National Association of Secretaries of State summer conference, we respectfully request that you join your colleagues in expressing collective opposition to the commission and its data request. At a time when barely half of eligible voters exercise the franchise, we should instead be taking every possible step to remove barriers to voting in America.

Our democracy is stronger when more, not fewer, citizens are involved in the electoral process. If the right to vote is denied, we will fail our democracy and it cannot survive. Given your role as Secretary of State, it is your mission and responsibility to ensure access to the ballot by upholding the guarantees of our laws and Constitution. All Secretaries of State should stand united in protecting the voting rights of our nation’s citizens and rejecting the commission’s outrageous request.

Public Comment 130: July 2017 - Congress - Stop FERC Abuse of Authority on Pipelines

The New Progressive Alliance in addition to other organizations urged selected members of Congress to “Stop FERC from Misusing Authority on Pipelines” with the below letter.

Delaware Riverkeeper Network ~ Keep Southeast Nashville Healthy PTA- Green Local School District ~ Green Soccer Association Green Meadows Home Owners Association Green Lacrosse Club ~ Green Youth Football Green Little League/Softball Federation ~ Gas Free Seneca Seneca Lake Guardian, A Waterkeeper Affiliate ~ Toxics Action Center FCCPR, Franklin Co Continuing the Political Revolution Prince William Soundkeeper ~ South Coast Neighbors United Earth Action, Inc. FaCT-Faith Communities Together for a Sustainable Future CARCS (Citizens Against the Rehoboth Compressor Station) We Are Cove Point Aquashicola/Pohopoco Watershed Conservancy Stop the Algonquin Pipeline Expansion (SAPE) ~ Greening Greenfield WWALS Watershed Coalition, Inc. Concerned Citizens for a Safe Environment (CCSE) Greenbelt Climate Action Network Grassroots Environmental Education No Sharon Gas Pipeline/Clean Energy Now Breathe Easy Susquehanna County ~ Free Nelson Living Rivers & Colorado Riverkeeper ~ Conestoga Community Group Citizens Coalition for a Safe Community Northjersey Pipeline Walkers ~ Advocates for Cherry Valley River Healers ~ Schuylkill Pipeline Awareness The Wei ~ People Over Pipelines ~ Pipeline Education Group Waccamaw Riverkeeper ~ Winyah Rivers Foundation Durham CCAP ~ PEACE Youth ~ Coalition to Reroute Nexus (CoRN) Food & Water Watch ~ ECHO Action NH & NH Pipeline Resistance Peacemakers of Schoharie County ~ Resist the Pipeline Friends of Nelson ~ Green America ~ Berks Gas Truth Rockfish Valley Investments, LLC ~ Environment New Jersey Preserve Newport Historic Properties ~ Albany Bicycle Coalition Home Energy Efficiency Team ~ SAYMA Earthcare Action Network Sullivan Alliance for Sustainable Development Big Bend Conservation Alliance The Campaign for Clean Water Exceptional Value Team Summers County Residents Against the Pipeline (SCRAP)

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The Delaware Township Citizens Against the Pipeline (DTCAP) Steeleworks ~ OVEC-Ohio Valley Environmental Coalition ~ Stop NED People Demanding Action PAUSE - People of Albany United for Safe Energy Fair Compensation for Underground Natural Gas Storage No Fracked Gas in Mass ~ Preserve Roanoke/Bent Mountain Protect Our Water, Heritage Rights ~ Tinker Tree Play/Care Carroll Engineering Corporation ~ Friends of Buckingham Our Santa Fe River, Inc. ~ Concerned Citizens of Otego NY Arden Enterprises ~ Preserve Giles County Bucks Environmental Action ~ Bucks Sierra Club Oregon Citizens Against the Pipelines ~ Milwaukee Riverkeeper Preserve Newport Historic Properties ~ Peoples Climate Movement NY Beyond Extreme Energy ~ Lange Tree Farm ~ New Progressive Alliance Responsible Drilling Alliance ~ Interfaith Power & Light 350 Cape Cod Hopewell Township NJ Citizens Against the PennEast Pipeline City of Lambertville NJ Citizens Against the PennEast Pipeline Delaware Township NJ Citizens Against the PennEast Pipeline Kingwood Township NJ Citizens Against the PennEast Pipeline Alexandria Township NJ Citizens Against the PennEast Pipeline Holland Township NJ Citizens Against the Penn East Pipeline Sustainable Medina County ~ Clean Water Action Oregon Shores Conservation Coalition 350 New Jersey-Rockland County ~ HALT- PennEast Advocates for Springfield, NY Stop the West Roxbury Lateral Pipeline (SWRL) Virginia River Healers ~ Greenbrier River Watershed Association

July 20, 2017

To: Numerous Congressmen

You are among a handful of members of Congress that have expressed an understanding of the harms that are being inflicted on communities across the nation as a result of the way the Federal

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Energy Regulatory Commission (“FERC” or “Commission”) misuses its authority over natural gas pipelines, LNG exports and related infrastructure. In addition, you seem to recognize that meaningful reforms are needed and want to be part of identifying, advancing and securing those reforms. We are reaching out to gauge your interest in working with us to put in place these reforms.

It is with increasing frequency and growing magnitude, that the Federal Energy Regulatory Commission is abusing its authority and the law in alarming ways. After three decades of FERC’s unaccountable and irresponsible approach to energy development, the trust of the American people has been strained beyond the breaking point. And, to be honest, our trust that Congress wants to fix the problem is withering. We are hopeful that you will prove us wrong and become a champion for the kind of meaningful reform that is truly needed.

We are urging you to lead a call for Congressional hearings into the abuses of power and law being inflicted by FERC, infringing on property rights, states’ right, peoples’ rights, and environmental protection. We have assembled a dossier to document FERC’s abuses and brought representatives of beleaguered communities from across the nation to share their experiences in a Peoples Hearing held in Washington DC. Our findings demonstrate that Congressional hearings and investigation are needed.

We are urging you to be a lead voice opposing legislative rollbacks when it comes to review and/or approval of natural gas infrastructure.

And we are asking you to champion meaningful reforms that will prevent ongoing and future abuses of power and law by FERC. As it currently stands, the language of the Natural Gas Act is being misused by FERC to deny people of their legal and constitutional rights, to strip the legal authority of states, to undermine the authority of other federal agencies, to ignore the mandates of the Clean Water Act and the National Environmental Policy Act, to trample private property rights, to take from communities the protection of public parks, forests and conserved lands that they have invested heavily in protecting, to take jobs and destroy small businesses, to inflict on our communities health, safety and environmental harms, all for the benefit of a single industry seeking to advance its own corporate profits and business edge over its competitors.

With this letter, we are identifying for you the meaningful reforms that are needed. Recent pronouncements of soft ball legislative proposals will not remedy the abuses communities are suffering. Legislative proposals that are only focused on the public participation process of FERC and not the taking of the judicial, legal, state, property, or environmental rights we have been highlighting are simply not good enough. Soft ball legislative reforms that don’t go to the root of the problems we have been alerting you to will not receive our praise or support. A legislative proposal that is not a true legislative fix is an anathema to us.

These are among the reforms we need:

First and foremost, we need to remove the authority for review and approval of pipelines and other natural gas infrastructure from FERC. With this remedy many of the fixes listed below become no longer necessary. FERC has demonstrated its bias toward the natural gas infrastructure industry. The abuses and problems are so ingrained reform will be difficult if possible. The most effective approach would be to remove the power of pipeline and LNG approval from FERC and place it in the hands of another agency, one that has clean energy, community and environmental

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protection goals as its priority mandate, and will do the cumulative and holistic review and decisionmaking, including prioritizing the clean energy options that are needed to protect communities, protect the environment, and minimize climate changing emissions.

If FERC retains authority over natural gas infrastructure including pipelines and LNG exports, then all of the below fixes are necessary because of the highly biased and abusive way FERC implements current laws including the Natural Gas Act, National Environmental Policy Act, Clean Water Act and others.

Remove the Power of Eminent Domain. The ability of FERC to give the power of eminent domain to private pipeline companies must be removed. There is no shortage of power in this nation now or in the foreseeable future. In addition, we have viable and growing clean energy pathways to follow, pipeline projects are routinely advanced to support corporate interests and goals rather than public benefit or need, and an increasing number of pipeline infrastructure projects are to serve the export of gas to overseas nations. Given all of these facts, the Commission has no business allowing a private company to use eminent domain for a self-serving project at the expense of American property rights. If a project is not good enough to curry the favor of landowners then it should not be powerful enough to take their property rights.

Remove language that results in preemption of state or local laws or authority. A fundamental underpinning of our nation is respect for the rights of states to govern within their boundaries and to ensure the protection of the health, safety and welfare of their people. States’ rights are carefully honored throughout our nation’s laws and history. Stripping states and municipalities of their legal authority, particularly given the tremendous health, safety and economic harms pipelines inflict on communities is not justified. In addition, there is no reason that natural gas pipeline projects should not be subject to the same laws that all other industries are subject to, and that other arms of the energy industry must comply with. To exempt interstate natural gas infrastructure from the state and local laws that apply to every other industry gives them an inappropriate competitive advantage. This respect for the rights of states to take leadership in the protection of their citizens is carefully recognized and provided for in the area of environmental protection, particularly the implementation of the Clean Water Act.

Prohibit FERC from approving a project and/or allowing it to proceed with any element of construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted. Currently, FERC approves pipelines and allows them to proceed through phases of construction and eminent domain regardless of whether or not they have received all necessary reviews and approvals from other agencies including states. Consequently, pipelines have proceeded with the power of eminent domain and significant construction that inflicts irreparable harm on economic and environmental interests. The law needs to make clear that FERC cannot approve a project and allow it to proceed with any element of construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted. Other approaches for addressing the concern:  Clarify the law to make clear that State Section 401 Clean Water Act approvals have primacy in the FERC review and approval process. Section 401 of the Clean Water Act specifically reads: “no [federal] license or permit shall be granted until the certification required by this section has been granted or waived.” 33 U.S.C. § 1341(a)(1). Requiring Section 401 certification from the states prior to federal action ensures that states’ rights are honored, that state standards are met, and that public and private resources are not

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unnecessarily lost. It also ensures that the federal government is held accountable to the same standards as private entities, an important point of equity. Despite this clear, black letter law and the important policy it represents, FERC routinely issues Certificates of Public Convenience and Necessity prior to state decisionmaking on 401 Certifications for FERC pipeline and infrastructure projects. The result is to undermine state authority, and in some instances, has resulted in the taking of property rights, damage of business, jobs and the environment for construction of a pipeline that a state ultimate rejects. 401 primacy prevents such irreversibly harmful outcome.  Ensure Full Applicability of all Federal Laws. Currently, FERC approves pipelines and allows them to proceed through phases of construction and eminent domain regardless of whether or not they have received all necessary reviews and approvals from other agencies, such as wetland permits from the US Army Corps or completed endangered species review from the U.S. Fish & Wildlife Service. The law needs to make clear that FERC cannot approve a project and allow it to proceed with any element of construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted. Prohibit projects from advancing to construction without having all permits/approvals/certifications necessary from any and all agencies that have authority.

Require a genuine demonstration of need for a project that is objectively verified by experts. To this end the following scenarios need to be addressed:  Pipeline companies routinely assert “need” for a project because it will lower costs, improve profits or enhance the ability to compete with others in the gas and/or pipeline industry. These assertions demonstrate corporate goals and desires. None of these scenarios demonstrate public needs that warrant the economic, environmental or property rights harms inflicted by a project and so should be explicitly prohibited.  Pipeline companies routinely assert need by presenting contracts for pipeline capacity that are from related corporate entities, as such they use their own connected operations to put forth an unverified claim of genuine need. Pipeline companies should be prohibited from engaging in self-dealing in need demonstration – no contractual indealing should be allowed for manufacturing need, i.e. company cannot claim it needs a new pipeline for a gas source that is itself or some subsidiary self or related company that is, in fact, just another form of itself.  Pipeline companies routinely assert need so the company can tap into an alternative source of gas, regardless that there is no threat to the source for their business use, it is simply a preferred business option. Preferred business operations of this kind should not be allowed for asserting need.  Pipeline company claims that end of pipeline communities “need” their gas are often debunked by experts in the field who are quickly ignored by FERC in their reviews. Expert reports challenging company claims of need should be given primacy in the review process, rather than being disregarded if in conflict with pipeline claims.  “Need” considerations uniformly focus on the end goal of securing gas, rather than focusing on the end goal of securing energy. This means that clean energy or other viable alternatives are ignored in the FERC review and approval process. Consideration of need must focus on “energy” needs of the end users and require full and fair consideration of whether clean energy alternatives could fulfill the need for energy identified. Proof of need should include a mandated demonstration that renewable strategy cannot be used to fulfill energy goal being asserted

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 Demonstration of need must be based on more than assertion that a pipeline or export facility has customers, it needs to demonstrate a genuine end-use need that cannot be fulfilled by renewable options; Revisions of law are needed to address all of these scenarios as none of them demonstrate public needs that warrant the economic, environmental or property rights harms inflicted by a project and so should be explicitly prohibited.

The use of Tolling Orders should be prohibited. Tolling orders are routinely used to place people in legal limbo, unable to challenge a FERC approval even when the agency has allowed the company to use the power of eminent domain to take property rights and is approving construction and operation of project sections. If tolling orders are not prohibited then other mechanisms for addressing the problem include:  Prohibit projects from advancing in any way, shape or form, including eminent domain and/or construction, if there is an outstanding rehearing request/tolling order;  Mandate FERC response to rehearing requests within 30 days and prohibit projects from advancing in any way, shape or form during that period.

Instill Mandatory penalties and stop work orders for violations during construction, operation, and maintenance that are commensurate with the level of harm inflicted. Violations by pipeline companies during construction, operation and maintenance are routine, with hundreds documented for a single project. Also documented is FERC’s failure to ever (never) issue a civil penalty or stop work order to address the violations. As a result, it is more cost beneficial for a pipeline company to ignore environmental protection laws than to comply with them. In addition, violations are reviewed by FERC in terms of company response, rather than magnitude of the severity of the incident. The law mandating penalties needs the level of penalty assessed to be based upon the severity of the environmental and community harm inflicted.

There should be a ban put in place on Liquefied Natural Gas Exports. If the goal of drilling and fracking is truly energy independence, that end goal is not served through exports. In addition, the level of community harm and sacrifice is too great for an energy supply that is then shipped overseas to support foreign nations, industries and users.

Provisions need to be placed in the law that ensure an appropriate level of accountability and oversight of the agency to both Congress and the people of the United States. Provisions should include:  Prohibit FERC’s use of third party consultants with actual or potential bias.  Change structure of FERC commissioners – add a public representative Commissioner position.  Mandate removal of Commissioners that are demonstrated to engage in any degree of conflict in their decisionmaking.  Prohibit Commissioners or other agency staff from working for the pipeline, oil or gas industry, or any of their legal, messaging, lobbying or other related representatives, for a period of 5 years prior to, and a period of 5 years post, their employment with the agency.  Require a public advocate be appointed for each pipeline that is representative of environmental resources, property owners, public land interests that will be impacted by the project.  Put in place stronger requirements for information disclosure and timelines by which info has to be released.

