Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
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Economic Hardship Due to Rent Increase Sparks Community Concern in Springfield
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 15, 2026
Bureau of Ocean Energy Management
U.S. Department of the Interior
Re: Request to extend the public comment period for proposed seabed mining leases off Virginia's Coast
The City of Virginia Beach appreciates the opportunity to provide comments regarding the Bureau of Ocean Energy Management's consideration of leasing federal waters off Virginia's Eastern Shore for potential seabed mining activities. Given ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 15, 2026 Bureau of Ocean Energy Management U.S. Department of the Interior Re: Request to extend the public comment period for proposed seabed mining leases off Virginia's Coast The City of Virginia Beach appreciates the opportunity to provide comments regarding the Bureau of Ocean Energy Management's consideration of leasing federal waters off Virginia's Eastern Shore for potential seabed mining activities. Giventhe potential implications for Virginia's coastal communities, we respectfully request that BOEM extend the current 30-day public comment period by at least 60 days.
This proposal raises a number of complex environmental, economic, and operational questions that warrant careful evaluation. At this stage, there remain too many unknowns regarding the potential impacts to marine ecosystems, fisheries, tourism, maritime industries, military operations, and other coastal interests to allow for a fully informed assessment.
An extended comment period would provide local governments, stakeholders, subject matter experts, and the public with additional time to review the available information, better understand the potential implications, and provide meaningful feedback. Given the significance of this proposal and its potential long-term effects, additional public engagement will help ensure that any future decisions are based on the best available information.
Thank you for your consideration of this request.
Sincerely,
Robert M. "Bobby" Dyer
Mayor
City of Virginia Beach
*
Government Agency Type: Local
Government Agency: City of Virginia Beach
*
Original text of letter here: https://www.regulations.gov/comment/BOEM-2026-0100-0496
July 15, 2026
Bureau of Ocean Energy Management
U.S. Department of the Interior
Re: Request to extend the public comment period for proposed seabed mining leases off Virginia's Coast
The City of Virginia Beach appreciates the opportunity to provide comments regarding the Bureau of Ocean Energy Management's consideration of leasing federal waters off Virginia's Eastern Shore for potential seabed mining activities. Given ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 15, 2026 Bureau of Ocean Energy Management U.S. Department of the Interior Re: Request to extend the public comment period for proposed seabed mining leases off Virginia's Coast The City of Virginia Beach appreciates the opportunity to provide comments regarding the Bureau of Ocean Energy Management's consideration of leasing federal waters off Virginia's Eastern Shore for potential seabed mining activities. Giventhe potential implications for Virginia's coastal communities, we respectfully request that BOEM extend the current 30-day public comment period by at least 60 days.
This proposal raises a number of complex environmental, economic, and operational questions that warrant careful evaluation. At this stage, there remain too many unknowns regarding the potential impacts to marine ecosystems, fisheries, tourism, maritime industries, military operations, and other coastal interests to allow for a fully informed assessment.
An extended comment period would provide local governments, stakeholders, subject matter experts, and the public with additional time to review the available information, better understand the potential implications, and provide meaningful feedback. Given the significance of this proposal and its potential long-term effects, additional public engagement will help ensure that any future decisions are based on the best available information.
Thank you for your consideration of this request.
Sincerely,
Robert M. "Bobby" Dyer
Mayor
City of Virginia Beach
*
Government Agency Type: Local
Government Agency: City of Virginia Beach
*
Original text of letter here: https://www.regulations.gov/comment/BOEM-2026-0100-0496
Easterseals Advocates for Improved Customized Employment Reporting and Clarification of Transition Discovery Use in Pre-Employment Services
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 20, 2026
Maureen Carasiti
Easterseals Southern California
1063 McGaw Avenue, Suite 100, Irvine, CA 92614
RE: ED-2026-SCC-1717-0001, Department of Education-Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911)
To Whom It May Concern,
Thank you for the opportunity to provide comment regarding the Case Service Report (RSA-911), under Federal Register docket number ED-2026-SCC-1717: ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 20, 2026 Maureen Carasiti Easterseals Southern California 1063 McGaw Avenue, Suite 100, Irvine, CA 92614 RE: ED-2026-SCC-1717-0001, Department of Education-Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911) To Whom It May Concern, Thank you for the opportunity to provide comment regarding the Case Service Report (RSA-911), under Federal Register docket number ED-2026-SCC-1717:Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911).
My name is Maureen Carasiti, and I am the Director of Easterseals WorkFirst Employment Services at Easterseals Southern California (ESSC). ESSC is one of the largest disability services organizations in California, providing essential services and on-the-ground supports to nearly 30,000 people each year-from early childhood programs for the critical first five years, to autism services, daily and independent living services for adults, employment services and more.
ESSC WorkFirst Employment Services provides one-on-one, customized services throughout
Southern California for people with disabilities interested in entering, or re-entering, the workforce.
ESSC WorkFirst has supported over 14,000 jobseekers over the past 12 years, providing one-on-
one services that help people build robust lives through increased economic self-sufficiency. In
2017 ESSC WorkFirst became a vendored provider of the Inland Regional Center, part of
California's regional center system serving individuals with developmental disabilities, and in 2018
ESSC became the first provider of Customized Employment (CE) services certified by the California
Department of Rehabilitation (CDOR). In July of the same year, ESSC was one of three agencies to
take part in the CDOR customized employment pilot, which ran through June of 2019. To-date,
ESSC has served over 600 people with disabilities and veterans with Customized Employment
services, in the process becoming a nationally recognized leader in the field.
ESSC supports the Rehabilitation Services Administration's (RSA) efforts to strengthen the RSA-
911. Our comments, on which we have collaborated with our partners at Griffin-Hammis
Associates, focuses on suggestions to revise the RSA-911 in two areas:
1. Improving the ability to distinguish Customized Employment from Supported Employment
and better reflect current CE practice;
2. Clarifying the use of Transition Discovery as a methodology for delivering existing Pre-
Employment Transition Services.
1. Improving the ability to distinguish Customized Employment from Supported Employment
and better reflect current CE practice
In order to achieve these goals, we recommend a number of targeted revisions that, we believe, will
improve reporting consistency, provide analytical clarity, and ultimately better differentiate CE and
Support Employment within the RSA-911 data collection.
Supported Employment Services (Data Elements 254 and 255):
o We recommend revising the Supported Employment service definition to remove
the phrase "including customized employment" or otherwise clarify the relationship
between the Supported Employment and Customized Employment service
definitions.
o As currently written, the Supported Employment definition incorporates
Customized Employment while separate Customized Employment service data
elements are also collected. This creates overlapping coding practices, reducing
analytical clarity and limiting RSA's ability to isolate CE-specific utilization and
outcomes. In practice, individuals receiving Customized Employment services may
appropriately be coded under both service categories, resulting in less distinct
national data.
Customized Employment Services (Data Elements 275 and 276)
o We recommend revising the Customized Employment service definition to read:
Designed to meet the specific strengths, support needs, and work interests
of the individual with a significant or most significant disability through
Discovery, customized job development and negotiation strategies that
address the business needs of employers, and ongoing support services.
o This revision would improve the clarity and consistency of RSA-911 reporting in
three important ways. First, adding ongoing support services better reflects how
Customized Employment is implemented in practice and reduces the need for
overlapping Supported Employment coding to capture those services. Second,
clarifying the reference to individuals with significant or most significant disabilities
addresses ambiguity between the CE definition and the broader Supported
Employment framework, supporting more consistent interpretation across states.
