Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Indigenous Communities Urge Caution on Proposed Deep-Sea Mining in Marianas Trench
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WASHINGTON, Jan. 15 -- A public comment letter addressed to the Bureau of Ocean Energy Management (BOEM) has raised urgent concerns from Indigenous Chamorro communities regarding a proposed plan for commercial leasing of outer continental shelf minerals off the Commonwealth of the Northern Mariana Islands. The letter emphasizes the cultural and environmental importance of the Marianas Trench, asserting that the area is not just an economic resource but a sacred space integral to Indigenous identity and survival.
The correspondence expresses strong opposition to deep-sea mining activities, citing
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WASHINGTON, Jan. 15 -- A public comment letter addressed to the Bureau of Ocean Energy Management (BOEM) has raised urgent concerns from Indigenous Chamorro communities regarding a proposed plan for commercial leasing of outer continental shelf minerals off the Commonwealth of the Northern Mariana Islands. The letter emphasizes the cultural and environmental importance of the Marianas Trench, asserting that the area is not just an economic resource but a sacred space integral to Indigenous identity and survival.
The correspondence expresses strong opposition to deep-sea mining activities, citingthe potential irreversible damage to a unique ecosystem that has evolved under extreme conditions. Detractors of the proposal argue that such actions could lead to species extinction, pollution, and significant disruption to fragile marine habitats. They point to the Mariana Trench National Wildlife Refuge, established by the U.S. Fish & Wildlife Service, which aims to protect the extraordinary biodiversity existing six miles under the ocean's surface.
Acknowledging the critical role of the ocean in the culture and tradition of the Chamorro and Carolinian people, the letter articulates a rich history that connects these communities to the waters surrounding them. For many, fishing transcends mere sustenance; it embodies a spiritual practice that honors the sea. This deep-rooted connection suggests that mining in these sacred waters could inflict lasting damage not only on the environment but also on community identity.
Moreover, the impacts of climate change, food insecurity, and economic challenges already facing Guam and the Northern Mariana Islands are compounded by the threat of deep-sea mining. Community advocates assert that damaging fisheries and marine ecosystems that families depend on for their livelihoods would exacerbate existing vulnerabilities. Research from NOAA indicates that Pacific Island fisheries are vital for local survival, underscoring calls for stringent protective measures against potential harm from mining activities.
Advocates stress the need for BOEM to engage in meaningful consultations with Indigenous communities prior to making decisions that will affect their ancestral lands and waters. The letter insists that any actions taken without proper consultation would violate the trust given to federal agencies to respect Indigenous rights.
In light of the highlighted concerns, the advocates urge BOEM to prioritize environmental protection and the voices of Indigenous peoples, citing the necessity of clear scientific evidence that mining can occur without causing lasting harm before moving forward with any plans. The letter concludes with an emphatic call to honor Indigenous interests and ensure that any decisions respect the sacredness of the Marianas Trench.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1026
Federal Agency Urged to Enhance Environmental Reviews for Seabed Mining
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WASHINGTON, Jan. 15 -- A public comment letter submitted to the Bureau of Ocean Energy Management (BOEM) emphasizes the critical need for thorough environmental assessments regarding potential seabed mining operations in the waters off the Commonwealth of the Northern Mariana Islands (CNMI). The letter, authored by a CNMI resident and cultural advocate, highlights the necessity for BOEM to adhere to U.S. environmental laws while addressing the potential impacts of mineral extraction on local ecosystems and communities.
The resident noted that seabed mining activities should comply with the CNMI
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WASHINGTON, Jan. 15 -- A public comment letter submitted to the Bureau of Ocean Energy Management (BOEM) emphasizes the critical need for thorough environmental assessments regarding potential seabed mining operations in the waters off the Commonwealth of the Northern Mariana Islands (CNMI). The letter, authored by a CNMI resident and cultural advocate, highlights the necessity for BOEM to adhere to U.S. environmental laws while addressing the potential impacts of mineral extraction on local ecosystems and communities.
The resident noted that seabed mining activities should comply with the CNMIlaw and the National Environmental Policy Act (NEPA), which mandates full evaluations of social, economic, and environmental consequences before pursuing any extraction permits. The letters raised concerns over the impacts seabed mining could have on the health of marine environments, traditional fishing practices, and food security for local communities that rely on these resources.
Drawing parallels with recent developments in American Samoa, the author reported a rush by federal agencies, including BOEM, to hastily advance seabed mineral leasing without sufficient local engagement. Allegedly, the public comment period for both American Samoa and the CNMI was inadequately short, limiting opportunities for effective community input on a matter deeply affecting their future.
The letter further reflects apprehensions that premature leasing by the agency could lead to speculative claims over valuable mineral resources, ultimately undermining the interests of local stakeholders. Specific calls for BOEM included ensuring any decisions regarding mining projects consider scientific studies that outline potential harms and benefits, contributing to a more informed and equitable approach to resource management.
Particularly alarming to the letter's author were the proposed operational methodologies and the potential long-term cumulative effects on marine biodiversity. The writer asserted that commercial seabed mining, executed without comprehensive environmental research, could lead to irreversible ecological damage. With historical ties to the sea, the Indigenous Chamorro and Carolinian communities maintain that their input is vital in any conversations surrounding resource extraction pressures that threaten their cultural and environmental heritage.
The author insisted that any decision by BOEM regarding seabed mining should involve informed participation from Indigenous perspectives, underscoring that local communities are not just affected parties but also essential stewards of the marine environment they inhabit. As the agency moves forward, the necessity to integrate community voices into the process remains a pivotal issue for the protection of both local culture and marine ecosystems.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1022
Bureau of Ocean Energy Management Faces Pushback Against Proposed Deep-Sea Mining
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WASHINGTON, Jan. 15 -- A public comment letter submitted to the Bureau of Ocean Energy Management (BOEM) underscores the growing concerns surrounding the proposed commercial leasing for seabed mining in the Outer Continental Shelf of the Commonwealth of the Northern Mariana Islands (CNMI) and Guam. The letter highlights potential environmental, economic, and cultural impacts associated with the initiative, calling for a comprehensive analysis prior to any further action.
The communication stresses that the proposed mining activities could pose irreversible harm to the fragile ecosystems in the
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WASHINGTON, Jan. 15 -- A public comment letter submitted to the Bureau of Ocean Energy Management (BOEM) underscores the growing concerns surrounding the proposed commercial leasing for seabed mining in the Outer Continental Shelf of the Commonwealth of the Northern Mariana Islands (CNMI) and Guam. The letter highlights potential environmental, economic, and cultural impacts associated with the initiative, calling for a comprehensive analysis prior to any further action.
The communication stresses that the proposed mining activities could pose irreversible harm to the fragile ecosystems in theregion, which are among the least understood on the planet. It argues that any adverse environmental effects could extend beyond the CNMI, notably affecting Guam's ecosystem and communities that rely heavily on the ocean for their livelihoods. The letter calls for a transparent, science-led environmental impact analysis along with consultations with local residents before proceeding with the leasing process.
The absence of consent from both CNMI and Guam communities for this Request for Information (RFI) is also a point of contention. The letter emphasizes that free, prior, and informed consent is a fundamental principle outlined in the United Nations Declaration on the Rights of Indigenous Peoples, and asserts that proper public hearings should be a prerequisite for moving forward.
Environmental concerns in the letter are significant, citing potential damage to marine life and ecosystems that could stem from mining operations. The Bureau of Statistics and Plans has indicated that damage could impact a wider expanse, leading to potential threats such as biodiversity loss and disruption of food chains. The integrity of the Mariana Trench Marine National Monument, a protected area, could also be jeopardized.
Mining could also bring about economic challenges for both CNMI and Guam, particularly as tourism in Guam generates substantial economic activity derived from its marine environment. Reports suggest that substantial ecological damage from mining could lead to significant economic losses in tourism and associated industries. Additionally, the letter warns that the sediment plumes generated from mining operations could affect local fisheries and food security.
Finally, the letter outlines pressing legal questions regarding the legality of BOEM's proposal and its compliance with international laws. It calls for an examination of whether the mining operations would infringe on the rights of Indigenous populations to their natural resources. It urges the agency to rethink its approach to seabed mining, pointing to alternative technologies and practices that could alleviate environmental and economic pressures.
In conclusion, the document advocates for a halt to the leasing process, echoing calls from diverse groups around the world for a moratorium on deep-sea mining until all implications are thoroughly understood.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1008
Concerns Raised Over Deep-Sea Mining Lease Near Northern Mariana Islands
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WASHINGTON, Jan. 15 -- A public comment letter submitted by environmental advocates expresses strong opposition to the proposed commercial leasing for Outer Continental Shelf minerals offshore the Commonwealth of the Northern Mariana Islands. The request, issued by the Bureau of Ocean Energy Management (BOEM), has sparked widespread concern about its potential implications for local ecosystems, cultural heritage, and the economy of surrounding areas, including Guam.
The letter highlights apprehension over the environmental impacts of leasing, specifically regarding potential harm to marine biodiversity
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WASHINGTON, Jan. 15 -- A public comment letter submitted by environmental advocates expresses strong opposition to the proposed commercial leasing for Outer Continental Shelf minerals offshore the Commonwealth of the Northern Mariana Islands. The request, issued by the Bureau of Ocean Energy Management (BOEM), has sparked widespread concern about its potential implications for local ecosystems, cultural heritage, and the economy of surrounding areas, including Guam.
The letter highlights apprehension over the environmental impacts of leasing, specifically regarding potential harm to marine biodiversityand ecosystems. Citing data from environmental organizations, it underscores that the full ramifications of deep-sea mining remain largely unknown. Advocates argue that mining activities cannot occur in isolation from other environmental stressors, including climate change, and stress the necessity for a precautionary approach to ensure the protection of fragile ocean habitats.
Experts referenced in the letter caution against rushing into mining operations, emphasizing that any exploration could result in irreversible consequences for marine life. The authors advocate for a moratorium on deep-seabed mining until comprehensive studies can ascertain the long-term effects on ocean health, biodiversity, and the human communities relying on these ecosystems. The continued progress towards deep-sea mining is viewed as a threat to areas deemed pristine and essential for numerous marine species.
The letter also sheds light on economic and social concerns for local populations, particularly the Chamorro people of Guam and the Northern Mariana Islands. It notes that deep-sea mining could disrupt vital fisheries and longstanding cultural practices, while providing little to no economic benefit for the area. Local economies heavily reliant on marine-related tourism could suffer severe repercussions should pollution result from mining activities, impacting public health and safety.
Advocates stress that without clear evidence of economic advantage and firm regulatory measures, allowing such operations to move forward would be irresponsible. They call upon the agency to reconsider the lease proposal, emphasizing the existing gaps in data and transparency surrounding mining governance.
In conclusion, the letter represents a growing coalition of voices urging a halt to deep-sea mining initiatives as the international community grapples with the complexities of ocean resource management. Observations by leading experts surrounding the anticipated environmental and social repercussions have prompted calls for caution and reevaluation of the proposed commercial endeavors. The future of marine ecosystems hangs in the balance as stakeholders await the agency's decision.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1045
Concerns Raised Over Impacts of Proposed Deep-Sea Mining in Mariana Islands
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WASHINGTON, Jan. 15 -- A public comment letter addressed to the Bureau of Ocean Energy Management (BOEM) has highlighted significant concerns regarding the potential impact of proposed deep-sea mining activities in the Mariana Islands. The letter, authored by a resident with deep ties to the region, emphasizes the detrimental effects such operations could have on local ecosystems and the community's reliance on marine resources.
