The New Progressive Alliance periodically makes Public Comments by itself or with other organizations  in support of the Unified Platform. The Public Comments are often made to to federal agencies and legislative bodies in the United States and Canada. They are reproduced here in full and also briefly mentioned with our other activities in the Annual Reports and on our website under "News."  After Public Comment 231 we stopped automatically publishing all comments unless they were made by the New Progressive Alliance.

• Public Comment 224: January 2020 - SEC allow shareholder Free Speech
• Public Comment 225: February 2020 - SEC allow shareholder Free Speech
• Public Comment 226: February 2020-CA Sec. State – Fair Voting
• Public Comment 227: March 2020-Congress-Clean Budget
• Public Comment 228: April 2020-POTUS,Congress-No excess DC Tax
• Public Comment 229: May 2020-Companies Stop ALEC
• Public Comment 230: June 2020-Banks-Don’t drill in Arctic
• Public Comment 231: June 2020-Congress-No Fraud
• Public Comment 232: September 2020 - Washington Ecology-Stop Methanol Refinery
• Public Comment 233: September 2021 - FAA - Space X Environmental Assessment
• Public Comment 234: November 2021 - Donziger Support
• Public Comment 235: November 2021 - Federal Insurance Office - Make Insurance Accountable
• Public Comment 236: January 2022 - California-Stop Solar Tax
• Public Comment 237: January 2022 - DOE - Hanford Nuclear Waste
• Public Comment 238: March 2022 - DOT & NHTSA - Good to use Cameras on EVs
• Public Comment 239: April 2022 Congress - Support PLUM
• Public Comment 240: April 2022 Congress-no Poison Pill Riders
• Public Comment 241: May 2022 Insurance Companies - No Artic Drilling
• Public Comment 242: July 2022 Congress and FCC Reject DISH
• Public Comment 243: December 2022 Congress-Avoid Default
• Public Comment 244: December 2022 Congress-Stop biomass poison pill riders
• Public Comment 245: January 2023 US Dept. of Agriculture-Stop Pipeline

 

Public Comment 224: January 2020 - SEC allow shareholder Free Speech

January 2020

To: Vanessa Countryman, Secretary

Securities & Exchange Commission

100 F St., NE

Washington, DC 20549

Re: File Number S7-23-19

We, the undersigned, are deeply concerned about the need to build an economy that will be successful over the long term. This means we need to ensure that social, environmental, and corporate governance issues facing corporations are effectively addressed. As we know, significant improvement across these issues is needed if our economy and society are to thrive for generations to come.

Investors, including small investors, have an important role to play in identifying for corporations a number of risks and corporate impacts of which they may not be aware. These risks and impacts may damage specific companies and the larger economy.

Since 1934, the shareholder proposal process (Rule 14a-8) has been a positive tool that enables investors to share important information with fellow investors and with corporate management. It is working well and should certainly not be weakened. We are very concerned about the following proposed changes and write to oppose the following:

• Increasing the stock ownership level from $2,000 to a whopping $25,000 for shares held for a year. This flies in the face of the SEC’s claimed support for the “main street individual investor.” The ownership level for filing a resolution should remain at $2,000 regardless of the number of years of ownership. In addition, shareholders should retain their long-standing ability to combine their shares if needed in order to meet the $2,000 threshold needed to file a resolution.
• Increasing the percentage of support a shareholder resolution needs in order to be resubmitted for consideration. The current levels of support are working well and allow new, cutting-edge issues to garner support over time. At present, a first year-resolution needs 3% support, a second-year resolution needs 6% support, and subsequent submissions need 10% support. Increasing those thresholds to 5%, 15%, and 25% will prevent important resolutions from being re-filed, and will not help companies improve.
• Limiting investors or their representatives to one shareholder resolution per shareholder meeting. There is no evidence that this is needed and only serves to limit shareholder engagement.
• Requiring investors to be available for dialogue with corporate management even when they have hired financial professionals for their shareholder advocacy. This disrupts the client-manager relationship and represents a major change to the well-established process.

While some companies claim that the current shareholder resolution process is onerous to them, the average company in the Russell 3000 receives only one shareholder proposal every seven years. The benefits of hearing from investors on key issues should be a priority of corporate management.

Thank you for your attention to these concerns. We look forward to hearing that the shareholder proposal process, Rule 14a-8, will be preserved.

 

Public Comment 225: February 2020 - SEC allow shareholder Free Speech

(In January 2020 the New Progressive Alliance in Public Comment 224 joined many other individuals in individually writing the Security and Exchange Commission not to blindly back corporate power by restricting shareholders from making comments. In addition in February we also signed onto this collaborative letter to the SEC with 16 other organizations urging the same goal.)

 

February 3, 2020

 

Hon. Jay Clayton, Chairman

Hon. Robert J. Jackson Jr., Commissioner

Hon. Allison Herren Lee, Commissioner

Hon. Hester M. Peirce, Commissioner

Hon. Elad L. Roisman, Commissioner

Vanessa A. Countryman, Secretary U.S. Securities and Exchange Commission

100 F Street, N.E. Washington, D.C. 20549

 

RE: Proposed Procedural Requirements and Resubmission Thresholds Under Exchange Act Rule 14a-8 (File Number S7-23-19) 

 

Dear Chairman Clayton and Commissioners Jackson, Lee, Peirce and Roisman,

 

On behalf of the undersigned organizations we respectfully submit comments on the regulation proposed by the Securities and Exchange Commission (SEC, Agency) regarding shareholder resolutions. The proposal process is one of the key ways that shareholders engage with corporate managers about emerging issues that impact long term risks and performance. The proposed changes to the shareholder proposal rules would make it harder for investors to access the levers of shareholder democracy and should not be advanced.

 

We are most concerned about the effect these rules will have on the shareholder proposals filed every year calling on corporations to disclose their political activity to their investors. 

 

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. In his majority opinion in Citizens United, Justice Kennedy assumed that with this new paradigm of spending, there would at least be robust disclosure so that shareholders could assess whether the political activity of their companies presented significant risk. This robust disclosure regime did not exist then and it doesn�t exist now.

 

A company’s political activity- both its election spending and lobbying- is relevant to its shareholders because it can present significant reputational risk if not disclosed and managed properly. Many customers and the purchasing public are paying close attention to whether a company�s political activity lines up with its corporate values. If there is a disconnect companies can face bad press, boycotts, or targeted social media campaigns. 

For example, AT&T came under public scrutiny after it was revealed that the company paid attorney Michael Cohen--who has since been sentenced to three years in prison for campaign finance violations and fraud--$600,000 to consult on policy matters without disclosing that information to shareholders. This was following five years of calls from AT&T�s shareholders to disclose the full extent of its lobbying activity and oversight policies, including payments for direct and indirect lobbying. Clearly shareholders were right to make this demand. It is important for companies to be transparent in order to prove corporate integrity and reputational soundness. 

 

Corporations are vulnerable on the election spending front as well. For example, in 2018 it was reported in the press that Florida- based grocery chain Publix and its leadership donated at least $670,000 to Gubernatorial candidate Adam Putnam who publicly declared himself a “proud NRA sellout.” Publix�s support of this pro- National Rifle Association candidate caused a public uproar as the revelation came only months after the massacre at Marjorie Stoneman Douglas High School in Parkland, Florida. The students protested the company’s support of Putnam by staging �die- ins� at two stores, which led to the company suspending its political contributions.

Understanding the risks posed by undisclosed political activity, shareholder proposals calling on companies to be honest about their political activity are one of the most frequently filed proposals every year, with 93 filed at the start of the 2019 proxy season. 

The shareholder proposal process has been used for successful dialogues between shareholders and management around disclosure. As of 2019, 316 companies in the influential S&P 500 reported to the CPA- Zicklin Index that they disclose some or all of their election-related spending or that they prohibit such spending. Additionally, investors have filed nearly 400 shareholder proposals on lobbying disclosure since 2011, which have resulted in more than 75 agreements that provide greater transparency around corporate lobbying activity. 

 

The new rules the agency is proposing would halt this important progress and make it incredibly difficult for investors to raise political activity disclosure with their companies. Recent analysis from the Sustainable Investments Institute, looking at all environmental, social, and governance (ESG) resolutions voted on in corporate elections from 2010 through late 2019 found that about 30% would not have been eligible for resubmission under the new thresholds. Of those proposals, the ones on political activity, human rights, and climate change would have been most impacted. Of those three most affected categories of resolutions, political spending disclosure resolutions are more than 3 times more impacted than the next impacted issue, human rights reporting. Further analysis found that 40% of political spending disclosure proposals would have been excluded if these rules had been in place from 2004- 2018.

 

Ultimately, the SEC should move forward with a rule requiring all public corporations to disclose their political spending. Investors want more information about how their corporations engage in politics. 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 late 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. 

 

However, in the absence of that rule, the SEC should absolutely not move forward with rules that make it harder for shareholders to engage with their companies over these issues. 

 

The federal agency tasked with protecting American investors should be encouraging a robust system of checks and balances between the owners of corporate wealth and companies’ management, not shutting down the main path for providing shareholder input. The SEC should be facilitating shareholder democracy, not undermining it. This new set of rules should not be advanced.

 

Should staff have any questions, please do not hesitate to contact Rachel Curley at signing organization Public Citizen via email at [email protected] or via phone at 202-454-5195.

 

Sincerely,

 

Amazon Watch

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

Campaign for Accountability

Citizens for Responsibility and Ethics in Washington (CREW)

Fossil Free California

Friends Fiduciary Corporation

Greenpeace USA

Harrington Investments, Inc.