Finally, explicitly identifying the core components of CE-including Discovery,
customized job development, and ongoing support services-more clearly
distinguishes Customized Employment from broader employment services and
strengthens the usefulness of national CE data.
Type of Exit (Data Element 354)
o We recommend maintaining a distinct exit category for individuals who exit after a
signed IPE in competitive integrated employment through Customized Employment.
o Maintaining a separate exit category improves RSA's ability to distinguish
Customized Employment from broader Supported Employment, track CE
implementation over time, and evaluate CE-specific outcomes.
Employment Outcome at Exit (Data Element 356)
o We recommend maintaining a distinct employment outcome category for
Customized Employment in Competitive Integrated Employment.
o Separate employment outcome categories improve RSA's ability to isolate and
evaluate CE-specific employment outcomes, implementation trends, and technical
assistance needs across states.
2. Clarifying the use of Transition Discovery as a methodology for delivering existing Pre-
Employment Transition Services
We have an additional recommendation focused on Transition Discovery. We recommend that RSA
clarify, within the RSA-911 instructions or related technical assistance, that Transition Discovery
may be used as a methodology for delivering existing Pre-Employment Transition Services when its
activities align with the required Pre-ETS categories. This is not intended for Transition Discovery to
replace or expand the required Pre-ETS activities. Rather, it is to support the appropriate use of
Transition Discovery, which provide a person-centered framework for delivering existing services in
a more individualized and coordinated manner by strengthening job exploration counseling,
informing individualized work-based learning experiences, supporting self-advocacy, and guiding
postsecondary planning.
The required Pre-ETS activities provide important opportunities for students with disabilities to
explore careers, participate in work-based learning experiences, develop workplace readiness
skills, and strengthen self-advocacy. However, these activities are often delivered as discrete
services rather than as part of a coordinated, individualized process that builds on each experience
over time. Transition Discovery provides that continuity by helping students identify their strengths,
interests, support needs, and emerging vocational themes, using each experience to inform the
next and ultimately supporting more informed transition planning.
Unlike Customized Employment Discovery, which is intended to culminate in an individualized
employment outcome, Transition Discovery would support a progression of individualized
employment experiences throughout the transition years. These experiences may include work-
based learning experiences, internships, informational interviews, and other individualized work
experiences that help students make increasingly informed employment and postsecondary
decisions while remaining engaged in school.
Based on ESSC's experience, the revisions we have proposed in the two sections above would
improve reporting consistency, reduce overlapping coding practices, strengthen the reliability of
national Customized Employment data, and enhance RSA's ability to evaluate CE implementation
and outcomes over time. In addition, clarifying that Transition Discovery may be used to deliver
existing Pre-ETS services would encourage more individualized transition planning while promoting
continuity between school and adult vocational rehabilitation. Information developed through this
process could inform future employment planning and reduce the need to begin Customized
Employment Discovery only after school exit.
We truly appreciate the opportunity to provide comment. It is our hope that these will support best
practices and strengthened outcomes in Customize Employment and Supportive Employment
alike.
Maureen Carasiti,
Director, Easterseals WorkFirst Employment Services
Easterseals Southern California
*
Organization Name: Easterseals Southern California
Category: Community Organization
*
Original text of letter here: https://www.regulations.gov/comment/ED-2026-SCC-1717-0015
July 20, 2026
Maureen Carasiti
Easterseals Southern California
1063 McGaw Avenue, Suite 100, Irvine, CA 92614
RE: ED-2026-SCC-1717-0001, Department of Education-Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911)
To Whom It May Concern,
Thank you for the opportunity to provide comment regarding the Case Service Report (RSA-911), under Federal Register docket number ED-2026-SCC-1717: ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 20, 2026 Maureen Carasiti Easterseals Southern California 1063 McGaw Avenue, Suite 100, Irvine, CA 92614 RE: ED-2026-SCC-1717-0001, Department of Education-Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911) To Whom It May Concern, Thank you for the opportunity to provide comment regarding the Case Service Report (RSA-911), under Federal Register docket number ED-2026-SCC-1717:Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911).
My name is Maureen Carasiti, and I am the Director of Easterseals WorkFirst Employment Services at Easterseals Southern California (ESSC). ESSC is one of the largest disability services organizations in California, providing essential services and on-the-ground supports to nearly 30,000 people each year-from early childhood programs for the critical first five years, to autism services, daily and independent living services for adults, employment services and more.
ESSC WorkFirst Employment Services provides one-on-one, customized services throughout
Southern California for people with disabilities interested in entering, or re-entering, the workforce.
ESSC WorkFirst has supported over 14,000 jobseekers over the past 12 years, providing one-on-
one services that help people build robust lives through increased economic self-sufficiency. In
2017 ESSC WorkFirst became a vendored provider of the Inland Regional Center, part of
California's regional center system serving individuals with developmental disabilities, and in 2018
ESSC became the first provider of Customized Employment (CE) services certified by the California
Department of Rehabilitation (CDOR). In July of the same year, ESSC was one of three agencies to
take part in the CDOR customized employment pilot, which ran through June of 2019. To-date,
ESSC has served over 600 people with disabilities and veterans with Customized Employment
services, in the process becoming a nationally recognized leader in the field.
ESSC supports the Rehabilitation Services Administration's (RSA) efforts to strengthen the RSA-
911. Our comments, on which we have collaborated with our partners at Griffin-Hammis
Associates, focuses on suggestions to revise the RSA-911 in two areas:
1. Improving the ability to distinguish Customized Employment from Supported Employment
and better reflect current CE practice;
2. Clarifying the use of Transition Discovery as a methodology for delivering existing Pre-
Employment Transition Services.
1. Improving the ability to distinguish Customized Employment from Supported Employment
and better reflect current CE practice
In order to achieve these goals, we recommend a number of targeted revisions that, we believe, will
improve reporting consistency, provide analytical clarity, and ultimately better differentiate CE and
Support Employment within the RSA-911 data collection.
Supported Employment Services (Data Elements 254 and 255):
o We recommend revising the Supported Employment service definition to remove
the phrase "including customized employment" or otherwise clarify the relationship
between the Supported Employment and Customized Employment service
definitions.
o As currently written, the Supported Employment definition incorporates
Customized Employment while separate Customized Employment service data
elements are also collected. This creates overlapping coding practices, reducing
analytical clarity and limiting RSA's ability to isolate CE-specific utilization and
outcomes. In practice, individuals receiving Customized Employment services may
appropriately be coded under both service categories, resulting in less distinct
national data.
Customized Employment Services (Data Elements 275 and 276)
o We recommend revising the Customized Employment service definition to read:
Designed to meet the specific strengths, support needs, and work interests
of the individual with a significant or most significant disability through
Discovery, customized job development and negotiation strategies that
address the business needs of employers, and ongoing support services.
o This revision would improve the clarity and consistency of RSA-911 reporting in
three important ways. First, adding ongoing support services better reflects how
Customized Employment is implemented in practice and reduces the need for
overlapping Supported Employment coding to capture those services. Second,
clarifying the reference to individuals with significant or most significant disabilities
addresses ambiguity between the CE definition and the broader Supported
Employment framework, supporting more consistent interpretation across states.
Finally, explicitly identifying the core components of CE-including Discovery,
customized job development, and ongoing support services-more clearly
distinguishes Customized Employment from broader employment services and
strengthens the usefulness of national CE data.
