Testimony, Comments and Letters to Agencies

The Member Scholars of the Center for Progressive Reform frequently testify before congressional committees on a range of topics related to the organization’s core issues.  In addition, Member Scholars often communicate with federal agencies, filing comments on proposed regulations, or bringing important matters to their attention. 

Browse Testimony or Letters and Comments.

 
CPR Member Scholars’ testimony before congressional committees include:
 
2009
2008
  • Bill Buzbee's April 16, 2008 testimony before the U.S. House Committee on Transportation and Infrastructure on the Rapanos and SWANCC decisions and the Clean Water Restoration Act. And the news release.
  • Sidney Shapiro's April 2, 2008 testimony before the Subcommittee on Information Policy, Census and National Archives of the U.S. House Committee on Oversight and Government Reform, on the Federal Advisory Committee Act of 2008.

2007

  • Rena Steinzor’s October 17, 2007 testimony before the Subcommittee on Superfund and Environmental Health of the U.S. Senate Environment and Public Works Committee, on the Bush Administration’s failure to pursue Superfund cleanups.
  • David Vladeck’s September 12, 2007 testimony to the Senate Judiciary Committee on the Bush Administration’s push for agency preemption of state tort laws.
  • David Vladeck’s February 13, 2007 testimony on EO 13422 before the Committee on Science and Technology Subcommittee on Investigations and Oversight, U.S. House of Representatives.

2006

  • William Buzbee’s August 1, 2006 testimony before the Fisheries, Wildlife and Water subcommittee of the Senate Environment and Public Works Committee, on the implications of the Supreme Court’s decision in the Rapanos case for efforts to protect America’s waterways from polluters.

2005

  • Robert R.M. Verchick’s November 17, 2005 testimony before the U.S. Senate Committee on the Environment and Public Works on how preliminary findings on the failure of New Orleans’ levees should be incorporated into future plans for hurricane protection.
  • Tom McGarity’s November 10, 2005 testimony to Congress on the National Environmental Policy Act (NEPA).
  • Robert R.M. Verchick’s September 29, 2005 testimony before the Subcommittee on Environment and Hazardous Materials of the House Committee on Energy & Commerce on what went wrong before, during and immediately after Hurricane Katrina.
  • Sidney Shapiro’s July 20, 2005 testimony before the Subcommittee on Regulatory Affairs of the House Government Reform Committee on the Information Quality Act.
  • Sidney Shapiro’s April 12, 2005 congressional testimony on OMB’s regulatory “hit list” before the House Subcommittee on Regulatory Affairs of the Committee on Government Reform.

2004

  • Catherine O’Neill’s November 17, 2004 testimony to the Subcommittee on Energy Policy, Natural Resources, and Regulatory Affairs of the House Government Reform Committee on mercury pollution credit-trading proposals.
  • Robert R.M. Verchick’s February 25, 2004 testimony before the Subcomittee on Energy Policy, Natural Resources and Regulatory Affairs of the House Committee on Government Reform, on the Office of Management and Budget’s Draft 2004 Report to Congress on the Costs and Benefits of Federal Regulation.

2003

  • Rena Steinzor’s September 16, 2003 testimony to Congress on the Bush EPA’s poor enforcement record, September 16, 2003.
  • Rena Steinzor’s June 6, 2003 testimony before the Subcommittee on Energy Policy, Natural Resources, and Regulatory Affairs of the Committee on Government Reform on proposals to elevate EPA to Cabinet status.
  • Lisa Heinzerling’s (then a Member Scholar) March 11, 2003 testimony on OMB’s Draft 2003 Report to Congress on the Costs and Benefits of Federal Regulation.

2002

  • Rena Steinzor’s June 13, 2002 testimony to the House Subcommittee on Water Resources and the Environment on Water Quality Trading Policy.

 

 
Letters and comments from Member Scholars to federal agencies include:
 