Interfaith Center on Corporate Responsibility 

New Progressive Alliance

No Coal in Oakland

Public Citizen

Sierra Club

U.S. Public Interest Research Group

Voices for Progress

Women's Earth and Climate Action Network (WECAN)

YourStake.org

 

Public Comment 226: February 2020-CA Sec. State – Fair Voting

February 2020

The Honorable Alex Padilla

Secretary of State

1500 11th Street

Sacramento, CA 95814

 

Cc: Los Angeles County Registrar

Dean Logan

Los Angeles County

Supervisors

Senate Elections Committee

Chair Tom Umberg

Assembly E

lections Committee Chair Marc Berman

 

RE: Request for revisions to Voting Solutions for All People’s

(VSAP 2.0) Conditions for Approval

 

Dear Secretary Padilla:

 

The organizations and individuals listed below write to you bec

ause we are gravely troubled by remaining fundamental security flaws in Voting Solutions for All People (VSAP) 2.0, and to respectfully request that you require additional conditions on the approval of VSAP 2.0 to enhance voters’ trust in the integrity of elections in Los Angeles and wherever it might be used in the future.

 

Los Angeles’s VSAP 2.0 has the potential to positively influenc

e the election system market as the nation’s first publicly-owned voting system while also modernizing elections in Los Angeles County. But Los Angeles County has not yet complied with provisions stipulated in SB 360 for research and development that require disclosure of the source code used, which leaves unfulfilled the promise that VSAP 2.0 could become the nation’s first open-source voting system1. We ask the County and State to work diligently to comply with SB360 and to lead California and the nation toward increased election transparency and security by releasing VSAP 2.0’s source code as open-source under a prudent governance plan.

 

We are appreciative that the State imposed key certification re

quirements in your January 24th 2020 conditional approval, particularly the conditions that enhance security, require the option for voters to use hand-marked paper ballots, and require a review of the functionality and usability of the “More” button on BMDs. However, we remain concerned that VSAP 2.0 still has serious flaws that necessitate further conditions on approval. Though we understand it might not be possible for Los Angeles to resolve these issues before the March 3rd primary, we respectfully request that you impose these conditions to the extent possible before the November 2020 election and certainly before granting full certification.

 

• VSAP 2.0 must be re-designed to either use separate ballot b

oxes or to redirect the paper path so that a ballot does not pass under the print head after being reviewed by the voter. 1 SB 360’s explicitly stated intent included that “California receive the benefits of the publicly funded development of a nonproprietary voting system in the state.“ Section 19202(e)(1) allowed local jurisdictions to contract and pay for “Research and development of a new voting system that has not been certified or conditionally approved by the Secretary of State and uses only nonproprietary software and firmware with disclosed source code...” Though Los Angeles County contracted with Smartmatic to develop VSAP, it has not yet disclosed the source code it created and used, and so California has not yet received the benefits that SB 360 intended and explicitly called for.

• We recognize that VSAP 2.0’s design was aimed to give all voters, even those that can’t handle a paper ballot, the opportunity to mark, verify, and cast a paper ballot privately and independently and we commend the intention of this mechanism. However, VSAP 2.0’s design includes a major inherent security flaw in that the ballot passes under the print head after the voter has cast it. This security flaw exists even though the print head is normally lifted by VSAP 2.0 software when the ballot is reinserted. The problem is that if the software is hacked, it can direct the print head to tamper with the verified ballot. University of California at Berkeley Professor Dr. Philip Stark, inventor of risk-limiting audits, summarized the danger in VSAP 2.0’s current design in his January 20th public comment: “The design of the VSAP BMD is defective from a security perspective: the ballot passes under the print head after the voter last sees the paper. This allows the ‘opportunity to mark’ flaw.2 The use of a cam to lift the print head while the ballot is cast is not adequate protection, because that cam is itself controlled by software. The paper path for casting the ballot should not include the print The ballot box should be physically separate from the BMD, or at least not in the same path as the printer.” This flaw could be addressed by redesigning VSAP 2.0’s BMDs to make it mechanically impossible for verified ballots to travel under the print head before being deposited in the ballot box. We understand this change will take time. In the interim we ask you to require Los Angeles to disable the automatic feed mechanism for verified ballots in VSAP 2.0 BMDs and to remove the attached ballot boxes. Instead, the County should provide unattached ballot boxes into which voters can deposit the ballots printed by the BMDs after the voters have verified their votes. This will significantly reduce the risk profile of the VSAP 2.0 system in the short term. Los Angeles could make the same kind of accommodations for voters with disabilities as do other California counties that use BMDs and separate ballot boxes. In the long term it should be possible to redesign VSAP 2.0 so that it’s mechanically impossible for the ballots to pass under the print head after being verified by the voter. Until then, or if that is too costly, requiring the use of traditional ballot boxes, as done in other counties, is necessary to avoid this major security flaw. 2) VSAP 2.0 must be re-designed to not rely on QR codes or barcodes for tabulation. We are also gravely concerned that VSAP 2.0 uses QR codes for actual tabulation. Although voters can verify the selections that the BMD prints on their ballot in their own language, they cannot do so on the QR codes that VSAP 2.0 will actually use to tally votes. This concern is shared broadly by computer scientists and election security experts, who instead recommend that jurisdictions not use ballot-marking devices with QR codes or barcodes.3 In the seminal 2 “Serious design flaw in ESS ExpressVote touchscreen: ‘permission to cheat’”, 9/14/2018, https://freedom-to-tinker.com/2018/09/14/serious-design-flaw-in-ess-expressvote-touchscreen-permission-to-cheat/ 3 See, e.g., Hursti, Harri. Presentation to the Presidential Advisory Commission on Election Integrity, September 12, 2017; Andrew W. Appel, Richard A. Demillo, Philip B. Stark, “Ballot-Marking Devices (BMDs) Cannot Assure the Will of the Voters,” pp. 16-17, April 21, 2019, https://ssrn.com/abstract=3375755.

The election security publication released last year by The National Academies of Sciences, Engineering and, Medicine, the authors stated that barcode-based devices “raise security and verifiability concerns”.4As described in a discussion document from the US’s National Institute of Standards and Technology (NIST): “Malicious or faulty production of a barcode may cause a vote capture device to present the voter with different ballot selections than what will be interpreted by the voting machine. If barcodes are used for tabulation of cast ballots, any modification of a voter’s ballot selections may go undetected and impact the election results.”5Although the State’s conditional approval admirably requires that the jurisdiction verify that the information in the QR code or barcode matches the voter-verified human-readable text when conducting post-election audits, this is not enough. The number of ballots verified in this fashion is too small to catch sophisticated malicious discrepancies, and there would be major questions about how to handle any discrepancies found. Colorado’s Secretary of State has disallowed the use of QR codes and other printed barcodes, saying they pose a threat to election security and verifiability of ballots. Here’s an excerpt from the state’s September 16, 2019 press release: “Colorado Secretary of State Jena Griswold announced that Colorado will stop using ballots with QR codes. The removal of QR codes will increase the security of vote tabulation and ensure voters can accurately verify that their ballots are correctly marked... Although voters can see their vote choices, they cannot verify that the QR code is correct... QR codes could be among the next target of an attack and are potentially subject to manipulation.” We acknowledge that modifying VSAP 2.0’s tallying system to use optical character recognition (OCR) to tally the actual voter-verified human-readable text instead of relying on QR codes would likely take time. However, it is completely feasible. Both the Hart InterCivic Verity Voting system6 and Smartmatic BMD A4-6007 use OCR to tally votes on ballots printed by their ballot marking devices. This change is absolutely crucial for ballots to be truly voter-verified. 3) Please require ballot-on-demand printers for voters who prefer hand-marked paper ballots. We are pleased that the conditional certification of VSAP 2.0 includes the requirement that all polling locations offer voters the option to hand-mark a paper ballot. This provision recognizes that many voters prefer hand-marked paper ballots and many election experts believe they have inherent advantages including creating a paper trail that — unlike a BMD printout — cannot be hacked which increases voter confidence. Nevertheless, using write-in absentee ballots will be highly problematic because requiring voters to actually hand-write their selections — offices, candidates, ballot measure numbers, etc. — will slow voters down dramatically, induce errors that may disenfranchise voters, and make votes hard to read and count. It also 4 “Securing the Vote: Protecting American Democracy,” National Academies of Sciences, Engineering, and Medicine, p. 80, https://www.nap.edu/catalog/25120/securing-the-vote-protecting-american-democracy.5 NIST discussion paper, https://collaborate.nist.gov/voting/pub/Voting/CyberSecurity/BarcodesEncodingPaperJune14-2019.pdf, June 14, 2019. 6 “New Jersey Certifies Newest Hart InterCivic Voting System”, June 4, 2019, New Jersey Certifies Newest Hart InterCivic Voting System 7 “Smartmatic Response to eRFI – New Voting System”, August 24, 2018, https://sos.ga.gov/admin/files/Smartmatic%20RFI_Redacted.pdf

• · 4 violates California Elections Code Section 13103’s requirements that all ballots must list the title of each office and all the qualified candidates in addition to the titles and summaries of measures. Although write-in ballots may be the only solution available for the March primary, this issue must be rectified for the following elections. We therefore urge you to change the conditional certification provisions so they require all vote centers to offer standard, printed paper ballots, either printed in advance or by ballot-on-demand printers, as provided in many other California counties. 4) Please require new, full, and independent testing before final certification. We are very concerned that many of VSAP 2.0’s violations of the California Voting System Standards (CVSS) will not be fixed by the March election — and some not until 2021 — but we appreciate that the State’s conditional certification directed the County to develop modifications to VSAP2.0 to bring it into compliance with the CVSS requirements. However, it is not clear whether the State intends to require the system to undergo further independent testing to affirm that the modifications do, in fact, remediate the violations of the CVSS, and also do not adversely impact the system in another way. As the National Election Defense Coalition and Free Speech For People wrote in their January 20th comment: “VSAP should not receive certification until the areas of non-compliance have been remediated fully, and the modified system is re-tested by an independent testing authority to independently and transparently establish conformity with the CVSS.” Voting system testing and certification best practices dictate that any modifications to a voting system to address non-compliance with standards must be tested by an independent testing authority to establish compliance with the standards. It is improper to simply accept assurances from the County and its contractor(s) that the system has been brought into compliance and no new liabilities created. We therefore respectfully request your office require a completely new set of independent tests and reports by Freeman, Craft, McGregor Group before certification. Summary We understand that some of these requests may be impracticable to implement before the March 3rdprimary. Therefore, we respectfully request that the above additional conditions for certification be adopted by the State and implemented in time for the November 2020 election or as soon as feasible depending on the requirement. In a time when foreign governments and other bad actors are attacking our election systems, it is incumbent upon you as Secretary of State to address these issues to lessen voters’ well-founded doubts about election security. Given the vast resources of those who would attack our elections, such vulnerabilities must be addressed, whether they’re easy or difficult to exploit, because voter confidence is the cornerstone of our democracy. Thank you.  

