The NOPR’s analysis of dishwashers is superficially detailed and modern in its research methods. In the areas discussed above and numerous others, the research embodied in it appears to be inadequate as a foundation for a rule that will apply to every dishwasher sold in the United States after 2019. Whatever errors and uncertainties are in the document, it is ultimately just an assertion that the DOE is better than consumers at choosing the energy efficiency and other attributes of dishwashers.
Under the authority of the Clean Water Act (CWA) of 1972, the Environmental Protection Agency (EPA) is proposing new technology requirements for all new and existing dental practices that use dental amalgam, which is the main source of mercury discharges into publicly owned treatment works (POTWs). The proposed rule would require dental offices to use amalgam separators and best management practices (BMPs) for capturing mercury and other metals before they are discharged into POTWs.
This comment, which reiterates concerns laid out in the attached opinion piece, does not represent the views of any particular affected party or special interest group but is designed to assist FINRA as it considers implementing the Comprehensive Automated Risk Data System (CARDS).
The focus of the committee’s white paper on how to “foster” various television distributors, while understandable, was nonetheless misguided. Such an inquiry will likely lead to harmful rules that favor some companies and programmers over others, based on political whims. Congress and the FCC should get out of “fostering” the video distribution markets completely. A light-touch regulatory approach will prevent the damaging effects of lobbying for privilege and will ensure the primacy of consumer choice.
This comment considers the potential impact of the Office of Personnel Management’s (OPM) proposed rule change to the Multi-State Plan Program (MSP) for the affordable insurance exchanges created through the Patient Protection and Affordable Care Act of 2010. The purpose of the proposed rule is to further explain OPM’s direction in meeting the statutory requirements of the MSP program concerning health issuers that establish an MSP option with OPM.
The Environmental Protection Agency and Army Corps of Engineers have proposed a rule changing the definition of “waters of the United States” under the Clean Water Act (CWA). Under the status quo, whether or not a water body qualifies as jurisdictional “waters of the United States” is determined case-by-case and based on precedence, science, and case law.
The federal government’s own tips for submitting effective comments in regulatory proceedings note, “A constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision-making.” This guide explains how to prepare a comment on a proposed regulation, using economic analysis that supports each claim.
The proposed rule is promulgated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) and recommends new requirements for trains transporting a large volume of Class 3 flammable liquids (mostly ethanol and Bakken crude).
As part of the FAA Modernization and Reform Act of 2012 (FMRA), Congress ordered the Federal Aviation Administration (FAA) to integrate unmanned aircraft systems (UASs)—sometimes referred to as drones—into the National Airspace System by September 2015. As part of that effort, the FAA is currently accepting comments on its “Interpretation of the Special Rule for Model Aircraft” (Section 336 of the FMRA) and the FAA’s enforcement authority over model aircraft as affirmed by the statute.