Type of Exit (Data Element 354)
o We recommend maintaining a distinct exit category for individuals who exit after a
signed IPE in competitive integrated employment through Customized Employment.
o Maintaining a separate exit category improves RSA's ability to distinguish
Customized Employment from broader Supported Employment, track CE
implementation over time, and evaluate CE-specific outcomes.
Employment Outcome at Exit (Data Element 356)
o We recommend maintaining a distinct employment outcome category for
Customized Employment in Competitive Integrated Employment.
o Separate employment outcome categories improve RSA's ability to isolate and
evaluate CE-specific employment outcomes, implementation trends, and technical
assistance needs across states.
2. Clarifying the use of Transition Discovery as a methodology for delivering existing Pre-
Employment Transition Services
We have an additional recommendation focused on Transition Discovery. We recommend that RSA
clarify, within the RSA-911 instructions or related technical assistance, that Transition Discovery
may be used as a methodology for delivering existing Pre-Employment Transition Services when its
activities align with the required Pre-ETS categories. This is not intended for Transition Discovery to
replace or expand the required Pre-ETS activities. Rather, it is to support the appropriate use of
Transition Discovery, which provide a person-centered framework for delivering existing services in
a more individualized and coordinated manner by strengthening job exploration counseling,
informing individualized work-based learning experiences, supporting self-advocacy, and guiding
postsecondary planning.
The required Pre-ETS activities provide important opportunities for students with disabilities to
explore careers, participate in work-based learning experiences, develop workplace readiness
skills, and strengthen self-advocacy. However, these activities are often delivered as discrete
services rather than as part of a coordinated, individualized process that builds on each experience
over time. Transition Discovery provides that continuity by helping students identify their strengths,
interests, support needs, and emerging vocational themes, using each experience to inform the
next and ultimately supporting more informed transition planning.
Unlike Customized Employment Discovery, which is intended to culminate in an individualized
employment outcome, Transition Discovery would support a progression of individualized
employment experiences throughout the transition years. These experiences may include work-
based learning experiences, internships, informational interviews, and other individualized work
experiences that help students make increasingly informed employment and postsecondary
decisions while remaining engaged in school.
Based on ESSC's experience, the revisions we have proposed in the two sections above would
improve reporting consistency, reduce overlapping coding practices, strengthen the reliability of
national Customized Employment data, and enhance RSA's ability to evaluate CE implementation
and outcomes over time. In addition, clarifying that Transition Discovery may be used to deliver
existing Pre-ETS services would encourage more individualized transition planning while promoting
continuity between school and adult vocational rehabilitation. Information developed through this
process could inform future employment planning and reduce the need to begin Customized
Employment Discovery only after school exit.
We truly appreciate the opportunity to provide comment. It is our hope that these will support best
practices and strengthened outcomes in Customize Employment and Supportive Employment
alike.
Maureen Carasiti,
Director, Easterseals WorkFirst Employment Services
Easterseals Southern California
*
Organization Name: Easterseals Southern California
Category: Community Organization
*
Original text of letter here: https://www.regulations.gov/comment/ED-2026-SCC-1717-0015
David Carbon of Amazon Prime Air Nominated to FAA National Airspace System Advisory Committee
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
National Airspace System Advisory Committee (NAC) Nomination
David Carbon
Name: David Carbon
Title: VP GM, Amazon Prime Air
Contact Information: provided directly to FAA NAC Coordinator
Biography
David Carbon joined Amazon in March 2020 as VP GM, Prime Air. He is responsible for all aspects of
Prime Air including Design, Certification, Build, Fulfillment, and Operations. Prior to joining Amazon,
Carbon was Vice President ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. National Airspace System Advisory Committee (NAC) Nomination David Carbon Name: David Carbon Title: VP GM, Amazon Prime Air Contact Information: provided directly to FAA NAC Coordinator Biography David Carbon joined Amazon in March 2020 as VP GM, Prime Air. He is responsible for all aspects of Prime Air including Design, Certification, Build, Fulfillment, and Operations. Prior to joining Amazon, Carbon was Vice Presidentof Operations (COO) for Boeing's 787 Program. In this capacity, he was
responsible for the end-to-end build and delivery of the 787-8, 9, and 10. Previously, he led the 747
Operation, Machining and Emergent Operations, Boeing Salt Lake City, and Boeing/Hawker de Havilland
Australia. Prior to joining Boeing in September 2001, Carbon worked for the Ford Motor Company, holding
roles in Final Assembly, Powertrain, R&D, and the President's Office. He received his undergraduate
degree in legal studies and politics from La Trobe University, a Masters of Business Leadership from the
Royal Melbourne Institute of Technology, and successfully completed the Advanced Management Degree
at Harvard University.
I confirm I meet all Committee eligibility requirements to serve as a member of the NAC and would
represent the unmanned aircraft system industry.
FLIGHT
SAFETY "%4
FOUNDATION
July 14, 2026
The Honorable Bryan Bedford
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Dear Administrator Bedford:
lam writing to express my strong support for the nomination of David Carbon, vice president and general manager
of Amazon Prime Air, to serve as the unmanned aircraft system (UAS) industry representative on the Federal
Aviation Administration's (FAA) National Airspace System Advisory Committee (NAC).
As president and CEO of Flight Safety Foundation - an independent, nonprofit organization dedicated to the
continuous improvement of aviation safety worldwide - | have had the privilege of working with Mr. Carbon in his
capacity as a member of our Board of Governors.
Demonstrated Expertise in UAS Design, Manufacturing, and Operations
Mr. Carbon leads Amazon Prime Air, an organization that designs, manufactures, and operates its own unmanned
aircraft systems for commercial delivery. Prior to joining Amazon in 2020, he served as vice president of operations
for Boeing's 787 Program. He brings a traditional aerospace discipline to UAS development - rooted in decades of
experience at Boeing and Ford Motor Company - that elevates the rigor and safety standards of the emerging
drone industry.
Experience in UAS Policy Development and Implementation
Mr. Carbon served on the FAA's Drone Advisory Committee and regularly engages directly with regulators and
policymakers around the world to support the development and implementation of regulatory frameworks for
commercial drone operations. His perspective bridges the gap between traditional aviation and emerging UAS
technologies - precisely the balance the NAC requires.
Commitment to Safe Integration of UAS into the National Airspace System
Safety has been the guiding principle of Mr. Carbon's Prime Air leadership. His engagement with Flight Safety
Foundation demonstrates an unwavering commitment to ensuring that UAS integration raises the safety bar for all
airspace users.
Mr. Carbon's unique aerospace leadership make him an exceptional candidate for this role.
Sincerely,
Hassan Shahidi
President and CEO
Flight Safety Foundation | 1920 Ballenger Ave, 4" Floor, Alexandria, VA 22314 USA | +1 703.739.6700 | flightsafety.org
*
Organization Name: Amazon
*
Original text of letter here: https://www.regulations.gov/comment/FAA-2026-7097-0019
National Airspace System Advisory Committee (NAC) Nomination
David Carbon
Name: David Carbon
Title: VP GM, Amazon Prime Air
Contact Information: provided directly to FAA NAC Coordinator
Biography
David Carbon joined Amazon in March 2020 as VP GM, Prime Air. He is responsible for all aspects of
Prime Air including Design, Certification, Build, Fulfillment, and Operations. Prior to joining Amazon,
Carbon was Vice President ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. National Airspace System Advisory Committee (NAC) Nomination David Carbon Name: David Carbon Title: VP GM, Amazon Prime Air Contact Information: provided directly to FAA NAC Coordinator Biography David Carbon joined Amazon in March 2020 as VP GM, Prime Air. He is responsible for all aspects of Prime Air including Design, Certification, Build, Fulfillment, and Operations. Prior to joining Amazon, Carbon was Vice Presidentof Operations (COO) for Boeing's 787 Program. In this capacity, he was
responsible for the end-to-end build and delivery of the 787-8, 9, and 10. Previously, he led the 747
Operation, Machining and Emergent Operations, Boeing Salt Lake City, and Boeing/Hawker de Havilland
Australia. Prior to joining Boeing in September 2001, Carbon worked for the Ford Motor Company, holding
roles in Final Assembly, Powertrain, R&D, and the President's Office. He received his undergraduate
degree in legal studies and politics from La Trobe University, a Masters of Business Leadership from the
Royal Melbourne Institute of Technology, and successfully completed the Advanced Management Degree
at Harvard University.