 

FROM:

California Clean Money Campaign

Trent Lange Californians for Disability Rights

Randy Hicks Free Speech for People John Bonifaz  

5 Indivisible

California Green Team Jennifer Tanner

Money Out Voters In Michele Sutter

National Election Defense

Coalition Susan Greenhalgh

Progressive Democrats of America Alan Minsky

Indivisible San Jose Rebecca Elliott

Indivisible Marin Susan Morgan

SoCal 350 Jack Eidt

Normal Heights Indivisible Mala Wingerd

Indivisible Ventura Adriene Couter

Indivisible CA-33 Duane Bindschadler

Feminists in Action Jessica Craven

Rooted in Resistance Ruth Richardson

Indivisible East Bay Andrea Lum

Indivisible CA-43 Vlad Popescu

Indivisible Sausalito Lisa Bennett

Indivisible San Francisco Anna Krasner

New Progressive Alliance

Progressive Democrats of S.

M. Mountains Dorothy Reik

Dr. Richard DeMillo, Professor of Computer Science, Georgia Ins

titute of Technology*Dr. Douglas W. Jones, Associate Professor of Computer Science, University of Iowa

Dr. Trent Lange, President and Executive Director, California Clean Money Campaign Dr. Philip Stark, Professor of Statistics, University of California, Berkeley*

 

Public Comment 227: March 2020-Congress-Clean Budget

 

Dear Member of Congress,

 

The Clean Budget Coalition, an alliance of labor, scientific, consumer, research, good government, faith, civil rights, community, health, environmental, and public interest groups, writes you to urge FY21 appropriations bills that are free from policy riders that harm the public.

 

No appropriations titles, package of bills, or continuing resolutions (should that be deemed the appropriate path to continue funding the government), should move forward if they contain poison pill policy riders that go against the public interest.

 

Unfortunately, such poison pill riders have existed as favors to corporate and special interests in previous appropriations cycles and therefore a set of “legacy poison pills,” must be removed from the FY21 appropriations bills.  We ask that you take that stance as Congress processes the FY21 appropriations bills—keeping out new policy riders that would harm the public as well as removing those that have become embedded.

 

The American people oppose the abuse of the budget process to roll back public protections. The budget should fund the things that Americans care about, not undo essential safeguards. The American people support policies to: 

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

Again, the public does not support including damaging policy in must-pass appropriations bills that would undo any of these protections, and any previously included policy of that nature must be removed. .

 

We urge Members of Congress to fully fund important public services and to reject any flawed bills that fail to remove poison pill policy riders that would undo essential public safeguards.

 

Sincerely,

 

20/20 Vision

AFL-CIO

AFSCME

Alaska Wilderness Action

American Association for Justice

American Bird Conservancy

Americans for Financial Reform

American Federation of Teachers

Animal Wellness Action

Austistic Self Advocacy Network

Bend the Arc Jewish Action

Center for American Progress

Center for Biological Diversity

Center for Reproductive Rights

Center for Science in the Public Interest

Coalition on Human Needs

Coalition for Health Funding

Common Cause

Communications Workers of America

Consumer Action

Consumer Federation of America

Defenders of Wildlife

Democracy 21

Earthjustice

Endangered Species Coalition

GreenLatinos

Greenpeace USA

Harrington Investments, Inc.

Hispanic Federation

Humane Society Legislative Fund

Impact Fund

Innovative Green Builders

The Institute for Agriculture and Trade Policy

International Fund for Animal Welfare

Jewish Council for Public Affairs

The Leadership Conference on Civil and Human Rights

League of Conservation Voters

Main Street Alliance

NARAL Pro-Choice America

National Association for College Admission Counseling

National Association of Consumer Advocates

National Center for Lesbian Rights

National Coalition for the Homeless

National Community Reinvestment Coalition

National Council of Jewish Women

National Employment Law Project

National Employment Lawyers Association

National Fair Housing Alliance

National Low Income Housing Coalition

National Partnership for Women & Families

National Women's Health Network

National Women’s Law Center

Natural Resources Defense Council

New Jersey Association on Correction

New Progressive Alliance

Ocean Conservancy

Partnership for Policy Integrity

Planned Parenthood Federation of America

People for the American Way

People’s Action

Public Citizen

Public Knowledge

Rachel Carson Council

Safe Climate Campaign

SEIU

Sexuality Information and Education Council of the United States

Sierra Club

Union of Concerned Scientists

The United State of Women

U.S. PIRG

Voices for Progress

The Wilderness Society

Woodstock Institute

Public Comment 228: April 2020-POTUS,Congress-No excess DC Tax

April 14, 2020

 

President Donald J. Trump

Majority Leader Mitch McConnell

Minority Leader Charles Schumer

Speaker of the House Nancy Pelosi House

Minority Leader Kevin McCarthy

 

Dear President Trump and Congressional Leadership:

 

The tyranny of taxation without representation laid upon the people of the colonies by

the British Crown was the fuel that sparked the American Revolution. More than two-

hundred years have passed since the United States declared our independence from that

oppression. Yet, for the more than seven hundred thousand people who call Washington,

D.C., home, this unjust system remains.

 

The CARES Act, recently passed and signed into law, has brought that injustice into

stark relief. The people of D.C. pay all the taxes everyone does, and the federal government treats D.C. as a state in hundreds of ways. However, the CARES Act includes D.C. with the territories, which shortchanges the tax-paying residents of Washington, DC out of $725 million of needed aid to fight the coronavirus.

 

D.C. is not a territory. D.C. bears all the responsibilities of citizenship and deserves

the benefits. This is not a time for opponents of D.C.’s efforts to secure Statehood to make a political statement.

 

Washington, D.C., like every state in the nation, is dealing with unprecedented

challenges and, like every state, needs the full support and resources of the federal

government to ensure the safety and well-being of D.C.’s residents. 

 

We, the one hundred undersigned organizations, demand that in the next

coronavirus relief bill Washington, D.C., be made whole and receive the discretionary

funding that was awarded to each state in the CARES Act.

 

Sincerely,

DC Vote

51 for 51

ACLU of DC

AFSCME

American Arab Anti-Discrimination Committee

American Ethical Union

American Family Voices

American Federation of Government

Employees (AFGE)

American Federation of Teachers

American Postal Workers Union

Americans for Democratic Action

Anacostia Coordinating Council

Audubon Naturalist Society

Autistic Self Advocacy Network

Brookland Huddle for the Future

Can’t Stop! Won’t Stop! Consulting

Center for Disability Rights

Center for Environmental Health

Center for Popular Democracy

Clean Elections Texas

Clean Water Action

Coalition to Preserve, Protect & Defend

Council on American-Islamic Relations

(CAIR)

D.C. Hunger Solutions

D.C. Statehood - Yes We Can!

Daily Kos

DC Chamber of Commerce

DC Democratic Party

DC Environmental Network

DC Marijuana Justice

DC NORML

DC Statehood Coalition

DC Statehood Green Party

Death with Dignity National Center

DemList

Democracy for America

Democracy Initiative

DEMOS

End Citizens United Action Fund

Endangered Species Coalition

Food & Water Action

Friends of the Earth

GLAA

GreenLatinos

Greenpeace US

Hip Hop Caucus

Human Rights Campaign

Indivisible

Institute for Agriculture and Trade Policy

Justice For Muslims Collective

League of Conservation Voters

League of Women Voters of the District of

Columbia

League of Women Voters of the United

States

Metro DC PFLAG

Muslim Public Affairs Council (MPAC)

NAACP

NARAL Pro-Choice America

National Center for Transgender Equality

National Community Reinvestment

Coalition (NCRC)

National Council of Jewish Women

National Education Association

National Employment Law Project

National Equality Action Team

National Federation of Democratic Women

National LGBTQ Task Force Action Fund

National Organization for Women, DC

Chapter

Neighbors United for DC Statehood

NETWORK Lobby for Catholic Social

Justice

New Mexicans for Money Out of Politics

New Progressive Alliance

NORML

Our Revolution

People For the American Way

Physicians for Social Responsibility

Planned Parenthood Federation of

America

Planned Parenthood of Metropolitan

Washington, DC

Poder Latinx

Pride at Work

Public Citizen

Public Justice Center

Rachel Carson Council

Rural Coalition

SEIU

SEIU 32BJ

Sierra Club

Small Planet Institute

Stand Up! for Democracy in DC (Free DC)

Subcontinental Drift

Sunrise Movement DC

The Leadership Conference on Civil and

Human Rights

The United Methodist Church - General

Board of Church and Society

UNITE HERE Local 25

United We Dream Network

URGE: Unite for Reproductive & Gender

Equity

Ward 2 Democrats

Ward 3 Democrats

Ward 7 Democrats

Ward 8 Democrats

Washington Ethical Society

Washington Legal Clinic for the Homeless

Washington Parks & People

 

Public Comment 229: May 2020-Companies Stop ALEC

May 2020

We are writing to urge that you cease your association with, and end your funding of, the

American Legislative Exchange Council (ALEC), which is leading an effort to lobby government officials—including President Trump—to ignore public health officials and discontinue mitigation measures before the COVID-19 outbreak is under control.