The letter asserts that harvesting materials from the seabed could unleash sediments and harmful plumes into the surrounding waters, jeopardizing the delicate balance
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WASHINGTON, Jan. 15 -- A public comment letter addressed to the Bureau of Ocean Energy Management (BOEM) has highlighted significant concerns regarding the potential impact of proposed deep-sea mining activities in the Mariana Islands. The letter, authored by a resident with deep ties to the region, emphasizes the detrimental effects such operations could have on local ecosystems and the community's reliance on marine resources.
The letter asserts that harvesting materials from the seabed could unleash sediments and harmful plumes into the surrounding waters, jeopardizing the delicate balanceof the marine food web. The author indicates that this contamination could directly affect subsistence fishing, a vital source of sustenance for island communities. This point is particularly critical as many residents depend on pristine waters for their livelihoods and cultural practices.
Mentioning the unique environmental challenges faced by the islands, the letter cautions that rigorous regulations and continuous monitoring of marine resources will be necessary before any mining projects can be considered viable. The author voices a strong opposition to deep-sea mining under conditions that threaten the health of local waters and, consequently, the well-being of the communities.
Additionally, the author raises concerns about the economic implications the mining project may hold for tourism, which is vital for the local economy. Despite the Outer Continental Shelf being located around 128 miles from Saipan, it is suggested that the plumes and sediment stirred up by mining activities could disperse far beyond the mining site. The potential adverse effects on marine life could disrupt recreational activities such as snorkeling, which are integral to the tourist appeal of the region. With tourism being the primary driver of private enterprise in the Marianas, these impacts could be staggering.
In conclusion, the letter urges BOEM to consider the culturally and economically intertwined nature of the ocean with the communities it supports. The author appeals for comprehensive long-term monitoring and consulting with Indigenous communities to safeguard their interests and the marine environment before proceeding with the mining proposal. The sentiments echoed in this letter reflect broader worries among residents and lawmakers alike regarding the future of their waters and livelihoods in the face of industrial development.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1004
Concerns Raised Over Proposed Deep-Sea Mining in Mariana Islands
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WASHINGTON, Jan. 15 -- In a public comment letter addressed to the Bureau of Ocean Energy Management, Frank A. Camacho, Ph.D., has expressed strong opposition to plans for deep-sea mining in the Mariana Islands. The proposed mining would take place within the U.S. Exclusive Economic Zones (EEZs) surrounding U.S. Pacific territories, raising significant environmental concerns regarding its impact on fragile marine ecosystems.
Camacho argues that such mining operations could have profound and irreversible effects on both seafloor and hydrothermal vent ecosystems. These unique habitats are not barren
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WASHINGTON, Jan. 15 -- In a public comment letter addressed to the Bureau of Ocean Energy Management, Frank A. Camacho, Ph.D., has expressed strong opposition to plans for deep-sea mining in the Mariana Islands. The proposed mining would take place within the U.S. Exclusive Economic Zones (EEZs) surrounding U.S. Pacific territories, raising significant environmental concerns regarding its impact on fragile marine ecosystems.
Camacho argues that such mining operations could have profound and irreversible effects on both seafloor and hydrothermal vent ecosystems. These unique habitats are not barrenas previously believed but are home to a diverse array of specialized biological communities, including vital microbial assemblages crucial to global biogeochemical cycles. He highlights that the ecological roles of these organisms are not fully understood, emphasizing their potential benefits to fields such as biomedicine and industrial chemistry.
The scientist notes that the biodiversity in these ecosystems is not uniform, with many species remaining undescribed due to limited sampling efforts. Research indicates that even adjacent habitats can host distinct taxonomic assemblages. The letter underscores that mining could jeopardize unique biological communities before they are documented, advocating for comprehensive assessments of marine biodiversity prior to any operations.
Another pressing concern raised is the potential impact of sediment plumes created by the mining on pelagic food webs and fisheries. Highlighting that many fish caught in Guam's waters come from within the U.S. EEZ, Camacho stresses the lack of empirical data on how sediment reintroduced into the water column would affect planktonic communities, a crucial food source for marine organisms. He calls for ecotoxicological studies to determine risks to local marine larvae presented by heavy metals and other materials that mining operations could introduce.
In light of the outlined risks, Camacho proposes several research initiatives before any mining could be considered. This includes conducting pre-disturbance assessments of marine biodiversity, performing ecotoxicological studies on the effects of pollutants, and investigating the behavior of sediment plumes from mining activities. He also suggests establishing a long-term monitoring program to gauge the sustained effects of any mining operations.
In conclusion, Camacho asserts that protecting the Mariana Islands' ecosystems is essential for maintaining their ecological integrity and scientific value for future generations. Given the high level of scientific uncertainty and ecological risk involved, he advocates for a prohibition on deep-sea mining in this area and other U.S. Pacific territories.
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0351-1005
CENTER ON BUDGET AND POLICY PRIORITIES CALLS FOR WITHDRAWAL OF PROPOSED PUBLIC CHARGE REGULATION
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WASHINGTON, Jan. 6 -- The Center on Budget and Policy Priorities submitted a public comment letter to the U.S. Department of Homeland Security expressing strong opposition to a Notice of Proposed Rulemaking regarding the public charge ground of inadmissibility under 8 CFR Parts 103 and 212.
In their correspondence, the organization emphasized the potential chaos and harm the proposed rule could inflict on immigrant families and their access to critical public benefits.
The CBPP, a nonpartisan policy organization, highlighted that the proposed rescission of the 2022 public charge regulations
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WASHINGTON, Jan. 6 -- The Center on Budget and Policy Priorities submitted a public comment letter to the U.S. Department of Homeland Security expressing strong opposition to a Notice of Proposed Rulemaking regarding the public charge ground of inadmissibility under 8 CFR Parts 103 and 212.
In their correspondence, the organization emphasized the potential chaos and harm the proposed rule could inflict on immigrant families and their access to critical public benefits.
The CBPP, a nonpartisan policy organization, highlighted that the proposed rescission of the 2022 public charge regulationscould exacerbate confusion and fear among immigrant families. This apprehension is likely to lead parents, including those with U.S. citizen children, to forgo essential benefits that they are legally entitled to receive. The letter noted that the NPRM fails to address the profound chilling effects observed following the 2019 public charge rule, which caused many eligible individuals to withdraw from vital support programs like Medicaid and the Supplemental Nutrition Assistance Program (SNAP).
According to the CBPP, the proposed rule threatens to create substantial inequities and could significantly impact public health and well-being. Research indicates that the current chilling effects contribute to increased food insecurity, inadequate health care access, and adverse educational outcomes, particularly among children in immigrant families.
The organization further warned that the proposed reinstatement of broad discretion for immigration officers could introduce bias in public charge assessments, leading to inconsistent and discriminatory determinations based on race, ethnicity, and national origin. As the CBPP pointed out, the NPRM lacks clear parameters, which undermines the regulatory framework intended to ensure fair and equitable treatment in immigration matters.
Compounding these issues, the letter explained that the NPRM does not adequately address reliance interests built over years of clear regulatory guidance. Many immigrant families have made life-altering decisions based on existing public charge regulations, and changes to these guidelines could adversely affect their access to necessary support services, placing undue strain on state and local economies.
The CBPP urged the DHS to withdraw the NPRM, maintaining that the proposed changes would create confusion, disproportionately harm immigrant families, and ultimately degrade public welfare. Instead, the organization advocates for the preservation of the existing 2022 regulations that provide clearer guidelines and promote equitable access to vital public benefits for families in need.
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The letter was written by:
Shelby T. Gonzales ... Margot Dankner
Vice President for Immigration Policy ... Senior Policy Analyst
Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0304-4751
Albuquerque BioPark Society Urges Fish and Wildlife Service to Retain ESA Blanket Rule Protections
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WASHINGTON, Jan. 6 -- The Albuquerque BioPark Society has expressed serious concerns regarding a proposed rule by the U.S. Fish and Wildlife Service that seeks to eliminate the Section 4(d) "blanket rule" option. This action is believed to potentially extend the duration during which certain species may not receive critical protections under the Endangered Species Act, exacerbating the risk of extinction for vulnerable species.
The organization highlighted alarming statistical findings from prior research indicating that the average timeline for species listing petitions has drastically exceeded
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WASHINGTON, Jan. 6 -- The Albuquerque BioPark Society has expressed serious concerns regarding a proposed rule by the U.S. Fish and Wildlife Service that seeks to eliminate the Section 4(d) "blanket rule" option. This action is believed to potentially extend the duration during which certain species may not receive critical protections under the Endangered Species Act, exacerbating the risk of extinction for vulnerable species.
The organization highlighted alarming statistical findings from prior research indicating that the average timeline for species listing petitions has drastically exceededthe statutory limit of two years. In a comprehensive analysis of over 1,300 species petitions from 1973 to 2014, it was revealed that the average wait time for these petitions to progress to final rule status stretched to approximately 12.1 years. The Albuquerque BioPark Society conducted a similar evaluation of protected species in New Mexico, where the average period from the latest petition notice to the effective final rule came out to 12.2 years, significantly overshadowing the mandated timeline.
An illustrative case cited by the organization is the Sacramento Mountains checkerspot butterfly, which faced a prolonged petition process that placed it at greater risk. Initially petitioned for protection in 1999, the butterfly was not granted formal protection until 2022. During that time, its population plummeted from 1,629 adults documented in the late 1990s to only one known living individual now in captivity. Such stark declines highlight the detrimental effects of delayed action on species that urgently require intervention.
In light of these findings, the Albuquerque BioPark Society urged the U.S. Fish and Wildlife Service to retain the "blanket rule" option under Section 4(d), stating that this provision is crucial for providing necessary protections while more detailed, species-specific rules are developed. The organization emphasized that many species cannot withstand additional delays without protections as they face ongoing threats in their habitats.
The Albuquerque BioPark Society is hopeful that the agency will reconsider the implications of the proposed rule and its potential impact on species conservation. By maintaining the current "blanket rule," the U.S. Fish and Wildlife Service could ensure that protections are not just theoretical, but immediately protective, offering a lifeline to species on the brink of extinction.
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Read full text of letter here: https://www.regulations.gov/comment/FWS-HQ-ES-2025-0029-14547
AASA Urges Treasury and IRS to Preserve State Authority in Scholarship Tax Credit Rules
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WASHINGTON, Jan. 6 -- AASA, The School Superintendents Association, has submitted a public comment letter to the U.S. Department of the Treasury and the Internal Revenue Service regarding Notice 2025-70/IRS-2025-0466, which invites feedback on the Individual Tax Credit for Qualified Contributions to Scholarship Granting Organizations (SGOs). Representing over 10,000 local school district leaders, AASA emphasizes the importance of state control and flexibility in educational funding and policy.