I confirm I meet all Committee eligibility requirements to serve as a member of the NAC and would
represent the unmanned aircraft system industry.
FLIGHT
SAFETY "%4
FOUNDATION
July 14, 2026
The Honorable Bryan Bedford
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Dear Administrator Bedford:
lam writing to express my strong support for the nomination of David Carbon, vice president and general manager
of Amazon Prime Air, to serve as the unmanned aircraft system (UAS) industry representative on the Federal
Aviation Administration's (FAA) National Airspace System Advisory Committee (NAC).
As president and CEO of Flight Safety Foundation - an independent, nonprofit organization dedicated to the
continuous improvement of aviation safety worldwide - | have had the privilege of working with Mr. Carbon in his
capacity as a member of our Board of Governors.
Demonstrated Expertise in UAS Design, Manufacturing, and Operations
Mr. Carbon leads Amazon Prime Air, an organization that designs, manufactures, and operates its own unmanned
aircraft systems for commercial delivery. Prior to joining Amazon in 2020, he served as vice president of operations
for Boeing's 787 Program. He brings a traditional aerospace discipline to UAS development - rooted in decades of
experience at Boeing and Ford Motor Company - that elevates the rigor and safety standards of the emerging
drone industry.
Experience in UAS Policy Development and Implementation
Mr. Carbon served on the FAA's Drone Advisory Committee and regularly engages directly with regulators and
policymakers around the world to support the development and implementation of regulatory frameworks for
commercial drone operations. His perspective bridges the gap between traditional aviation and emerging UAS
technologies - precisely the balance the NAC requires.
Commitment to Safe Integration of UAS into the National Airspace System
Safety has been the guiding principle of Mr. Carbon's Prime Air leadership. His engagement with Flight Safety
Foundation demonstrates an unwavering commitment to ensuring that UAS integration raises the safety bar for all
airspace users.
Mr. Carbon's unique aerospace leadership make him an exceptional candidate for this role.
Sincerely,
Hassan Shahidi
President and CEO
Flight Safety Foundation | 1920 Ballenger Ave, 4" Floor, Alexandria, VA 22314 USA | +1 703.739.6700 | flightsafety.org
*
Organization Name: Amazon
*
Original text of letter here: https://www.regulations.gov/comment/FAA-2026-7097-0019
Cooperative Credit Union Association Seeks Clarifications and Parity in Implementation of Stablecoin Issuance Rules Under GENIUS Act
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 17, 2026
Ms. Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
RE: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (GENIUS Act Supplemental Proposed Rule)
(Docket No. NCUA-2026-1024; RIN ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 17, 2026 Ms. Melane Conyers-Ausbrooks Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, VA 22314 RE: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (GENIUS Act Supplemental Proposed Rule) (Docket No. NCUA-2026-1024; RIN3133-AG10)
Dear Ms. Conyers-Ausbrooks:
On behalf of its member credit unions, the Cooperative Credit Union Association, Inc. ("Association") appreciates the opportunity to comment on the National Credit Union Administration (NCUA) Board's supplemental proposed rule on Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration to implement the GENIUS Act. The Association is the state trade association representing nearly 200 state and federally-chartered credit unions located in the states of Delaware, Massachusetts, New Hampshire, and Rhode Island, which further serve over 5 million consumer members. The Association developed these comments in consultation with our members.
Question 1: Are the definitions in the proposed rule appropriately scoped? How
should they be improved?
The Association urges the Board to clarify the definition of definition of "Subsidiary of
an Insured Credit Union" in relation to state-chartered credit unions' investments in
permitted payment stablecoin issuers (PPSI) to ensure that federally-insured state-
chartered credit unions have a level competitive playing field with federal credit
unions in the PPSI arena.
Specifically, we urge the Board to clarify in the final rule that the Board believes state-
chartered federally insured credit unions should be authorized to invest in PPSIs
which are credit union service organizations (CUSOs) without specific action by state
regulators if the state-chartered credit unions are already authorized to invest in
CUSOs under state law (unless the state law expressly prohibits investments in PPSI
CUSOs).
845 Donald Lynch Boulevard, Marlborough, MA 01752
Tel: 508-481-6755 | Toll-Free: 800-842-1242 | www.ccua.org
Question 2: Given the GENIUS Act's frequent use of banking-specific terminology,
has the proposed rule struck the appropriate balance of maintaining consistency
with the standards and terminology used in the GENIUS Act and proposed by the
other primary Federal payment stablecoin regulators while also reflecting the
nuances of the credit union industry and its terminology?
We urge the Board to clarify in the final rule that "deposits" and "share accounts"
receive equal treatment under the rule.
The best approach would be to define the term "deposits" to include "share accounts"
as well as deposits for purposes of Part 706 of NCUA Rules.
Question 55: The proposed rule's requirements for Reserve Asset diversification
and concentration include two options: (1) a flexible, principles-based baseline
requirement plus a quantitative safe harbor or (2) quantitative requirements
applicable to all PPSIs. Which option is more appropriate?
The Association urges the Board to adopt Option A for Reserve Asset diversification
under proposed Section 706.202(c).
We believe that Option A's principles-based approach coupled with Option A's
quantitative safe harbor will impose lower regulatory burdens than Option B's
mandatory qualitative limits on all issuers would.
However, we believe that a PPSI which is a subsidiary of a well-capitalized smaller
NCUA-regulated FICU Parent Company, such as those below the asset size making
them subject to supervision by the Office of National Examination and Supervision
(ONES), should be able to hold more than Section 706.202(c)'s proposed maximum
40% of its funds at the well-capitalized FICU Parent Company.
This will help small federally-insured credit unions (FICUs) develop PPSIs with
sufficient economies of scale to be competitive with non-FICU PPSIs.
Question 61: Should the proposed rule include other measures to encourage
Reserve Assets to be held in the form of fully insured deposits and/or Share
Accounts?
No, we believe that requiring Reserve Assets to be held in fully-insured deposits
would be impractical. Uninsured deposits and uninsured share accounts present
relatively low risks that natural-person credit unions are routinely exposed to at
corporate credit unions and banks. Managing such counterparty credit risk exposures
is an everyday thing for most credit unions, and this also helps promote market
discipline.
Page 2
In contrast, a requirement that all Reserve Assets be fully insured would increase
regulatory burdens by effectively requiring either brokered deposits or for the PPSI to
have a very high number of individual banking relationships. Either would lead to
increased costs and lower efficiency with limited benefits in terms of counterparty
risk reduction.
Question 154: The NCUA is considering a variable capital component based on a
percentage of Outstanding Issuance Value. This component could address
operational risks associated with maintaining the Reserve Assets and issuing
Payment Stablecoins to Customers. This component may vary directly with the
Outstanding Issuance Value.