Page 7 of 10

 Mandate Commissioners provide public hearing opportunities before them, as a body, before final decisionmaking;  Mandate FERC use latest science in analysis and decisionmaking;  Prohibit waivers, variations and/or changes to a project after its application been submitted for review by FERC; if changes are proposed mandate the new proposal be subject to the full agency and public review and approval process.  Add an environmental justice standard, including community involvement, for pipeline projects that are within a 10 mile proximity of an environmental justice community.  Prohibit self interest in FERC staff and Commissioners:  Prohibit investments in companies regulating,  Prohibit Commissioners or staff from being involved in decisions that benefit directly or indirectly the staff, Commissioner, their families or professional colleagues.  Mandate public hearings during NEPA process that are within 20 miles of any community that will be impacted by a proposed project;  Mandate minimum 120 days to comment on any FERC NEPA documents or proposed project approvals.

Mandate full and fair application of NEPA and prevent any rollback of this important and iconic information and review legislation. Among the clarifying and confirming provisions required:  Clarity on prohibition against segmentation and provide an expansive definition of that term;  Express obligation to ensure cumulative impact reviews and give that term an expansive definition;  Ensure review includes consideration of the fracking/drilling/shale gas extraction that a project induces and/or supports and the end uses of the gas whether it be a new power plant, export, industrial, residential;  Ensure consideration of alternatives not limited to alternate routes but includes alternative ways to create the energy that is asserted as needed;  Mandate robust health and safety impact analyses and prohibit projects that will adversely impact health and/or safety of a community/region.  Heightened scrutiny of affiliate relationships, wherein regulated utilities are the pipeline customers while their affiliates are investing as pipeline developers. Here's recent Congressional testimony on this particular issue: tinyurl.com/Peress-6-14-16

Require leadership from FERC for renewables:  change FERC’s mission to include priority obligation to advance renewables;  seek a way to mandate/incorporate approval of the renewable energy option if it can be demonstrated to fulfill the claimed energy need being advanced by the pipeline company.  mandate FERC carry out a robust climate change analysis and if approval of a project demonstrates it will contribute climate change emissions and cannot demonstrate (when considering cradle to grave impacts of the source and/or end use of the gas) it will improve climate change conditions then FERC is mandated to reject the project.

For thirty years FERC has served as a rubber stamp agency for pipeline and LNG infrastructure. It has misused its authority and the law at every turn in order to advance these projects. Meaningful and substantive reforms are needed. Ideally Congress will hold Congressional hearings to expose the abuses and help identify and shape the reforms needed. But given that legislators are increasingly

Page 8 of 10

putting forth window dressing fixes rather than the strong substantive reforms needed, we provide this robust list of fixes that need to be pursued firmly, quickly and without compromise.

Respectfully,

Maya K. van Rossum, the Delaware Riverkeeper, Delaware Riverkeeper Network Chris Tuley, President, Keep Southeast Nashville Healthy Tammy Daly, Executive Member, PTA- Green Local School District Tammy Daly, Recreational Director, Green Soccer Association Tammy Daly, President, Green Meadows Home Owners Association Jeremy Brueck, President, Green Lacrosse Club Greg Mazzagatti, President, Green Youth Football Joe Bologa, Treasurer, Green Little League/Softball Federation Yvonne Taylor, Vice President, Gas Free Seneca Joseph Campbell, President, Seneca Lake Guardian, A Waterkeeper Affiliate Claire B.W. Miller, Lead Community Organizer, Toxics Action Center Robert A Armstrong, Jr, FCCPR, Franklin Co Continuing the Political Revolution Kate McLaughlin, President, Prince William Soundkeeper Wendy M. Graca, Co-Founder & Secretary, South Coast Neighbors United Mary Gutierrez, Executive Director, Earth Action, Inc. Ron Prosek, President, Board of Directors, FaCT-Faith Communities Together for a Sustainable Future Tracy Manzella, Executive Director, CARCS (Citizens Against the Rehoboth Compressor Station) Donny Williams, Organizer, We Are Cove Point Jim Vogt, President, Aquashicola/Pohopoco Watershed Conservancy Amy Rosmarin, Co-Founder, Stop the Algonquin Pipeline Expansion (SAPE) Nancy Hazard , Member, Greening Greenfield John S. Quarterman, Suwannee Riverkeeper, WWALS Watershed Coalition, Inc. Sharon Felton , Communications, Concerned Citizens for a Safe Environment (CCSE) Lore Rosenthal, Program Coordinator, Greenbelt Climate Action Network Patricia Wood, Executive Director, Grassroots Environmental Education Bri McAlevey, President, No Sharon Gas Pipeline/Clean Energy Now Rebecca Roter, Chairperson, Breathe Easy Susquehanna County Marion E. Kanour, Founder, Free Nelson John Weisheit , Conservation Director, Living Rivers & Colorado Riverkeeper Nancy Jeffries , Board Member, Conestoga Community Group Paul Ferrazzi, Executive Director, Citizens Coalition for a Safe Community Diane L Wexler, Founder, Northjersey Pipeline Walkers Lynn Ellen Marsh, President, Advocates for Cherry Valley Tom Burkett, Director, River Healers Leah Zerbe, Co-Founder, Schuylkill Pipeline Awareness Kimi Wei, CEO, The Wei Agnes Marsala, President, People Over Pipelines Eleanor Amidon, Networker, Pipeline Education Group Cara Schildtknecht, Riverkeeper, Waccamaw Riverkeeper April O'Leary, Program Officer, Winyah Rivers Foundation

Page 9 of 10

Ann Marshall, Organizer, Durham CCAP Tina Venini, Co-Founder, PEACE Youth Paul L Gierosky, Coalition to Reroute Nexus (CoRN) Mark Schlosberg, Co-Organizing Director, Food & Water Watch Stephanie Scherr, Director, ECHO Action NH & NH Pipeline Resistance Wayne R Stinson, Action Committee Leader, Peacemakers of Schoharie County James O. Michel, Co-Founder, Resist the Pipeline Ernie Reed, President, Friends of Nelson Todd Larsen, Executive Co-Director, Green America Karen Feridun, Founder, Berks Gas Truth Richard Averitt, Manager/Member, Rockfish Valley Investments, LLC Doug O'Malley, Director, Environment New Jersey Clarence B. Givens, Chairman, Preserve Newport Historic Properties Lorenz M. Worden, President, Albany Bicycle Coalition Audrey Schulman, President, Home Energy Efficiency Team Deni Elliott, Representative, SAYMA Earthcare Action Network Linda Reik, Board Member, Sullivan Alliance for Sustainable Development Joselyn Fenstermacher, Board Vice President, Big Bend Conservation Alliance Faith Zerbe, Chair, The Campaign for Clean Water Exceptional Value Team Susan Bouldin, Representative to POWHR (Protect Our Water Heritage Rights), Summers County Residents Against the Pipeline (SCRAP) Debbie Bradley, The Delaware Township Citizens Against the Pipeline (DTCAP) Sara Steele, Steeleworks Vivian Stockman, Vice Director, OVEC-Ohio Valley Environmental Coalition Cathy Kristofferson, Co-Founder, Stop NED Andrea Miller, Executive Director, People Demanding Action Diana Wright, Facilitator, PAUSE - People of Albany United for Safe Energy Claude P. Bowie, Jr., Fair Compensation for Underground Natural Gas Storage Rosemary Wessel, Founder/Program Director, No Fracked Gas in Mass Roberta M. Bondurant, Preserve Roanoke/Bent Mountain Roberta M. Bondurant, Protect Our Water, Heritage Rights Natalie Cronin, Chief Play Artist, Tinker Tree Play/Care Howard C. Lopshire, PLS., PP., Carroll Engineering Corporation Lakshmi Fjord, Friends of Buckingham Michael J. Roth, Treasurer, Our Santa Fe River, Inc. Stuart Anderson, Community Organizer, Concerned Citizens of Otego NY Judith Kay McClintock, Arden Enterprises Richard Shingles, Coordinator, Preserve Giles County Sharon Furlong, Bucks Environmental Action Sharon Furlong, Bucks Sierra Club Martha Neuringer, Oregon Citizens Against the Pipelines Cheryl Nenn, Riverkeeper, Milwaukee Riverkeeper Frances Dowdy Collins and Paul B. Collins, Preserve Newport Historic Properties Leslie Cagan, Coordinator, Peoples Climate Movement NY Ted Glick, Beyond Extreme Energy

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Walt and Danuta Lange, Lange Tree Farm Ed Griffith, Liason, New Progressive Alliance Robert Cross, Responsible Drilling Alliance Joelle Novey, Director, Interfaith Power & Light Lisa Coedy, Co-Leader, 350 Cape Cod Patty Cronheim, Hopewell Township NJ Citizens Against the PennEast Pipeline Judy Detrano, City of Lambertville NJ Citizens Against the PennEast Pipeline Marty Wissig, Delaware Township NJ Citizens Against the PennEast Pipeline Maureen Syrnick and Debra Kratzer, Kingwood Township NJ Citizens Against the PennEast Pipeline Jacqueline Freedman, Alexandria Township NJ Citizens Against the PennEast Pipeline Lorraine Crown, Holland Township NJ Citizens Against the Penn East Pipeline Kathie Jones, Organizer, Sustainable Medina County David Pringle, NJ Campaign Director, Clean Water Action Phillip Johnson, Executive Director, Oregon Shores Conservation Coalition Jerome Wagner, President, 350 New Jersey-Rockland County Helen Davis Chaitman, Linda Christman, Vince DiBianca, Jacqueline Evans, Christiana Foglio, Michael Heffler, Ann Marshall, Maureen Syrnick & Rosalind Westlake, Board of Trustees, HALT- PennEast Tara Sumner, Vice President, Advocates for Springfield, NY Nancy Wilson, Member, Steering Committee, Stop the West Roxbury Lateral Pipeline (SWRL) Tom Burkett, Spokesperson, Virginia River Healers John J. Walkup III, President , Greenbrier River Watershed Association

Public Comment 131: July 2017 - Washington State Ecology - Stop Millennium

July 24, 2017

Department of Ecology

Washington State

PO Box 47600

Olympia, WA 98504-7600

The New Progressive Alliance at http://newprogs.org/ urge Ecology to deny the 401 certification of Millennium’s project. It is based on a bad business plan, harms the health of Washington residents, would impede traffic and emergency vehicles, and would certainly raise Greenhouse global warming gases.

This is a Bad Business Plan

Why is this important to the Department of Ecology? It is because a bad business plan means that when the business goes under we will be left with the pollution while China gets the profits.

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 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."

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. 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. 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.

Millennium will be Disastrous for Health

Approval of 401 certification would violate Washington State’s water quality standards, harm designated uses and drinking water, and contravene the state’s Antidegradation Policy. Consider the Columbia River and countless streams and rivers that would be harmed by Millennium’s coal trains.

The U.S. Fish and Wildlife Service opposes Millennium’s plans to pollute the Columbia with coal dust: “The [U.S. Fish and Wildlife] Service has significant concerns regarding the foreseeable impacts of the Millennium Longview Coal Terminal project. The Service believes that the current proposal would have adverse impacts to fish, wildlife, and tribal trust resources . . . . The Service believes that the SEPA co-leads [i.e., the Washington Department of Ecology and Cowlitz County] should recommend against approval of this proposed facility/project.” See http://www.millenniumbulkeiswa.gov/Comments/MBTL-SEPA-DEIS-0003458-100753.pdf

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.

Rail Traffic will slow Traffic and Emergency Vehicles

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.

Greenhouse Gas Emissions

Millennium would certainly result in more greenhouse gas and climate change. Coal 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

Millennium Bulk Terminals proposes to export 44 million metric tons of coal annually. It would be the biggest coal terminal in North America. 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.

Since its inception, Millennium Bulk Terminals’ proposal to build North America’s largest coal export terminal has drawn unprecedented opposition. As noted under Millennium will be Disastrous for Health, The U.S. Fish and Wildlife Service opposes Millennium’s plans. In addition over 250,000 public comments have flooded in opposing the project. Ecology has received unprecedented expert testimony from Tribes, state and federal agencies, impacted communities, and the people of the Pacific Northwest to deny Millennium’s proposal.

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 by fossil fuel companies. Cities and towns and states pick up the tab while companies keep the profits. Washington should not fall for this Millennium scam that will cause the state to lose jobs, money, and harm the environment.

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, 2901, 2904, 2979, 3029, 3090, 3145-3177, 3224, and 3349 of the article located here: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Public Comment 132: September 2017 - Seattle Disability Commission - end sub-minimum wage for disabled people

September 4, 2017

Seattle Office of Labor Standards
810 Third Ave., Suite 375
Seattle, WA 98104-1627
Attn: Karina Bull, OLS Policy Manager

[email protected]

The New Progressive Alliance at http://newprogs.org/ fully agrees with the Seattle Disability Commission which voted unanimously to recommend the city end the sub-minimum wage for disabled people. There is no evidence that lowering the minimum wage increases hiring of handicapped people. In addition, disabled people frequently need more money to survive.

Thank you for your consideration.

Public Comment 133: September 2017 - Congress Stop Idealogical Irrelevant Riders

(This comment is similar to the one we made in Public Comment 126 in July 2017.)

September 5, 2017

Dear Members of Congress,

We, the undersigned organizations, write to ask you to oppose any House FY 2018 appropriations bills or packages which include harmful policy riders.

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

Harmful policy riders are measures that the public opposes and would be unpopular to move 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 protect our campaign finance and election systems, to provide access to justice and fair housing, to protect civil rights, and to ensure continued access to vital health care services including reproductive health care.

Contentious poison pill riders are intended to advance the priorities of special interest donors, supporters and should not be included in funding bills. Highlighting just a small portion of the proposed egregious riders, the proposed house bills and associated proposed amendments to the appropriations package include:  Funding for a controversial wall on the Mexican border, money that should instead go to disaster efforts and to help rebuild damaged communities.  A provision to block ongoing and potentially life-saving research involving fetal tissue.  A policy blocking patients from accessing care at Planned Parenthood health centers.  A provision to prohibit the use of any funds in the bill from being used to “implement, administer, enforce, or further” provisions of the Affordable Care Act (ACA).  Denial of funding for the 2020 decennial census unless questions are included regarding a respondent’s U.S. citizenship and immigration status.  An amendment that stops the Mueller investigation after 180 days and limits the scope of the investigation.  A provision that seeks to restructure the Consumer Financial Protection Bureau (CFPB), which would hinder the Bureau’s mission to protect consumers’ financial interests, and a provision to prevent the CFPB from banning forced arbitration clauses in consumer contracts that currently allow corporations to rip off consumers with impunity.  An amendment that splits the 9th Circuit Court, which is one of the more progressive circuits in the country.  A provision that would prevent the U.S. Securities and Exchange Commission (SEC) from finalizing new rules to require public corporations to disclose their political spending to shareholders.  A provision that would allow for the withdrawal of the Clean Water Rule, which would protect the drinking water of 117 million people, without following the proper procedures required under the Administrative Procedure Act of 1946.  A policy that delays the Environmental Protection Agency's (EPA) latest health standards for ground-level ozone smog pollution for ten years, preventing Americans from even having the right to know if the air they breathe is unhealthy for ten years and severely delaying cleanup steps.  Amendments that would strip protections for animals currently under the Endangered Species Act, undermining the scientific basis of those decisions.  Elimination of funding for private enforcement of federal fair housing laws while private enforcement is the primary way that federal fair housing laws are enforced.  A provision that would prevent the Department of Housing and Urban Development (HUD) from implementing its Affirmatively Furthering Fair Housing (AFFH) rule, which helps states and communities better understand how to fulfill its federal fair housing obligations required by law. (At the time in which this letter was sent this amendment was withdrawn.)  An amendment that would halt the enforcement of the Department of Labor’s final fiduciary rule that would ensure financial advisors work in their clients’ best interests instead of lining their pockets.  A policy that would halt the implementation of the Occupations Safety and Health Administration’s (OSHA) final rule on silica, which causes renal disease, silicosis, lung cancer, and other terrible illnesses in workers exposed to the toxic dust.  A provision that would prohibit the Equal Employment Opportunity Commission (EEOC) from implementing a rule to collect pay data that could show pay discrimination in a variety of sectors and employers.  A rider to stop the Department of Education from enforcing the Gainful Employment rule, which would save students and tax payers millions of dollars in student loans.  A provision that would undermine protections for the collective bargaining rights of workers at tribalowned enterprises.  Various provisions that would prevent the National Labor Relations Board (NLRB) from enforcing basic labor law protections.  An amendment that would prohibit the Consumer Product Safety Commission from using funds to finalize their proposed rule from November 2016 to limit carbon monoxide emissions from portable generators.  A policy rider to block the Department of Justice from entering into agreements with corporate wrongdoers, such as environmental polluters, that require the corporate wrongdoer to make payments to third-party actors as part of a settlement agreement with the federal government.
We also urge Members of Congress to support increasing the spending caps to fund pivotal programs for the American people via the budget while opposing flawed funding proposals that include poison pill policy riders like those listed above and the many others proposed for inclusion.