The organization expresses the expectation that the Treasury and the IRS will align their regulations
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WASHINGTON, Jan. 6 -- AASA, The School Superintendents Association, has submitted a public comment letter to the U.S. Department of the Treasury and the Internal Revenue Service regarding Notice 2025-70/IRS-2025-0466, which invites feedback on the Individual Tax Credit for Qualified Contributions to Scholarship Granting Organizations (SGOs). Representing over 10,000 local school district leaders, AASA emphasizes the importance of state control and flexibility in educational funding and policy.
The organization expresses the expectation that the Treasury and the IRS will align their regulationswith Congressional intent, particularly in terms of allowing states autonomy to design and implement tax credit programs. AASA urges the agency to ensure states have the authority to monitor scholarship programs effectively and to set standards for SGOs that align with educational priorities. This includes tracking academic progress of scholarship recipients and maintaining eligibility requirements for existing scholarship programs.
AASA emphasizes that the flexibility granted to states is crucial to their participation in the federal tax credit program. The organization argues that when states are empowered to determine their requirements for SGOs, they can better serve local educational needs. The letter requests clarification from the agency on the authority of states to decide which SGOs operate within their jurisdiction, consistent with statutory guidelines.
Further, AASA insists on the necessity of monitoring and preventing waste, fraud, and abuse in the scholarship program. The organization highlights successful oversight practices from states with established tax credit programs, such as Florida, which has developed legislative measures to increase transparency in the allocation of taxpayer funds.
The comments also focus on the need for states to retain the ability to define eligibility for scholarships based on their unique educational landscapes. This could involve prioritizing assistance for students from disadvantaged backgrounds or those with special needs. AASA calls for clear guidance from the agency to ensure states can gather pertinent data that illustrates the impact of scholarship programs on different student populations.
In addition to these broader concerns, AASA raises specific technical issues in its comments, such as the need for a flexible interpretation of the types of educational expenses that qualify under federal law. The association hopes that forthcoming regulations will encompass a wide range of supportive services, including tutoring and mental health resources, to enhance the educational outcomes for students in need.
AASA anticipates that the forthcoming guidance will reflect the importance of state discretion and promote effective collaboration between federal and state educational initiatives.
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The letter was signed by:
Sasha Pudelski, Director of Advocacy, AASA, The School Superintendents Association
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Read full text of letter here: https://www.regulations.gov/comment/IRS-2025-0466-1349
California Farm Bureau Advocates for Restoration of 2020 Exclusion Regulations
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WASHINGTON, Jan. 6 -- The California Farm Bureau Federation has submitted a public comment letter to the U.S. Fish and Wildlife Service (FWS), expressing strong support for proposed revisions to critical habitat regulations under the Endangered Species Act (ESA). The letter, received on December 22, urges the agency to rescind the 2024 rule and restore the framework established in 2020, which the Farm Bureau argues brings clarity and balance to the designation process.
With representation from approximately 28,000 members across California, the Farm Bureau plays a pivotal role in advocating for
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WASHINGTON, Jan. 6 -- The California Farm Bureau Federation has submitted a public comment letter to the U.S. Fish and Wildlife Service (FWS), expressing strong support for proposed revisions to critical habitat regulations under the Endangered Species Act (ESA). The letter, received on December 22, urges the agency to rescind the 2024 rule and restore the framework established in 2020, which the Farm Bureau argues brings clarity and balance to the designation process.
With representation from approximately 28,000 members across California, the Farm Bureau plays a pivotal role in advocating foragricultural interests and responsible stewardship of natural resources. It emphasizes that the restoration of the 2020 regulations is essential to maintain the integrity of the ESA while considering economic implications alongside environmental needs.
The Farm Bureau highlights that the proposed changes would allow FWS to better analyze site-specific factors by reinstating discretion for exclusion when benefits outweigh the costs. By rescinding the limitations of the 2024 rule, the agency can incorporate vital economic and social data into its decision-making process, ensuring that individual cases receive the attention they require.
In addition to supporting the return of the 2020 exclusion framework, the organization commends the proposed clarification that federal lands may also be excluded under specific circumstances. The Farm Bureau points out that the mere presence of federal ownership should not impede exclusion if substantial consultation costs or opportunities for conservation exist outside the federal scope. This flexibility is seen as fundamental to achieving ecological goals without compromising agricultural viability.
Moreover, the Farm Bureau calls for an emphasis on credible information when evaluating economic impacts, underscoring that accurate assessments must factor in potential losses associated with critical habitat designations. This comprehensive approach aims to support informed decisions that minimize adverse effects on rural communities and align with species recovery efforts.
One notable aspect of the letter is the emphasis on the significance of voluntary conservation agreements and partnerships. The Farm Bureau urges the Service to recognize these initiatives as valuable assets within the balancing analysis, thereby promoting cooperative conservation efforts rather than redundant federal regulations.
In conclusion, the California Farm Bureau Federation asserts that the restoration of the 2020 exclusion regulations will contribute to a balanced approach that respects both agricultural needs and conservation goals. By reinforcing this framework, the agency would not only foster species recovery but also maintain the viability of California's rich agricultural landscape.
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The letter was signed by:
Shannon Douglass, President
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Re: Docket No. FWS-HQ-ES-2025-0048, Endangered and Threatened Wildlife and
Plants; Regulations for Designating Critical Habitat
Read full text of letter here: https://www.regulations.gov/comment/FWS-HQ-ES-2025-0048-12414
California Farm Bureau Advocates for Restoration of 2019 ESA Regulations
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WASHINGTON, Jan. 6 -- The California Farm Bureau Federation has submitted a public comment letter to the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. The organization expresses strong support for the proposal to revert to the 2019 regulatory framework under the Endangered Species Act concerning interagency cooperation regulations. This proposal seeks to rescind the 2024 amendments that altered consultation processes and restore the previous definitions relating to environmental effects.
The Farm Bureau, representing approximately 28,000 members across 57 counties,
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WASHINGTON, Jan. 6 -- The California Farm Bureau Federation has submitted a public comment letter to the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. The organization expresses strong support for the proposal to revert to the 2019 regulatory framework under the Endangered Species Act concerning interagency cooperation regulations. This proposal seeks to rescind the 2024 amendments that altered consultation processes and restore the previous definitions relating to environmental effects.
The Farm Bureau, representing approximately 28,000 members across 57 counties,emphasizes the importance of clear and consistent consultation procedures for agricultural producers, irrigation districts, and local governments involved in projects requiring federal permits. They argue that the 2019 rule not only improved predictability but also facilitated the timely review of various projects, thus reducing delays and litigation risks.
Key aspects of the 2019 rule highlighted by the Farm Bureau include the definition of "effects of the action," which effectively focuses on direct impacts rather than speculative effects. This change is crucial for maintaining rigorous biological standards while ensuring administrative efficiency in ESA consultations. They stress that restoring the definition will help avoid ambiguous analyses that hinder timely decision-making.
Farm Bureau comments touch on the significance of the Supreme Court's decision in Loper Bright Enterprises v. Raimondo, which underscored the importance of adhering to statutory intent in regulatory interpretations. They commend the Services for aligning their proposal with this principle, thereby reinforcing both legal and practical frameworks for agencies involved in consultations.
The organization advocates for a clear distinction between consultation duties under Section 7(a)(2) and separate obligations under Section 7(a)(1). They assert that returning to the 2019 language will help ensure that consultations are procedural safeguards rather than tools for expanding conservation responsibilities to non-federal entities.
The letter notes that reinstating Section 402.17 is critical for maintaining a transparent and consistent framework regarding the assessment of activities that are "reasonably certain to occur." The Farm Bureau urges clarification in upcoming rules to avoid extending federal consultation requirements to state or local decisions, which could potentially complicate compliance for agricultural operations.
The Farm Bureau believes that restoring the 2019 ESA regulations will benefit agricultural and rural communities by re-establishing a framework that emphasizes transparency and scientific evaluation. The organization remains optimistic that these changes can facilitate effective conservation efforts while ensuring that agricultural production remains viable and efficient.
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The letter was signed by:
Shannon Douglass, President
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Re: Docket No. FWS-HQ-ES-2025-0044, Endangered and Threatened Wildlife and Plants
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Read full text of letter here: https://www.regulations.gov/comment/FWS-HQ-ES-2025-0044-10296
Burgeoning Oil and Gas Plans in Gulf Raise Concerns for Endangered Sea Turtles
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WASHINGTON, Jan. 6 -- A research biologist from Florida has submitted a public comment letter to the Bureau of Ocean Energy Management (BOEM), urging the agency to reconsider its oil and gas lease sale proposals in vital habitats for endangered sea turtles. The letter expresses concerns about the environmental ramifications associated with potential leasing in areas that are critical to the survival of multiple sea turtle species in the Gulf of Mexico.
In the letter, the biologist highlights the importance of the Gulf as a breeding and feeding ground for five federally-listed threatened or endangered
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WASHINGTON, Jan. 6 -- A research biologist from Florida has submitted a public comment letter to the Bureau of Ocean Energy Management (BOEM), urging the agency to reconsider its oil and gas lease sale proposals in vital habitats for endangered sea turtles. The letter expresses concerns about the environmental ramifications associated with potential leasing in areas that are critical to the survival of multiple sea turtle species in the Gulf of Mexico.
In the letter, the biologist highlights the importance of the Gulf as a breeding and feeding ground for five federally-listed threatened or endangeredsea turtle species. Notably, the Northwest Atlantic leatherback sea turtle population relies heavily on this region as a foraging site during migration periods. Research conducted over a span of 14 years has documented essential habitats where these turtles gather, emphasizing that oil and gas platforms already pose a substantial threat to their populations. The Gulf's northeastern areas, which include the Florida panhandle, create a network of vital corridors where these turtles are highly active.
The biologist contends that increasing oil and gas activities, particularly seismic blasting and additional platforms, will place further pressures on these vulnerable populations. Evidence from past oil spills, such as the notorious Deepwater Horizon incident, reveals the devastating impacts on sea turtles at all stages of life, including significant mortality rates due to oil contamination and habitat degradation. This history underscores the potential consequences of further exploitation of marine resources in such sensitive ecosystems.
Moreover, the letter outlines the economic impact that turtle populations have on Florida's tourism industry. The state attracts thousands of visitors eager to witness sea turtles in their natural habitats. A spike in offshore drilling activities, which inherently involves the risk of oil spills, would jeopardize these natural attractions and harm the state's tourism-driven economy.
In closing, the biologist calls for the BOEM to protect U.S. waters from any new oil and gas leases associated with the 11th National Outer Continental Shelf Oil and Gas Leasing Program. Additionally, the letter advocates for a thorough update of the draft programmatic environmental impact statement to assess the cumulative effects of proposed drilling operations and oil spills on the environment.
As discourse surrounding the rights and protection of endangered species intensifies, the call to safeguard marine habitats remains critical amid ongoing challenges posed by industrial expansion.
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The letter was written to:
Walter D. Cruickshank, Acting Director
Bureau of Ocean Energy Management
1849 C Street, NW
Washington, District of Columbia 20240
The letter was written by:
Daniel R Evans
Research Biologist
Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0483-1564
Brookfield Zoo Chicago Urges Withdrawal of Proposed Rule on Endangered Species
Carter Struck
WASHINGTON, Jan. 6 -- Brookfield Zoo Chicago has submitted a public comment letter to the U.S. Fish and Wildlife Service (USFWS), expressing concerns regarding a proposed rule that could hinder the timely listing of endangered species and protections for critical habitats. The zoo, which has collaborated closely with USFWS on various species recovery initiatives, emphasized that any complication in the listing process contradicts the core mission of the Endangered Species Act (ESA).