In terms of requiring more than the proposed $5 million in minimum initial capital,
we urge the Board to allow PPSIs to maintain capital ratios that are consistent with
those of the OCC and the other federal banking regulators for bank PPSIs. Credit
union PPSIs should have parity with bank PPSIs and other non-FICU PPSIs to ensure
credit union PPSIs are not competitively disadvantaged.
We note that the assets held by PPSIs are limited to those with low credit risk such as
U.S. Treasury Securities as well as bank and credit union deposits. These exposures
also have low risk ratings under the Basel III Framework and therefore require
relatively little risk-based capital.
Question 162: Should the NCUA further refine or clarify any of the concepts or
definitions outlined in this proposed [Bank Secrecy Act and sanctions
compliance] supervision and enforcement framework?
We support the Board's PPSI Section 706.204(c) and Subpart E approach to Bank
Secrecy Act and sanctions compliance that would be equivalent to the anti-money
laundering/countering the financing of terrorism (AML/CFT) and sanctions rules
already applicable to credit unions in most respects.
We agree with the Board that there is no need to reinvent the wheel.
Question 166: The NCUA invites comment on the two options for permitting
greater information sharing with the FinCEN Director regarding AML/CFT
enforcement actions or significant AML/CFT supervisory actions. In particular,
would the disclosure of confidential supervisory information to FinCEN
compromise attorney-client privilege, other applicable privileges, or otherwise
undermine the preservation of privilege in 12 U.S.C. 1821(t)?
The Association supports "Option B" for proposed Section 706.504 because
Option B provides credit unions with greater legal protections in relation to
confidential credit union information than the proposed Option A.
Page 3
This is because Option B would not "waive, invalidate, destroy, or otherwise affect any
privilege or protection available under Federal or State law, including the attorney-
client privilege, the work-product doctrine, the bank-examination privilege, or any
other confidentiality or evidentiary privilege" in relation to information the credit
union shared with FinCEN and NCUA.
PPSI Examination Fees
PPSIs under NCUA supervision should pay examination fees so that the costs of PPSI
supervision are borne by the PPSIs and not by FICUs.
GENIUS Act Self-Executing Provisions on Federal Preemption
The GENIUS Act's statutory federal preemption provisions should also be
incorporated into the Part 706 rule to reduce regulatory uncertainty and increase the
regulation's ease of use, both of which will reduce compliance burdens.
Thank you for the opportunity to comment on the NCUA Board's supplemental
proposed rule on Implementing the Guiding and Establishing National Innovation for
U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the
Jurisdiction of the National Credit Union Administration to implement the GENIUS
Act.. If you have any questions or desire further information, please do not hesitate to
contact the Association at (508) 481-6755 or govaff-reg@ccua.org.
Sincerely,
Ronald McLean
President/CEO
Cooperative Credit Union Association, Inc.
rmclean@ccua.org
Page 4
*
Organization Name: Cooperative Credit Union Association
*
Original text of letter here: https://www.regulations.gov/comment/NCUA-2026-1024-0017
July 17, 2026
Ms. Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
RE: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (GENIUS Act Supplemental Proposed Rule)
(Docket No. NCUA-2026-1024; RIN ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 17, 2026 Ms. Melane Conyers-Ausbrooks Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, VA 22314 RE: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (GENIUS Act Supplemental Proposed Rule) (Docket No. NCUA-2026-1024; RIN3133-AG10)
Dear Ms. Conyers-Ausbrooks:
On behalf of its member credit unions, the Cooperative Credit Union Association, Inc. ("Association") appreciates the opportunity to comment on the National Credit Union Administration (NCUA) Board's supplemental proposed rule on Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration to implement the GENIUS Act. The Association is the state trade association representing nearly 200 state and federally-chartered credit unions located in the states of Delaware, Massachusetts, New Hampshire, and Rhode Island, which further serve over 5 million consumer members. The Association developed these comments in consultation with our members.
Question 1: Are the definitions in the proposed rule appropriately scoped? How
should they be improved?
The Association urges the Board to clarify the definition of definition of "Subsidiary of
an Insured Credit Union" in relation to state-chartered credit unions' investments in
permitted payment stablecoin issuers (PPSI) to ensure that federally-insured state-
chartered credit unions have a level competitive playing field with federal credit
unions in the PPSI arena.
Specifically, we urge the Board to clarify in the final rule that the Board believes state-
chartered federally insured credit unions should be authorized to invest in PPSIs
which are credit union service organizations (CUSOs) without specific action by state
regulators if the state-chartered credit unions are already authorized to invest in
CUSOs under state law (unless the state law expressly prohibits investments in PPSI
CUSOs).
845 Donald Lynch Boulevard, Marlborough, MA 01752
Tel: 508-481-6755 | Toll-Free: 800-842-1242 | www.ccua.org
Question 2: Given the GENIUS Act's frequent use of banking-specific terminology,
has the proposed rule struck the appropriate balance of maintaining consistency
with the standards and terminology used in the GENIUS Act and proposed by the
other primary Federal payment stablecoin regulators while also reflecting the
nuances of the credit union industry and its terminology?
We urge the Board to clarify in the final rule that "deposits" and "share accounts"
receive equal treatment under the rule.
The best approach would be to define the term "deposits" to include "share accounts"
as well as deposits for purposes of Part 706 of NCUA Rules.
Question 55: The proposed rule's requirements for Reserve Asset diversification
and concentration include two options: (1) a flexible, principles-based baseline
requirement plus a quantitative safe harbor or (2) quantitative requirements
applicable to all PPSIs. Which option is more appropriate?
The Association urges the Board to adopt Option A for Reserve Asset diversification
under proposed Section 706.202(c).
We believe that Option A's principles-based approach coupled with Option A's
quantitative safe harbor will impose lower regulatory burdens than Option B's
mandatory qualitative limits on all issuers would.
However, we believe that a PPSI which is a subsidiary of a well-capitalized smaller
NCUA-regulated FICU Parent Company, such as those below the asset size making
them subject to supervision by the Office of National Examination and Supervision
(ONES), should be able to hold more than Section 706.202(c)'s proposed maximum
40% of its funds at the well-capitalized FICU Parent Company.
This will help small federally-insured credit unions (FICUs) develop PPSIs with
sufficient economies of scale to be competitive with non-FICU PPSIs.
Question 61: Should the proposed rule include other measures to encourage
Reserve Assets to be held in the form of fully insured deposits and/or Share
Accounts?
No, we believe that requiring Reserve Assets to be held in fully-insured deposits
would be impractical. Uninsured deposits and uninsured share accounts present
relatively low risks that natural-person credit unions are routinely exposed to at
corporate credit unions and banks. Managing such counterparty credit risk exposures
is an everyday thing for most credit unions, and this also helps promote market
discipline.
Page 2
In contrast, a requirement that all Reserve Assets be fully insured would increase
regulatory burdens by effectively requiring either brokered deposits or for the PPSI to
have a very high number of individual banking relationships. Either would lead to
increased costs and lower efficiency with limited benefits in terms of counterparty
risk reduction.
Question 154: The NCUA is considering a variable capital component based on a
percentage of Outstanding Issuance Value. This component could address
operational risks associated with maintaining the Reserve Assets and issuing
Payment Stablecoins to Customers. This component may vary directly with the
Outstanding Issuance Value.