Sincerely,

National Groups:

9to5

National Association of Working Women Action on Smoking and Health

AFL-CIO AFSCME

Alaska Wilderness League

Alliance for Retired Americans

American Association for Justice

American Bird Conservancy

Americans for Financial Reform

Asbestos Disease Awareness Organization

Association of Reproductive Health Professionals

Autistic Self Advocacy Network Bend the Arc

Jewish Action

Black Women's Health Imperative

Carmelite NGO

Catholics for Choice

Center for Biological Diversity

Center for Justice & Democracy

Center for Progressive Reform Center for Science in the Public Interest

Clean Water Action

Coalition on Human Needs

Common Cause

Communications Workers of America (CWA)

Consumer Action

Corporate Accountability International

Daily Kos

Defenders of Wildlife

Democracy 21

Earthjustice

Earthworks

Economic Policy Institute

Policy Center

Endangered Species Coalition

Environment America

Family Equality Council

Free Press Action Fund

Friends of the Earth

Government Accountability Project

GreenLatinos

Grounded Solutions

Network Hip Hop Caucus

Hispanic Federation

Homeowners Against Deficient Dwellings

ICAST (International Center for Appropriate and Sustainable Technology)

Institute for Agriculture and Trade Policy

Interfaith Power & Light

Jewish Women International

Just Foreign Policy

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

Main Street Alliance NAACP

NARAL Pro-Choice America

National Abortion Federation

National Asian Pacific American Women’s Forum (NAPAWF)

National Association for College Admission Counseling

National Association of Consumer Advocates

National Association of Social Workers

National Black Justice Coalition

National Center for Lesbian Rights

National Center for Transgender Equality

National Coalition for LGBT Health

National Coalition for the Homeless

National Council for Occupational Safety and Health

National Council of Jewish Women

National Education Association

National Employment Law Project

National Fair Housing Alliance

National Immigration Law Center

National Latina Institute for Reproductive Health

National Low Income Housing Coalition

National Partnership for Women & Families

National WIC Association

National Women's Health Network

National Women's Law Center

Natural Resources Defense Council

NETWORK Lobby for Catholic Social Justice

New America's Open Technology Institute

New Progressive Alliance

Newtown Action Alliance PAI

People For the American Way

Physicians for Social Responsibility

PLACE Planned Parenthood Federation of America

PolicyLink

Population Connection Action Fund

Population Institute

Power Shift

Network Progressive Congress Action Fund

Public Citizen

Public Knowledge

Rachel Carson Council

Raising Women's Voices for the Health Care We Need

Safe Climate

Campaign Service Employees International Union

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

Sierra Club

SiX Action

Stand Up America

States United to Prevent Gun Violence

The Arc of the United States

The Bright Lines Project

The Center for Reproductive Rights

The Impact Fund

The Wilderness Society

U.S. PIRG

UnidosUS (formerly National Council of La Raza)

Union of Concerned Scientists

United Church of Christ,

OC Inc.

United Steelworkers

Voces Verdes

Voices for Progress

Woodstock Institute

Workplace Fairness

Young Invincibles

State Groups AIDS Alabama, Inc.

Anti-Poverty Network of New Jersey

Arizona Coalition to End Homelessness

Arizona Housing Alliance

CASA of Oregon

Church Women United in New York State

Earth Action, Inc.,

Florida Empower

Missouri Equality

California Florida Alliance for Consumer Protection

Habitat for Humanity Virginia

Housing Action Illinois

Housing Community Development Network of New Jersey

Housing Works Rhode Island

Kentucky Equal Justice Center

Massachusetts Consumers Council

Monarch Housing Associates,

New Jersey Montana Environmental Information Center

New Jersey Association on Correction

New Jim Crow Movement,

Florida and California Ohio CDC Association

PeterCares House, Maryland Public Justice Center, Maryland

The Interfaith Alliance of Colorado

Vermont Affordable Housing Coalition

Virginia Housing Alliance

Washington Low Income Housing Alliance

Local Groups:

AFGE Council 238 Alfred E Smirh Resident Association, New York, NY Antioch Urban Ministries, Inc. DBA Matthew's Place, Atlanta, GA Central New York Citizens in Action, Inc., Utica, NY Clarksburg-Harrison Regional Housing Authority, Harrison County, WV Family Emergency Shelter Coalition (FESCO), Hayward, Alameda County, CA Greater Kansas City Coalition to End Homelessness, Kansas City, MO Harrington Investments, Inc., Napa, CA Homeless Solutions, Inc., Morris County, NJ Homestead Affordable Housing, Inc., Holton, KS Housing Authority of the City of Columbia, MO Lake County Crisis Center, Lake County, OR Meals on Wheels of Lehigh County, PA Plymouth Housing Group, Seattle, WA ROSE Community Development, Portland, OR Seattle Human Services Coalition, Seattle, WA Sitka Community Land Trust, Sitka, AK South Florida Community Development Coalition, Miami-Dade, FL South Florida Interfaith Worker Justice Southern Oregon Climate Action Now Springfield Housing Authority, Springfield, IL The Architects Collective, Los Angeles, CA Toledo Area Jobs with Justice & Interfaith Worker Justice Coalition, Toledo, OH YWCA-GCR, Inc., New York, NY Sargent Shriver National Center on Poverty Law, Chicago, IL

Public Comment 134: September 2017 - DRBC Stop Penn East Pipeline

The New Progressive Alliance joined with other organizations in the below letter.

September 13, 2017

Steven J. Tambini, Executive Director
Delaware River Basin Commission
25 State Policy Drive
West Trenton, NJ 08628-0360

Re: PennEast Pipeline Project

Dear Mr. Tambini,

On April 26, 2017 the New Jersey Department of Environmental Protection issued a determination that the PennEast application materials submitted to the state were significantly deficient and incomplete. Among the deficiencies were:
• Delineations of all freshwater wetlands, transition areas and open waters;
• Soil borings and/or other physical indicators of wetlands, transition areas or open waters;
• Other identified information pertaining to wetlands, open waters and transition areas;
• An amended Phase I Archaeological Survey Report investigating the entire proposed alignment for the PennEast Pipeline project occurring in the State of New Jersey.

Subsequently, on June 28, 2017, NJDEP determined the PennEast Pipeline Company’s application for state approval of its project to be “administratively closed” due to the company’s failure to remedy the significant deficiencies and its failure to provide full information in a timely fashion for Clean Water Act decisionmaking. In its determination letter the NJDEP wrote:

“…given the complexity of the remaining deficient items, and the lack of demonstrated progress on the part of the applicant, it appears that it would be unlikely that an additional 60 days would allow substantial progress on the application. This application will be deemed ‘administratively closed’ as of the date of this letter.”

Even the FERC Final EIS notes a wealth of missing information, including much, if not most of which, speaks to issues that have a direct effect on the quality and health of the surface waters, groundwater and wetlands of the Delaware River watershed under the jurisdiction of the DRBC.

And so we urge the DRBC to formally make a determination that you too find the information on the record with the Delaware River Basin Commission to be inadequate and incomplete and that as a result the DRBC will not be undertaking any consideration of the PennEast Pipeline project at this time as pertains to a DRBC docket for any portion of the construction of this project.

In addition, we ask that you confirm for the public that you will not hold any public hearings until such time as the information filed with the DRBC is demonstrated and verified to be both complete and accurate.

And we urge you to make clear, for the public, FERC and PennEast, that the DRBC intends to enforce its authority as clearly articulated in its November 14, 2014 letter to the PennEast Pipeline Company that “DRBC review and approval are required prior to the commencement of any water withdrawal, discharge, or earth disturbance activities.” This is particularly important give that a quorum of Commissioners has been restored at FERC and so a Certificate of Public Convenience and Necessity may be imminent.

Public Comment 135: September 2017 - Organizations Oppose FERC

September 20, 2017

The Federal Energy Regulatory Commission (FERC) has a long record through both Democratic and Republican administrations of blindly approving and refusing to regulate energy companies. In Public Comment 135 the New Progressive Alliance joins with other organizations in supporting a rally at FERC’s first meeting since January 1017 on September 20, 2017. Our joint statement appears below in Public comment 136.

The Federal Energy Regulatory Commission will hold its first meeting since January on September 20th, 2017, now that Trump's nominees Robert Powelson and Neil Chatterjee have received Senate approval and a quorum has been re-established. FERC has wasted no time getting back to business and have already approved the Nexus pipeline.

If only Congress would move as quickly in investigating FERC's abuses of power, something more than 200 organizations have been calling for since September 2016. In fact, rather than investigate FERC, both the Senate and the House have put forward bills that would expand FERC's authority in support of Trump's dirty energy plan.

That's why we planned a day of actions in D.C. on September 20^th, 2017. We will hold a rally in front of FERC from 8:30 - 9:30 before some attendees enter the meeting as others stay outside and chant. We will also be visiting Congressional offices that day.

The following 104 diverse,nationwide organizations have all signed on in support of this effort.

Delaware Riverkeeper Network

Berks Gas Truth

Beyond Extreme Energy

Green America

OVEC-Ohio Valley Environmental Coalition

Safe Energy Rights Group, Inc.

Coalition for Responsible Siting of LNG Facilities

River Healers

Wild Virginia

Agape Community

Center for Health, Environment & Justice

198 Methods

The Enviro Show

No Fracked Gas in Mass

Lancaster Against Pipelines

Resist Spectra

Communities for Safe and Sustainable Energy

Bold Alliance

ECHO Action NH: #FossilFree603

PAUSE - People of Albany United for Safe Energy

350NYC

SCRAM

Center for Biological Diversity

Stop NED

Alliance To Protect Our People And The Places We Live

Food & Water Watch

Toxics Action Center

Berkshire Environmental Action Team

The Shalom Center

Northjersey Pipeline Walkers

Resist the Pipeline

Damascus Citizens for Sustainability

Pennsylvania Alliance for Clean Water and Air

Northern NJ Chapter, National Organization for

Women

Earthworks

The Essene Church of Peace

Global Coalition for Peace

Gas Free Seneca

Seneca Lake Guardian, A Waterkeeper Affiliate

Sullivan Area Citizens for Responsible Energy

Development (SACRED)

Christians For The Mountains

Citizens Coalition for a Safe Community

Athens County (Ohio) Fracking Action Network

STOP (Sandisfield Taxpayers Opposing the

Pipeline)

Frack Free Genesee

Catskill Citizens for Safe Energy

Sullivan Alliance for Sustainable Development

NJ State Industrial Union Council

350NJ

350 Central Mass

Aytzim: Ecological Judaism

Potomac Riverkeeper Network

Green Education and Legal Fund

Interfaith Moral Action on Climate

350 Fairfax

Pay it Forward Global Foundation

Greenbrier River Association

New Hampshire Pipeline Awareness

New Progressive Alliance

AMP Creeks Council

Lebanon Pipeline Awareness

Norfolk Catholic Worker

New Mexico Story Power

Ogre Ogress Productions

NH Pipeline Resistance

Catskill Mountainkeeper

Bucks County Environmental Action

Schuylkill Pipeline Awareness

Mason Pipeline Committee

LAWPA (Local Authority Western PA)

Interfaith Power & Light (DC.MD.NoVA)

Grassroots Environmental Education

Philadelphia PSR

Stop the Algonquin Pipeline Expansion

100grannies for a Livable Future

LEPOCO Peace Center (Lehigh-Pocono

Committee of Concern)

Coalition to Protect New York

Nuclear Information and Resource Service

Green Party of Santa Clara County

Organic Consumers Association

People Demanding Action

Rachel Carson Council

Sierra Club New York City Group

Earth Echoes....Stories for a small planet

Greenpeace

Protect Our Water Heritage Rights - POWHR

Interreligious Eco-Justice Network

Amistad Catholic Worker

Hip Hop Caucus

Oil Change International

350 Loudoun

Fractivist.org

Peace Action of Staten Island

Preserve Roanoke/ Bent Mountain

Hilltown Community Rights

Concerned Citizens of Lebanon County

Advocates for Springfield

Possibilities Retreat Center

Project CoffeeHouse

FreshWater Accountability Project

HoCo Climate Action (Howard County, MD)

Friends of Buckingham

Hartford Catholic Worker

Public Comment 136: September 2017 - Congress Letter Opposing FERC

September 20, 2017

Honorable Members of Congress and the Senate:

President Donald Trump is fast tracking a Dirty Energy Agenda that is putting our country at grave risk. Hurricanes Harvey and Irma have put an exclamation point on the realities of how harmful climate change will be for our present and future communities if we do not swiftly transition from coal, oil, and fracked gas to a clean energy path. The damage will be to human life and safety, to our local and national economies, to businesses large and small, and to our healthy environments necessary to sustain food, air, water, and flood protection for present and future generations.

President Trump is seeking multiple avenues to increase use of coal, gas and oil fracked from shale, and other dirty fossil fuels. Among President Trump’s Dirty Energy Agenda is:

---> advancing three pro-industry representatives as Commissioners to the Federal Energy Regulatory Commission (FERC);
---> advocating rollback of environmental regulations and project review requirements, including rollback of guidance that ensured consideration of climate changing impacts of FERC regulated fossil fuel projects; and
---> increasing the power of the Federal Energy Regulatory Commission to advance dirty fossil fuel pipelines despite its documented abuses of power and law.

Congress needs to be a check on the Dirty Energy Agenda of Donald Trump, not a rubber stamp. Rather than bring rationality to the President’s Dirty Energy plans, the Senate is considering Senate Bill 1460.

S 1460, sponsored by Senator Murkowski,

---> would increase greenhouse gas emissions and harm the environment and public health by furthering U.S. dependence on fossil fuel-based energy;
---> expedite review of new mining, oil, and gas permits, and drilling;
---> hasten approvals for liquified natural gas (LNG) export facilities, resulting in more pipelines and devastation to communities in the US in order to provide energy to foreign nations;
---> expanding research and development for extracting methane hydrates.

S1460 does nothing to increase renewable energy production in the U.S. and instead would further solidify our dependence on foreign nations who are taking the lead on ensuring their ability to supply this clean energy of the future.

Among the biggest concerns of the signers of this letter is that S1460 would make FERC the lead agency in the authorization of fracked gas projects, requiring other agencies to give “deference” to FERC. FERC is already recognized as failing to provide independent, thoughtful, and rational review to infrastructure projects. Greenhouse gas emissions, property rights impacts, environmental harms, and job loss are all given short shrift in FERC’s reviews. FERC is now well known for its misuse of eminent domain authority, its efforts to undermine state authority, and its misuse of a legal loophole to rob communities of their ability to challenge pipeline projects before their property rights are taken and construction is allowed to begin.