ALEC’s work in this effort, which your company is funding through its support of ALEC, poses a serious threat to the health and safety of all us all. Recently, ALEC teamed up with a coalition of far-right lobbying groups to launch the “Save Our Country” campaign protesting the public health quarantine orders put in place to reduce the health risks of COVID-19. As The Washington Post recently reported, the ALEC-led coalition’s focus is on “pushing for the White House and GOP lawmakers to push back against health professionals who have urged more caution."

Among health professionals, the consensus is clear on the risks of rolling back protective measures too early. As a prominent epidemiologist from Columbia University put it, “The math is unfortunately pretty simple. It’s not a matter of whether infections will increase but by how much.” Dr. Anthony Fauci, the leading infectious-disease expert at the National Institutes of Health, has warned that “unless we get the virus under control, the real recovery economically is not going to happen.” Prematurely moving to lift public-safety regulations poses a clear threat to public health.

ALEC’s own partner organizations, such as the Convention of States and FreedomWorks are organizing and promoting dangerous protests in a variety of states in direct violation of public health orders, which we know will lead to the increased spread of COVID-19. These organizations have previously sponsored ALEC conferences and have been active members of ALEC along with your company.

Make no mistake, your continued financial support of ALEC is an active endorsement of this dangerous effort. The money your company is contributing to ALEC is helping fund this campaign—one which is direct contravention of public health guidelines.

ALEC has a long and well-documented history of opposing what is in the interest of the public for the sake of profit. The organization’s agenda has included limiting people’s access to lifesaving healthcare, denying climate science and repealing environmental safeguards that keep our air and water safe and clean, restricting workers’ right to safe working conditions, lobbying on behalf big tobacco corporations against commonsense public health interests, promoting laws that have led to more gun violence, privatizing social safety nets like Medicare, Medicaid and Social Security—the list goes on. ALEC pushes this dangerous agenda behind closed doors, skirting state gift and lobbying laws at lavish resorts where legislators and lobbyists conspire in secret to rig the rules of the game without the public’s consent. Much like ALEC’s anti-transparent operating style, it has also pushed anti-democratic laws that block Americans’ right to vote and restrict voters’ right to know who is funding political campaigns.

We, the undersigned organizations, work on a variety of issues and don’t always agree on every policy, but are well aware of the suffering and anxiety many people are feeling because of the COVID-19 pandemic. Many of those who have gotten sick, are dealing with emergency family care issues, or have lost their job are members of our organizations. We understand the damage the COVID-19 crisis has caused to our communities and economy and support lifting public safety measures when it’s safe, but now is not the time to rush a political agenda or jump to unfounded conclusions. To get through this crisis together, we must follow science and listen to public health experts instead of shutting them out of the conversation.

At this time of crisis, we are asking your company align its values with what’s best for the health and safety of everyone, reject this dangerous political campaign that will only prolong this crisis and put us all at risk, and immediately cease all funding and sever all ties with ALEC.

 

Sincerely,

 

New Progressive Alliance and over 70 other Organizations

 

Public Comment 230: June 2020-Banks-Don’t drill in Arctic

 

Bank of America
US Bank
Truist Bank (recent merger of BB&T and SunTrust)
PNC Bank
Capital One
BNY Mellon
Charles Schwab

We, the Gwich’in Steering Committee, and the undersigned organizations, oppose any efforts to develop oil and gas in the Arctic National Wildlife Refuge in northeast Alaska. As one of the largest U.S. banks, we ask you to join your peers and stand with the Gwich’in Nation by adopting a formal policy to prohibit financing for the exploration, production and transportation of oil and gas in the Arctic Refuge and across the Arctic region.

This is an unprecedented time in our history. Time when we are all seeking refuge. Refuge in family, safety, our health and nature. As we have been reminded so vividly over the past few months, our interconnectedness is inescapable. What happens across the world impacts us at home, and what happens at home impacts others across the world.

The roots of the Gwich’in peoples, our “Sacred Place Where Life Begins” and our ancestral homeland that has sustained us for thousands of years, is under direct attack. Despite the COVID-19 crisis, which is harming our health and economy, the Trump administration continues to barrel forward with destroying sacred places like the coastal plain of the Arctic Refuge. This misguided rush disrespects long-held, popular and bi-partisan protections for the Refuge; suppresses concerns from scientists; and is yet another example of contempt for Indigenous rights in the push to sell our public lands to big oil companies.

It is more important than ever that financial institutions and investors demonstrate their commitment to keeping our heritage intact. Drilling in the Arctic Refuge is short-sighted, risky and unnecessary -- it will exacerbate global warming in an area that is already ground-zero for climate impacts and will cause irreversible destruction to a sacred landscape. You have a responsibility to limit investor risk and drilling in the Arctic Refuge is nothing if not risky and expensive.

The case for protecting this sacred land is so clear that we have already seen other major U.S. financial institutions like Goldman Sachs, JPMorgan Chase, Citigroup, Morgan Stanley and Wells Fargo, in addition to more than a dozen global banks, announce they will not fund any new oil and gas development in the Arctic Refuge and across the Arctic region. These banks recognize the risks and the reputational consequences should they support the violation of such an important landscape and our human rights. The vast majority of the American people continue to oppose drilling in the Arctic Refuge. According to recent polling, 70% of voters oppose drilling in the Arctic Refuge.

Now, in solidarity with the Gwich'in Nation, the organizations below are calling on you to join other financial institutions who have taken a stand by agreeing not to finance fossil fuel development in the Arctic. We are calling on you to not violate the human rights of Alaska Indigenous communities, harm iconic wildlife like polar bears and the Porcupine caribou, and exacerbate the devastating climate impacts we are facing by investing in Arctic drilling. Current and future generations depend on your forward-thinking commitments to human rights and the health of our planet.

The public is watching you more closely than ever before, and if you facilitate the destruction of our sacred homelands, you will have to answer to the Gwich’in Nation and the millions of Americans who stand with us. We will continue to hold any bank, oil company or politician accountable that seeks to benefit from the destruction of the Arctic Refuge. Do not fund drilling in the Sacred Place Where Life Begins.

 

Sincerely,

Bernadette Demientieff

Gwich’in Steering Committee, Alaska

 

 

• 350 Colorado
• 350 Eastside
• 350NYC
• 350 Silicon Valley
• Adrian Dominican Sisters, Portfolio Advisory Board
• Advocates for the Environment
• AIDA (Inter-American Association for Environmental Defense)
• Alaska Wilderness League
• Alternatives North
• American Packrafting Association
• Arctic Audubon Society
• Arctic Treks
• Arctic Wild
• BankTrack
• Basin and Range Watch
• Braided River
• Breadcrumbs Theatre Troupe
• Canadian Parks and Wilderness Society, Yukon Chapter
• Center for Biological Diversity
• Central Colorado Wilderness Coalition
• Climate Hawks Vote
• Congregation of St. Joseph
• Daughters of Charity, Province of St. Louise
• Defenders of Wildlife
• Earth Action, Inc.
• Earthworks
• Ecology North
• Endangered Species Coalition
• Eyak Preservation Council
• Fairbanks Climate Action Coalition
• First Peoples Worldwide
• Franciscan Action Network
• Friends of Alaska National Wildlife Refuges
• Friends of the Earth U.S.
• Fund Our Future
• Glasswaters Foundation
• Great Old Broads for Wilderness
• Green America
• Green Latinos
• Greenpeace USA
• Harrington Investments, Inc.
• Hip Hop Caucus
• Hrrrl Scouts
• Institute for Policy Studies Climate Policy Program
• Interfaith Center on Corporate Responsibility
• Land is Life
• Last Real Indians
• LPESM Riau
• Market Forces
• Mazaska Talks
• Mercy Investment Services, Inc.
• Movement Rights
• National Audubon Society
• National Wildlife Federation
• National Wildlife Refuge Association
• Native Movement
• New Progressive Alliance
• Northern Alaska Environmental Center
• Natural Resources Defense Council (NRDC)
• Nuclear Information and Resource Service
• U.R.S
• Oil Change International
• Physicians for Social Responsibility Pennsylvania
• Progressive Democrats of America
• Rachel Carson Council
• Rainforest Action Network
• Rise and Resist
• Rocky Mountain Wild
• San Juan Citizens Alliance
• San Luis Valley Ecosystem Council
• Save Our Illinois Land
• Sheep Mountain Alliance
• Sierra Club
• Sustaining Way
• The Climate Museum
• The Wilderness Society
• Trustees for Alaska
• Turtle Island Restoration Network
• Unitarian Universalist Service Committee
• Utah Diné Bikéyah
• Western Watersheds Project
• WildEarth Guardians
• Women’s Earth and Climate Action Network (WECAN)

 

Public Comment 231: June 2020-Congress-No Fraud

The Hon. Mitch McConnell (R-KY)

The Hon. Charles Schumer (D-NY)

            The Hon. Nancy Pelosi (D-CA)

The Hon. Kevin McCarthy (R-CA)

 

RE: Coalition Urges Support for the CORE Act

 

Dear Members of the Senate and House:

We strongly urge that Congress strengthen the oversight and anti-corruption measures over the $3 trillion and growing Coronavirus relief legislative programs.

Our organizations represent broad and diverse constituencies across the ideological spectrum concerned about the potential for fraud, waste and abuse of the nation’s largest spending packages in history.

Congress recently passed three relief bills, with the last and most robust being the Coronavirus Aid, Relief, and Economic Security Act, (“CARES Act”), which provide critical aid to citizens and businesses struggling to stay afloat in the wake of the Coronavirus pandemic. The CARES Act contains several notable oversights provisions designed to promote transparency of how these funds are being spent. But these oversight measures have been slow to be implemented, if at all. Even with the limited transparency measures currently in place, many instances of self-dealing fraud and waste have already become public record. The potential for further abuse is enormous, which demands further actions by Congress to protect taxpayer dollars and to ensure that relief funds are being spent as intended and for the good of the nation as a whole.