In its letter, the organization highlighted its long-standing partnership with USFWS and the National Marine Fisheries
... Show Full Article
WASHINGTON, Jan. 6 -- Brookfield Zoo Chicago has submitted a public comment letter to the U.S. Fish and Wildlife Service (USFWS), expressing concerns regarding a proposed rule that could hinder the timely listing of endangered species and protections for critical habitats. The zoo, which has collaborated closely with USFWS on various species recovery initiatives, emphasized that any complication in the listing process contradicts the core mission of the Endangered Species Act (ESA).
In its letter, the organization highlighted its long-standing partnership with USFWS and the National Marine FisheriesService (NMFS) to facilitate successful recovery efforts for various species. For instance, the zoo has been instrumental in the reintroduction of Mexican wolves and the recovery of endangered species like the Guam kingfisher and Puerto Rican crested toad through extensive breeding and management programs. Brookfield Zoo Chicago argues that the proposed regulations could jeopardize these efforts and lead to unnecessary delays that threaten these species' survival.
Brookfield Zoo, operated by the Chicago Zoological Society (CZS), is recognized internationally for its commitment to animal care and conservation. The organization serves nearly two million visitors each year and maintains an array of nearly 3,600 animals, many of which are endangered or threatened. The zoo's conservation mission focuses on fostering a deeper connection between the public and wildlife, aiming to cultivate a community committed to ecological stewardship.
The zoo also addressed process-related concerns in its letter, stressing that the 30-day comment period, coinciding with the holiday season, is insufficient for stakeholders to adequately review the proposed changes. Additionally, the organization criticized the USFWS for issuing related proposals separately, complicating the public's understanding of how they interrelate and their cumulative effects on conservation strategies.
A key issue raised in the letter involves the ambiguous terminology introduced by the proposed rule, particularly concerning "foreseeable future" and the definitions related to species recovery. Brookfield Zoo Chicago fears that such ambiguities might lead to premature delisting of species without ensuring that populations are genuinely stable, potentially undermining decades of conservation efforts and hastening species decline.
In conclusion, Brookfield Zoo Chicago appeals for the Administration to withdraw the proposed rule and reaffirm its commitment to the foundational objectives of the ESA, emphasizing the importance of conserving endangered species and their essential ecosystems. The organization remains dedicated to working collaboratively with conservation partners to ensure the protection of vulnerable wildlife.
***
The letter was signed by:
Brookfield Zoo Chicago
*
Re: Docket No. FWS-HQ-ES-2025-0039; Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat. Brookfield Zoo Chicago respectfully submits the following comments on Docket No. FWS-HQ-ES-2025-0039; Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat.
* * *
Read full text of letter here: https://www.regulations.gov/comment/FWS-HQ-ES-2025-0039-35550
Society for Range Management Advocates for Tailored Conservation Strategies
Carter Struck
WASHINGTON, Dec. 28 -- The Society for Range Management (SRM) has submitted a public comment letter to the U.S. Fish and Wildlife Service, addressing proposed rule changes to the Endangered Species Act (ESA) specifically regarding section 4(d). The organization, dedicated to promoting sustainable rangeland stewardship, emphasized the need for a balanced approach that incorporates ecological data while accommodating regional management practices.
In its letter, SRM underscored the importance of including a variety of stakeholders, including ranchers and land managers, in discussions around species
... Show Full Article
WASHINGTON, Dec. 28 -- The Society for Range Management (SRM) has submitted a public comment letter to the U.S. Fish and Wildlife Service, addressing proposed rule changes to the Endangered Species Act (ESA) specifically regarding section 4(d). The organization, dedicated to promoting sustainable rangeland stewardship, emphasized the need for a balanced approach that incorporates ecological data while accommodating regional management practices.
In its letter, SRM underscored the importance of including a variety of stakeholders, including ranchers and land managers, in discussions around speciesconservation. The organization believes that effective conservation strategies should be developed in partnership with those who implement them on the ground, rather than in opposition. This collaborative approach is seen as essential for achieving practical outcomes in conservation efforts.
The letter expressed support for the proposed rescission of the "blanket" 4(d) rule, suggesting that tailored, species-specific conservation strategies could provide a more effective means of addressing the unique ecological requirements of species like sage grouse and prairie chickens. However, the organization cautioned that the agency must be prepared to address potential challenges, particularly in terms of providing adequate resources and staffing to implement these strategies across federal lands.
In discussing the proposed broadening of factors for critical habitat exclusions, SRM advocated for decisions that are not only economically viable but also grounded in sound research. The organization raised concerns that expanded exclusion criteria might allow non-ecological considerations to overshadow the necessary habitat requirements for endangered species. Furthermore, SRM noted a lack of focus on Threatened, Rare, and Endangered (TR&E) habitats within rangeland ecosystems in the current proposals.
The Society for Range Management urged the U.S. Fish and Wildlife Service to prioritize the use of the best available scientific data when making habitat designations. The organization believes that a commitment to robust data should inform all decisions regarding species listing and habitat exclusions.
In closing, SRM extended a request to be included in future discussions regarding the ESA changes, expressing eagerness to collaborate with the agency to uphold effective rangeland wildlife habitat management based on sound ecological principles. The society remains dedicated to playing a constructive role in these critical conservation efforts.
***
The letter was written by:
Dr. Jeff Goodwin
President, Society for Range Management
Society for Range Management
100 N 27th St., Suite 600 D, Billings, MT 59101 | www.rangelands.org
Read full text of letter here: https://www.regulations.gov/comment/FWS-HQ-ES-2025-0029-14572
National Civic Art Society President Shubow Seeks Spot on DOT Infrastructure Beautification Council
By Lin Andre Vitin
WASHINGTON, Dec. 4 -- Justin Shubow, president of the National Civic Art Society, has submitted a letter to the U.S. Department of Transportation nominating himself for a position on the Beautifying Transportation Infrastructure Council. The nomination (DOT-OST-2025-1194) emphasized his background as a leading proponent for traditional design and a widely quoted critic of contemporary architecture. The nominee is a former Chairman of the U.S. Commission of Fine Arts, an independent federal agency that functions as the aesthetic review board for Washington, D.C.
The individual affirmed that he
... Show Full Article
WASHINGTON, Dec. 4 -- Justin Shubow, president of the National Civic Art Society, has submitted a letter to the U.S. Department of Transportation nominating himself for a position on the Beautifying Transportation Infrastructure Council. The nomination (DOT-OST-2025-1194) emphasized his background as a leading proponent for traditional design and a widely quoted critic of contemporary architecture. The nominee is a former Chairman of the U.S. Commission of Fine Arts, an independent federal agency that functions as the aesthetic review board for Washington, D.C.
The individual affirmed that hemeets all Council eligibility requirements. The submission to the agency highlighted his national profile, noting that media outlets have described him as one of architecture's biggest critics. His experience advising the federal government includes a presidential appointment as Chairman of the Commission of Fine Arts. He serves as a Peer Professional for the General Services Administration's Design Excellence Program, which involves advising on the design of federal projects. He also serves on the Board of Advisors of the Roger Scruton Legacy Foundation and the Board of Academic Advisors of the Alexander Hamilton Institute for the Study of Western Civilization.
His background includes extensive policy advocacy and academic experience. The nominee has testified in Congress on topics such as the future of the National Mall and the design of the Dwight D. Eisenhower Memorial. He delivered a talk to a U.S. Senate Steering Committee concerning a previous Executive Order on federal architecture. The letter mentioned the nominee authored a critical examination of the Eisenhower memorial's competition and design.
The advocate's writing on architectural criticism appears in numerous publications, including Fox News, Forbes, City Journal, First Things, Public Discourse, The Washington Post, and The Weekly Standard. He is a former editor at Forward newspaper and Commentary magazine, and is a recipient of a Robert Novak Journalism Fellowship. He has delivered talks on architecture and other subjects at various institutions including the U.S. Department of State, Baylor University, and the Universities of Michigan, Pennsylvania, and Virginia. Academically, he holds a B.A. from Columbia University and a J.D. from Yale Law School, and pursued four years of study in philosophy at the University of Michigan, where he also taught philosophy courses at the University and Yale College.
***
Read full text of letter here: https://www.regulations.gov/comment/DOT-OST-2025-1194-0006
Behavior Analyst Urges FDA Panel to Review Acetaminophen Use and Child Neurodevelopment
Carter Struck
WASHINGTON, Dec. 4 -- Michael Moates, executive director of Crosspoint Health, Wichita, Kansas, has submitted a public comment letter to the Food and Drug Administration urging the agency's Pediatric Advisory Committee to review the relationship between prenatal acetaminophen exposure and child neurodevelopmental outcomes, specifically autism spectrum disorder and attention deficit hyperactivity disorder. Moates stated that the topic is squarely within the committee's remit and justifies attention, despite the evidence not yet establishing causation.
The analyst noted that the available data shows
... Show Full Article
WASHINGTON, Dec. 4 -- Michael Moates, executive director of Crosspoint Health, Wichita, Kansas, has submitted a public comment letter to the Food and Drug Administration urging the agency's Pediatric Advisory Committee to review the relationship between prenatal acetaminophen exposure and child neurodevelopmental outcomes, specifically autism spectrum disorder and attention deficit hyperactivity disorder. Moates stated that the topic is squarely within the committee's remit and justifies attention, despite the evidence not yet establishing causation.
The analyst noted that the available data showsconflicting results. The highest quality human evidence to date, nationwide sibling control analyses from Sweden, found no association between prenatal acetaminophen use and neurodevelopmental outcomes once shared familial genetics and environment were accounted for. The comment attributed earlier signals to confounding by indication, such as fever, infection, and pain, or to recall bias from relying on maternal memory. The analyst pointed out that this structural limitation is often shared by observational studies, which can inflate apparent consistency when multiple reports rely on the same potentially flawed methodology.
The letter contrasted these findings with qualitative reviews, including one associated with Harvard, that concluded the weight of evidence favored an association, yet failed to resolve the critical issue of familial confounding. Conversely, the committee was reminded that a review in The British Medical Journal concluded existing evidence does not clearly link maternal paracetamol use with the conditions once study quality is weighed. Additionally, leading obstetric guidance has emphasized that undertreatment of maternal fever and pain can itself harm mothers and fetuses.
The individual requested the committee recommend interim precautionary messaging to the agency. For consumer drug labels, the analyst advised language encouraging use only when medically needed at the lowest effective dose for the shortest time, with consultation for repeated or prolonged use. For clinicians, the recommendation was a communication summarizing the evidence, explicitly distinguishing association from causation, and discouraging routine or chronic use without a clear indication. Finally, the analyst urged the agency to establish a research roadmap that includes prospective pregnancy cohorts and advanced study designs like sibling comparison and Mendelian randomization.