It is bewildering that so many Senators who took a strong stance in support of the Paris Climate Agreement, who touted the need for U.S. climate leadership and transitioning to renewable energy, who consistently assert a concern for environmental protection, and who have been vocal critics of FERC’s project reviews, are now poised to support S1460 and other dirty energy legislation.

The signers of this letter have all experienced, first hand, the abuses of fracked gas infrastructure and the abuses of authority carried out by FERC. And so we urge you to reject S1460, to reject all legislation that seeks to further empower and embolden FERC and that rolls back environmental protections.

Instead we urge you to advance and support legislation that:

---> advances clean energy industries, jobs and technologies and seeks to position the United States as a clean energy leader, and that
---> calls for hearings into FERC’s abuses of power and law and to use those findings to identify and advance needed reforms to the Natural Gas Act.

Advancing President Trumps Dirty Energy Agenda, and legislation like S1460, the Energy Modernization Act of 2015, HR 1900 (of the past) and other such legislation, is damaging to our nation. Oil and gas pipelines are damaging to our nation’s economy. By contrast, advancement of clean energy industries are a job creator and economic driver. Pipeline investments suck up financial resources and political energy that could and should be used for business investments that will maximize near term and long term job benefits. Investment in clean energy generates a greater number of long term jobs that bring greater capacity for worker learning and advancement. In fact, for every million dollars invested in clean energy jobs (including wind, solar, eco-friendly water, and efficiency) we generate 6 to 8 times the number of direct jobs, and 3 times the number of direct, indirect and induced jobs collectively. (1)

The claim of economic benefits from FERC approved pipelines (including jobs, local tax revenue and savings on energy) are dwarfed by the economic costs those pipelines inflict. For example
---> While Millennium Pipeline company claims its ESU project will generate $2 billion of economic value it will cost between $4.7 billion to $18.8 billion in economic harm;
---> While the PennEast pipeline company asserts it will provide $2.3 billion of economic value over 30 years, analysis shows it will cost communities between $13.3 billion to $56.6 billion in economic harm.

Pipelines reduce the market value of our homes, sometimes by as much as 5 to 40% (2), while at the same time reducing the marketability of homes. Unable to sell their homes for fair value or at all, people, kids and families are forced to live next to the pipeline infrastructure forced upon them by eminent domain that endangers and disturbs them or to sell their property at a loss, a loss which most people can ill afford to bear. The fear of living next to a pipeline is well founded. The rate of accident, incidents and explosions of recently built pipelines exceeds rates of the past with gas transmission lines installed in the 2010s having annual average incident rates exceeding that of pre-1940s pipes (3). In the past 20 years, the Pipeline and Hazardous Materials Safety Administration has recorded 5,679 “significant” pipeline incidents (i.e., resulting in $50,000 or more in costs), 310 fatalities, 1,301 injuries, and nearly $8 billion in costs and damages. That works out to an average, every year, of 284 incidents (including explosions) 65 injuries, 16 deaths, and nearly $390 in annual costs and damages.

Even the industry recognizes that pipeline infrastructure is advancing too fast, with too many pipelines being built in an unplanned fashion to make sense.

“Speaking to attendees at the 21st Annual LDC Gas Forums Northeast conference in Boston Tuesday, [RBN Energy LLC President Rusty] Braziel said an evaluation of price and production scenarios through 2021 suggests the industry is planning too many pipelines to relieve the region’s current capacity constraints.” (4)

“We believe that the Appalachian Basin’s takeaway capacity will be largely overbuilt by the 2016-2017 time frame,” said Elle G. Atme, Vice President, Marketing and Midstream operations for independent producer Range Resources. (5)

According to the Institute for Energy Economics and Financial Analysis (IEEFA)
“The pipeline capacity being proposed exceeds the amount of natural gas likely to be produced from the Marcellus and Utica formations over the lifetime of the pipelines.” “…[T]he regulatory environment created by FERC encourages pipeline overbuild.” (6)

All the way around – jobs, economics, environment, health, property values, quality of life, climate change, and honoring our obligation to future generations – continuing investments in dirty fossil fuels, and its infrastructure, is a fool’s errand.

We write to urge you to oppose Donald Trump’s Dirty Energy Agenda and instead to:
1. Oppose any legislation before you that does anything but strengthen review of, and protections from, fossil fuel development including infrastructure, including S1460;
2. Call for Congressional hearings into the abuses of law and power by FERC, and to, as a result of the hearing process, identify and advance needed legislative and regulatory reforms;
3. Put in place a moratorium on new fracked gas infrastructure approvals by FERC until identified reforms from the hearing process are put in to place;
4. Advance legislation and agency mandates that fast track advancement of clean energy alternatives and strive to position the United States as an international clean energy leader.

-------------------------------------------------------------------------------------
(1) See e.g. The Economic Benefits of Investing in Clean Energy, Dept of Economics and Pollitical Economy Research Institute, Univ of Massachusetts, Amherst, June 2009
(2) E.g. http://www.ldnews.com/story/news/local/2016/01/02/pipelines-could-affect-property-values/77984160/; http://www.forensic-appraisal.com/gas_pipelines_q_a
(3) http://pstrust.org/wp-content/uploads/2013/03/Incidents-by-age-of-pipes-PST-spring2015-newsletter-excerpt.pdf
(4) See Failure to Demonstrate Need Attachment 2, Jeremiah Shelor, Marcellus/Utica on Pace for Pipeline Overbuild, Says Braziel, Natural Gas Intelligence, June 8, 2016.
(5) Marcellus-Utica could soon be overpiped, Kallanish Energy, February 2, 2016.
(6) IEEFA, Risks Associated with Natural Gas Pipeline Expansion in Appalachia, April 2016.

Respectfully,

OVEC-Ohio Valley Environmental Coalition
Delaware Riverkeeper Network
Safe Energy Rights Group, Inc.
Coalition for Responsible Siting of LNG Facilities
River Healers
Wild Virginia
Agape Community
Center for Health, Environment & Justice
198 methods
The Enviro Show
No Fracked Gas in Mass
Lancaster Against Pipelines
Resist Spectra
Safe Energy Rights Group (SEnRG)
Berks Gas Truth
Communities for Safe and Sustainable Energy
Bold Alliance
ECHO Action NH: #FossilFree603
PAUSE- People of Albany United for Safe Energy
350NYC
SCRAM
Center for Biological Diversity
StopNED
Alliance To Protect Our People And The Places We Live
Food & Water Watch
Toxics Action Center
Berkshire Environmental Action Team
The Shalom Center
North Jersey Pipeline Walkers
Resist the Pipeline
Damascus Citizens for Sustainability
Pennsylvania Alliance for Clean Water and Air
Northern NJ Chapter, National Organization for Women
Earthworks
Earthworks
The Essene Church of Peace
Global Coalition for Peace
Gas Free Seneca
Seneca Lake Guardian, A Waterkeeper Affiliate
Sullivan Area Citizens for Responsible Energy Development (SACRED)
Christians For The Mountains
Citizens Coalition for a Safe Community
Athens County (Ohio) Fracking Action Network
STOP (Sandisfield Taxpayers Opposing the Pipeline)
Frack Free Genesee
Catskill Citizens for Safe Energy
Sullivan Alliance for Sustainable Development
NJ State Industrial Union Council
350NJ
350 Central Mass
Aytzim: Ecological Judaism
Potomac Riverkeeper Network
Green Education and Legal Fund
Interfaith Moral Action on Climate
350 Fairfax
Pay it Forward Global Foundation
Greenbrier river association
New Hampshire Pipeline Awareness
New Progressive Alliance
AMP Creeks Council
Lebanon Pipeline Awareness
Norfolk Catholic Worker
New Mexico Story Power
OgreOgress productions
http://www.kevinrauch.com
NH Pipeline Resistance
Catskill Mountainkeeper
Bucks County Environmental Action
Schuylkill Pipeline Awareness
Mason Pipeline Committee
LAWPA (Local Authority Western PA)
Interfaith Power & Light (DC.MD.NoVA)
Grassroots Environmental Education
Philadelphia PSR
Stop the Algonquin Pipeline Expansion
100grannies for a Livable Future
LEPOCO Peace Center (Lehigh-Pocono Comittee of Concern)
Coalition to Protect New York
Nuclear Information and Resource Service
Green Party of Santa Clara County
Organic Consumers Association
The Shalom Center
People Demanding Action
Rachel Carson Council
Sierra Club New York city Group
Earth Echoes….Stories for a small planet
Protect Our Water Heritage Rights – POWHR
Interreligious Eco-Justice Network
Amistad Catholic Worker
Hip Hop Caucus
Schuylkill Pipeline Awareness
Oil Change International
Greenpeace

Public Comment 137: September 2017 - CA Disclose Act AB 249 Governor Sign

In June 2017 in Public comment 123 The New Progressive Alliance with other organizations backed the California Disclose ACT AB 14. This passed both houses and is now before the governor as AB 249. This letter went to Governor Brown urging him to sign.

September 27, 2017

Honorable Jerry Brown

Governor, State of California

State Capitol, Suite 1173

Sacramento, CA 95814

Cc: The Honorable Kevin Mullin and Marc Le vine and Members of the California State Senate and Assembly

RE: AB 249 (Mullin and Levine) – Support

Dear Governor Brown,

The below listed organizations are pleased to support AB 249, 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 ballot.

Campaign spending on ballot measures has reached unprecedented levels. Nearly $1 billion was spent in California on ballot measures from 2012 to 2016, 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 and therefore who is asking for their vote.

AB 249 significantly improves disclosures on ballot measure and independent expenditure ads, requiring their three largest funders to be shown clearly and unambiguously on television and print ads regardless of whether they’re paid for by primarily-formed or general purpose committees. It applies with appropriate nuances to all major forms of political advertising (radio ads, robocalls, television, electronic, print).

AB 249 also expands existing reporting follow-the-money earmarking rules for contributions to candidates to include contributions meant for specifically identified committees or ballot measures. Even more importantly, it ensures that when a committee primarily formed to support or oppose a state candidate or ballot measure contributes to another committee primarily formed to support or oppose a state candidate or ballot measure and the funds used were earmarked for that candidate or ballot measure, that they must report the earmarked contributions and that those earmarked contributions must be shown on the ads if they’re a top contributor.

These rules will, for the first time, reveal true funders on ballot measure ads when the funders attempt to hide behind one or more layers of misleading front groups, while providing a reasonable exemption for unnecessary new earmarking tracking of small donors giving up to $500 a year for specific ballot measures.

AB 249 would thus stop voters from being routinely and legally misled about funders of ballot measure ads.

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.

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 249, the most famous of which is this, from Justice Scalia:

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 AB 249, with more than 90,000 signing petitions urging the legislature to pass this year’s California DISCLOSE Act. We therefore respectfully ask for your support of AB 249. 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 below respectfully SUPPORT AB 249 and request that you sign it into law.

FROM: California Clean Money Campaign (Sponsor)

American Family Voices

California Alliance for Retired Americans

California Church IMPACT

California Common Cause

Californians for Disability Rights

California League of Conservation Voters

California Physicians Alliance

California Public Interest Research Group (CALPIRG)

Citizens for Responsibility and Ethics in Washington (CREW)

Coalition for Clean Air

Communication Workers of America District 9

Consumer Watchdog

CounterPAC

Courage Campaign

CREDO

Daily Kos

Democracy for America

Endangered Habitats League

Free Speech for People

Friends of the Earth

League of Women Voters of California

LegitAction

Lutheran Office of Public Policy

Maplight

Money Out People In

Money Out Voters In

New Progressive Alliance

Our Revolution California

People for the American Way

People Demanding Action

Public Citizen

Represent.Us

Social Security Works

Take Back Our Republic

Voices For Progress Education Fund

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

[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)

Public Comment 138: October 2017 - World Bank - Stop Financing Fossil Fuels

October 7, 2017

President of the World Bank

The Honorable Jim Yong Kim

The World Bank

1818 H Street NW

Washington, DC 20433

The World Bank’s primary purpose is to fight poverty. While I hope the World Bank will shift investments through its Climate Change Action Plan, these positive steps risk being undermined by ongoing direct and indirect World Bank support for fossil fuel development. This support will lock countries into a fossil fuel future, which will contribute to continued warming of the planet.

In April 2015 we at the New Progressive Alliance had a statement accepted by the United Nations on fossil fuel subsidies and it appears little has changed since then. (We have printed the comment at the end of this letter.)

The New Progressive Alliance at http://newprogs.org/ urges the following steps.

- phasing out all investment in fossil fuels increasing the World Bank's focus on renewable energy and energy access

- providing much greater transparency about the impact investments in energy are having on the lives of ordinary men, women and children

- ensuring all energy projects funded by the World Bank help lift more people out of energy poverty.

(Public Comment 71: April 2015 - UN ECOSOC Energy Subsidies)

The below was submitted to the Office for United Nations ECOSOC Support and Coordination of the United Nations Department of Economic and Social Affairs as a written statement for the 2015 ECOSOC High-Level Segment (HLS) for NGOs in ECOSOC consultative status. In June 2015 we learned that the Public Comment was accepted for distribution to all participants of the 2015 High Level Segment NGO meeting from July 6 - 10, 2015 at United Nations Headquarters and was being translated into the six official United Nations languages.

April 24, 2015

The theme for the 2015 session of the Economic and Social Council is “Managing the transition from the Millennium Development Goals to the sustainable development goals: what it will take”.

The most important factor in sustainable development goals is sustainable environmental progress in the face of climate change which has already started. Given the predictions of the vast majority of scientists on future generations this is the most important issue we should be addressing right now. It will be greatly affect all eight of the Millennium Developmental Goals.

A major problem in preventing climate change is governments and the World Bank subsidizes and supports fossil fuels more than renewable energy. A remedy would be if the United Nations listed for every country the ratio of subsidies for fossil fuel to subsidies for renewable energy. A reasonable initial goal would be to have subsidies for renewable energy be equal to or greater than subsidies for fossil fuel.

There is a huge cost to using fossil fuels quite apart from climate change. That cost is rising. It consistently costs the United States well over ten billion dollars a year for fossil fuel subsidies. It recently rose from 12.7 billion in 2009 to 18.5 billion in 2013. 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, a cost that would be eliminated by eventually transitioning instead to 100% renewable energy. More than just the costs of massively subsidizing the failed fossil fuel business model is involved. There are also externalities - such as healthcare costs due to pollution, government guaranteed loans, environmental destruction through mountaintop removal for coal, tar sands oil drilling, fracking for natural gas, and wars for oil and uranium. Also consistently ignored is the price for adjusting to the effects of global climate change - even if possible - is far greater than the cost of stopping global warming at this stage.

Unlike the climbing costs of fossil fuels, the cost of renewable energy is declining and has been for decades. One should be able to compare with each country the total subsidies for fossil fuels with the total subsidies for renewable energy. Of course, the United Nations and the World Bank should never again subsidize fossil fuels for developing nations. Let renewable energy play on a level playing field with fossil fuels and it will expand even faster and lessen the degree of climate change. Publishing where countries are really spending their money would allow groups such as the New Progressive Alliance to push them in the right direction.

