Public Comments from 2020 on (224 on)

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 publishing the comments in full 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 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.




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)


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


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, 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,

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, NIST discussion paper,, 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,

  • · 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.  



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.




20/20 Vision



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


Endangered Species Coalition


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


Sexuality Information and Education Council of the United States

Sierra Club

Union of Concerned Scientists

The United State of Women


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.



DC Vote

51 for 51



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


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 Statehood Coalition

DC Statehood Green Party

Death with Dignity National Center


Democracy for America

Democracy Initiative


End Citizens United Action Fund

Endangered Species Coalition

Food & Water Action

Friends of the Earth



Greenpeace US

Hip Hop Caucus

Human Rights Campaign


Institute for Agriculture and Trade Policy

Justice For Muslims Collective

League of Conservation Voters

League of Women Voters of the District of


League of Women Voters of the United



Muslim Public Affairs Council (MPAC)


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


Neighbors United for DC Statehood

NETWORK Lobby for Catholic Social


New Mexicans for Money Out of Politics

New Progressive Alliance


Our Revolution

People For the American Way

Physicians for Social Responsibility

Planned Parenthood Federation of


Planned Parenthood of Metropolitan

Washington, DC

Poder Latinx

Pride at Work

Public Citizen

Public Justice Center

Rachel Carson Council

Rural Coalition



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


United We Dream Network

URGE: Unite for Reproductive & Gender


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 Securitythe 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.




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.



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.


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  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
  • 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
  • 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


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.


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 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: Other construction activities will have minimal environmental impact based upon previous experience.



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

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.



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