In terms of requiring more than the proposed $5 million in minimum initial capital,
we urge the Board to allow PPSIs to maintain capital ratios that are consistent with
those of the OCC and the other federal banking regulators for bank PPSIs. Credit
union PPSIs should have parity with bank PPSIs and other non-FICU PPSIs to ensure
credit union PPSIs are not competitively disadvantaged.
We note that the assets held by PPSIs are limited to those with low credit risk such as
U.S. Treasury Securities as well as bank and credit union deposits. These exposures
also have low risk ratings under the Basel III Framework and therefore require
relatively little risk-based capital.
Question 162: Should the NCUA further refine or clarify any of the concepts or
definitions outlined in this proposed [Bank Secrecy Act and sanctions
compliance] supervision and enforcement framework?
We support the Board's PPSI Section 706.204(c) and Subpart E approach to Bank
Secrecy Act and sanctions compliance that would be equivalent to the anti-money
laundering/countering the financing of terrorism (AML/CFT) and sanctions rules
already applicable to credit unions in most respects.
We agree with the Board that there is no need to reinvent the wheel.
Question 166: The NCUA invites comment on the two options for permitting
greater information sharing with the FinCEN Director regarding AML/CFT
enforcement actions or significant AML/CFT supervisory actions. In particular,
would the disclosure of confidential supervisory information to FinCEN
compromise attorney-client privilege, other applicable privileges, or otherwise
undermine the preservation of privilege in 12 U.S.C. 1821(t)?
The Association supports "Option B" for proposed Section 706.504 because
Option B provides credit unions with greater legal protections in relation to
confidential credit union information than the proposed Option A.
Page 3
This is because Option B would not "waive, invalidate, destroy, or otherwise affect any
privilege or protection available under Federal or State law, including the attorney-
client privilege, the work-product doctrine, the bank-examination privilege, or any
other confidentiality or evidentiary privilege" in relation to information the credit
union shared with FinCEN and NCUA.
PPSI Examination Fees
PPSIs under NCUA supervision should pay examination fees so that the costs of PPSI
supervision are borne by the PPSIs and not by FICUs.
GENIUS Act Self-Executing Provisions on Federal Preemption
The GENIUS Act's statutory federal preemption provisions should also be
incorporated into the Part 706 rule to reduce regulatory uncertainty and increase the
regulation's ease of use, both of which will reduce compliance burdens.
Thank you for the opportunity to comment on the NCUA Board's supplemental
proposed rule on Implementing the Guiding and Establishing National Innovation for
U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the
Jurisdiction of the National Credit Union Administration to implement the GENIUS
Act.. If you have any questions or desire further information, please do not hesitate to
contact the Association at (508) 481-6755 or govaff-reg@ccua.org.
Sincerely,
Ronald McLean
President/CEO
Cooperative Credit Union Association, Inc.
rmclean@ccua.org
Page 4
*
Organization Name: Cooperative Credit Union Association
*
Original text of letter here: https://www.regulations.gov/comment/NCUA-2026-1024-0017
Family Research Council Urges Labor Department to Exclude Certain IVF Practices From Fertility Benefits
Carter Struck
WASHINGTON, July 21 -- The Family Research Council has submitted a public comment letter to the U.S. Department of Labor Employee Benefits Security Administration regarding the proposed rule on excepted fertility benefits. The organization expressed support for clarifications that would protect human embryos and address root causes of infertility for married couples seeking fertility care.
The Family Research Council emphasized its vision of a culture that values all human life and supports flourishing families. It urged the Departments of Health and Human Services, Labor, and the Treasury to ... Show Full Article WASHINGTON, July 21 -- The Family Research Council has submitted a public comment letter to the U.S. Department of Labor Employee Benefits Security Administration regarding the proposed rule on excepted fertility benefits. The organization expressed support for clarifications that would protect human embryos and address root causes of infertility for married couples seeking fertility care. The Family Research Council emphasized its vision of a culture that values all human life and supports flourishing families. It urged the Departments of Health and Human Services, Labor, and the Treasury toensure that qualifying fertility services exclude procedures that undermine human dignity. Specifically, the organization called for excluding selective reduction, embryonic cryopreservation, genetic screening, and surrogacy from benefits coverage, citing ethical concerns about embryo destruction, euthanasia-like practices, and risks to women and children. The group also requested that any covered embryo creation be tied to binding disposition plans prohibiting embryo destruction or research donation, instead promoting embryo adoption.
In addition to safeguarding embryos, the letter recommended recognizing restorative reproductive medicine (RRM) methods as qualifying fertility benefits. These approaches, including NaProTechnology and fertility-awareness methods, aim to diagnose and treat underlying causes of infertility rather than solely relying on in vitro fertilization (IVF), which has comparatively low live birth rates and ethical challenges. The council highlighted clinical studies demonstrating that RRM can yield substantial live birth outcomes while addressing both female and male infertility factors.
Further, the organization proposed limiting benefits for embryo adoption exclusively to married husband-and-wife couples to promote stable family environments for children from the earliest stages of life. It also advocated excluding surrogacy arrangements from the benefits as they separate children from birth mothers and may lack proper legal protections.
The Family Research Council concluded by urging the Departments to adopt these recommendations in the final rule to both support married couples confronting infertility and uphold the dignity and wellbeing of all human life. The agency's efforts to establish excepted fertility benefits, the letter stresses, should advance family health with respect for ethical fertility treatments and safeguards for vulnerable children.
*
Read full text of letter here: https://www.regulations.gov/comment/EBSA-2026-0232-3310
The Family Research Council emphasized its vision of a culture that values all human life and supports flourishing families. It urged the Departments of Health and Human Services, Labor, and the Treasury to ... Show Full Article WASHINGTON, July 21 -- The Family Research Council has submitted a public comment letter to the U.S. Department of Labor Employee Benefits Security Administration regarding the proposed rule on excepted fertility benefits. The organization expressed support for clarifications that would protect human embryos and address root causes of infertility for married couples seeking fertility care. The Family Research Council emphasized its vision of a culture that values all human life and supports flourishing families. It urged the Departments of Health and Human Services, Labor, and the Treasury toensure that qualifying fertility services exclude procedures that undermine human dignity. Specifically, the organization called for excluding selective reduction, embryonic cryopreservation, genetic screening, and surrogacy from benefits coverage, citing ethical concerns about embryo destruction, euthanasia-like practices, and risks to women and children. The group also requested that any covered embryo creation be tied to binding disposition plans prohibiting embryo destruction or research donation, instead promoting embryo adoption.
In addition to safeguarding embryos, the letter recommended recognizing restorative reproductive medicine (RRM) methods as qualifying fertility benefits. These approaches, including NaProTechnology and fertility-awareness methods, aim to diagnose and treat underlying causes of infertility rather than solely relying on in vitro fertilization (IVF), which has comparatively low live birth rates and ethical challenges. The council highlighted clinical studies demonstrating that RRM can yield substantial live birth outcomes while addressing both female and male infertility factors.
Further, the organization proposed limiting benefits for embryo adoption exclusively to married husband-and-wife couples to promote stable family environments for children from the earliest stages of life. It also advocated excluding surrogacy arrangements from the benefits as they separate children from birth mothers and may lack proper legal protections.
The Family Research Council concluded by urging the Departments to adopt these recommendations in the final rule to both support married couples confronting infertility and uphold the dignity and wellbeing of all human life. The agency's efforts to establish excepted fertility benefits, the letter stresses, should advance family health with respect for ethical fertility treatments and safeguards for vulnerable children.