The above is documented under “Costs” in the article The Environment at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Public Comment 139: October 2017 – Cowlitz County Stop Millennium

October 24, 2017

Cowlitz County:

[email protected]

The New Progressive Alliance at http://newprogs.org/ urges Cowlitz County to reject the Shoreline Substantial Development and Conditional Use Permit for Millennium Bulk Terminals. It is based on a bad business plan, harms the health of Washington residents, would impede traffic and emergency vehicles, and would certainly raise Greenhouse global warming gases.

This is a Bad Business Plan

A bad business plan means that when the business goes under we will be left with the pollution while China gets the profits.

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.

Millennium will be Disastrous for 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.

Millennium's environmental review found that cancer rates, rail congestion, and harm from climate change would increase if the 44 million-ton per year facility is built. These permits are clearly in the public interest. We should not trade our clean air and water for coal export. And coal is a dying industry. Innovation and clean energy will benefit our entire region in the long term.

Rail Traffic will slow Traffic and Emergency Vehicles

Greenhouse Gas Emissions

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

John F. Kennedy

Conclusion

Millennium Bulk Terminals would be the biggest coal terminal in North America. Exporting coal does not protect local, state, or national interests.

Property damage, lost lives, environmental damage, and health costs are never paid by fossil fuel companies. Cities and towns and states pick up the tab while companies keep the profits. Coal companies are not responsible for these health effects or for clean up when coal ash spills and destroys water supplies. Washington should not fall for this Millennium scam that will cause the state to lose jobs, money, and harm the environment.

Please review the abundance of substantive, critical comments from Tribes, state and federal agencies, elected leaders, health professionals, and residents of the region and reject the Shoreline Substantial Development and Conditional Use Permit for Millennium Bulk Terminals.

Sincerely,

Ed Griffith

New Progressive Alliance

1000 17^th Ave. #306

Longview, WA 98632-2358

United States of America

References:

Public Comment 140: October 2017 – Washington State Ecology – Stop Millennium

October 24, 2017

Washington State

Department of Ecology

PO Box 47600

Olympia, WA 98504-7600

The New Progressive Alliance at http://newprogs.org/ urges the Department of Ecology to reject the Shoreline Substantial Development and Conditional Use Permit for Millennium Bulk Terminals. It is based on a bad business plan, harms the health of Washington residents, would impede traffic and emergency vehicles, and would certainly raise Greenhouse global warming gases.

This is a Bad Business Plan

Why is this important to the Department of Ecology? It is because a bad business plan means that when the business goes under we will be left with the pollution while China gets the profits.

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.

Millennium will be Disastrous for 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.

Rail Traffic will slow Traffic and Emergency Vehicles

Greenhouse Gas Emissions

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

John F. Kennedy

Conclusion

Millennium Bulk Terminals would be the biggest coal terminal in North America. Exporting coal does not protect local, state, or national interests.

References:

Public Comment 141: December 2017 - Congress - Don't Strip the SEC of its Power

December 6, 2017

The Honorable Mitch McConnell

Senate Majority Leader

Room S-230, The Capitol

Washington, D.C. 20510

The Honorable Paul Ryan

Speaker of the House

Room H-232, The Capitol

Washington, DC 20515

The Honorable Charles Schumer

Senate Minority Leader

322 Hart Senate Office Building

Washington, D.C. 20510

The Honorable Nancy Pelosi

House Minority Leader

233 Cannon House Office Building

Washington, DC 20515

The Honorable Thad Cochran

Chairman, Senate Appropriations Committee

113 Dirksen Senate Office Building

Washington, D.C. 20510

The Honorable Rodney P. Frelinghuysen

Chairman, House Appropriations Committee

2306 Rayburn House Office Building

Washington, DC 20515

The Honorable Patrick Leahy

Vice Chair, Senate Appropriations Committee

437 Russell Senate Building

Washington, DC 20510

The Honorable Nita Lowey

Ranking Member, House Appropriations Committee

2365 Rayburn House Office Building

Washington, DC 20515

Dear Leader McConnell, Speaker Ryan, Leader Schumer, Leader Pelosi, Chairman Cochran, Chairman Frelinghuysen, Senator Leahy, and Representative Lowey:

As you work to prepare any fiscal year 2018 appropriations bills or continuing resolutions, we respectfully request that you reject any language that would limit the Securities and Exchange Commission’s (SEC) ability to study, develop, propose, finalize, issue, or implement a rule requiring public companies to disclose political spending to shareholders.

Since the U.S. Supreme Court’s decision in Citizens United v. FEC came down in 2010, corporations have been allowed to spend unlimited undisclosed amounts of money to influence American elections and in turn affect policy outcomes. Noting the danger of “dark money” for both American democracy and the shareholders of the companies that are spending in secret, a strong coalition of diverse allies has been working together since the decision to bring corporate spending in politics into the light.

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

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

Without direction from the SEC, there are no rules or procedures established in the United States to ensure that shareholders – those who actually own the wealth of corporations – are informed of, or have the right to approve, decisions on spending their money on politics. Investors want more disclosure in order to make sound investment decisions. That is why 1.2 million comments- the most in the agency’s history- have come into the SEC on this rulemaking petition from diverse stakeholders including the founder of Vanguard, John Bogle, five state treasurers, a bi- partisan group of former SEC chairs and commissioners, and investment professionals representing $690 billion in assets.

We believe that the rider blocking the SEC from making progress on this rulemaking was inappropriately included in the appropriations process and that the budget should be free of any poison pill policy riders. We urge you to put forth a clean budget free of such riders, particularly the one impeding transparency for shareholders. We are grateful for your leadership and appreciate your consideration of this request to restore transparency and accountability to our democracy.

Sincerely,

American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)

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

Boston Common Asset Management

Campaign for Accountability

Center for Biological Diversity

Center for Media and Democracy

Citizen Works

Citizens for Responsibility and Ethics in Washington (CREW)

Common Cause

Democracy 21

Dominican Sisters of Hope

End Citizens United

Every Voice

Franciscan Action Network

Free Speech For People

Government Accountability Project

Green Century Capital Management

Greenpeace

Interfaith Center on Corporate Responsibility

New Progressive Alliance

OIP Trust

People For the American Way

Public Citizen

Shareholder Association for Research & Education

Timothy Brennan, Treasurer & CFO, Unitarian Universalist Association

Ursuline Sisters of Tildonk, U.S. Province

U.S. Public Interest Research Group

Voices for Progress

Wisconsin Democracy Campaign

Women's Institute for Freedom of the Press

Zevin Asset Management

Public Comment 142: December 2017 - Congress- Legislative Priorities

December 6, 2017

Dear Senator/Representative:

Week after week, the 111 undersigned national organizations have watched as Congress has put off carrying out its responsibilities to address urgent priorities: continued health care coverage for our children and all low/moderate income people, emergency relief from natural disasters, continuing legal status for the Dreamers and other immigrants with Temporary Protected Status, lifting appropriations caps to prevent serious underfunding of vital programs, and enactment of full-year funding for FY 2018. Instead, House and Senate leadership has pressed forward with tax cut proposals that would make things worse for low- and middle-income people whose needs should be the focus of your attention. Our traditions and values of conscience and faith impel us to call upon you to put first things first.

As organizations representing people of faith, service providers, and civil rights, labor, and policy experts and advocates for people in need, we assess the success or failure of our leaders based on their actions to protect the most vulnerable among us, to treat all people fairly, and to invest responsibly in our shared future. Actions by Congress to address the following issues are urgently needed before you leave for the December holidays:

· Children’s Health Insurance Program (CHIP) Reauthorization; Community Health Centers (CHC’s) Funding Extension; Maternal, Infant, and Early Childhood Home Visiting Program (MIECHV) Reauthorization: CHIP serves 9 million children and 370,000 pregnant women. This extremely successful program should have been reauthorized by September 30. Now after nearly two months of inaction, states are starting to run out of funds and must notify parents that they may lose insurance for their children. Arizona, California, Connecticut, Hawaii, Idaho, Minnesota, Mississippi, Ohio, Oregon, Nevada, Pennsylvania, and Utah are expected to run out of federal CHIP funds by no later than the end of December, with many other states running out in the first quarter of 2018. It is unconscionable for Congress to be putting the health of millions of children at risk. Action is needed now on a 5-year reauthorization, without seeking to pay for CHIP reauthorization with cuts either in CHIP or in other important programs such as Medicare, Medicaid, or the Prevention and Public Health Fund. Similarly, the Community Health Center Fund expired on September 30, and should be extended for 5 years. CHC’s serve 27 million people; if the Fund is not extended, 9 million could lose their health care. Congress should also enact a 5-year reauthorization of the Maternal, Infant, and Early Childhood Home Visiting Program (MIECHV), to continue and expand its proven success in improving maternal and newborn health and development.

· Continuation of Deferred Action for Childhood Arrivals (DACA) and Temporary Protected Status (TPS): Nearly 800,000 people who came to this country as children are at risk of losing their legal status here because of President Trump’s decision to end the DACA program by March 2018. Even before then, 122 Dreamers are being discontinued from DACA each day, a total of over 10,000 so far. There is bipartisan support for helping the Dreamers, who contribute to their communities every day through their work, studies, and service. Congress must act to protect these young people through passage of the DREAM Act, without unacceptable conditions that will harm others. We also call upon you to urge the Administration to continue or reinstate Temporary Protected Status for 320,000 people from Haiti, El Salvador, Nicaragua, Honduras, Nepal, Somalia, Sudan, South Sudan, Syria and Yemen. They came here fleeing violence and/or natural disaster, and the countries they left are still dangerous and unable to cope with their return. Many have been here for decades, are contributing to their communities, and have U.S. citizen children. Deporting them would cause the U.S. to lose $164 billion in GDP. Please stand against endangering them and against splitting parents from children.

· Provide urgently needed relief and recovery for Puerto Rico, the Virgin Islands, Texas, Florida, and for communities hit by wildfires: The devastation in Puerto Rico and the U.S. Virgin Islands is unprecedented. Half of Puerto Rico remains without electricity with at least 472,000 homes destroyed or damaged; public health remains at high risk. Hundreds of billions of dollars will be needed to assist with the recovery for all places recently afflicted by these natural disasters, and Congress needs to provide much more than its initial efforts, and must do so quickly. The Trump Administration’s recent request is grossly inadequate, and especially inequitable in requiring these emergency services to be paid for through cuts to other programs. Budget law rightly exempts emergency funding from being paid for, to ensure a swift and adequate response. Just as Louisiana was temporarily spared having to pay Medicaid reimbursement after Hurricane Katrina’s devastation, Puerto Rico should be relieved of paying towards Medicaid during its recovery period.

· Lift sequester caps in a bipartisan approach to allow more adequate funding for domestic and international priorities, not just for the military; enact omnibus spending legislation without poison pill riders: The CR will expire on December 8. Congress needs to enact a bipartisan bill to lift the sequester caps for at least two years before an omnibus spending bill can be completed. Such legislation should adhere to the “parity principle” that has guided past sequestration deals by providing equal sequester relief for defense and non-defense accounts. Without lifting the caps, we cannot make the investments we need in housing, education, job training, child care, Head Start, public health and safety, and infrastructure. The Census Bureau requires more funding to carry out an accurate 2020 Census, vital for a fair distribution of federal grants to states and for accurate redistricting. We will be unable to provide adequately for Meals on Wheels and other nutrition programs, home heating and cooling assistance, substance use disorder and mental health services, and assistance for people with disabilities. Lifting the caps equitably must be a top priority for Congress, so that it can proceed as quickly as possible to enact an omnibus spending bill for the rest of FY 2018. An adequately funded omnibus will allow investments that will provide for economic growth and opportunity, and should not be undermined by divisive poison pill riders. It is vitally important that increases in appropriated spending are not paid for by cuts that would reduce or eliminate essential services provided by programs such as Medicaid, Medicare, the Affordable Care Act, SNAP, the Social Services Block Grant, SSI, and other entitlement programs.

Carrying out your responsibilities in these critical areas should be Congress’ top priorities in the weeks ahead. It is simply unacceptable to let time run out on essential funding and protections for vulnerable people. Please work actively to ensure that the items listed above are enacted, free-standing or in other legislative vehicles, before Congress leaves in December.

Sincerely,

Adorers of the Blood of Christ

African American Health Alliance

AFSCME

AIDS United

Alliance of Baptists

American Association of University Women (AAUW)

American Friends Service Committee

American Muslim Health Professionals

Appalachian Independence Center, Inc.

Asian & Pacific Islander American Health Forum

Association of Asian Pacific Community Health Organizations

Association of Farmworker Opportunity Programs

Association of Programs for Rural Independent Living

Association of School Business Officials International (ASBO)

Autistic Self Advocacy Network

Benedictine Sisters of Baltimore

Bread for the World

Campaign for Youth Justice

Center for Community Change Action

Center for Law and Social Policy (CLASP)

Center for Medicare Advocacy

Child Care Aware of America

Child Welfare League of America

Children's Defense Fund

Children's Leadership Council

Children’s Advocacy Institute

Christian Reformed Church in North America, Office of Social Justice

Coalition on Human Needs

Community Learning Partnership

Community Resource Exchange

Congregation of Our Lady of Charity, US Provinces

Daughters of Charity - USA

Disciples Center for Public Witness

Doctors for America

Endangered Species Coalition

Every Child Matters

Family Focused Treatment Association

Food Research & Action Center (FRAC)

Franciscan Action Network

Friends Committee on National Legislation

Generations United

Global Justice Institute

HCAN

Healthy Teen Network

HEAR US Inc.

HIV Prevention Justice Alliance

Homeowners Against Deficient Dwellings

Interfaith Worker Justice

Justice in Aging

Leadership Conference of Women Religious

LIFT

Meals on Wheels America

NAKASEC

National Advocacy Center of the Sisters of the Good Shepherd

National Alliance to End Sexual Violence

National Association for Children's Behavioral Health

National Association of Social Workers

National Association of State Head Injury Administrators

National Association of State Long-Term Care Ombudsman Programs (NASOP)

National Birth Defects Prevention Network

National Black Justice Coalition

National Center for Healthy Housing

National Center for Lesbian Rights

National Council of Churches

National Council of Jewish Women

National Domestic Violence Hotline

National Employment Law Project

National Health Care for the Homeless Council

National Housing Law Project

National Immigration Law Center

National Juvenile Justice Network

National Latino Farmers & Ranchers Trade Association

National Law Center on Homelessness & Poverty

National Low Income Housing Coalition

National Network to End Domestic Violence

National Organization for Women

National Rural Education Association

National WIC Association

National Women's Law Center

NETWORK Lobby for Catholic Social Justice

New Progressive Alliance

NMAC

People Demanding Action

People For the American Way

PolicyLink

Poligon Education Fund

Progressive Congress Action Fund

Project Inform

ProLiteracy

Protect All Children's Environment

Provincial Council Clerics of St. Viator (Viatorians)

Racial and Ethnic Health Disparities Coalition

RESULTS

Ryan White Medical Providers Coalition

Sisters of Charity of Nazareth Congregational Leadership

Sisters of Charity, BVM

Sisters of Mercy South Central Community

Sisters of the Presentation of the Blessed Virgin Mary

Tax March

Teach Plus

The Leadership Conference on Civil and Human Rights

The Network of Jewish Human Service Agencies

Treatment Action Group

U.S. Breastfeeding Committee

UnidosUS

Union for Reform Judaism

Union Of Presentations Sisters

United Church of Christ, Justice and Witness Ministries

Voices for Progress

YWCA USA

ZERO TO THREE

Public Comment 143: December 2017 - Congress - Net Neutrality

December 12, 2017

The Honorable John Thune

Chairman

U.S. Senate Committee on Commerce, Science and Transportation

Washington, D.C. 20510

The Honorable Bill Nelson

Ranking Member

U.S. Senate Committee on Commerce, Science and Transportation

Washington, D.C. 20510

The Honorable Greg Walden

Chairman

Energy and Commerce Committee

2125 Rayburn House Office Building

Washington, D.C. 20515

The Honorable Frank Pallone

Ranking Member

Energy and Commerce Committee

2125 Rayburn House Office Building

Washington, D.C. 20515

Dear Chairman Thune, Chairman Walden, Ranking Member Nelson, and Ranking Member

Pallone:

A free and open internet is vital to core American values. It affects the freedom to share our thoughts and opinions freely, the ability to organize, and the opportunity to innovate and create. The principle of net neutrality – that all data on the internet should be treated equally, and internet service providers (ISPs) should not discriminate or provide preference to any data, regardless of its source, content, or destination – is what has made the internet the great engine of free expression, organizing, and economic opportunity that it is today.

