EPA Regulatory Reform Sample Comment Scripts for the Savvy Citizen.
ACTION ALERT: EPA REGULATORY REFORM – PUBLIC COMMENTS ENDS 5/15/17. Comment Early and Often!
Guest Contributor: Clean Energy is the Way Forward – Sample Script for Monday, May 1, 2017
(Please do not cut and paste! Edit the script to make it your own and add personal commentary. These scripts are designed to inform and are for inspiration and ideas!)
Click here to submit your comments: Proposed Rule (Evaluation of Existing Regulations) and Comment Submission Link
Clean Energy is the Way Forward
According to an EPA News Release (dated 28 March, 2017), “The Energy Independence Executive Order directs agencies responsible for regulating domestic energy production to submit plans to the White House, which will identify, and propose measures to revise or rescind, regulatory barriers that impede progress towards energy independence. Moreover, the Order rescinds several Obama executive orders and policies related to climate change. It also directs the Administrator of the Environmental Protection Agency and the Secretary of the Interior to review, and if necessary, revise or rescind, several regulations that may place unnecessary, costly burdens on coal-fired electric utilities, coal miners, and oil and gas producers. ‘The American people deserve an EPA that works to protect both the environment and enables a growing economy,’ said Administrator Pruitt.”(1)
This narrative of “job-killing regulations” dates back several decades, but is not supported by the facts. While it is the case that concentrated job with specific industries, due to regulations, the overall balance is “a wash” (according to a University of Pennsylvania professor and editor of Does Regulation Kill Jobs, Cary Coglianese) with equal numbers of jobs created in other industries—or in the regulated industry itself (2).
Also, corporations have blamed shut-downs and lay-offs on regulations when such is not the case. Near the city where I live, Seattle, ASARCO blamed the closing of its copper-smelting plant on regulations—but the plant had closed before those regulations took effect (3).
Furthermore, federal regulations have the effect of protecting our public and environmental health while creating a level playing field for the industries affected: Because all a corporation’s competitors are affected by the same regulations, no competitive burden is placed on any one corporation. If the federal government abandons its regulatory responsibility, companies will face a patchwork of state and local regulations.
The primary stake-holders of the EPA are not coal-fired electric utilities, and oil and gas producers. They are American citizens, whose health is the fundamental reason for regulations that protect against pollution. As Berkeley economist W. Reed Walker wrote in a 2013 study (4) the EPA itself has calculated that the health benefits of the Clean Air Amendments (1990 to 2010) are between $160 billion and $1.6 trillion. At a time when health care costs are rising, it is in the economic interest of the United States to continue to prevent health costs caused by unregulated and under-regulated pollution.
US policy and resources should be directed at assisting those who lose their jobs (e.g., coal miners and workers in other fossil fuel industries), rather than re-trenching and attempting to save industries that are not beneficial to our overall economic and public health future. Clean energy initiatives generate jobs, and reduce harms to our health and environment. They, not fossil fuels, are the way forward.
The following additional studies have found that regulations to reduce and prevent pollution and other harms do not cause a net loss in jobs:
Berman, Eli, and Linda TM Bui. “Environmental regulation and labor demand: Evidence from the south coast air basin.” Journal of Public Economics 79.2 (2001): 265-295.
Belova, Anna, et al. “Environmental regulation and industry employment: A reassessment.” (2013).
Guest Contributor: Melinda Mueller, Seattle WA
(1) “EPA to Review the Clean Power Plan Under President Trump’s Executive Order.” EPA. Environmental Protection Agency, 28 Mar. 2017. Web. 01 May 2017.
(2) Coglianese, Cary, Adam M. Finkel, and Christopher Carrigan, eds. Does Regulation Kill Jobs?. University of Pennsylvania Press, 2014.
(3) Semuels, Alana. “Do Regulations Really Kill Jobs?” The Atlantic. Atlantic Media Company, 19 Jan. 2017. Web. 01 May 2017
(4) Walker, W. Reed. “The transitional costs of sectoral reallocation: Evidence from the clean air act and the workforce.” The Quarterly journal of economics (2013): qjt022.
What is “Your Daily Docket”?
– 3 weeks of daily scripts until the Public Comment period closes May 15, 2017 –
Your Daily Docket provides 3 weeks of daily scripts for public comments for the Proposed Rule, Evaluation of Existing Regulations, aka (in Trump/Pruitt’s minds) “how best to gut the EPA”. Trump/Pruitt are likely expecting industry to flood the public comments docket with their wish lists, and call it a day on May 15 when the comment period closes. However, a quick look at the comments submitted so far have been more to the tune of, “I like to breathe. When I can’t breathe I get scared. I also like to drink water.” https://www.regulations.gov/docket?D=EPA-HQ-OA-2017-0190
We want to encourage you and your neighbors to enter comments on the open docket early and often until the public comment period closes on May 15.
Your Daily Docket provides daily scripts for ideas and inspiration for your own comments. Take the daily comments and make them your own. We aim to make each Your Daily Docket speak to a particular issue.
Let’s use our collective voice for ourselves, our planet and future generations!
Featured image information: TRUCKS HAUL COAL FROM THE NAVAJO MINE TO THE FOUR CORNERS GENERATING PLANT. Shiprock, Arizona. May, 1972. Environmental Protection Agency. Still Picture Records Section, Special Media Archives Services Division (NWCS-S). Public Domain.