Sens. Richard Blumenthal (D-Conn.), Elizabeth Warren (D-Mass.) and Chris Coons (D-Del.), and Reps. John Sarbanes (D-Md.) and Pramila Jayapal (D-Wash.), have proposed oversight legislation that would do exactly that: the Coronavirus Oversight and Recovery Ethics Act (“CORE Act”).

Without adding any significant new spending to the Coronavirus relief programs, the CORE Act would:

• Rein in Conflicts of Interest. The bill would impose conflict of interest standards on the hiring of contractors; restrict the revolving door between government officials, lobbyists and contractors; and enhance transparency of financial interests at stake.
• Guarantee the Independence of Inspectors General. The Inspectors Generals (IGs) are charged with monitoring compliance with the laws and ethics rules by government officials as well as recipients of the relief funds. The bill would mandate that IG vacancies be automatically filled without delay and that IGs could only be removed from office for cause.
• Strengthen the CARES Act Oversight Entities. The CORE Act would grant the Congressional Oversight Commission subpoena authority and expand its scope to cover all relief spending. It would require all oversight entities to file regular public records and withhold the salaries of senior executives found not to be in compliance. The bill also would provide additional protections for whistleblowers.
• Restrict Lobbying and Political Expenditures by Recipients of Relief Funds. The bill would require an open book of all lobbying activity targeting relief funds and prohibit closed door meetings and private phone calls by lobbyists and government officials. It would also ban political expenditures by recipients of relief funds for one year after relief loans have been repaid.
• Enhance Transparency. The CORE Act would require all contractors and grantees of relief funds to file regular public reports on how the funds are being spent. The CORE Act offers commonsense oversight and transparency measures solely dedicated to ensuring that our taxpayer dollars are being awarded to those in need and spent according to the intent of the law. These oversight measures would not significantly add to the cost of the Coronavirus relief program and, in fact, could save taxpayers billions of dollars in fraudulent and wasteful contracts and awards.

Experience has taught us that corruption and waste frequently comes with emergency spending programs by the government. Experience has also taught us that oversight measures like those contained in the CORE Act can prevent that corruption and waste. For these reasons we urgently call upon Congress to adopt the CORE Act either as a stand-alone bill or as an amendment to the next relief package, as expeditiously as possible.

Sincerely,

New Progressive Alliance and many other organizations

 

Public Comment 232: September 2020 - Washington Ecology-Stop Methanol Refinery

The New Progressive Alliance has also previously warned various agencies and people about the dangers of this fracked gas methanol refinery in Public Comments 101, 128, 149, 150 and 190.

 

September 30, 2020

 

State of Washington

Department of Ecology

300 Desmond Drive SE

Lacey, WA 98503

 

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

1. Northwest Innovation Works (NWIW) openly and demonstrably lied.

• NWIW misled your agency and the public about the purpose and impacts of the refinery as well as the project’s upstream and downstream climate pollution.
• There is no evidence that the Kalama will displace Chinese coal. There is neither evidence nor an agreement nor even a Chinese statement indicating that this is true.
• NWIW ignores both the amount and potency of methane and fracking pollution.
• NWIW ignores credible scientific studies and instead uses imaginative discredited methods.
• NWIW ignores a whole range of information on fracking to rely on a single fracking area in British Columbia.
• NWIW (repeatedly) that the methanol would be burned in vehicles while all the time telling regulators and the public (repeatedly) that it was instead all for plastics. The difference is millions of tons of carbon pollution.
• The whole NWIW argument rests on the notion that Kalama methanol would “displace” dirtier forms of energy in Chinese and global markets. The displacement argument is based on the false belief that economic modeling can accurately predict global fuel markets, technology developments, Chinese consumer behavior, and regulations for the next 40 years. It should be especially clear in a turbulent year like this one that our models often cannot accurately forecast most of these things even for a single year. Further China is increasingly investing in renewable energy making the predictions even more questionable.
• NWIW would cause a huge amount of climate pollution. It would boost climate emissions “upstream” (from fracking and piping the gas), on-site (as the petrochemical refinery converts gaseous methane into the liquid petrochemical methanol), and “downstream” (from converting the methanol into plastics or vehicle fuel, and then burning that fuel).

 

2. Increased Pollution

• This would be the largest methanol refinery in the world.
• 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 best-guess analysis shows that pollution caused by the facility would be equivalent to 4.6 million tons of carbon dioxide pollution each year. That means that this one project would be equal to around 5 percent of the state’s total climate emissions from all other activities combined. Even worse various rates for gas transportation leakage rates, end-use for the methanol, time-frame for evaluation climate potency, and other factors show that it is possible the facility’s all-in carbon pollution could be as much as 9.4 million metric tons per 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,” #6, 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,” #14, 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 to 5 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 have operated under emergency drought restrictions. For more documentation on the dangers to fresh water   see “The Environment,” #16, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

3. 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 and natural gas rates.

 

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

 

4. Huge Taxpayer Costs

• The company is asking U.S. taxpayers to own the financial risk—up to $2.1 billion—if the proposed methanol refinery fails.
• The Port recently applied for a $11.5 million dollar federal BUILD grant to construct a massive dock in the Columbia River for NWIW’s methanol ships, while the private company is pitching the US Department of Energy on a $2 billion loan guarantee. See BUILD Grant Supporting Documents: 6.26 Letter of support for Port of Kalama BUILD app 2018.4.27 Federal BUILD Grant Announcement
• To feed the methanol refinery’s massive water demand, the Port of Kalama asked the U.S. Department of Agriculture for a $15 million low-interest loan to fund construction of an industrial well on the shores of the Columbia River. See USDA Loan for Well Supporting Documents: 6.26 Port of Kalama Special Meeting Minutes 2014.8.27 Port of Kalama Meeting Minutes
• According to a fiscal analysis prepared for the Washington legislature, existing tax loopholes will allow NWIW to avoid paying $143 million in state and local sales taxes. NWIW successfully lobbied against legislation designed to close those loopholes. See Sales Tax Loopholes Supporting Document: 2.24 Methanol plants could qualify for hundreds of millions in tax breaks, Tacoma News Tribune
• NWIW is asking the U.S. Department of Energy for a loan guarantee. If NWIW goes bankrupt, the federal government could be responsible for paying some or all of the $2.1 billion cost of building the methanol refinery. See DOE Loan Guarantee Documents: Credit Paper on NWIW Request for Loan Guarantee NWIW Presentation Reissue
• NWIW gave the private investment firm Stonepeak the exclusive option to fund construction of the methanol refinery in exchange for part ownership. Much of the money Stonepeak would use to build NWIW’s methanol refinery comes from Washington public employees’ retirement investments. See WA Retirement Funds Document: 12.14 Washington State Bets Retirement Funds on Fracked Gas, Sightline
• The corporate owner of the project, Pan Pacific Energy, has already received between $150,000 and $350,000 in CARES Act loans. According to Propublica, the loan was to maintain 8 jobs, and it can be forgiven entirely under certain circumstances.

 

5. 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. Further China could also use methanol as a fuel source which would worsen climate impacts. The world methanol market has been oversupplied as recently as 2008 when many plants were just starting up. As China’s economy cools, it remains obvious that profits are not sustainable.

Conclusion:

Consider the record of dishonesty by Northwest Innovation Works, total pollution, the higher utility rates, huge taxpayer costs, and the overwhelming evidence this is bad business plan. Then please oppose the proposed methanol refinery in Kalama, Washington.

 

Public Comment 233: September 2021 - FAA - Space X Environmental Assessment

Ms. Stacey Zee

SpaceX PEA, c/o ICF, 9300 Lee Highway

Fairfax, VA 22031

 

[email protected]

 

The New Progressive Alliance at http://www.newprogs.org/ congratulates the FAA on its thorough, fair and comprehensive draft environmental review for the proposed SpaceX program in Boca Chica, Texas. We urge the FAA to accept SpaceX construction and activities at Boca Chica. We oppose activities causing damage to the environment such as line 3, fossil fuel expansion, and fossil fuel subsidies; not legitimate industrial activities. We think these SpaceX activities do not constitute an environmental danger and should be supported.

The FAA's evaluation of a permit or license application includes a review of 1) public safety issues; 2) national security or foreign policy concerns; 3) insurance requirements for the launch operator; and 4) potential environmental impact. We will comment on one, two, and four.

 

Public Safety Issues

Space X will use Operational Closures as described in S.4.8 and the extensive Mitigation Measures as described in Table S-4 to maximize safety. SpaceX has shown with extensive activities since 2002 that it values safety and testing to validate its space activities. SpaceX activities pose no significant public safety issues.

National Security or Foreign Policy Concerns

We put humans on the moon in 1969 – over half a century ago. There is no physical law or history guaranteeing we will forever maintain that lead. An ever increasing number of countries are using and even launching satellites and space probes. Despite this, SpaceX remains the only United States company that has reached orbit not based upon decades old designs. We need to move beyond legacy space if we are to remain competitive. SpaceX’s activities at Boca Chica are the best and only chance for the United States to maintain its position as a leader in space.

Potential Environmental Impact

The New Progressive Alliance agrees with S.5 Summary of Environmental Consequences. Space X operations have a negligible effect on the environment. What we oppose is the continual expansion of and giving huge subsidies to fossil fuels.

We support Space X construction as described in S.4.9, specifically the solar farm. Solar energy has proven to be effective in reducing greenhouse gases. See part 18 of this reference for documentation: http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty Other construction activities will have minimal environmental impact based upon previous experience.

 

Conclusion

Since Space X has an almost 20 year record of innovation and reliability. Their emphasis on reuse means less environmental consequences, less cost, and greater reliability.

Certainly there are uncertainties, but this draft environmental review does an excellent job of setting out the likely parameters. SpaceX has shown both ability and a commitment to adjust to changing conditions. The New Progressive Alliance urges the FAA to accept SpaceX construction and activities at Boca Chica.