Unfortunately, a radical draft order proposed by Federal Communications Commission (FCC) Chairman Ajit Pai would silence everyone’s voices and dismantle Americans’ freedoms by rolling back rules that protect net neutrality, giving companies free rein to dismantle the open internet. This proposed order would allow ISPs to control what individuals see and do on the internet without strong oversight for consumers. It departs from 15 years of bipartisan agreement from FCC chairs that the agency has both the authority and the responsibility to protect consumers and competition in the broadband marketplace. This is nothing more than an attack on the rights and freedoms of all Americans, and a gift to already powerful corporations. It is especially damaging to individuals and communities that have historically struggled to share their stories.

The current FCC rules—established in 2015 with the Open Internet Order and upheld in court—protect freedom of expression and an open marketplace for businesses to compete, free of interference from ISPs. These open internet protections are tremendously popular. They are supported by almost 80 percent of Americans in recent polling and also by millions of Americans who commented to the FCC and called Congress to keep the rules in place. Since the 2015 net neutrality protections were adopted, we have seen continued innovation on the internet and increasing revenues and investments from ISPs. Under a free and open internet, everyone wins.

In his proposed order, Chairman Pai removes even the most basic protections for all content to be treated equally online. If the order passes on December 14, ISPs will be able to slow down or even block the content of websites for any reason, stifling free speech and skewing the marketplace.

Despite his rhetoric, since becoming chairman, Pai has steadily stood on the side of big companies and made it harder for all Americans to have access to a free and open internet, and created new obstacles for Americans to connect and communicate. He has set out to not only repeal net neutrality, but to cut aid to families in low-income communities in an assault on Lifeline. Under Pai’s new policies, the digital divide will only deepen, innovative new businesses will struggle to compete, and the voices of millions will be silenced.

With the vote scheduled for December 14, we strongly urge Congress to stand up for the communities you serve by protecting net neutrality. Tell the FCC to pull the vote for this proposed order. A free and open internet protects a free and open society for all Americans—regardless of race, gender, faith, ability or disability, or socioeconomic status. These values are what make us Americans. We urge you to fight for your communities and our society.

We, the undersigned organizations, representing a diverse group of consumer, media, technology, library, arts, civil liberties, and civil rights advocates, artists, and musicians, urge you and your colleagues to support the current net neutrality rules in place, and tell the FCC to stop its proposed plan to end them.

Sincerely,

18MillionRising.org

A Herr Smith & EE Smith Library

Abel J. Morneault Memorial Library

Access Humboldt

Access Now

Access Sonoma Broadband

ADAPT Montana

Akaku Maui Community Media

Alice James Books

Allied Media Projects

Alternate ROOTS

American Association of Colleges for Teacher Education

American Civil Liberties Union

American Library Association

Appalshop, Inc.

Arts & Democracy

Association of College and Research Libraries

Association of Research Libraries

Association of University Presses

Barclay Public Library District

Black Women’s Health Imperative

Boston Library Consortium

Butte Public Library

BYP100

Cahokia Public Library

Campaign for Youth Justice

Carlinville Public Library

CASH Music

CCTV Center for Media and Democracy

Center for Democracy & Technology

Center for Media Justice

Center for Rural Strategies

Center for Social Inclusion

Central Community High School #71

Charleston Carnegie Public Library

Clarke University

Coalition of Religious Publishing Associations

Color Of Change

Common Cause

Common Frequency

Courage Campaign

CreaTV San Jose

Daily Kos

Dayton Public Library

Defending Rights & Dissent

Demand Progress

Dignity and Power Now

Disability Rights Education & Defense Fund

Electronic Frontier Foundation

Ella Baker Center for Human Rights

Engine

EveryLibrary

Faithful Internet

Fight for the Future

Forward Together

Frank Bertetti Benld Public Library

FREE Families Rally for Emancipation and Empowerment

Free Press Action Fund

Free Speech Coalition

Friends of the Earth

Future of Music Coalition

Galatia Public Library

Garrard Co Public Library

Girl Friday

Global Action Project

Government Information Watch

Harristown Public Library District

Hawarden Public Library

HealthHIV

Hollaback!

Homeowners Against Deficient Dwellings

Hope Welty Public Library

Illinois Heartland Library System

Illinois Library Association

Institute for Local Self-Reliance

International Documentary Association

Iowa Library Association

Iraq Veterans Against the War

Kingdom Access TV

LeadingAge

LitNet - The Literary Network

Mahomet Public Library District

Maine Library Association

Marion Carnegie Library

Martinez Street Women's Center

Mason City Public Library District

May First/People Link

Media Access Project

Media Action Center

Media Alliance

Media Mobilizing Project

Memorial Health System Professional Library

Michigan Library Association

Minnesota Library Association

Mississippi Valley Library District

Mobile Beacon

NARAL Pro-Choice America

Nashville Public Library

National Association of Consumer Advocates

National Coalition Against Censorship

National Coalition for LGBT Health

National Consumer Law Center, on behalf of its low-income clients

National Hispanic Media Coalition

National Juvenile Justice Network

National Organization for Women

Native Public Media

New America's Open Technology Institute

New Mexico Library Association

New Progressive Alliance

Oakland Privacy

Online Policy Group

Open Access Connections

Open MIC (Open Media and Information Companies Initiative)

OpenMedia

Oregon State University Libraries & Press

Orinda Progressive Action Alliance

PEN America

People Demanding Action

Popular Resistance

Progressive Technology Project

Prometheus Radio Project

Public Citizen

Public Justice Center

Public Knowledge

Race Forward

Rick Warren Memorial Public Library District

Rights4Girls

Robinson High School Library

RootsAction.org

RYSE Youth Center

Savvy System Designs

Smithton Public Library District

Society of American Archivists

Somos Un Pueblo Unido

South Carolina Small Business Chamber of Commerce

Southwest Organizing Project

St. Ambrose University Library

St. Paul Neighborhood Network

Stinson Memorial Public Library District

The Authors Guild

The Greenlining Institute

The Harry Potter Alliance

The People’s Press Project

The Tully Center for Free Speech

Tri-City Public Library

United Church of Christ, OC Inc.

United Plant Savers

United Spinal Association

Urbana-Champaign Independent Media Center

Venice Public Library

Voqal

Wedsworth Memorial Library

WFNU Frogtown Community Radio

Williamsburg (Iowa) Public Library

Women In Media & News

Women's Institute for Freedom of the Press

Women's Media Center

Woodhull Freedom Foundation

World Wide Web Foundation

Worthington Libraries

Writers Guild of America West

Young Women United

Public Comment 144: December 2017 – Congress – Challenge Trump on Environment

December 18, 2017

Donald Trump has been in office for less than a year and already his presidency is steeped in controversy from mounting evidence and seeming admissions of obstruction of justice to credible and increasing claims of sexual assault to legitimate questions about whether the decisions made and actions taken are to serve the goals of foreign leaders or Trump’s own family at the expense of U.S. citizens, communities and constitutional rights.

As the country grapples with the administration’s wrongdoing and how to address it, Trump has been taking aggressive action to roll back important environmental protections and perpetuate, and even increase, the power of the fossil fuel industry. His actions will only exacerbate the climate crisis we face and threaten the future of the earth.

Members of Congress of conscience, regardless of their political affiliation, should not allow Donald Trump to drive a political agenda of
Π increasing the political power of industry and corporate lobbyists,
Π perpetuating and increasing our nation’s dependence on dirty fossil fuels,
Π advancing more pipelines and energy export facilities that are abusing communities, taking property rights, wrecking environments, and
Π undermining the ability of the clean energy industry to generate sustainable jobs while stimulating a healthy habitat.

We appeal to all members of Congress to recognize the threats that the Trump agenda poses to our national security and our very ability to survive. We are at the nexus of environmental disaster and political chaos. Congress has an obligation to serve the best interests of our republic and must oppose actions by Donald Trump to advance legislation, regulations, policies and decisions that devastate our future.

In the past year Donald Trump and his administration have advanced a series of actions and decisions which will have devastating impacts on our environment, on U.S. citizens, communities, jobs, future generations and the future of our earth. Here is but a short list of concerning actions and decisions taken:

⇒ Advanced a Tax Plan that calls for fossil fuel drilling in the Artic National Wildlife Refuge to pay for the tax cuts that benefit the wealthiest among us as well as corporations already flush with cash;
⇒ Advanced a Tax Proposal that would partially or completely roll back tax breaks meant to encourage wind and solar development;
⇒ Signed executive order to advance approval of the Keystone XL and Dakota Access oil Pipelines;
⇒ Suspended a study of health risks on residents who live near mountain top removal coal mine sites;
⇒ Repealed anti-corruption rule that required energy companies to disclose payments to foreign governments;
⇒ Instructed the EPA to rewrite the ‘water of the United States’ rule in ways that reduce environmental protection;
⇒ Instructed the EPA to stop collecting methane emissions data from around 15,000 oil and gas operations, under the advisement of industry;
⇒ Instructed EPA to roll back fuel efficiency standards that are designed to push down greenhouse gases and other pollutant declaring they are too “costly for automakers”;
⇒ Denied a bid to halt the use of harmful pesticides that EPA scientists identified as being harmful to public health;
⇒ Rolled back limits on toxic discharges, including arsenic, lead, and mercury, from power plants into public water;
⇒ Placed a 2 year pause on regulations that would reduce emission leaks from oil and gas operators, despite regulator acknowledgement that the pollution leaks result in “disproportionate” harm to children ;
⇒ Canceled rule to protect whales and turtles from Fishing Nets
⇒ Took action to shrink Bears Ears and Grand Staircase Monuments and thereby opening the door for fossil fuel development;
⇒ Decreasing the EPA’s budget by 31%, which will result in the elimination of programs to restore the Great Lakes, Chesapeake Bay, and Puget Sound. As well as end the EPA’s lead-risk reduction and radon detection programs and cut funds for the Superfund cleanup program;
⇒ Signed joint resolution passed by Congress revoking the U.S, Department of Interior’s “Stream Protection Rule” that placed stricter restrictions on dumping mining waste into surrounding waterways;
⇒ Withdrew from the Paris Climate Deal;
⇒ Signed an executive order fast-tracking approval for “high priority infrastructure projects.” Any governor or Cabinet secretary may ask for a project to be designated as high-priority if approved by the chairman of the White House Council on environmental Quality, the project will go to the front of the line for any agency required to review and approve it;
⇒ Nominated Robert Powelson, member of Pennsylvania’s Public Utility Commission during the period of rapid natural gas development in Pennsylvania and Neil Chatterjee, an energy policy adviser to US Senate Majority Leader Mitch McConnell, and Kevin McIntyre an attorney who has represented fossil fuel and utility interests for FERC;
⇒ Signed an executive order reviewing any actions in the past decade that expanded existing national marine sanctuaries or established new ones and may have interfered with potential gas and oil development or mineral extraction;
⇒ Instructed the Department of the Interior to review and possibly repeal safety and enforcement standards that protect over 40 national parks from impacts of oil and gas drilling including the Everglades, Grand Teton, and Mesa Verde;
⇒ Directed the EPA to withdraw and rewrite rules that mandate power plants limit carbon dioxide, including new rules promulgated under the Clean Air Act;
⇒ Ordered the Attorney General’s office to stop defending certain measures that would reduce coal plan pollution;
⇒ Withdrawing regulations that require government agencies to consider the effects of climate change when deciding whether to issue permits for fossil fuel production or infrastructure projects such as pipelines;
⇒ Dismantled hydraulic fracking rules from BLM that improved safety standards for hydraulic fracturing wells and ensured contaminated wastewater is appropriately stored and required drilling companies to disclose when they are using toxic chemicals;
⇒ Repeal previous executive orders on climate change that were designed to help prepare the US for impacts of climate change including floods, rising seas, prolonged heat waves, and wildfires;
⇒ Removed Department of Interior’s moratorium on new Coal mining on federal lands;
⇒ Withdrew a rule that would help consumers buy more fuel-efficient tires;
⇒ Overturned a ban on the hunting of predators in Alaskan wildlife refuges.

We are all left to ask the important question “why”. Why has Donald Trump taken these devastating steps and why is Congress not speaking up and speaking out to try and stop him?

Again, we appeal to all members of Congress to:

recognize the threats that the Trump agenda poses to our national security and our very ability to survive; and

to serve the best interests of our republic by opposing the actions of Donald Trump to advance legislation, regulations, policies and decisions that devastate our future.

Respectfully,

Maya van Rossum, the Delaware Riverkeeper, Delaware Riverkeeper Network

Ted Glick, Beyond Extreme Energy

Karen Feridun, Founder, Berks Gas Truth

Todd Larsen, Executive Co-Director, Green America

George Billard, Co-Founder, SCRAM

Kathie Jones, Organizer, Sustainable Medina County

Georgina Shanley, Co - Founder, Citizens United for Renewable Energy (CURE)

Ed Griffith, Liason, New Progressive Alliance

Kevin Zeese, Co-Director, Popular Resistance

Vivian Stockman, Vice Director, OVEC-Ohio Valley Environmental Coalition

Yvonne Taylor, Vice President, Gas Free Seneca

Mary Gutierrez, Executive Director, Earth Action, Inc.