***
The letter was written by:
OFFICE OF DR. MICHAEL MOATES
Licensed Behavior Analyst | Registered Naturopath
Certified Employee Assistance Professional
Executive Director, Crosspoint Health
Director, American College Of Neurodiversity Practitioners
Master Of Science In Nursing Candidate, Herzing University
Fellow, Institute For Social Innovation, Fielding Graduate University
Advocacy Leader, Graduate Student Nursing Academy
*
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-3774-0005
Financial Experts Raise Alarm Over Stablecoin Reserve Rules
By Lin Andre Vitin
WASHINGTON, Dec. 4 -- Attorney Howard B. Adler, former deputy assistant treasury secretary for the Financial Stability Oversight Council, and Alex J. Pollock, senior fellow at the Mises Institute, Auburn, Alabama, have submitted a public comment letter to the U.S. Department of the Treasury concerning the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The authors warned that the inclusion of uninsured deposits in domestic and foreign banks as allowable reserves introduces serious financial stability risks.
The comment contended that, contrary
... Show Full Article
WASHINGTON, Dec. 4 -- Attorney Howard B. Adler, former deputy assistant treasury secretary for the Financial Stability Oversight Council, and Alex J. Pollock, senior fellow at the Mises Institute, Auburn, Alabama, have submitted a public comment letter to the U.S. Department of the Treasury concerning the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The authors warned that the inclusion of uninsured deposits in domestic and foreign banks as allowable reserves introduces serious financial stability risks.
The comment contended that, contraryto popular discussion, the act does not create virtually risk-free backing for stablecoins because uninsured deposits are an entirely different class of risk than government-guaranteed investments like short-term Treasury bills. The authors asserted that the legislation ties stablecoin risk directly to banking risk, citing instances of bank failures over the last half-century. The experts recalled the 2023 incident where Circle's USD Coin lost its dollar peg after the company disclosed that a substantial portion of its reserves was tied up at the collapsed Silicon Valley Bank. They warned that this same problem could happen again under the act's provisions.
The experts were greatly concerned with the act permitting reserves to be held in uninsured deposits at foreign banks, particularly those that are correspondents of U.S. banks. The comment suggested the act provides a strong incentive for stablecoin issuers, including bank subsidiaries, to hold reserves as uninsured deposits rather than low-yielding Treasury debt. This business model--where a bank subsidiary issues a stablecoin and deposits the interest-free reserve funds in its parent bank--would likely be viewed as more profitable than investing the proceeds in U.S. Treasury bills, the authors explained.
The letter concluded that placing reserves in uninsured bank deposits exposes stablecoin holders to the risks of domestic and foreign bank failures and exposes taxpayers to the risk of supporting a stablecoin bailout alongside a bank bailout. To lessen this risk, the authors recommended that bank regulators impose rigorous standards, including strict limits on individual bank holdings and the application of standard risk-based capital requirements against all uninsured deposits held by payment stablecoin issuers.
***
The letter was signed by:
Alex J. Pollock
Senior Fellow, Mises Institute
Formerly Principal Deputy Director, Office of Financial Research
alexjpollock43@gmail.com
312-401-8366
453 East Illinois Road
Lake Forest, Illinois 60045
*
Howard B. Adler
Attorney
Formerly Deputy Assistant Treasury Secretary for FSOC
hadler1951@gmail.com
301-502-7814
11103 Cripplegate Road
Potomac, Maryland 20854
*
Read full text of letter here: https://www.regulations.gov/comment/TREAS-DO-2025-0037-0313
Behavior Analyst Urges FDA Panel to Review Acetaminophen Use and Child Neurodevelopment
Carter Struck
WASHINGTON, Dec. 4 -- Michael Moates, executive director of Crosspoint Health, Wichita, Kansas, has submitted a public comment letter to the Food and Drug Administration urging the agency's Pediatric Advisory Committee to review the relationship between prenatal acetaminophen exposure and child neurodevelopmental outcomes, specifically autism spectrum disorder and attention deficit hyperactivity disorder. Moates stated that the topic is squarely within the committee's remit and justifies attention, despite the evidence not yet establishing causation.
The analyst noted that the available data shows
... Show Full Article
WASHINGTON, Dec. 4 -- Michael Moates, executive director of Crosspoint Health, Wichita, Kansas, has submitted a public comment letter to the Food and Drug Administration urging the agency's Pediatric Advisory Committee to review the relationship between prenatal acetaminophen exposure and child neurodevelopmental outcomes, specifically autism spectrum disorder and attention deficit hyperactivity disorder. Moates stated that the topic is squarely within the committee's remit and justifies attention, despite the evidence not yet establishing causation.
The analyst noted that the available data showsconflicting results. The highest quality human evidence to date, nationwide sibling control analyses from Sweden, found no association between prenatal acetaminophen use and neurodevelopmental outcomes once shared familial genetics and environment were accounted for. The comment attributed earlier signals to confounding by indication, such as fever, infection, and pain, or to recall bias from relying on maternal memory. The analyst pointed out that this structural limitation is often shared by observational studies, which can inflate apparent consistency when multiple reports rely on the same potentially flawed methodology.
The letter contrasted these findings with qualitative reviews, including one associated with Harvard, that concluded the weight of evidence favored an association, yet failed to resolve the critical issue of familial confounding. Conversely, the committee was reminded that a review in The British Medical Journal concluded existing evidence does not clearly link maternal paracetamol use with the conditions once study quality is weighed. Additionally, leading obstetric guidance has emphasized that undertreatment of maternal fever and pain can itself harm mothers and fetuses.
The individual requested the committee recommend interim precautionary messaging to the agency. For consumer drug labels, the analyst advised language encouraging use only when medically needed at the lowest effective dose for the shortest time, with consultation for repeated or prolonged use. For clinicians, the recommendation was a communication summarizing the evidence, explicitly distinguishing association from causation, and discouraging routine or chronic use without a clear indication. Finally, the analyst urged the agency to establish a research roadmap that includes prospective pregnancy cohorts and advanced study designs like sibling comparison and Mendelian randomization.
***
The letter was written by:
OFFICE OF DR. MICHAEL MOATES
Licensed Behavior Analyst | Registered Naturopath
Certified Employee Assistance Professional
Executive Director, Crosspoint Health
Director, American College Of Neurodiversity Practitioners
Master Of Science In Nursing Candidate, Herzing University
Fellow, Institute For Social Innovation, Fielding Graduate University
Advocacy Leader, Graduate Student Nursing Academy
*
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-3774-0005
Concerned Women for America Backs DOT Changes to Sex-Based Terminology in Drug Testing
Carter Struck
WASHINGTON, Dec. 2 -- Concerned Women for America (CWA) has expressed support for proposed changes to sex-based terminology and procedures within the U.S. Department of Transportation's "Procedures for Transportation Workplace Drug and Alcohol Testing Programs" (RIN 2105-AF28). In a public comment letter, the organization emphasized that these amendments are vital for maintaining the clarity of federal regulations in relation to the biological distinctions between men and women.
CWA conveyed its view that the characterization of sex should adhere to immutable definitions grounded in scientific
... Show Full Article
WASHINGTON, Dec. 2 -- Concerned Women for America (CWA) has expressed support for proposed changes to sex-based terminology and procedures within the U.S. Department of Transportation's "Procedures for Transportation Workplace Drug and Alcohol Testing Programs" (RIN 2105-AF28). In a public comment letter, the organization emphasized that these amendments are vital for maintaining the clarity of federal regulations in relation to the biological distinctions between men and women.
CWA conveyed its view that the characterization of sex should adhere to immutable definitions grounded in scientificunderstanding, asserting that biological sex should not be overridden by personal claims of gender identity. They believe it is essential for federal law and policy to explicitly recognize the binary nature of sex as objectively determined, reinforcing that acknowledgment is key to protecting the dignity and privacy of individuals.
The organization acknowledged the previous administration's commitment to uphold women's dignity through policies that affirm their biological classification, referencing an initiative designed to protect women in diverse areas such as healthcare, education, and sports. CWA stated that the administration's stance aligns with its broader objective to affirm sex-based distinctions to ensure that women have adequate protections in all public and private sectors.
Moreover, CWA highlighted the importance of these proposed regulations in restoring and maintaining clear distinctions between male and female for effective identification, documentation, treatment, and enforcement. They argued that without such clarity, the implementation of federal programs could falter. The organization criticized the influence of what they termed "fabricated terminology" associated with modern gender ideology, describing it as subjective and prone to misuse, which jeopardizes legal protections grounded in sex.
CWA is calling upon the Department of Transportation to expedite the finalization of this supplement to RIN 2105-AF28, asserting that achieving its intended objectives will contribute significantly to accuracy and consistency in regulations. The organization believes that such policies are necessary not only for the integrity of transport workplace programs but also for broader implications related to sex and gender within government frameworks.
Concerned Women for America remains committed to advocating for policies that they believe will affirm and protect the unique rights of women, emphasizing the importance of scientifically accurate definitions in federal regulations.
***
Read full text of letter here: https://www.regulations.gov/comment/DOT-OST-2021-0093-0499
American Pistachio Growers Urge FDA To Exclude Nuts From Ultra-Processed Food Classification
Carter Struck
WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, now
... Show Full Article
WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, nowvalued at approximately $1.9 billion. The organization works toward advancing nutritional awareness, health research, legislative advocacy, and marketing efforts to promote the consumption of pistachios. Their letter details extensive research showcasing the numerous health benefits of pistachio consumption, including its role as a complete protein and its positive impacts on heart health, blood glucose control, and weight management.
The organization cautioned the agency that misclassifying nutritious foods like pistachios as UPFs could diminish consumer confidence and lead to reduced consumption of these healthful snacks. It highlighted that pistachios possess unique nutritional qualities and should not be categorized alongside foods that are heavily processed and lack beneficial nutrients.
In its response to various queries posed by the agency, APG suggested that exemptions should be made for raw agricultural commodities and minimally processed foods. They explained that certain processing methods, such as roasting, do not fundamentally alter the health attributes of pistachios. Additionally, APG underscored the importance of defining UPFs in a way that would avoid discouraging the consumption of beneficial foods, as an overly broad classification could inadvertently include items that are vital to a balanced diet.
Furthermore, the letter emphasized that the nutritional density of foods, including factors such as protein quality, should play a crucial role in their classification. By advocating for a science-based approach, APG aims to ensure that foods delivering essential nutrients are not mistakenly reclassified as unhealthy options.
As discussions around the UPF classification continue, APG urges the FDA to approach this issue with careful consideration of both consumer health implications and the integrity of the food supply chain. The organization remains committed to promoting the health benefits of pistachios and hopes to facilitate more informed dietary choices among consumers nationwide.
***
The letter was signed by:
Zachary Fraser
President & CEO
American Pistachio Growers
ZFraser@americanpistachios.org
559.475.0435
*
Cadee Condit
Vice President, Government Affairs
American Pistachio Growers
CCondit@americanpistachios.org
*
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4980
American Pistachio Growers Urge FDA To Exclude Nuts From Ultra-Processed Food Classification
Carter Struck
WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, now
... Show Full Article
WASHINGTON, Dec. 2 -- The American Pistachio Growers (APG), Fresno, California, has submitted a public comment letter to the Food and Drug Administration (FDA) regarding the classification of ultra-processed foods (UPFs). In this letter, APG has strongly advocated for the exemption of pistachios from being labeled as ultra-processed, a classification they argue could mislead consumers regarding the health benefits of these nuts.