 

Public Comment 234: November 2021 - Donziger Support

The New Progressive Alliance wrote an encouraging letter to Steven Donziger, a human rights and environmental lawyer and activist illegally imprisoned in the United States. We along with Amnesty International and the United Nations support whistle blowers and human rights activists such as Donziger and Assange.

 

November 12, 2021

 

Steven Donziger

Register No: 87103-054

Federal Correction Institution

Pembroke Station

Danbury, CT 06811

 

Be aware and remember that Amnesty International, the New Progressive Alliance, the United Nations, and many other organizations and people have not forgotten you.

Even if main stream media looks the other way, we regularly post about your case on multiple social media sites. We will continue to do this on a continual basis.

As a retired lawyer and environmentalist, it breaks my heart to see where the United States is on civil rights and the environment. We wish and pray that strength, blessings, and a bright future be yours.

 

Public Comment 235: November 2021 - Federal Insurance Office - Make Insurance Accountable

Director Seitz,

Thank you, Federal Insurance Office, for taking up the issue of climate change and insurance. 

The New Progressive Alliance believes federal regulation should only be invoked when necessary for a greater public good or when necessary for the survival and competitiveness of an industry. We believe both conditions are present here.                                                                                    

The Problem

The disastrous effects of fossil fuels are documented in the article “The Environment” sections one and three at  http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

Insurance companies are fueling climate change. They provide coverage for fossil fuel wells, pipelines, and refineries. They also invest billions into companies that produce fossil fuels. 

Though insurance companies are uniquely vulnerable to the impacts of climate change they continue to invest in fossil fuels that will only make the climate crisis worse.

In California, homeowners are struggling to find insurance in wildfire-prone areas. Hurricane-devastated communities in Louisiana wait months for the claims payments they need to rebuild, if they recover insurance money at all. These changes in the availability and affordability of insurance will have the biggest impact on the most vulnerable communities, those already on the frontlines of climate chaos. Minorities and low-income people are most at risk of losing coverage and protection in the wake of a climate crisis. The Federal Insurance Office should call attention to the harm insurers are doing by abandoning these communities. 

It is necessary to hold insurance companies accountable for the harm they cause to vulnerable communities as they take advantage of and contribute to the climate crisis.

The Solution

The Task Force on Climate Related Financial Disclosures recently recommended that insurers report on their insured emissions. This full disclosure should be the bare minimum.

It is in both the public’s best interest as well as the insurers’ best interest to act now to limit the insurance industry’s contributions to climate change. The Federal Insurance Office should use the full extent of its authority to thoroughly investigate how insurance companies take advantage of and contribute to the worsening climate crisis.

At a minimum insurers should disclose insured emissions and losses on those insured emissions. It is in both the public and the insurer’s interest to also limit or stop insuring and investing in fossil fuels.

 

Public Comment 236: January 2022 - California-Stop Solar Tax

January 12, 2022

The Honorable Gavin Newsom
1021 O Street, Suite 9000
Sacramento, CA 95814

 

California Public Utilities Commission

[email protected]

 

California usually leads in renewable energy which has been very good for the people and the economy. An exception is the proposed Solar Energy tax which would buck this beneficial trend.

The New Progressive Alliance at http://www.newprogs.org/  has California members which have invested at their own expense in renewable energy. This tax would invalidate both their investment and the federal program to encourage renewable energy. See https://solarbuildermag.com/residential-solar/californias-nem-3-0-proposal-impact-on-solar-value-fees-could-add-up-to-more-than-the-cost-of-the-systems-themselves/

This Solar Tax is a triple blow to renewable energy.

First is the tax which unfairly taxes renewable energy.

Second is the reduction in prices in selling renewable energy back to the grid.

Third, it is unfair to those who invested in solar energy under NEM1.0 and NEM 2.0 and were guaranteed rules would be in place for 20 years. To change an existing contract to 15 years is unfair and probably illegal. This means more money spent by California on litigation.

This solar Tax flies in the face of common sense because California needs to provide more rather than less energy resiliency in the face of unprecedented wildfires and grid outages.   

 

Public Comment 237: January 2022 - DOE - Hanford Nuclear Waste

January 29, 2022

Department of Energy

Subj: Hanford Nuclear Waste and the Test Bed Initiative

The New Progressive Alliance at http://www.newprogs.org/  urges the DOE to use the Test Bed Initiative to check an alternative to the present unsatisfactory DOE plans putting off removal and treatment of Hanford nuclear waste until the 2040s.

Hanford’s tanks hold some of the nation’s most toxic and radioactive waste which have been stored there since the 1940s when we were in a desperate war and before there were safety standards. There are 13 million gallons of leaking nuclear wastes in Hanford’s older Single-Shell High Level Nuclear Waste Tanks which has already been shown to have entered Hanford’s soils, groundwater, and the Columbia River. There has been no full scientific investigation of health effects, but there are plenty of reports by local doctors.

Initial tests from High-Level Nuclear Waste Tank SY-101 were successful and suggest that wastes can be fully removed and treated at much less cost than the unproven “supplemental treatment,” for which USDOE is considering use of “grout” or cement and burying the waste in a Hanford landfill. That landfill will leak and re-contaminate groundwater and pose risks for thousands of years.

The New Progressive Alliance urges the Department of Energy to use the Test Bed Initiative and consider it as an alternative to the present plans for Hanford nuclear wastes which are too little and too late.

 

Public Comment 238: March 2022 - DOT & NHTSA - Good to use Cameras on EVs

March 18, 2022

Subj: use of cameras to replace mirrors

The New Progressive Alliance at http://www.newprogs.org/  encourages the National Transportation Highway Safety Administration and the Department of Transportation to support using cameras instead of traditional mirrors in automobiles for the following reasons.

• It is safer because cameras give a consistent fixed picture and do not have to have the mirrors constantly be readjusted. The reality is people do not adjust their mirrors before each drive.
• It is safer because in tight spaces a side mirror is far more likely to cause damage.
• Side mirrors cause additional drag which is bad for fuel consumption.
• It allows the American automotive industry to better compete with other companies which are doing away with side mirrors.
• Automatic driving with FSD is coming whether it takes two years or twenty years. Using cameras is a necessary step to remain competitive.
• Requiring side mirrors when they are unnecessary puts the United States at a disadvantage.

 

Public Comment 239: April 2022 Congress - Support PLUM

April 2022

The Honorable Chuck Schumer The Honorable Mitch McConnell

Majority Leader Minority Leader

United States Senate United States Senate

 

Re: Support for Periodically Listing Updates to Management Act (The PLUM Act, S.857)

Dear Majority Leader Schumer and Minority Leader McConnell: 

On behalf of the undersigned bipartisan group of civil society organizations, we write to urge passage of the Periodically Listing Updates to Management Act (PLUM Act, S.857), which would increase transparency and oversight of the most senior leaders of the Executive Branch. The Homeland Security and Governmental Affairs Committee voted to favorably report the bipartisan legislation on March 30, 2022.

The publication United States Government Policy and Supporting Positions, commonly called the Plum Book, is a congressional document published every four years that lists more than 9,000 political appointees. It contains information on senior federal civil servants in the legislative and executive branches that may be subject to noncompetitive appointment (e.g., agency heads and policy advisors). In other words, it contains positions that often have a close and confidential relationship with the agency head or other key officials — plum positions.

Appointments and vacancy information contained in the Plum Book rapidly go out of date as a consequence of the report’s infrequent publication. As amended, the PLUM Act would modernize the Plum Book and annually publish online an updated directory of senior government leaders. It requires the Director of the U.S. Office of Personnel Management “to establish and maintain a public directory of the individuals occupying Government policy and supporting positions.” Publication of the physical book would sunset after a few years. The PLUM Act would resolve an important issue raised by the Government Accountability Office, which noted in a March 2019 report that “there is no single source of data on political appointees serving in the executive branch that is publicly available, comprehensive, and timely.” It would address GAO’s conclusion that such a source of “information would facilitate congressional oversight and hold leaders accountable.” 

An online PLUM book would facilitate independent review and analysis related to office vacancies and appointments. Publication may also increase visibility for these job opportunities and encourage a wider pool of diverse candidates to pursue these positions. We would welcome the opportunity to discuss this further. Please contact Daniel Schuman, Policy Director for Demand Progress at [email protected] or 240-237-3930.

 

Public Comment 240: April 2022 Congress-no Poison Pill Riders

April 2022

Dear Senators and Members of Congress,

The Clean Budget Coalition – an alliance of labor, scientific, consumer, research, good government, faith, civil rights, community, health, environmental, business, and public interest groups – urges you to pass FY23 appropriations bills free from policy riders that harm the public.

No appropriations package should move forward if it contains “poison pill” policy riders that go against the public interest. Unfortunately, such poison pill riders have existed as favors to corporate and special interests in previous appropriations cycles and therefore a set of “legacy poison pills” must be removed from the final FY 23 appropriations bills. And while we are encouraged that Congress was recently able to pass and sign an updated spending budget for the 2022 Fiscal Year, avoiding yet another year of relying on an insufficient continuing resolution funding structure, we continue to be dismayed that legacy riders remained in the final spending package. These legacy riders do not represent the will of the American people, but harmful special interest groups that wish to circumvent the legislative process through this misguided budgetary practice. It is long past time for these riders to be removed.

Congress has one more opportunity to pass clean spending bills that place the focus of the federal budget and appropriations process back where it belongs: on providing ample funding and advancing the public interest. We ask that you make it a priority to keep out new policy riders that would harm the public and remove legacy riders that have been embedded in previous appropriations bills.