2010
  • OMB Report to Congress on Costs and Benefits of Regulation. Each year, the White House Office of Management and Budget submits a report to Congress on the costs and benefits of federal regulation.  And each year, CPR Member Scholars critique the report.  In their 2010 comments, Sidney Shapiro, Amy Sinden, Rena Steinzor, and James Goodwin make several points: 1) aggregating costs and benefits of regulations is unproductive; OMB has signaled its intent to continue micro-managing agency regulating; and OMB's call for transparency should apply to OMB itself.
  • Letter to White House Counsel re OIRA.  On March 17, 2010, CPR Board Members Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden and Rena Steinzor wrote a letter to White House Counsel Robert Bauer requesting a review of "ongoing violations of presidential executive orders by the Office of Information and Regulatory Affairs," specifically, OIRA's routine assertion of jurisdiction over "guidance documents" from regulatory agencies despite EO 13,497 despite a revocation of that authority by the President; OIRA's exceeding deadlines for completing reviews under the terms of EO 12,866; and OIRA's failure to disclose "before and after" documents allowing the public to determine what changes were made to regulatory actions after OIRA's review (again, a violation of EO 12,866).
  • OSHA Listens Presentation.  On March 4, 2010, CPR Policy Analyst Matt Shudtz made a presentation from Member Scholar Rena Steinzor and himself to an "OSHA Listens" session, chaired by OSHA Administrator David Michaels.  The presentation drew on Workers at Risk: Regulatory Dysfunction at OSHA (700 kb download), CPR White Paper #1003, by CPR Member Scholars Thomas McGarity, Rena Steinzor, and Sidney Shapiro, and CPR Policy Analyst Matthew Shudtz.  Read the presentation.
  • Toyota Safety Letter.  On February 9, 2010, CPR Member Scholars Rena Steinzor and Sidney Shapiro sent a letter to the House Oversight and Government Reform Committee outlining important questions it should put to the National Highway Traffic Safety Administration, in the wake of its failure to force speedy action on safety problems with several Toyota models.  Read the letter.
  • Comments on Draft Water Quality Report for the Chesapeake Bay.  CPR Policy Analyst Yee Huang's comments on EPA's draft 202a Water Quality Report & 203 Strategy for the Chesapeake Bay, January 8, 2010.

2009

  • Letter to OIRA on Coal Ash Regulation.  On December 22, 2009, CPR President Rena Steinzor sent a letter to OIRA Administrator Cass Sunstein concerning OIRA involvement in EPA's announcement that it was delaying potential action on regulation of coal ash. The announcement came after OIRA had held a series of meetings with industry interests.
  • Letter to OIRA on 2009 OMB Report to Congress.  On November 5, 2009, CPR Member Scholars Rena Steinzor and Amy Sinden, with CPR Policy Analyst James Goodwin filed comments with the OMB Office of Information and Regulatory Affairs on OMB's annual report to Congress on the costs and benefits of regulation.
  • Letter to White House Science Adviser and OIRA Administrator.  On October 22, 2009, CPR President Rena Steinzor and Board Member Robert Glicksman sent a letter to White House Science Advisor John Holdren and OIRA Administrator Cass Sunstein regarding OMB interventions in EPA science programs. The letter examined two incidents involving OMB meddling in IRIS and EDSP.
  • Comments on ESA Consultation Rules.  On August 3, 2009, CPR Member Scholars Mary Jane Angelo, Holly Doremus, and Daniel J. Rohlf, and CPR Policy Analyst James Goodwin submitted comments to the U.S. Fish and Wildlife Service (FWS) proposing several ways to improve regulations for implementing interagency consultations under the Endangered Species Act.  Read James Goodwin's blog entry on the comments.
  • Letter to White House Science Advisor.  On April 3, 2009, CPR Member Scholars Rena Steinzor and Wendy Wagner sent a letter to White House Science Advisor John Holdren with several recommendations for protecting science from politics in the Obama Administration.  Read the letter and the news release. On May 13, 2009, after the White House formally opened the science policy development process up for public comment, CPR Member Scholar Reina Steinzor and Policy Analyst Matthew Shudtz submitted formal comments, expanding on some points in the April 3 letter.
  • Letter on Endangered Species Act Consultation Regulation.  April 1, 2009 letter to Interior Secretary Salazar and Commerce Secretary Locke from CPR Member Scholars Holly Doremus, Robert Glicksman, Alejandro Camacho, Daniel Rohlf, and Policy Analyst Margaret Clune Giblin, urging the Secretaries to take advantage of a 60-day window for withdrawing a Bush Administration midnight regulation weaking a requirement that agencies consult on actions that would harm endangered or threatened species.
  • Final Comments on Obama Regulatory Review Process.  Comments from John Applegate, Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden, Rena Steinzor, Robert Verchick (collectively the CPR board), Comments Regarding Executive Order on OMB Regulatory Review, March 16, 2009.  Read the web article.
  • Preliminary Comments on Obama Regulatory Process Memo.  Rena Steinzor's February 20, 2009 letter to OMB chief Peter Orszag submitting preliminary comments for OMB consideration as it prepares recommendations for President Obama on ways to reform the regulatory process.  The letter also called for a formal review period for OMB's proposal once a draft was prepared.
  • Endangered Species Act Interagency Cooperation.  CPR's Holly Doremus, Robert Glicksman, Alejandro Camacho, Daniel Rohlf and Margaret Clune Giblin, joined by Mark Schwartz (UC Davis), October 10, 2008, Comments on the U.S. Fish & Wildlife Service and National Marine Fisheries Service's Proposed Rule on Interagency Cooperation under the Endangered Species Act.

2008

2007 and Earlier