APG, which represents over 850 members from farms primarily in California, Arizona, and New Mexico, emphasized the rapid growth of the American pistachio industry, nowvalued at approximately $1.9 billion. The organization works toward advancing nutritional awareness, health research, legislative advocacy, and marketing efforts to promote the consumption of pistachios. Their letter details extensive research showcasing the numerous health benefits of pistachio consumption, including its role as a complete protein and its positive impacts on heart health, blood glucose control, and weight management.
The organization cautioned the agency that misclassifying nutritious foods like pistachios as UPFs could diminish consumer confidence and lead to reduced consumption of these healthful snacks. It highlighted that pistachios possess unique nutritional qualities and should not be categorized alongside foods that are heavily processed and lack beneficial nutrients.
In its response to various queries posed by the agency, APG suggested that exemptions should be made for raw agricultural commodities and minimally processed foods. They explained that certain processing methods, such as roasting, do not fundamentally alter the health attributes of pistachios. Additionally, APG underscored the importance of defining UPFs in a way that would avoid discouraging the consumption of beneficial foods, as an overly broad classification could inadvertently include items that are vital to a balanced diet.
Furthermore, the letter emphasized that the nutritional density of foods, including factors such as protein quality, should play a crucial role in their classification. By advocating for a science-based approach, APG aims to ensure that foods delivering essential nutrients are not mistakenly reclassified as unhealthy options.
As discussions around the UPF classification continue, APG urges the FDA to approach this issue with careful consideration of both consumer health implications and the integrity of the food supply chain. The organization remains committed to promoting the health benefits of pistachios and hopes to facilitate more informed dietary choices among consumers nationwide.
***
The letter was signed by:
Zachary Fraser
President & CEO
American Pistachio Growers
ZFraser@americanpistachios.org
559.475.0435
*
Cadee Condit
Vice President, Government Affairs
American Pistachio Growers
CCondit@americanpistachios.org
*
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4980
Barry University School of Law Environmental & Earth Law Clinic Supports Proposed Rule to Protect Southern Hognose Snake Under Endangered Species Act
Carter Struck
WASHINGTON, Dec. 2 -- The Barry University School of Law Environmental and Earth Law Clinic, Orlando, Florida, has submitted a public comment letter to the Fish and Wildlife Service urging for the finalization of a proposed rule to list the Southern Hognose Snake as a threatened species. This proposed action comes in response to the ongoing decline in this species' population, with the clinic emphasizing its vital role in the longleaf pine ecosystem.
The Environmental and Earth Law Clinic acknowledges the effectiveness of the Endangered Species Act, crediting it for preventing the extinction of
... Show Full Article
WASHINGTON, Dec. 2 -- The Barry University School of Law Environmental and Earth Law Clinic, Orlando, Florida, has submitted a public comment letter to the Fish and Wildlife Service urging for the finalization of a proposed rule to list the Southern Hognose Snake as a threatened species. This proposed action comes in response to the ongoing decline in this species' population, with the clinic emphasizing its vital role in the longleaf pine ecosystem.
The Environmental and Earth Law Clinic acknowledges the effectiveness of the Endangered Species Act, crediting it for preventing the extinction ofover 99 percent of listed species. In their letter, the clinic expressed support for the U.S. Fish and Wildlife Service's determination that the Southern Hognose Snake, or Heterodon simus, warrants protection under Section 4(d) of the Act due to threats such as habitat loss, climate change, and predation.
The Southern Hognose Snake has seen a dramatic decline in its range and population, having lost a significant portion of its historical habitats. According to the Service's findings, the longleaf pine ecosystems, which once spanned over 90 million acres, have drastically reduced to less than 3 million acres today. The clinic pointed out that this habitat is crucial not just for the Southern Hognose but also supports a diverse array of other species.
In their submission, the clinic articulated several key threats impacting the Southern Hognose Snake. Road mortality, habitat fragmentation, and the introduction of non-native species contribute to the species' vulnerability. Additionally, climate-related changes pose further challenges, potentially altering available habitats and food sources.
The proposed protective regulations include prohibitions against various harmful actions, including harassment, harm, and illegal trade of the Southern Hognose Snake. The clinic argues that these measures are essential for preventing further population declines and ensuring the long-term survival of the species.
Barry University's Environmental and Earth Law Clinic emphasized the importance of collaboration among federal and state agencies, private landowners, and conservationists to successfully restore and protect habitats vital to the Southern Hognose Snake's survival. They urged the Service to take decisive action in implementing the proposed rule and encourage ongoing conservation efforts.
***
The letter was signed by:
Barry University School of Law Environmental and Earth Law Clinic
Prepared by Emilie Bailey, Emma Berman, Serena Sapp, and Emily Inboden
*
Read full text of letter here: https://www.regulations.gov/comment/FWS-R4-ES-2025-0210-0197
Healthy Food America Executive Director Urges FDA To Adopt NOVA Classification For Ultra-Processed Foods
Carter Struck
WASHINGTON, Dec. 2 -- James Krieger, executive director of Healthy Food America, Seattle, Washington, submitted a public comment letter to the Food and Drug Administration regarding its request for information on Ultra-Processed Foods (UPFs). The official contended that growing and convincing evidence linking UPF consumption to health harms is sufficient to merit regulatory and policy action to reduce exposure to these products.
The academic stated that a large body of cross-sectional and prospective studies, along with randomized trials, demonstrates an association between UPF consumption and
... Show Full Article
WASHINGTON, Dec. 2 -- James Krieger, executive director of Healthy Food America, Seattle, Washington, submitted a public comment letter to the Food and Drug Administration regarding its request for information on Ultra-Processed Foods (UPFs). The official contended that growing and convincing evidence linking UPF consumption to health harms is sufficient to merit regulatory and policy action to reduce exposure to these products.
The academic stated that a large body of cross-sectional and prospective studies, along with randomized trials, demonstrates an association between UPF consumption andelevated risk of chronic diseases, including cardiovascular and metabolic disease, certain cancers, and mental health disorders. The comment noted that these studies found consumption adversely affects physiologic pathways, contributing to increased body weight and hypertension. Given that more than 50% of calories consumed in the U.S. come from UPFs, the available evidence clearly supports taking regulatory action, the executive director argued.
The primary recommendation was for the FDA to adopt the NOVA classification system as the best processed food classification system for use with the U.S. food supply. The expert asserted that an evidence-based definition must start with NOVA because it has been validated in epidemiologic and clinical studies with respect to adverse health outcomes. The system identifies UPFs based on the presence of marker ingredients--a set of cosmetic and non-culinary additives--regardless of their mass or position in the ingredient list. The agency was advised that general flavors should be used as markers, but only certified colors should be counted.
The comment further stated that nutritional content should not be the marker for UPFs, though nutrient consideration can serve as a complementary approach to identify unhealthy foods or allow exemptions for otherwise healthy products. The Clinical Professor Emeritus noted that using processing criteria to identify UPFs is impractical unless the FDA mandates public disclosure of the type and extent of processing at the product level. The term "UPF" should be retained due to public familiarity, the comment concluded, urging the agency to focus on a comprehensive strategy that addresses the problem instead of blaming certain foods.
***
The letter was signed by:
James Krieger, MD, MPH
Clinical Professor Emeritus, University of Washington School of Public Health
Executive Director, Healthy Food America
*
Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4949
Foundation for Defense of Democracies Urges Commerce Dept. to Prioritize American AI Exports Over China
Carter Struck
WASHINGTON, Dec. 2 -- The Foundation for Defense of Democracies has issued a public comment letter to the U.S. Department of Commerce urging the agency to streamline and prioritize American artificial intelligence (AI) exports. The organization believes that this initiative presents a prime opportunity for the United States to reinforce its technological leadership over China while fostering innovation that can ensure global stability and prosperity.
The letter outlines the unique advantages of the U.S. AI ecosystem, which integrates top-tier semiconductors, advanced cloud-computing capabilities,
... Show Full Article
WASHINGTON, Dec. 2 -- The Foundation for Defense of Democracies has issued a public comment letter to the U.S. Department of Commerce urging the agency to streamline and prioritize American artificial intelligence (AI) exports. The organization believes that this initiative presents a prime opportunity for the United States to reinforce its technological leadership over China while fostering innovation that can ensure global stability and prosperity.
The letter outlines the unique advantages of the U.S. AI ecosystem, which integrates top-tier semiconductors, advanced cloud-computing capabilities,and robust software resources alongside a supportive regulatory environment and substantial financial infrastructure. These components are deemed essential for driving commercial opportunities, all while underscoring America's alliances and military strengths. The organization highlights concerns regarding China's attempts to acquire U.S. AI technologies through illicit means, emphasizing the need for the Commerce Department to support American firms in protecting their innovations.
To safeguard national security while promoting AI exports, the Foundation advocates that the Commerce Department focus on partnerships with frontline democracies. Such collaborations, it argues, would not only enhance military capabilities but would also optimize resource allocation within the defense sector, distinguishing between trusted allies and authoritarian regimes. Partnerships with countries such as Israel and Ukraine are specifically cited as having the potential to enhance American military operations through the integration of battle-tested AI applications.
Additionally, the organization emphasizes the importance of cybersecurity in the export process. It advises that the Commerce Department implement stringent standards for cybersecurity, physical security, and ownership disclosure for companies seeking to export AI technology. This includes requiring comprehensive evaluations of foreign investments and adherence to U.S. economic security practices, which aim to mitigate risks from adversarial actions.
As the global AI landscape evolves and China strives to bolster its own capabilities, the Foundation asserts that the United States must act decisively to maintain its leadership. By prioritizing exports to nations that align with U.S. values and security interests, the Commerce Department can create robust partnerships and secure advantages against rival nations. The organization expressed optimism that its input could influence future policy decisions, enhancing not just the U.S. position in AI but also global security dynamics.
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The letter was written by:
Jack Burnham, Research Analyst, FDD's China Program
Craig Singleton, Senior Director and Senior Fellow, FDD's China Program
Leah Siskind, Director of Impact and AI Research Fellow
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Read full text of letter here: https://www.regulations.gov/comment/ITA-2025-0070-0013
Fair Finance Watch Opposes Charter Application for Bridge National Trust Bank
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WASHINGTON, Dec. 2 -- Fair Finance Watch (FFW), New York, has submitted a public comment letter to the Office of the Comptroller of the Currency (OCC) expressing opposition to the application for chartering Bridge National Trust Bank. The organization raised concerns over the potential implications for community banking and compliance with existing regulations.
FFW's letter highlights worrying claims that the proposed bank, associated with Stripe, is attempting to withhold fundamental policies that are crucial for transparency and privacy compliance. The organization is urging the OCC to extend
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WASHINGTON, Dec. 2 -- Fair Finance Watch (FFW), New York, has submitted a public comment letter to the Office of the Comptroller of the Currency (OCC) expressing opposition to the application for chartering Bridge National Trust Bank. The organization raised concerns over the potential implications for community banking and compliance with existing regulations.
FFW's letter highlights worrying claims that the proposed bank, associated with Stripe, is attempting to withhold fundamental policies that are crucial for transparency and privacy compliance. The organization is urging the OCC to extendthe comment period, indicating that a lack of public insights could negatively impact the assessment of whether the bank will adequately meet the needs of local communities.