*
Read full text of letter here: https://www.regulations.gov/comment/EBSA-2026-0232-3310
Columbus Housing Partnership Seeks Clarity and Support Amid Challenges With BABA Compliance Requirements
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 20, 2026
US Housing & Urban Development
451 7th Street, S.W.,
Washington, DC 20410
Re: BABA Waivers, Request for Information Response
Dear HUD:
Columbus Housing Partnership, dba Homeport, is an affordable housing developer in Columbus, Ohio. The HOME program has been a valued source of funding in many Homeport projects, since Homeport was founded in 1987, and Homeport has been working with a local general contractor ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 20, 2026 US Housing & Urban Development 451 7th Street, S.W., Washington, DC 20410 Re: BABA Waivers, Request for Information Response Dear HUD: Columbus Housing Partnership, dba Homeport, is an affordable housing developer in Columbus, Ohio. The HOME program has been a valued source of funding in many Homeport projects, since Homeport was founded in 1987, and Homeport has been working with a local general contractorand several manufacturers to source products that are BABA compliant for our upcoming construction projects.
In our experience, it has been difficult sourcing BABA compliant materials in the following categories:
Bathroom Accessories: bar holders, paper holders, shower rods with mounting brackets, and foam soap dispensers, etc.
HVAC Products: air handlers and coordinating equipment, including condenser coils heat pumps, and condensers.
Electrical Products: breakers, receptacles, switches, cover plates, patch panels and communication device (TV/Ethernet) with plate, etc.
Lighting and Safety Products: Door chimes, ADA compliant doorbells, smoke and carbon monoxide alarms, etc.
It has been a challenge integrating the BABA process into our pre-construction timeline and has called into question the value of the HOME funds. The extra cost for compliant materials produces a smaller net benefit of using the program. Over time, the BABA requirements will produce fewer affordable homes. For smoother implementation of the BABA program in future years, Homeport makes the following suggestions:
In general, Homeport would benefit from educational materials for developers, in addition to the information available to manufacturers.
Additional information about the BABA waiver review process before construction begins would aid in our design processes.
Clearer waiver application timelines. Understanding when BABA waivers should be submitted and when the review would be complete would assist in pre-development planning. Extended waiver approval timelines could interfere with project feasibility and closing timelines.
Additional information about the post-construction reporting would be helpful in future planning.
Thank you for the opportunity to provide feedback.
Sincerely,
David Mahan
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0098
July 20, 2026
US Housing & Urban Development
451 7th Street, S.W.,
Washington, DC 20410
Re: BABA Waivers, Request for Information Response
Dear HUD:
Columbus Housing Partnership, dba Homeport, is an affordable housing developer in Columbus, Ohio. The HOME program has been a valued source of funding in many Homeport projects, since Homeport was founded in 1987, and Homeport has been working with a local general contractor ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 20, 2026 US Housing & Urban Development 451 7th Street, S.W., Washington, DC 20410 Re: BABA Waivers, Request for Information Response Dear HUD: Columbus Housing Partnership, dba Homeport, is an affordable housing developer in Columbus, Ohio. The HOME program has been a valued source of funding in many Homeport projects, since Homeport was founded in 1987, and Homeport has been working with a local general contractorand several manufacturers to source products that are BABA compliant for our upcoming construction projects.
In our experience, it has been difficult sourcing BABA compliant materials in the following categories:
Bathroom Accessories: bar holders, paper holders, shower rods with mounting brackets, and foam soap dispensers, etc.
HVAC Products: air handlers and coordinating equipment, including condenser coils heat pumps, and condensers.
Electrical Products: breakers, receptacles, switches, cover plates, patch panels and communication device (TV/Ethernet) with plate, etc.
Lighting and Safety Products: Door chimes, ADA compliant doorbells, smoke and carbon monoxide alarms, etc.
It has been a challenge integrating the BABA process into our pre-construction timeline and has called into question the value of the HOME funds. The extra cost for compliant materials produces a smaller net benefit of using the program. Over time, the BABA requirements will produce fewer affordable homes. For smoother implementation of the BABA program in future years, Homeport makes the following suggestions:
In general, Homeport would benefit from educational materials for developers, in addition to the information available to manufacturers.
Additional information about the BABA waiver review process before construction begins would aid in our design processes.
Clearer waiver application timelines. Understanding when BABA waivers should be submitted and when the review would be complete would assist in pre-development planning. Extended waiver approval timelines could interfere with project feasibility and closing timelines.
Additional information about the post-construction reporting would be helpful in future planning.
Thank you for the opportunity to provide feedback.
Sincerely,
David Mahan
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0098
Asphalt Roofing Manufacturers Confirm Domestic Supply Meets Build America Buy America Act Requirements
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
ASPHALT ROOFING MANUFACTURERS ASSOCIATION
Submitted via www.regulations.gov
July 16, 2026
Department of Housing and Urban Development
Office of General Counsel, Regulations Division
4517" Street SW
Room 10276
Washington, DC 20410
RE: Asphalt Roofing Products Used in Housing Construction Pursuant to the Build America, Buy America Act (Docket No. FR-6616-N-01); 91 FR 36873 (June 18, 2026)
Dear Ms. Maria Chelo De Venecia,
The ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. ASPHALT ROOFING MANUFACTURERS ASSOCIATION Submitted via www.regulations.gov July 16, 2026 Department of Housing and Urban Development Office of General Counsel, Regulations Division 4517" Street SW Room 10276 Washington, DC 20410 RE: Asphalt Roofing Products Used in Housing Construction Pursuant to the Build America, Buy America Act (Docket No. FR-6616-N-01); 91 FR 36873 (June 18, 2026) Dear Ms. Maria Chelo De Venecia, TheAsphalt Roofing Manufacturers Association (ARMA) appreciates the opportunity to submit comments in response to the above referenced Request for Information (RFI) published in the June 18, 2026, Federal Register, by the Department of Housing and Urban Development (HUD). The RFI requests information on the availability of U.S.-manufactured products necessary for the construction and maintenance of housing and infrastructure projects funded through HUD's Federal Financial Assistance (FFA), to support implementation of the Build America, Buy America Act (BABA).
ARMA is a trade association representing North America's asphalt roofing
manufacturing companies and their raw material suppliers. Our members account for
approximately 90% of North American production of asphalt shingles and asphalt low-slope roof
membrane systems.*
Asphalt roofing products are widely used in residential roofing applications across the U.S. Asphalt
shingles are by far the most popular product for residential roofs in the U.S., including single-
family homes, attached townhouses, and low-rise apartment complexes. Indeed, asphalt shingles
make up 75-80% of the U.S. market for residential roofing.?, Low-slope asphalt roofs are specified
for use on commercial, industrial, and government buildings, as well as high-rise apartment/condo
buildings. Asphalt products, including polymer-modified bitumen membranes and built-up roofing
systems, are key materials used on low-slope roofs. Asphalt roofing products are in high demand
1 Additional information about ARMA's mission and activities can be found on its website,
https://asphaltroofing.org/about-arma/about-us/.
2 See Maria Harutyunyan, "Roofing Industry Statistics You Need to Know in 2026," Blogs for Roofers SEO (blog), Roofex
SEO, December 30, 2025, https://www.localroofingseo.agency/blog/roofing-industry-statistics.
Asphalt. The Roofing Solution:
2331 Rock Spring Road cents Forest Hill, MD 21050 cents PHONE: 443.640.1075 * FAX: 443.640.1031 * www.asphaltroofing.org
ASPHALT ROOFING"
MANUFACTURERS ASSOCIATION
in the marketplace due to their many advantages, including durability, longevity, and fire and
weather resistance.