However, we do wish to express our gratitude that appropriators in both the U.S. House and U.S. Senate were receptive to our coalition’s requests early in the previous budget negotiating period, removing several longstanding legacy riders from draft versions of the FY22 fiscal bill. And now as we enter FY23 negotiations, it is crucial that congressional lawmakers are even more firm in their commitment to keeping all harmful measures out of the final spending package. People across the nation have always opposed the abuse of the budget process to roll back public protections or create loopholes that hinder accountability. Especially as we look forward toward a post-pandemic future, the federal budget should fund priorities that Americans truly care about, not hack away at essential safeguards. The American people support policies to:

• Ensure safe and healthy food and products;
• Restrain Wall Street abuses;
• Protect our air, land, water and wildlife;
• Safeguard fair and safe workplaces;
• Guard against consumer rip-offs and corporate wrongdoing;
• Defend our campaign finance, election, and census systems, and support D.C. statehood;
• Provide access to justice and fair housing;
• Protect human and civil rights, including students’ protections and services in schools; and
• Guarantee continued access to vital health care services including comprehensive reproductive health care, among other things.

Again, the public does not support the inclusion of damaging policy riders in must-pass appropriations bills that would undo or block any of these protections, and any previously included measures doing so must be removed.

People across the United States deserve a 2023 budget that not only addresses the needs of the present but invests in a better future. For this reason, we urge Members of Congress and Senators to fully fund important public services and to reject any flawed bills that fail to remove poison pill policy riders that would undo essential public safeguards.

Sincerely,

20/20 Vision

AFL-CIO

African American Ministers in Action

AFSCME

Alaska Wilderness League Action

American Association for Justice

American Bird Conservancy

American Federation of Teachers

American Sustainable Business Council

Americans for Financial Reform

Animal Wellness Action

Autistic Self Advocacy Network

Bend the Arc Jewish Action

Blue Ridge Environmental Defense League

Catholics for Choice

Center for American Progress

Center for Biological Diversity

Center for Reproductive Rights

Center for Science in the Public Interest

Clean Water Action

Chapel Hill Organization for Clean Energy

Coalition on Human Needs

Coalition for Health Funding

Common Cause

Communications Workers of America

Consumer Action

Consumer Federation of America

DCVote

Defenders of Wildlife

Democracy 21

Earthjustice

Endangered Species Coalition

Environmental Working Group

GreenLatinos

Greenpeace USA

Harrington Investments, Inc.

Hispanic Federation

Humane Society Legislative Fund

Impact Fund

Innovative Green Builders

The Institute for Agriculture and Trade Policy

Impact Fund

Innovative Green Builders

The Institute for Agriculture and Trade Policy

International Fund for Animal Welfare

Jewish Council for Public Affairs

John Muir Project of Earth Island Institute

The Leadership Conference on Civil and

Human Rights

League of Conservation Voters

Los Padres ForestWatch

Main Street Alliance

NARAL Pro-Choice America

National Association for College Admission

Counseling

National Association of Consumer Advocates

National Association of Social Workers

National Center for Lesbian Rights

National Coalition for the Homeless

National Community Reinvestment Coalition

National Council of Jewish Women

National Employment Law Project

National Employment Lawyers Association

National Fair Housing Alliance

National Low Income Housing Coalition

National Partnership for Women & Families

National Women's Health Network

National Women’s Law Center

Natural Resources Defense Council

NETWORK Lobby for Catholic Social Justice

New Jersey Association on Correction

New Progressive Alliance

Ocean Conservancy

Partnership for Policy Integrity

Planned Parenthood Federation of America

People’s Action

Population Connection

Protect All Children’s Environment

Public Citizen

Public Justice Center

Public Knowledge

Rachel Carson Council

Safe Climate Campaign

SEIU

Sexuality Information and Education Council

of the United States

Sierra Club

Union of Concerned Scientists

The United State of Women

U.S. PIRG

Voices for Progress

Western Watersheds Project

Wildlife Conservation Society

The Wilderness Society

Woodstock Institute

 

Public Comment 241: May 2022 Insurance Companies - No Artic Drilling

To: Chubb, CNA, Liberty Mutual, Markel, RLI, The Hartford, Travelers, and WR Berkley, 

We, the Gwich’in Steering Committee, and the undersigned organizations, have called on you, and continue to call on you and other global insurers to commit to the protection of the Arctic National Wildlife Refuge in northeast Alaska from the harms of fossil fuel development. 

Your peer AIG (American International Group, Inc.) recently became the first U.S. insurance company to issue a policy stating that they will not underwrite or invest in new Arctic energy exploration activities. This makes AIG the first U.S. insurer to limit insurance of the Arctic oil & gas sector. They join 13 insurers and 29 major financial institutions who have restricted support for oil and gas drilling in the Arctic Refuge. This list includes five of Canada’s largest banks along with U.S. financial institutions like Goldman Sachs, JPMorgan Chase, Citigroup, Morgan Stanley, Bank of America, and Wells Fargo. These financial institutions recognize the risks and the reputational consequences they would face should they support the violation of Indigenous Peoples’ human rights and such an important ecosystem.  

We respectfully urge you to join your colleagues and competitors and: 

1. Issue clear, public statements refusing to provide insurance and investment to any energy exploration, development, production, and transportation in the Arctic Refuge and across the Arctic region;

2. Adopt a formal policy to prohibit new insurance products or the extension of existing insurance contracts to cover the exploration, production, or transportation of oil and gas in the Arctic Refuge, including surety bonds, commercial multiple peril insurance, and reinsurance;

3. Avoid financing oil and gas development in the Arctic Refuge by ruling out investments in companies involved in Arctic Refuge development and those that do not have policies prohibiting their own involvement in the Arctic Refuge;

4. Enact a fulsome policy that includes a commitment to operationalizing Indigenous Peoples’ right to free, prior and informed consent. 

 

Our lives and our sovereignty are non-negotiable. We will not allow the destruction of Iizhik Gwats’an Gwandaii Goodlit – the Sacred Place Where Life Begins – which has sustained us since time immemorial. These policies need to be put into place so that our people will continue to have a cultural and spiritual connection to our lands, waters, and animals for generations to come.

It is more important than ever that financial institutions and investors demonstrate their commitment to keeping our heritage intact. Drilling in the Arctic Refuge will cause irreversible destruction to a sacred landscape while being short-sighted, risky, and unnecessary. It will exacerbate global warming in an area that is already ground zero for climate impacts and warming four times faster than the rest of the world. 

In solidarity with the Gwich'in Nation, the organizations below are calling on you to join other financial institutions who have taken a stand by agreeing not to finance or insure oil and gas development in the Arctic. We are calling on you to not violate the human rights of Alaska Indigenous communities, harm wildlife, or exacerbate the devastating climate impacts we are facing by insuring in Arctic oil and gas activities. Current and future generations depend on your forward-thinking commitments to human rights and the health of our planet. 

 

Public Comment 242: July 2022 Congress and FCC Reject DISH

I am writing on behalf of the New Progressive Alliance concerning proposed FCC rule changes for the 12 GHz Spectrum (WT Docket No. 20-443).

The New Progressive Alliance opposes changes to the 12 GHz frequency band after others such as Starlink have made commitments and launched satellites based upon previous rules. The FCC should reject efforts to repurpose and change the rules relating to this spectrum that is used by satellite operators to provide high-speed broadband and other services throughout the world. Allowing an entirely new use of this spectrum would significantly interfere with already established broadband internet connections which others already rely on. Spectrum speculators such as DISH with no hardware want to repurpose the band for uses that would cause widespread interference and substantially degrade already established internet services while offering no alternatives for those who depend on those services for connectivity.

The FCC should be focused on expanding connectivity to Americans, especially those without service or with poor service. It should not be focused on changing the rules to satisfy speculative and poorly-defined technologies and individuals who have no clear plans to help close the digital divide.

Please reject efforts to change the rules regarding the 12 GHz frequency band and conclude this process.

 

Public Comment 243: December 2022 Congress-Avoid Default

December 13, 2022

Dear Representative/Senator:

The prospect of the federal government unable to pay all its obligations in the event Congress fails to increase the debt limit poses an alarming danger to U.S. and global economic stability. Such a default would lead to a steep rise in interest rates, a global market panic, loss of millions of jobs and loss of trillions of dollars in household wealth. Those who threaten breach of the debt limit are playing recklessly with millions of lives. That is why the undersigned 168 organizations concerned with meeting the basic needs of people with low incomes nationwide strongly urge you to use any procedural means necessary to vote before the end of the 117th Congress to increase or suspend the debt limit.

While there are many critically important issues that must be dealt with in the remaining weeks of this Congress, we submit that assuring the U.S. government’s capacity to pay its bills and meet its obligations is an essential act of responsibility that should be approved without delay. Congress enacts spending commitments every year and also makes decisions about revenues. These lawful decisions have required the federal government to borrow money. If members of Congress refuse to adjust the statutory debt limit, knowing that Congress has approved spending and revenues that necessitate borrowing, they would be abdicating their responsibility.

The consequences, according to a 2021 paper by Moody’s Analytics, would be “cataclysmic.” There is no doubt that the cataclysm, whether in 2021 or in the near future, would be most harshly felt by people with the lowest incomes, and their severe hardships would contribute to a downward spiral pulling the whole economy down. If Congress had failed to increase the debt limit in 2021, Moody’s estimated that 6 million jobs would have been lost, unemployment would have risen to 9 percent, and a stock sell-off would have wiped out $15 trillion in household wealth. Even the threat of a default in 2013 led to increased interest rates in shortand long-term Treasury yields, a cost borne by taxpayers. If there were to be a real default, Social Security, veterans and active-duty military would see at least a delay in their payments; if the inability to fund persisted, huge cuts in government services would occur affecting all federal services, including health care, housing, the military, nutrition, education, and much more.

Investments we must make in our children would be severely curtailed; protections for older Americans would be harshly cut as well. We know how vital these services are, and how much your constituents will suffer if payments are delayed or denied. With so much global uncertainty due to war and the continuing global impacts of the pandemic, it is unconscionable to add to economic precarity. With the prior experience that even the threat of default causes harm, we call on you to take that threat off the table, and to commit to a substantial increase in the debt limit or a lengthy suspension before the end of the 117th Congress.