The letter also emphasizes the necessity for a thorough examination under the Community Reinvestment Act (CRA). FFW articulated that it is imperative for regulators to assess how Bridge National Trust Bank intends to support low- and moderate-income neighborhoods, a critical obligation for all financial institutions. The group contends that the proposed bank's application includes indications that it would be exempt from CRA assessments, a stipulation that FFW strongly disputes.
Further raising alarms, FFW mentioned ongoing issues surrounding Strip's privacy history, referencing a court case where claims of privacy violations have surfaced against the company. They contextualize this with a broader critique of Stripe's ambitions in the fintech space, particularly highlighting their latest blockchain initiative, which some analysts believe could perpetuate corporate monopolies rather than create meaningful financial innovation.
FFW's public comment pushes for accountability, insisting on public access to the bank's internal policies and compliance measures. They criticize the current regulatory environment for considering proposals that might eliminate public notice and opportunity for community input regarding banks' applications to expand services. The group argues that the elimination of such requirements would undermine the CRA's core intent and risk sidelining community interests.
In conclusion, Fair Finance Watch demands public hearings regarding the application, expressing that the OCC must take into account the historical context of financial regulation and community needs in order to ensure equitable outcomes. As scrutiny over the bank's charter application intensifies, the outcome remains uncertain, signaling a pivotal moment in community bank oversight and financial industry regulations.
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The letter was signed by:
Matthew R. Lee, Esq.
Fair Finance Watch
PO Box 130222
Chinatown Station
NY NY 10013
718-716-3540
lee@fairfinancewatch.org
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Read full text of letter here: https://www.regulations.gov/comment/OCC-2025-0603-0003
Ex-DOT IG Soskin Submits Feedback on DOJ Firearms Rights Rule
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WASHINGTON, Dec. 2 -- Ex-Transportation Inspector General Eric J. Soskin submitted a public comment letter to the U.S. Department of Justice outlining critical feedback regarding its proposed rulemaking aimed at restoring firearms rights to individuals previously barred by federal law. This comment comes in the wake of a notice of proposed rulemaking issued by the DOJ on July 22, 2025, which intends to establish criteria for determining eligibility for relief from federal firearms disabilities.
The proponent of the letter emphasizes the necessity of refining the proposed rule to better align with
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WASHINGTON, Dec. 2 -- Ex-Transportation Inspector General Eric J. Soskin submitted a public comment letter to the U.S. Department of Justice outlining critical feedback regarding its proposed rulemaking aimed at restoring firearms rights to individuals previously barred by federal law. This comment comes in the wake of a notice of proposed rulemaking issued by the DOJ on July 22, 2025, which intends to establish criteria for determining eligibility for relief from federal firearms disabilities.
The proponent of the letter emphasizes the necessity of refining the proposed rule to better align withthe constitutional rights recognized in landmark Supreme Court cases, such as District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen. The letter argues that while the initiative is commendable, it could inadvertently perpetuate ongoing constitutional rights violations by placing obstacles in the way of eligible individuals seeking restoration of their Second Amendment rights.
Key suggestions include the implementation of a timeline for processing applications for relief, a mechanism for status updates, and the reduction of presumptions against relief that currently may hinder individuals who pose no genuine threat to public safety. The analysis points to the need for a more nuanced approach when assessing past criminal offenses that might affect eligibility, particularly with regards to non-violent offenses.
The letter also critiques the proposed rule's handling of state firearm-related convictions, arguing that it could penalize individuals who reside in states with stringent firearm laws that do not align with broader interpretations of Second Amendment rights. Notably, the author calls for a reconsideration of how individuals with established trustworthiness-such as law enforcement officers-are treated under this proposed rule.
Furthermore, the letter raises concerns about the proposed subsection allowing for arbitrary revocation of granted relief without due process. It suggests that any revocation must be preceded by a fair hearing, where individuals can contest the reasoning for their relief being rescinded.
As discussions around the restoration of Second Amendment rights progress, the letter underscores the importance of ensuring that the regulations introduced not only align with constitutional standards but also safeguard the rights of individuals against potential bureaucratic overreach. The author expresses hope that the DOJ will consider these recommendations to promote a more equitable process in the final rulemaking.
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Read full text of letter here: https://www.regulations.gov/comment/DOJ-LA-2025-0004-1306
Indiana Soybean Alliance Raises Concerns Over Ultra-Processed Food Classification
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WASHINGTON, Nov. 25 -- The Indiana Soybean Alliance Membership & Policy Committee, Indianapolis, has submitted a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing recent discussions surrounding the classification of ultra-processed foods (UPF). The ISA emphasizes the importance of clarity in defining UPF, arguing that an overly broad classification could unfairly group nutritionally beneficial products with less healthy foods.
In its letter, ISA highlighted the healthful properties of soybean oil, particularly high oleic soybean
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WASHINGTON, Nov. 25 -- The Indiana Soybean Alliance Membership & Policy Committee, Indianapolis, has submitted a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing recent discussions surrounding the classification of ultra-processed foods (UPF). The ISA emphasizes the importance of clarity in defining UPF, arguing that an overly broad classification could unfairly group nutritionally beneficial products with less healthy foods.
In its letter, ISA highlighted the healthful properties of soybean oil, particularly high oleic soybeanoil, which has made Indiana the leading producer of high oleic soybeans in the United States. The organization pointed out that soybean oil is low in saturated fat and contains heart-healthy monounsaturated fat, qualifying for health claims by the Food and Drug Administration (FDA). This oil is not just an important ingredient in various packaged goods but is also a staple in cooking, providing numerous nutritional benefits.
ISA expressed concern that food classification systems, particularly the NOVA classification, may inadequately reflect the healthfulness of certain foods. Many items considered ultra-processed, such as fruit-flavored yogurt and plant-based milks, can be nutrient-dense, while less processed foods may be lacking in nutritional value. The organization cautioned that public perceptions influenced by a faulty categorization of foods could lead to unnecessary doubts about safe and widely-used ingredients like seed oils.
Amid changing consumer attitudes toward processed foods, ISA cited a recent survey indicating that the majority of Americans do not actively avoid seed oils and consider them acceptable for consumption. The organization also referenced research indicating that higher intake of plant-based oils is associated with lower mortality rates related to cancer and cardiovascular diseases. These findings suggest that processing methods do not inherently determine dietary value.
As Indiana farmers continue to advocate for the benefits of high oleic soybean oil, ISA underscored the necessity for policies based on nutrient composition rather than vague classifications tied to processing methods. The organization emphasizes the contribution of high oleic soybean oil not only to health but also as a resource that provides economic support to farmers.
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The letter was signed by:
Courtney Kingery | CEO
Indiana Soybean Alliance
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5110
IDARE LLC Supports AI Export Program to Boost U.S. Leadership, Responsible Tech Use Abroad
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WASHINGTON, Nov. 25 -- IDARE LLC, Houston, Texas has submitted a public comment letter to the U.S. Department of Commerce providing input on the agency's Full-Stack AI Export Program established under Executive Order 14320. With annual revenues between $1 million and $2 million and a team of 20 to 50 employees, the company specializes in developing and exporting advanced artificial intelligence (AI) platforms aimed at sectors including Oil & Gas, Power & Utilities, Government, and Healthcare. The organization believes that the AI Export Program could enhance U.S. leadership in AI while promoting
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WASHINGTON, Nov. 25 -- IDARE LLC, Houston, Texas has submitted a public comment letter to the U.S. Department of Commerce providing input on the agency's Full-Stack AI Export Program established under Executive Order 14320. With annual revenues between $1 million and $2 million and a team of 20 to 50 employees, the company specializes in developing and exporting advanced artificial intelligence (AI) platforms aimed at sectors including Oil & Gas, Power & Utilities, Government, and Healthcare. The organization believes that the AI Export Program could enhance U.S. leadership in AI while promotingresponsible technology use in foreign markets.
According to the company, partner nations stand to gain access to reliable, U.S.-developed AI technologies that can lead to safer operations and improved decision-making in critical areas. The company offers two primary AI platforms, 'AI Easy' and 'KnowVerse AI', both of which are fully designed and developed in Houston. These platforms are aimed at delivering predictive analytics and autonomous AI solutions to enhance operational efficiencies across various sectors.
The company has identified several foreign markets that demonstrate strong potential for their AI exports, including the United Arab Emirates, Saudi Arabia, and India. They also suggest that federal support through export financing, political risk insurance, and partnerships via U.S. embassies could significantly boost export opportunities in these priority regions.
The letter highlights the necessity for the Full-Stack AI technology package to include various components that support real-world deployments. These include specific additions such as digital-twin models and integration frameworks tailored to industrial environments. The company emphasizes that clarifying the scope of the technology stack will ensure that proposals adequately represent the capabilities needed for actual implementation in critical infrastructure.
Additionally, the organization advocates for industry-led consortia within the program, recommending clear guidelines on governance structures and membership criteria to facilitate high-quality AI export packages. This guidance would promote stability and collaboration among both large and smaller firms, ensuring that they all meet requisite security and performance standards.
In their response, the company underscores that partnering with U.S. firms will provide foreign countries with trustworthy AI solutions while simultaneously bolstering U.S. competitiveness in the global market. By facilitating the export of secure and high-quality AI technologies, the Department can help reduce dependence on AI products from geopolitical rivals.
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The letter was signed by:
Dr. Khairul Chowdhury
CTO, IDARE LLC
Address: 11251 Northwest Frwy, STE 310,
Houston, TX-77092, USA
Email: kchowdhury@idare.io
Phone: +1 713 884 6390
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Read full text of letter here: https://www.regulations.gov/comment/ITA-2025-0070-0015
Florida Peanut Producers Association Raises Concerns About Ultra-Processed Foods Definition
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WASHINGTON, Nov. 25 -- The Florida Peanut Producers Association (FPPA), Marianna, has issued a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing concerns over the definitions of ultra-processed foods. The letter follows a Request for Information on this topic published by the Food and Drug Administration on July 25, 2025, which has raised critical discussions surrounding food classifications.
In the letter, the FPPA emphasizes that an oversimplified definition of "ultra-processed" could have negative implications for public
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WASHINGTON, Nov. 25 -- The Florida Peanut Producers Association (FPPA), Marianna, has issued a public comment letter to the U.S. Department of Health and Human Services and U.S. Department of Agriculture addressing concerns over the definitions of ultra-processed foods. The letter follows a Request for Information on this topic published by the Food and Drug Administration on July 25, 2025, which has raised critical discussions surrounding food classifications.
In the letter, the FPPA emphasizes that an oversimplified definition of "ultra-processed" could have negative implications for publichealth. They argue that a thorough consideration of a food's nutrient density and its overall health impact should be integral to any regulatory definitions. Peanut products, including peanuts and peanut butter, are highlighted as affordable and versatile sources of nutrition that can support health outcomes.
The organization points to substantial scientific evidence linking peanut consumption to a reduced risk of heart disease, cancer, and diabetes. The FPPA urges that the nutritional benefits of peanuts should be recognized, irrespective of whether they are consumed whole or in ground form. They stress the need for science-based guidelines that prioritize the nutritional composition and health value of food products, rather than relying on the degree of processing as the primary metric for classification.