Peter Drobny, Liason, We Are Seneca Lake

Jenni Siri, Founder, Frack Free Four Corners

Jim Vogt, President, Aquashicola/Pohopoco Watershed Conservancy

John Walkup III, President, Greenbrier River Watershed Association

Tara Sumner, Vice President, Advocates for Springfield, NY

Denise Elliott, Representative,

SAYMA Earthcare Action Network

Diane Beeny, Chair, Union County (NJ) Peace Council

Kathleen Maher, Treasurer, Bus For Progress

Tara Zrinski, Co-Chair, NorCo Democratic Women's council environmental committee

Lea Harper, Managing Director, FreshWater Accountability Project

Paul Ferrazzi, Executive Director, CitizensCoalition for a Safe Community

Doug O'Malley, Director, Environment New Jersey

Lakshmi Fjord, Steering Committee Member, Friends of Buckingham

Patricia Hine, Director, 350 Eugene, Oregon

Joseph Campbell, President, Seneca Lake Guardian, A Waterkeeper Affiliate

Lilia Fenton, Owner, Fenton Inn

Cara Schildtknecht, Waccamaw Riverkeeper, Winyah Rivers Foundation

Caroline Katmann, Executive Director, Sourland Conservancy

Vincent DiBianca, Chairperson & Trustee, Homeowners Against Landtaking -HALT

Laurie Granger,Founder, Organizer,

Raging Grannies Eugene (Oregon)

Rouanna Garden, Facilator, Interfaith Earthkeepers of Lane Co. Oregon

Kate McLaughlin, President, Prince William Soundkeeper

Joshua Vana, Member, RAPTORS -Rockingham Alliance for the Protection & Transformation of Our Resources & Society

Kelly Canavan, President, AMP Creeks Council

Debaura James, Representative, Securing Economic and Energy Democracy

Joelle Novey, Director, Interfaith Power & Light (DC.MD.NoVA)

Laura Ramnarace, Director, Resolutions Unlimited

Ann Pinca, President, Lebanon Pipeline Awareness

Asha Canalos, Co-Editor, Co-Director, New Mexico Story Power

Stephanie A. Scherr, Director, ECHO Action NH

Sue Durling, Direct Action Coordinator, NH Pipeline Resistance & Roaring Brook Affinity Group

David Meiser, Co-Founder, Bucks County Environmental Action

Kathy Chapman, Co-Chair, Mason Pipeline Committee

Kim Fraczek, Director, Sane Energy Project

Arianne Elinich, Director, Pennsylvania Earth Guardians

Will Fenton, Owner, Mountain Master Builders

Patty Cronheim, Founder, Hopewell Township Citizens Against the PennEast Pipeline

Debra Borowiec, Coordinator, LAWPA (Local Authority Western PA)

Jerolyn Deplazes, Secretary, Preserve Newport Historic Properties

Sara Steele, Owner, Steeleworks

Diane Wexler, Founder, Northjersey Pipeline Walker

Geremy Schulick, Convenor, New Haven Climate Movement

Ben Martin, Steering Committee Member, 350 CT

Terri Eickel, Director, Interreligious Eco-Justice Network

Bill Schultz, Riverkeeper, Raritan Riverkeeper

Tim Spiese, Board President, Lancaster Against Pipelines

Barbara Jarmoska, President, Project CoffeeHouse

Lisa Zimmerman, Director, SNYFGP

Robert Cross, Board of Directors President, Responsible Drilling Alliance

Ellen Weininger, Director, Educational Outreach, Grassroots Environmental Education

Ernie Reed, President, Friends of Nelson

Lynne Fischer, Founder, New Mexico Climate Action

Rebecca Sobel, Senior Climate & Energy Campaigner,

WildEarth Guardians

Rebecca Sobel, Coordinator, Frack Off Chaco

Terry Sloan, Director, Southwest Native Cultures

Galen Knight Ph.D., President, VitaleTherapeutics, Inc.

Nancy Tate, Coordinator, LEPOCO Peace Center (Lehigh-

Pocono Committee of Concern)

James Michel, Co-Founder, Resist the Pipeline

Jennifer Krill, Executive Director, Earthworks

Courtney Williams, Vice President, Safe Energy Rights Group (SEnRG)

Cheryl Nenn, Riverkeeper, Milwaukee Riverkeeper

Andrew Hudson, Founder, 198 methods

Stuart Anderson, Community Organizer, Concerned Citizens of Otego NY

Gail Musante, Official Signer, Sanford-Oquaga Area Concerned Citizens (S-OACC)

Terri MacKenzie, Chair, EcoSpirituality Group of SHCJ American Province

Cathy Strickler, Founder, Climate Action Alliance of the Valley

James Frisbee, Vice President, RJB Environmental

Martha Girolami, Member, Chatham Research Group

Sharon Furlong, Spokesperson, Bucks County Sierra Club

Walter Tsou, Executive Director, Philadelphia PSR

Ronnie Cummins, Director, Organic Consumers Association

Rabbi Arthur Waskow, Executive Director, The Shalom Center

Rea Miller, Executive Director, People Demanding Action

Robert K. Musil, President &CEO, Rachel Carson Council

Joseph Otis Minott, Executive Director and Chief Counsel, Clean Air Council

Iris Marie Bloom, Executive Director, Protecting Our Waters

Darree Sicher, Founder & President, United Sludge Free Alliance

Nyanna Susan Tobin, Storytellerand Founder, Earth Echoes..

Stories for a small planet

Rev. Sandra L. Strauss, Director of Advocacy & Ecumenical Outreach, Pennsylvania Council of Churches

Michael Gorr, Shaleshock, CNY

Luz Catarineau, Community Member, Amistad Catholic Worker

Carol Gay, President, NJ State Industrial Union Council

Christine Pepin, Council Member, Green Party of Santa Clara County

Anita Mentzer, Executive Director, Unitarian Universalist

Pennsylvania Legislative Advocacy Network (UUPLAN)

Lee Ziesche, Fossil Fuel Resistance Correspondent, Seeding Sovereignty

Heather Cantino, Steering Committee Chair, Athens County (OH) Fracking Action Network

Arrindell, Director, Damascus Citizens for Sustainability

Joe Levine, Director, Citizens For Water

Buck Moorhead, Chair, NYH2o

Ryan Dodson, Owner, Finish Line Painting

Pam Bishop, Principal, Concerned Citizens of Lebanon County

Debaura James, Representative, Securing Economic andEnergy Democracy of SW NM

Roberta Bondurant, Member, Preserve Roanoke/ Bent Mountain

Delta Carney, Secretary/Researcher, Hilltown Community Rights

Lynn Marsh, Trustee/President, Advocates for Cherry Valley

Elaine Tanner, Program Director, Friends For Environmental Justice

Janet Redman, US Policy Director, Oil Change International

Ann Marshall, Organizer, Durham CCAP

Linda Christman, President, Save Carbon County

Elisabeth Hoffman, Advocacy Team Member, HoCo Climate Action

Richmond Shreve, Publisher, No Fracking Bucks [NoFra

ckingBucks.org]

Cathy Kristofferson, Co-Founder, StopNED

Eleanor Amidon, Networker, Pipeline Education Group

Rosemary Wessel, Founder/Program Director, No Fracked Gas in Mass

Jane Winn, Executive Director, Berkshire Environmental Action Team

Glenn Freeman,Co-Founder, OgreOgress productions

Thomas Meyer, Senior Organizer, Food & Water Watch

Pat Bowen, Climate Justice Fighter, 100 Grannies for a Livable Future

Susan Zellner Hogan, Stop Pilgrim Pipeline

Brian R Smith, Founding Member, Willits Economic Localization

Don Ogden, Producer, The Enviro Show

Collin Thomas, Co-Founder, Capital District Against Fracking

Lorraine Crown, Holland Township NJ Citizens Against the PennEast Pipeline

Su Scherer, The Progressive Hub

Heidi Dhivya Berthoud, Secretary, Friends of Buckingham

Becky Meier, Co-Founder, Stop NY Fracked Gas Pipeline

Bernard August, Chairman, Committee Against Plutonium Economics

Diana Wright, Facilitator, PAUSE-People of Albany United for Safe Energy

Colleen McKinney, Co-Founder, People, Not Pipelines

Suzy Winkler, Co-Founder, Concerned Burlington Neighbors

Athena Bauerle, Kiss Electric LLC

Ken Dolsky, Founder, Already Devastated and Devalued Homeowners of Parsippany

Carol Sotiropoulos, Co-Coordinator, No Gas Pipeline in Grafton MA

Elizabeth Peer, Environment Team Lead, Indivisible Lambertville/New Hope

Michael Jacewicz, Plains TownshipCitizens Against PennEast

Carolyn Reilly, Bold Alliance

David Sligh, Wild Virginia

David Sligh, Dominion Pipeline Monitoring Coalition

Barbara Warren, Executive Director, Citizens' Environmental Coalition

Adrienne Morgado, Board Member, 350.org Bucks County

Bonnie Shapiro, President,

Northern NJ Chapter, National Organization for Women

Public Comment 145: December 2017 – State Attorney Generals – FERC Abuses

December 21, 2017

State Attorney Generals:

Dear Attorneys General,

We, representing communities across the nation being victimized by the Federal Energy

Regulatory Commission’s (FERC) misuse of power in its approval of interstate

transmission pipeline projects, are turning to you for both strength and leadership. We

write to urge you to use the full weight of your offices to speak up on behalf of New York State, and all states across the nation, to defend the right of states to review and

approve, or reject (in whole or in part), interstate natural gas transmission pipelines.

FERC has recently declared New York’s rejection of a Clean Water Act 401 Certification

for a pipeline project null and void. Despite that determination being disputed by New

York in court, FERC has gone ahead and granted the pipeline company authorization to

begin construction – thereby seeking to ensure that even a positive outcome in favor of

the state of New York will be rendered meaningless as the project will likely be fully or

significantly constructed by the time such a determination is made.

FERC’s actions in this case are an unprecedented usurpation of a federal authority

specifically delegated to states in order to protect natural resources. In this case FERC’s

overreach not only usurped New York State’s right and responsibility to protect water

quality, but also the process necessary to ensure that protection.

Regardless of your state’s position regarding fracking operations and its infrastructure,

this is an issue of states’ rights. We hope you will join with New York in defending them.

That defense would ideally take the form of an amicus brief or some other formal stance

on the matter.

The Clean Water Act and the Natural Gas Act specifically protect the rights of states to

review and approve, disapprove, or approve with modifications, interstate natural gas

pipeline projects that could harm the water resources of a state.

Section 401 Clean Water Act (CWA) states: “no [federal] license or permit shall be

granted until the certification required by this section has been granted or waived.” 33

U.S.C. § 1341(a)(1). Several courts, including the Supreme Court, have supported this

authority, stating:

“without [Section 401] certification, FERC lacks authority to issue a

license.” City of Tacoma v. FERC, 460 F.3d 53, 68 (D.C. Cir. 2006)

and

Section 401 “requires States to provide a water quality certification before

a federal license or permit can be issued….” PUD No. 1 of Jeerson Cnty. v. Wash. Dept. of Ecology, 511 U.S. 700, 707 (1994) (emphasis added).

In addition, recognizing the important balance of power between the states, this legal

authority preserved by the terms of the Clean Water Act is specifically referenced and

preserved in the federal Natural Gas Act.

As it is entitled to do by these laws, on August 30, 2017, the State of New York denied a

Section 401 Certification for the Millennium Pipeline Company’s Valley Lateral Project.

This denial was issued within the mandatory one year time from the date that New York

determined Millenniums 401 Certification application to be complete, which occurred

on August 31, 2016. Millennium argues that New York state was required to act within

one year from the time the company submitted its permit application on November 23,

2015, despite the fact that New York had issued several notices that the company’s

application was incomplete and identified additional information that was required for

agency decisionmaking.

True to form, FERC sided with the pipeline company and unilaterally determined that

New York state, despite its ongoing vigilance with regards to the project, had waived its

401 Certification authority and therefore Millennium was no longer bound to secure it –

in other words, New York State’s denial of the 401 Certification was, according to FERC,

meaningless as the state no longer had this power.

New York rightfully challenged, in court, this action by FERC to strip from the state its

legal authority to protect its water resources using section 401 of the federal Clean

Water Act.

Undeterred by the state’s legal opposition to FERC’s illegal act, on October 27, 2017 a

member of FERC’s staff issued a notice for the Valley Lateral Project to proceed with

construction. Millennium workers were soon after seen on the site preparing for

construction activity.

New York state was forced to expend additional state resources to file with the Second

Circuit for an emergency stay of the “Notice to Proceed with Construction” issued by the

Federal Energy Regulatory Commission on October 27, 2017. Thankfully, on November

2, the court granted the stay, at least temporarily, until the court is able to consider the

merits of New York’s filing for a Writ of Prohibition.

Across the nation FERC is abusing its power. It is stripping states of their legal

authority, it is undermining the rights of people to protect their property from the

misuse of eminent domain authority, and it is flagrantly ignoring legal obligations to

protect the environment and community rights.

In this situation, FERC is once again overstepping the bounds of the law by seeking to

strip a state of its legal authority to protect its natural resources from harm by pipeline

infrastructure.

We urge you to take strong and swift action to defend the rights of New York state, and

all states, under section 401 of the Clean Water Act by taking a strong and formal stance

against FERC’s actions to both declare New York’s authority waived and by issuing the

Notice to Proceed while this matter is being handled in the courts.

We also urge you to take this moment to call for congressional hearings into FERC’s

many abuses of its power and our laws – without in depth investigation, including

testimony from communities across the nation that have suffered at the hands of FERC,

these kinds of abuses will continue and grow.

The stakes for our environment, for public health, and for states’ legal authority could

not be higher. Our responsibility could not be weightier. We urge you to act now; to act

decisively; to act with commitment to the interests of your state and all Americans; to

act as guardians of the rule of law.

With respect,

Maya van Rossum, the Delaware Riverkeeper, Delaware Riverkeeper Network

George Billard, Co-Founder, SCRAM

Rosemary Wessel, Program Director, No Fracked Gas in Mass

Rebecca Roter, Chairperson, Co-Founder, Breathe Easy Susquehanna County

Sandy Schlaudecker

Kieran Conroy, Interfaith Member of Split Rock Prayer Camp Organizing Committee/Episcopal

Educational Director, Split Rock Sweetwater Prayer Camp of Ramapough Lenape Nation/

also Education/Family Ministry Director St.John’s Episcopal Cornwall)

Cathy Kristofferson, Co-Founder, StopNED

Kathy Chapman, Co-Chair, Mason Pipeline Committee

Dianna Richardson, Vice Chair, Preserve Montgomery County Virginia

Diane Wexler, Co-Founder, Northjersey Pipeline Walkers

Richard Riseling, Board Member, Sullivan Alliance for Sustainable Development

George Santucci, President, New River Conservancy

Kelly Finan

Ellen Darden, Co-Chair, Protect Our Water Heritage Rights Coalition -POWHR

April Keating, President, Mountain Lakes Preservation Alliance

Stephanie A. Scherr, Director, ECHO Action NH & NH Pipeline Resistance

Yvonne Taylor, Vice President, Gas Free Seneca

Joseph Campbell, President, Seneca Lake Guardian, A Waterkeeper Affiliate

Craig Stevens, Founder, Patriots From The Oil & Gas Shales Lakshmi Fjord

Vivian Stockman, Vice Director, OVEC-Ohio Valley Environmental Coalition

Susan McDonnell, Co-Founder, SAPE

Mary Gutierrez, Executive Director, Earth Action, Inc.