Sincerely,

20/20 Vision DC

ADAP Advocacy Association

Addiction Connections Resource

African American Health Alliance

AIDS Action Baltimore

Akron Bible Church

Alliance for Retired Americans

American Children's Campaign

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

American Geriatrics Society

American Society of Nephrology

Americans for Tax Fairness

Arkansas Community Organizations

Association for Gerontology and Human Development in Historically Black Colleges and Universities

Association of School Business Officials International (ASBO)

Association of University Centers on Disabilities

Atlanta Pride Committee

Avenue Community Development Corporation

Blackbelt & Central Alabama Housing

Brighter Beginnings

Casa Baltimore Limay

Center for Law and Social Policy (CLASP)

Center for Popular Democracy

CenterLink: The Community of LGBT Centers

Child Care Resources, Inc

Child Welfare League of America

Church World Service

Citizen Action of New York

Coalition Of Labor Union Women

Coalition on Human Needs

Communities Actively Living Independent & Free

Community Access National Network

Community Action Agency of New Haven

Community Action Partnership of North Central Missouri

Community Action Partnership of Sonoma County

Community Action Pioneer Valley

Consumer Action

Corporation for Supportive Housing

COVID Survivors for Change

Criminalization of Poverty Project at the Institute for Policy Studies

Death Penalty Action

Demand Progress

Dominican Sisters of Racine, WI

East Bay Housing Organizations (EBHO)

Educare Learning Network

Empower Next Generations

End Hunger Connecticut!

FamilyAid

Feeding New York State

First Focus Campaign for Children

Food Bank of Delaware

Food Bank of Northern Nevada

Food For Thought

Food Research & Action Center (FRAC)

Full Plates Full Potential

Futures Without Violence

Gaithersburg HELP

Georgia Alliance to End Homelessness

Green Mountain Self-advocates

Habitat for Humanity Chicago

Health Care for America Now

Health Care Voices

Healthcare Alternative Systems

Heights and Hills, Inc.

Hispanic Federation

HIV Medicine Association

Hocking Athens Perry Community Action (HAPCAP)

Illinois Action for Children

Illinois Hunger Coalition

Indivisible

Inspirational Gospel Assembly

Island Harvest Food Bank

Japanese American Citizens League

Jewish Family Service of Colorado

Johnson Park Center (JPC)

Just Harvest

Justice in Aging

Kansas Action for Children

Kids Above All

Kids and Car Safety

Laradon

LeadingAge

LiveSafe Resources

Main Street Alliance

Meals on Wheels California

Meals on Wheels Orange County

Methodist Action Program

Mile High United Way

Mount Vernon United Tenants

Mt. Graham Safe House

Multi-Service Center

Natchez Housing Authority

National Advocacy Center of the Sisters of the Good Shepherd

National Alliance to End Homelessness

National Alliance to End Sexual Violence

National Association for Hispanic Elderly

National Association of Councils on Developmental Disabilities

National Association of RSVP Directors

National Association of Social Workers

National Black Justice Coalition

National Child Care Association and National Early

National Coalition Against Domestic Violence

National Committee to Preserve Social Security and Medicare

National Council for Community and Education Partnerships

National Council of Jewish Women

National Council on Aging

National Disability Institute

National Employment Law Project

National Health Care for the Homeless Council

National Homelessness Law Center

National Housing Resource Center

National Immigration Law Center

National Leased Housing Association

National Low Income Housing Coalition

National NeighborWorks Association

National Network to End Domestic Violence

National Priorities Project at the Institute for Policy Studies

National WIC Association

National Women’s Law Center

NETWORK Lobby for Catholic Social Justice

New Hampshire School Administrators Association

New Jersey Association on Correction

New Progressive Alliance

New York StateWide Senior Action Council

Northwest Harvest

Office of The Rev. Dr. Chuck Currie

One Roof Community Housing

Patriotic Millionaires

Prevent Blindness

Prosperity Works

Public Advocacy for Kids (PAK)

Public Justice Center

Rachel Carson Council

REACH Beyond Domestic Violence, Inc.

RESULTS

ROC United

RootsAction.org

San Diego for Every Child

San Juan Center

School-Based Health Alliance

Sisters of Charity of Nazareth Western Province Leadership

Sisters of the Presentation

Social Security Works

Society of General Internal Medicine

Spectrum Health Care

St Francis Xavier Church

St. Francis Center

The Affordable Homes Group

The AIDS Institute

The Foodbank, Inc.

The Gerontological Society of America

The National Domestic Violence Hotline

Turning Point

Ujima Inc., The National Center on Violence Against Women in the Black Community

UnidosNow

United Church of Christ Justice and Local Church Ministries

Universal Income Project

Urban Resources Inc.

Utah Afterschool Network

Utahns Against Hunger

Valley Oak Children's Services

Voices for Progress

Voices for Vermont's Children

We All Rise

West Chester Food Cupboard

West Virginians for Affordable Health Care

Westfield Community Center Association

Witnesses To Hunger NH

 

Public Comment 244: December 2022 Congress-Stop biomass poison pill riders

December 7, 2022

To all members of Congress:

On behalf of more than 100 local, state, and national organizations, representing millions of

Americans who strongly support protecting our air, land, water, climate, and biodiversity, we

urge you to exclude environmental “poison pill” policy riders from the final FY 2023

appropriations legislation. While we commend the House and Senate for removing many of the

longstanding environmental riders from their respective Interior & Environment appropriations

bills, we ask that you exclude all the anti-environmental legacy riders from the final

appropriations package and refrain from adding new ones.

Specifically, we have concerns with Congress once again including a rider entitled “Policies

Relating to Biomass Energy” that directs federal agencies to treat forest biomass energy as

“carbon neutral” and “renewable.” Every year since 2016, this rider has been included in the

final enacted appropriations package, even when the House has omitted this language from its

own appropriations bill, or as happened last year, both chambers had passed bills with amended

language. It is scientifically indefensible to characterize forest biomass energy as “carbon

neutral” and inappropriate for Congress to legislate the science of biomass and climate change.

Multiple credible and deliberative scientific bodies in the US and internationally, including the

IPCC and the EPA’s own Science Advisory Board, have rejected the notion that burning wood

for energy is categorically carbon neutral. On the contrary, the science has continued to mount

that promoting forest biomass for energy can have significant damaging impacts on the climate

and our native forest ecosystems. Far from being instantaneously renewable, like wind and solar,

it takes decades to centuries for trees to reach maturity. Additionally, we are concerned that

facilities where forest bioenergy feedstocks are processed or utilized disproportionately burden

low-income communities and communities of color with harmful air pollution and other

environmental hazards.

While we appreciate that both the House and the Senate amended the language in their respective

bills this year to remove the objectionable “carbon neutrality” language, we believe that the new

language is still problematic. Directing federal agencies to establish policies that reflect the

“carbon benefits” of forest biomass energy amounts to a continuation of Congressional

interference with federal agencies’ scientific process. We therefore urge you to remove the

biomass energy provision altogether (Section 432 of the Interior & Environment appropriations

bill).

In addition, our groups strongly oppose Senator Manchin’s dirty permitting deal and urge you

not to attach this to the final appropriations bill or any other “must-pass” legislation that

Congress takes up this year. In addition to fast-tracking fossil fuel infrastructure, stifling

community engagement, and undermining bedrock environmental laws such as the National

Environmental Policy Act, this proposal could also fast-track large-scale biomass power projects,

to the detriment of frontline communities who continue to bear the brunt of harm from polluting

energy facilities.

In the coming weeks, Congress has an opportunity to pass a clean budget that contains no

harmful or extraneous policy riders. We appreciate the progress the Committees have made this

year and urge lawmakers to keep anti-environmental provisions out of the FY 2023 omnibus

entirely, whether they are new this year or carried forward from previous appropriations bills.

 

Sincerely,

The New Progressive Alliance and 106 other organizations

 

Public Comment 245: January 2023 US Dept. of Agriculture-Stop Pipeline

To: The Honorable Dr. Homer Wilkes

Under Secretary, U.S. Department of Agriculture. George Washington & Jefferson National Forests

Subj: Mountain Valley Pipeline and Equitrans Expansion Project Supplemental EIS #50036

From: New Progressive Alliance

Dear Dr. Wilkes:

The New Progressive Alliance opposes amendments to 11 crucial standards that are essential for protecting the Jefferson National Forest. We urge you to select Alternative (1) “No Action” and reject the proposed 11 changes for two reasons.

 

The first reason is Mountain Valley Pipeline are not entitled to environmental destruction just to expand fossil fuel infrastructure.

-Mountain Valley Pipeline do not provide sufficient assessment, monitoring, modeling, nor real-world analyses to support changes to the Forest Plan.

- The proposed changes serve as conveniences for the developer of one fossil fuel project to the detriment of lands held in the public trust.

-Mountain Valley Pipeline has a long history of improper and inadequate sediment and erosion control practices during construction resulting in more than 500 violations of permit conditions and environmental standards in Virginia and West Virginia.

-There is no need for the Mountain Valley Pipeline. To equate the damage done to treasured national forest land with “economic benefit” is a false equivalency.

-Look at the big picture. Pipelines worldwide leak and cause damage. There is an ever increasing use of renewable energy.  Together these two trends suggest a denial of the proposed changes.

 

The second reason is damage to the Jefferson National Forest. Remember, the Forest Service’s mandate to “sustain healthy, diverse and productive forests and grasslands for present and future generations.”

- It is reasonable to expect that new construction would cause additional adverse impacts to riparian zones, which serve an important role as buffers for waterways from sedimentation.

- The lowering or eliminating standards for soil health, old-growth forest, forest edge, and species competition will harm the Jefferson National Forest.

- The loss of old-growth forest, which plays a crucial role creating topsoil, simply cannot be mitigated.

- Allowing the Forest Service to break 11 of its own rules to accommodate Mountain Valley Pipeline sets a bad precedent for similar rule-breaking on national forests across the country.

 

For these reasons please reject the 11 proposed amendments to prevent unnecessary damage to Jefferson National Forest.

Sincerely,

Ed Griffith

New Progressive Alliance