Advocating for an approach focused on nutrient density and measurable health outcomes, the FPPA believes that such a framework will facilitate balanced, evidence-based dietary recommendations for consumers, thereby enhancing public health initiatives. They caution against relying on overly broad classifications that might mislead consumers about the health implications of their dietary choices.
In conclusion, the Florida Peanut Producers Association has called on the FDA and USDA to consider these recommendations seriously. They expressed appreciation for the opportunity to contribute to a discussion that could shape dietary guidelines and influence consumer behavior regarding nutrition. The FPPA remains dedicated to promoting both the economic and nutritional value of Florida-grown peanuts while educating consumers about healthy lifestyle choices.
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The letter was signed by:
Brittany Green
Executive Director
brittany@flpeanuts.com
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4849
Demos Opposes DHS Proposal to Use SAVE System for Voter Registration Verification
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WASHINGTON, Nov. 25 -- Demos, New York, has filed a public comment letter in opposition to the Department of Homeland Security's proposal to modify the Systematic Alien Verification for Entitlements Program System of Records (SAVE system). The letter argues that the proposed updates, which aim to include verification of U.S. citizenship for voter registration, pose serious risks to voter rights and data privacy.
Demos has highlighted that the SAVE system was originally designed to process applications for government benefits based on immigration status, not to function as a voter eligibility verification
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WASHINGTON, Nov. 25 -- Demos, New York, has filed a public comment letter in opposition to the Department of Homeland Security's proposal to modify the Systematic Alien Verification for Entitlements Program System of Records (SAVE system). The letter argues that the proposed updates, which aim to include verification of U.S. citizenship for voter registration, pose serious risks to voter rights and data privacy.
Demos has highlighted that the SAVE system was originally designed to process applications for government benefits based on immigration status, not to function as a voter eligibility verificationtool. The organization contends that utilizing the system in this manner could lead to widespread disenfranchisement. According to Demos, the suggested changes to the SAVE system would improperly repurpose sensitive Social Security data from millions of individuals without their consent, potentially violating the Privacy Act of 1974.
The organization raised concerns about the accuracy and reliability of the SAVE system for voter eligibility checks. It noted that the system is built on point-in-time data, which may contain outdated or erroneous information. States utilizing this system have already begun purging voter rolls, but face challenges in accurately verifying voter eligibility, increasing the likelihood of wrongful disenfranchisement.
Demos pointed out that the risks are particularly acute for derivative citizens born to American citizens abroad and naturalized citizens whose records have not been updated in the SAVE system. The organization emphasized that communities of color, often disproportionately affected by inaccuracies in data, may find themselves at higher risk of having their voting rights undermined.
Furthermore, Demos criticized the DHS proposal as a "solution in search of a problem," asserting that claims of widespread noncitizen voting have been consistently debunked. The organization emphasized that the utilization of Social Security data in this context not only raises substantial privacy concerns but could also compromise the integrity of the electoral process.
Demos urges the agency to halt any plans to leverage the SAVE system for voter eligibility verification purposes, warning that such actions could exacerbate existing inequities in voter access and create unjust hurdles for eligible voters. The call to action from Demos reflects a broader concern about maintaining the integrity of the democratic process while safeguarding individual privacy and civil rights.
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Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0337-0818
Cranberry Institute Advocates for Nutrient-Dense Classification in Ultra-Processed Foods Definition
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WASHINGTON, Nov. 25 -- The Cranberry Institute (CI), Carver, Massachusetts, has issued a public comment letter to the Food and Drug Administration (FDA) regarding the proposed definition of ultra-processed foods (UPFs), emphasizing the need for a nutrient-dense approach in labeling food products. The organization, representing approximately 90% of U.S. cranberry growers, asserts that the designation of certain cranberry products as UPFs could confuse consumers and contradict existing nutrition policies.
In the letter, the Cranberry Institute urged federal agencies to ensure that any future definition
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WASHINGTON, Nov. 25 -- The Cranberry Institute (CI), Carver, Massachusetts, has issued a public comment letter to the Food and Drug Administration (FDA) regarding the proposed definition of ultra-processed foods (UPFs), emphasizing the need for a nutrient-dense approach in labeling food products. The organization, representing approximately 90% of U.S. cranberry growers, asserts that the designation of certain cranberry products as UPFs could confuse consumers and contradict existing nutrition policies.
In the letter, the Cranberry Institute urged federal agencies to ensure that any future definitionof UPFs recognizes the nutritional contributions of cranberry products. The organization pointed out that cranberries and related products are sources of bioactive compounds that support heart and urinary tract health. Notably, the CI highlighted that products like sweetened dried cranberries and 27% cranberry juice cocktail should not be categorized as ultra-processed, as both have been acknowledged under the FDA's "healthy" claim framework.
The letter criticized the narrow focus on processing methods when classifying foods, arguing that a classification based on nutrient density is essential. It stressed that cutting, drying, and juicing are crucial methods for ensuring food safety and maintaining nutritional quality. By solely evaluating foods based on their processing, the agency risks mischaracterizing nutrient-rich products like cranberries and may inadvertently discourage fruit consumption among consumers.
Additionally, the Cranberry Institute referenced recent research indicating that the health benefits associated with fruit consumption extend beyond individual sugars to the whole fruit, including its fiber and nutrient content. The organization believes this perspective should inform FDA's approach to defining UPFs, suggesting that nutrient-dense foods with added sugars can still play a role in healthy diets.
Moreover, the CI called for policy clarification in the UPF definition, recommending a note that allows limited added sugars to enhance the palatability of naturally tart fruits, like cranberries, without designating them as ultra-processed. This adjustment would align with the FDA's "healthy" framework while promoting healthier dietary patterns.
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The letter was signed by:
William C. Frantz
Executive Director
Cranberry Institute
www.cranberryinstitute.org
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5028
American Olive Oil Producers Association, California Olive Oil Council, Olive Oil Commission of California Call for Clear Definition of Ultra-Processed Foods
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WASHINGTON, Nov. 25 -- The American Olive Oil Producers Association, Fresno, and California Olive Oil Council and Olive Oil Commission of California, both of Clovis, have submitted a public comment letter to the Food and Drug Administration (FDA) regarding the agency's request for information on ultra-processed foods (UPFs). Representing hundreds of American extra virgin olive oil (EVOO) growers and producers, these organizations emphasize that EVOO is critical for promoting health and combating diet-related chronic diseases in the United States.
The stakeholders commend the FDA's "Make America
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WASHINGTON, Nov. 25 -- The American Olive Oil Producers Association, Fresno, and California Olive Oil Council and Olive Oil Commission of California, both of Clovis, have submitted a public comment letter to the Food and Drug Administration (FDA) regarding the agency's request for information on ultra-processed foods (UPFs). Representing hundreds of American extra virgin olive oil (EVOO) growers and producers, these organizations emphasize that EVOO is critical for promoting health and combating diet-related chronic diseases in the United States.
The stakeholders commend the FDA's "Make AmericaHealthy Again" initiative aimed at reducing chronic illnesses linked to diet. They argue that while UPFs currently constitute over half the calorie intake for U.S. adults and children, a precise, science-based definition of these foods is essential. Their correspondence contends that UPFs are often characterized by high levels of saturated fat, sugar, and salt but lack nutritional value. Therefore, the organizations advocate for a comprehensive definition that considers both the methods of food processing and their nutritional qualities.
The letter highlights various food processing classification systems, noting that current models, including the widely used Nova system, do not sufficiently address the need for holistic definitions that account for nutritional quality. While acknowledging some definitions classify EVOO as minimally processed, the organizations assert that this categorization can misrepresent the health implications of different oils.
The group argues that products like EVOO, high in nutrients and health benefits, should not be labeled as UPFs simply due to minimal processing techniques, such as the use of natural gases for preservation. These methods enhance the nutritional quality of food rather than diminish it, fostering the consumption of healthier dietary options.
Furthermore, the letter points out that a clear distinction must be made between EVOO and refined oils, which undergo extensive processing that strips away beneficial compounds and introduces harmful elements. The organizations stress that the classification of foods, including the nuances of ingredient processing, should be reevaluated to reflect the health implications for consumers accurately.
In conclusion, the U.S. Olive Oil Industry advocates for scientifically based nutritional guidelines to facilitate informed consumer decisions and support public health. They express appreciation for the ongoing work by the FDA to create effective policies and look forward to contributing to initiatives that align with the goals of healthier American diets.
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The letter was signed by:
Kimberly Houlding
President and CEO
American Olive Oil Producers Association
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Suzanne Moreau
Executive Director
California Olive Oil Council
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Todd Sanders
Executive Director
Olive Oil Commission of California
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-5122
ALAIAB Submits Comment to FDA Expressing Reservations Over Ambiguity in Ultra-Processed Foods Definition
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WASHINGTON, Nov. 25 -- The American Institute of Food Industry and Agricultural Biotechnology (ALAIAB), San Jose, Costa Rica, has submitted a public comment letter to the Food and Drug Administration (FDA) expressing reservations about the classification of ultra-processed foods (UPFs). This communication emphasizes the complexity and ambiguity surrounding the existing definitions and potential implications for public health policy.
The letter outlines that the NOVA classification system, which has been widely used to categorize foods based on processing levels, has led to confusion among both
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WASHINGTON, Nov. 25 -- The American Institute of Food Industry and Agricultural Biotechnology (ALAIAB), San Jose, Costa Rica, has submitted a public comment letter to the Food and Drug Administration (FDA) expressing reservations about the classification of ultra-processed foods (UPFs). This communication emphasizes the complexity and ambiguity surrounding the existing definitions and potential implications for public health policy.
The letter outlines that the NOVA classification system, which has been widely used to categorize foods based on processing levels, has led to confusion among bothconsumers and nutrition experts. ALAIAB argues that the system lacks clear criteria and measurable parameters, which raises challenges when identifying ultra-processed foods and assessing their health impacts. Citing scientific reviews from various countries, the organization points out that current evidence linking UPF consumption to health outcomes remains inconclusive and requires further research.
ALAIAB calls for a more balanced, evidence-based approach towards defining and regulating UPFs. The organization underlines that nutrient composition should take precedence over the degree of processing when evaluating the healthfulness of food items. This perspective aligns with the World Health Organization's principles for healthy diets, which emphasize the importance of nutritional adequacy, balance, moderation, and variety.
Moreover, the letter discusses the role of food additives, particularly their regulatory oversight which ensures that only those proven to be safe are permitted in food products. ALAIAB explains that excessive focus on the quantity of additives may not provide a comprehensive understanding of a product's safety or quality.
In highlighting the impact of palatability and energy density, the letter also references studies demonstrating that UPFs can sometimes be beneficial, potentially contributing to adequate nutrient intake when consumed in moderation. Furthermore, the organization urges the FDA to consider how reformulation efforts can improve the nutritional profiles of ultra-processed products rather than stigmatizing processed foods entirely.
ALAIAB's letter culminates in a call for consumer education initiatives to promote better understanding of nutrition labels and encourage balanced dietary choices that include a variety of foods-including those that are processed. The organization insists that a comprehensive definition of UPFs should consider not only the level of processing but also the broader nutritional landscape and consumer perceptions, ensuring it aligns with contemporary dietary guidelines and scientific evidence.
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2025-N-1793-4858