Leah Ford

Sandra Kissam, Chair, Orange Residents Against Pilgrim Pipelines

Cara Schildtknecht, Waccaamaw Riverkeeper, Winyah Rivers Foundation

Christine Ellis

Harriet Shugarman, Executive Director, ClimateMama

Lynn Marsh, Douglas DeLong, Trustees/Partners, Landscape Alternatives LLC

Lynn Ellen Marsh, President/Trustee, Advocates for Cherry Valley

Stuart Anderson, Community Organizer, Concerned Citizens of Otego NY

Diana Wright, Facilitator, PAUSE-People of Albany United for Safe Energy

Kelly Canavan, President, AMP Creeks Council

Lorraine Crown, Holland Township NJ Citizens Against the PennEast Pipeline

Paul Ferrazzi, Executive Director, Citizens Coalition for a Safe Community

Will Scott, Riverkeeper, Yadkin Riverkeeper

Matt Shapiro, President, New Jersey Tenants Organization

Diane Beeny, Chair, Union County (NJ) Peace Council

Patricia Wood, Executive Director, Grassroots Environmental Education

Wenonah Hauter, Executive Director, Food & Water Watch

Irene E. Leech, President, Virginia Citizens Consumer Council

Chad Oba, President, Friends of Buckingham

Lora Baum

Sally Jane Gellert, Chairperson, Committee of Correspondence, Occupy Bergen County

Cheryl Nenn, Riverkeeper, Milwaukee Riverkeeper

Russ Layne, Infrastructure Committee Co-Chair, Sustainable Warwick

Paul L. Gierosky, Co-Founder, The Coalition to Reroute Nexus (CoRN)

Susan Van Dolsen

Jeeva Abbate, Director, Yogaville Environmental Solutions

Laurie Granger, Founder and Organizer, Raging Grannies Eugene

Wendy Insinger, Co-Host, Milkweed Poetry Workshop

Roger Moss, President, Community 2000, Community 2000

Suzannah Glidden, Co-founder, Stop the Algonquin Pipeline Expansion

Richard Averitt, Partner, Rockfish Valley Investments

Lea Harper, Managing Director, FreshWater Accountability Project

Greg Pace, Administrator, Guernsey County Citizens Support on Drilling Issues

Jill Wiener, Member, Catskill Citizens for Safe Energy

Jane Winn, Executive Director, Berkshire Environmental Action Team, Inc. (BEAT)

Kristin McCarthy, Director, Delaware Township Citizens Against the Pipeline (DTCAP)

Joshua Vana, Member, RAPTORS – Rockingham Alliance for the Protection & Transformation of Our Resources & Society

Karen London, Co-Founder, Sullivan Area Citizens for Responsible Energy (SACRED)

William F. Limpert

Lynn S. Limpert

Caroline Katmann, Executive Director, Sourland Conservancy

Kate McLaughlin, President, Prince William Soundkeeper

Jill Averitt

Molsie Petty

James Michel, Co-founder, Resist the Pipeline

Linda Christman, President, Save Carbon County

Scott Ballin

William T. Kellner

Donna M. Honigman

Bill T. Kellner

Joseph Plechavy

Ned D. Heindel

Kimberly Bubbenmoyer

Joelle Novey, Director, Interfaith Power & Light (DC.MD.NoVA)

Freck

John Elder, Vice President, Communities for Safe and Sustainable Energy

Sara Gronim,Co-Leader, 350 Brooklyn

Tara Sumner, Vice President, Advocates for Springfield

Ryan Talbott, Executive Director, Allegheny Defense Project

Jess Irish, Member, Sullivan County Residents Against Millennium

Doug O'Malley, Director, Environment New Jersey

SuzyWinkler, Co-Founder, Concerned Burlington Neighbors

Otto Butz, Founder, Milford Doers/Residents of Crumhorn Mountain

Elizabeth Nields, Owner, ElizabethNieldsClayWorkshop

Kevin Zeese, Co-Director, Popular Resistance

Margaret Flowers, Co-Director, Popular Resistance

Dwain Wilder, Editor, The Banner

Michael S. Goodman, Madison350.org

Peter Hudiburg, Founder, Plymouth Friends of Clean Water

Carole Marner, Founding Member, Compressor Free Franklin

David Sligh, Conservation Director, Wild Virginia

Carole Marner

Ted Glick, Organizer, Beyond Extreme Energy

Peter Drobny, Liason, We Are Seneca Lake

Linda Reik, Member, Board of Directors, Sullivan Alliance for Sustainable Development

Gail Musante, Official Signer, Sanford-Oquaga Area Concerned Citizens (S-OACC)

Carol March, Member, frackfreecatskills

Joseph Chernek

Daniel Taylor, Co-Founder, Concerned Residents of Oxford

LuRaye Tate, Principal, 224 Main Street, LLC

Tish Molloy, President, Guardians of the Brandywine

Doug Couchon, Co-Founder, Elmirans and Friends Against Fracking

Barbara DiTommaso, Co-Chair, Creation Care Team, St. Vincent's Catholic Church, Albany

Melanie Mintz, Owner, Melanie Mintz Design

Christine Macpherson, Founder, Complete It Cuomo

Maxine Bogash

William Reinhardt, County Legislator, Albany County Legislature

Judy Sabri, Member, SNYFGP

Jenny Lisak, Co-Director, Pennsylvania Alliance for Clean Water and Air

Ed Griffith, Liason, New Progressive Alliance

Todd Larsen, Green America

Public Comment 146: December 2017 – Health and Human Services – CDC Forbidden Words

December 21, 2017

The Honorable Eric Hargan

Acting Secretary Department of Health and Human Services

330 C Street SW

Washington, DC 20416

Dear Acting Secretary Hargan:

Our organizations were deeply concerned to read the reports in the Washington Post starting on Friday, December 15, 2017, that Centers for Disease Control and Prevention (CDC) budget analysts were informed they are discouraged from using seven words – including ‘“vulnerable,” “entitlement,” “diversity,” “transgender,” “fetus,” “evidence-based” and “science-based”’ – as they prepare the President’s Fiscal Year 2019 budget. As the nation’s premier public health agency, the CDC cannot carry out its mission of improving the health and safety of all Americans when its staff are urged to avoid using basic phrases that are so intrinsic to public health.

CDC serves as the command center for the nation’s public health defense system against emerging and reemerging infectious diseases, and other threats to health and safety. From aiding in the surveillance, detection and prevention of the Zika virus to playing a lead role in the control of Ebola in West Africa and detecting and responding to cases in the U.S., to monitoring and investigating disease outbreaks to pandemic flu preparedness, to addressing chronic diseases. CDC is the nation’s – and the world’s – expert resource and response center, coordinating communications and action and serving as the laboratory reference center. States, communities and the international community rely on CDC for accurate information and direction in a crisis or outbreak. In the United States, CDC serves as a leader in the federal-state-local public health enterprise, which encompasses state, territorial and local health agencies that protect the public every day. None of this can occur unless CDC is able to convey who is at risk, what the risk is and how the science dictates the risk be addressed using established language – including the seven words as appropriate. Science is the bedrock of sound public health and medical decision-making – and it should not be subject to partisan politics. HHS – including CDC – will not be successful in improving the health of Americans affected by these conditions if there is political interference – real or perceived – whether it be aimed at language or at undermining key scientific principles and policies. Our organizations urge the Department of Health and Human Services to assure the Department’s public health professionals and the public that science – and descriptions of it – remain at the heart of its mission. We look forward to your response clarifying these troubling reports.

Sincerely,

1,000 Days

AAHIVM

Academic Pediatric Association

Academy for Eating Disorders

Academy of Nutrition and Dietetics

AcademyHealth

Action for a Better Tomorrow - Sauk Valley

Action on Smoking and Health Addiction Connections Resource Advocate Medical Group Advocates for Better Children's Diets Advocates for Youth African American Health

Alliance Alaska Public Health Association

Ali Forney Center Allergy & Asthma Network

Alliance of Nurses for Healthy Environments

American Academy of Child & Adolescent Psychiatry

American Academy of HIV Medicine

American Academy of Pediatrics American Association for the Study of Liver Diseases

American Association of Colleges of Pharmacy

American Association of Directors of Child and Adolescent Psychiatry American Association of Health and Disability

American College of Occupational and Environmental Medicine American College of Physicians

American College of Preventive Medicine

American Council on Exercise

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

American Federation of Teachers

American Geriatrics Society

American Institute for Medical and Biological Engineering

American Lung Association

American Medical Student Association

American Muslim Health Professionals

American Pediatric Society

American Podiatric Medical Association, Inc.

American Public Health Association

American Sexual Health Association

American Society for Microbiology

American Society of Hematology

American Society of Tropical Medicine and Hygiene

American Statistical Association

American Thoracic Society

Arkansas Public Health Association

Asian Services In Action

Association of Accredited Public Health Programs

Association of Black Cardiologists

Association of Clinicians for the Underserved

Association of Departments of Family Medicine

Association of Family Medicine Residency Directors

Association of Medical School Pediatric Department Chairs Association of Nurses in AIDS Care

Association of Ohio Health Commissioners, Inc.

Association of Population Centers

Association of Schools and Programs of Public Health

Association of Women's Health, Obstetric and Neonatal Nurses Baltimore City Health Department

Big Cities Health Coalition

Blue Ridge Pride Center, Inc.

Boston Public Health Commission

Boulder County Public Health

Bradbury-Sullivan LGBT Community Center

Brooklyn Community Pride Center

Building Home Together

CAEAR Coalition

California Pan-Ethnic Health Network

California Public Health Association-North

Callen-Lorde Community Health

Center Campaign for Tobacco-Free Kids

Cancer Council of the Pacific Islands

Celmatix Inc.

Center for American Progress Center for Reproductive Rights

Center for Science in the Public Interest

Center on Halsted Center on Social Disparities in Health, University of California, San Francisco

CenterLink Chicago Department of Public Health

Children's Environmental Health Network

Cleveland Department of Public Health

Coalition for Health Funding

Colorado Children's Immunization Coalition

Colorado Health Institute

Community Health Councils

Connecticut Public Health Association

Contact Wellness Foundation

Council of State and Territorial Epidemiologists

CRI International Center for Biotechnology Crohn's & Colitis Foundation

Delaware Academy of Medicine / Delaware Public Health Association Department of Obstetrics, Gynecology and Reproductive Biology, Michigan State University

Detroit Hispanic Development Corporation

Detroit Wayne County Health Authority (d.b.a. Authority Health) Doctors for America Dorchester County Health Department

Drexel University Dornsife School of Public Health

East Bay Refugee Forum Element Health, Inc.

Entomological Society of America

Equality New York

EverThrive Illinois

Ferring Pharmaceuticals

FORGE, Inc.

Friends of the Earth

Futures Without Violence

Gay & Lesbian Center of Bakersfield

Gay City: Seattle's LGBTQ Center

GC University Lahore

Georgia Public Health Association

GLMA: Health Professionals Advancing LGBT Equality

Green & Healthy Homes Initiative

Hawaii Public Health Association

Health Resources in Action

HealthHIV

Henry Ford Medical Group

Hepatitis B Foundation

Hispanic Federation HIV Medicine Association

HLN Consulting, LLC

Homeowners Against Deficient Dwellings

Human Impact Partners

Identity Youth Center

Illinois Public Health Association

Immunization Action Coalition

Immunize Nevada

Indivisible Brookfield

Indivisible Carbondale

Indivisible Illinois

Indivisible South Suburban Chicago

Infectious Diseases Society of America

Institute for Basic Research

Institute of Systems Biology

Iowa Public Health Association

IQ Products

Jacobs Institute of Women's Health

JASMYN

Juneau Biosciences, LLC

Kansas City, Missouri Health Department

Kentucky Population Health Institute

KFSHRC

Lakeshore Foundation

Latino Commission on AIDS

LGBT Center OC

LGBT Detroit

LGBT Network

LGBTQ Law Project of NYLAG

Local Public Health Association of Minnesota

Long Island Crisis Center

Long Island Gay and Lesbian Youth (LIGALY)

Long Island LGBT Community Center (The Center)

Long Island Pride

Louisiana Public Health Association

Lung Cancer Alliance

Lynchburg Diversity Center

Magee-Womens Research Institute

March of Dimes

Maricopa County Department of Public Health

Mazzoni Center Medical Students for Choice

Missouri Public Health Association

MJH Grant Consulting

Montgomery County Health Department

Montana Public Health Association

NARAL Pro-Choice America

NASTAD National Alliance for Eye and Vision Research

National Association for Health and Fitness

National Association for Public Health Statistics and Information Systems

National Association of Councils on Development Disabilities

National Association of County and City Health Officials

National Black Justice Coalition

National Black Nurses Association

National Blood Clot Alliance

National Center for Health Research (NCHR)

National Center for Lesbian Rights

National Center for Transgender Equality

National Coalition for LGBT Health

National Coalition of STD Directors

National Collaborative for Health Equity

National Consumers League

National Council of Jewish Women

National Health Care for the Homeless Council

National Health Law Program

National Hispanic Medical Association

National Latina Institute for Reproductive Health

National Medical Association

National Network of Public Health Institutes

National Partnership for Women & Families

National Prevention Science Coalition to Improve Lives

National Recreation and Park Association

National Tuberculosis Controllers Association

National Women's Health Network

Nebraska Association of Local Health Directors

Nevada Public Health Association

New Hampshire Public Health Association

New Mexico Public Health Association

New Mexico Public Health Institute

New Progressive Alliance

New York City Department of Health and Mental Hygiene

North American Primary Care Research Group

North American Society for Pediatric and Adolescent Gynecology North Carolina Public Health Association

North County LGBTQ Resource Center

North Dakota Public Health Association

Ohio Public Health Association

one n ten

Oregon Public Health Association

Origins FTD, Inc.

Out Alliance

Pacific Pride Foundation

PAI Pediatric Policy Council

Pennsylvania Public Health Association

People For the American Way

Physicians for Reproductive Health

Planned Parenthood Federation of America

Population Association of America

Power to Decide

Pregnancy Specialty Center of Texas

Prevent Blindness

Prevention Institute

Pride and Joy Families/Lesbian and Gay Family Building Project Pride at Work Pride Center of the Capital Region

Pride for Youth Program on Endocrine Disruptor Strategies, Commonweal Program on Reproductive Health and the Environment Progressive Congress Action Fund Projects for Environmental Health, Knowledge, & Action, Inc.

Public Citizen

Public Health Advocates

Public Health Association of Nebraska

Public Health Association of NYC

Public Health Institute

Public Health Justice Collective

Pulmonary Fibrosis Advocates Racial and Ethnic Health Disparities Coalition

Rainbow Center

Redstone Global Center for Prevention and Wellness Research!America

Resource Center

Results for America

Robinson Research Institute

S2AY Rural Health Network

Sacramento LGBT Community Center

Safe States Alliance

SAGE

San Antonio Metropolitan Health District

San Francisco AIDS Foundation

School-Based Health Alliance

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

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

SHAPE America - Society of Health and Physical Educators Society for Adolescent Health and Medicine

Society for Pediatric Research

Society for Public Health Education

Society for Reproductive Biology

Society for the Study of Reproduction

Society of General Internal Medicine Society of Teachers of Family Medicine

South Carolina Public Health Association Southern Tier AIDS Program

Southwest Center for Health Innovation

Southwest Detroit Environmental Vision

Spina Bifida Association

State Key Laboratory of Reproductive Medicine, Nanjing Medical University

SunServe

Sustainability and Health Equity Lab/University of California, Berkeley Texas Association of City & County Health Officials

The AIDS Institute

The Arc of the United States

The Center: 7 Rivers LGBTQ Connection

The Consortium

The Cortland LGBTQ Center

The Empowered Patient Coalition

The Feinstein Institute for Medical Research

The Gay and Lesbian Community Center of Southern Nevada

The Immunization Partnership

The Lesbian, Gay, Bisexual & Transgender Community Center

The LGBT Center of Greater Reading

The LGBTQ Center of Long Beach

The LOFT LGBT Center

The Los Angeles Trust for Children's Health

The National Viral Hepatitis Roundtable

The Pride Center at Equality Park

The Research Institute at Nationwide Children's Hospital

The San Diego LGBT Community Center

The Source LGBT+ Center

The Trevor Project

The University of Texas Medical Branch Transgender Law Center Transgender Legal Defense and Education Fund

Trust for America’s Health

Truth Initiative

UC Irvine Center for Occupational and Environmental Health University of Wisconsin Population Health Institute

University Reproductive Associates

USDA-ARS

Utah Public Health Association

Vermont Public Health Association

Washington County Gay Straight Alliance, Inc.

Washington State Association of Local Public Health Officials Washington State Public Health Association

Welcome Back Initiative

West Suburban Action League

West Valley Neighborhoods Coalition

Whitman-Walker Health Wisconsin Alliance for Women’s Health Wisconsin Association of Local Health Departments and Boards Wisconsin Public Health Association

Woodstock Institute

Youth Outlook

Youth OUTright WNC, Inc.

Cc: Dr. Brenda Fitzgerald, Director, Centers for Disease Control and Prevention

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