In terms of BABA's requirements for use of domestically manufactured construction products,
asphalt roofing products are widely available in the U.S., with more than 100 manufacturing
facilities located in 30 states across the U.S. Further, the asphalt roofing manufacturing industry
has the supply capability to meet the demands for residential roofing under BABA. In 2025, over
16 billion sq ft of asphalt shingles were sold into the U.S., with an additional 4 billion square feet of
commercial asphalt roofing sold in the U.S. We note, however, that individual manufacturers are
best positioned to verify that their products satisfy the BABA manufacturing and supply chain
requirements.
ARMA is happy to answer any questions you may have or provide additional information related to
the use of asphalt roofing products in HUD-assisted projects. Feel free to contact me at
Sincerely,
Reed Hitchcock
Executive Vice President
Asphalt Roofing Manufacturers Association
Asphalt. The Roofing Solution:
2331 Rock Spring Road cents Forest Hill, MD 21050 cents PHONE: 443.640.1075 * FAX: 443.640.1031 * www.asphaltroofing.org
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0048
ASPHALT ROOFING MANUFACTURERS ASSOCIATION
Submitted via www.regulations.gov
July 16, 2026
Department of Housing and Urban Development
Office of General Counsel, Regulations Division
4517" Street SW
Room 10276
Washington, DC 20410
RE: Asphalt Roofing Products Used in Housing Construction Pursuant to the Build America, Buy America Act (Docket No. FR-6616-N-01); 91 FR 36873 (June 18, 2026)
Dear Ms. Maria Chelo De Venecia,
The ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. ASPHALT ROOFING MANUFACTURERS ASSOCIATION Submitted via www.regulations.gov July 16, 2026 Department of Housing and Urban Development Office of General Counsel, Regulations Division 4517" Street SW Room 10276 Washington, DC 20410 RE: Asphalt Roofing Products Used in Housing Construction Pursuant to the Build America, Buy America Act (Docket No. FR-6616-N-01); 91 FR 36873 (June 18, 2026) Dear Ms. Maria Chelo De Venecia, TheAsphalt Roofing Manufacturers Association (ARMA) appreciates the opportunity to submit comments in response to the above referenced Request for Information (RFI) published in the June 18, 2026, Federal Register, by the Department of Housing and Urban Development (HUD). The RFI requests information on the availability of U.S.-manufactured products necessary for the construction and maintenance of housing and infrastructure projects funded through HUD's Federal Financial Assistance (FFA), to support implementation of the Build America, Buy America Act (BABA).
ARMA is a trade association representing North America's asphalt roofing
manufacturing companies and their raw material suppliers. Our members account for
approximately 90% of North American production of asphalt shingles and asphalt low-slope roof
membrane systems.*
Asphalt roofing products are widely used in residential roofing applications across the U.S. Asphalt
shingles are by far the most popular product for residential roofs in the U.S., including single-
family homes, attached townhouses, and low-rise apartment complexes. Indeed, asphalt shingles
make up 75-80% of the U.S. market for residential roofing.?, Low-slope asphalt roofs are specified
for use on commercial, industrial, and government buildings, as well as high-rise apartment/condo
buildings. Asphalt products, including polymer-modified bitumen membranes and built-up roofing
systems, are key materials used on low-slope roofs. Asphalt roofing products are in high demand
1 Additional information about ARMA's mission and activities can be found on its website,
https://asphaltroofing.org/about-arma/about-us/.
2 See Maria Harutyunyan, "Roofing Industry Statistics You Need to Know in 2026," Blogs for Roofers SEO (blog), Roofex
SEO, December 30, 2025, https://www.localroofingseo.agency/blog/roofing-industry-statistics.
Asphalt. The Roofing Solution:
2331 Rock Spring Road cents Forest Hill, MD 21050 cents PHONE: 443.640.1075 * FAX: 443.640.1031 * www.asphaltroofing.org
ASPHALT ROOFING"
MANUFACTURERS ASSOCIATION
in the marketplace due to their many advantages, including durability, longevity, and fire and
weather resistance.
In terms of BABA's requirements for use of domestically manufactured construction products,
asphalt roofing products are widely available in the U.S., with more than 100 manufacturing
facilities located in 30 states across the U.S. Further, the asphalt roofing manufacturing industry
has the supply capability to meet the demands for residential roofing under BABA. In 2025, over
16 billion sq ft of asphalt shingles were sold into the U.S., with an additional 4 billion square feet of
commercial asphalt roofing sold in the U.S. We note, however, that individual manufacturers are
best positioned to verify that their products satisfy the BABA manufacturing and supply chain
requirements.
ARMA is happy to answer any questions you may have or provide additional information related to
the use of asphalt roofing products in HUD-assisted projects. Feel free to contact me at
Sincerely,
Reed Hitchcock
Executive Vice President
Asphalt Roofing Manufacturers Association
Asphalt. The Roofing Solution:
2331 Rock Spring Road cents Forest Hill, MD 21050 cents PHONE: 443.640.1075 * FAX: 443.640.1031 * www.asphaltroofing.org
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0048
AMA Supports FDA Proposal to Exclude GLP-1 Receptor Agonists From Compounding Bulk Drug List
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
June 23, 2026
The Honorable Kyle Diamantas
Acting Commissioner
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Re: FDA Proposal to Exclude GLP-1 Receptor Agonist Products from the 503B Bulks List
Dear Acting Commissioner Diamantas:
On behalf of the physician and medical student members of the American Medical Association (AMA), I am writing to express our support for the U.S. Food ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. June 23, 2026 The Honorable Kyle Diamantas Acting Commissioner U.S. Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 Re: FDA Proposal to Exclude GLP-1 Receptor Agonist Products from the 503B Bulks List Dear Acting Commissioner Diamantas: On behalf of the physician and medical student members of the American Medical Association (AMA), I am writing to express our support for the U.S. Foodand Drug Administration's (FDA) proposal (docket FDA-2018-N-3240) to exclude semaglutide, tirzepatide, and liraglutide from the list of bulk drug substances that may be used for compounding under section 503B of the Federal Food, Drug, and Cosmetic Act.
The AMA appreciates the FDA's commitment to ensuring that patients have access to safe, effective, and
high-quality medications that have undergone rigorous evaluation. Protecting patient safety must remain
paramount. Allowing GLP-1 receptor agonist products to be compounded from bulk substances by
outsourcing facilities risks exposing patients to products that have not been evaluated under the FDA's
drug approval standards. Compounding presents significant patient safety concerns, particularly given
documented variability in potency, purity, and labeling of compounded GLP-1 products.
The AMA affirms that an FDA decision to approve a new drug, to withdraw a drug's approval, or to
change the indications for use of a drug must be based on sound scientific and medical evidence.
Furthermore, such evidence should be evaluated by the FDA in consultation with its Advisory
Committees and expert extramural advisory bodies. We believe the Agency's proposal is consistent with
these principles and reflects an evidence-based approach to protecting patients and public health.
We also emphasize that it is longstanding AMA policy that the preparation of medications by a physician
for administration to patients treated within the physician's office constitutes the practice of medicine.
Physicians must retain the ability to exercise their professional judgment in tailoring treatments to
individual patients, including the appropriate use of compounded medications when clinically necessary
and in accordance with applicable law. This principle is distinct from large-scale compounding activities
and reinforces the importance of this appropriate regulatory oversight.
Excluding GLP-1 receptor agonists from the 503B bulks list appropriately recognizes that these products
are not suitable for routine compounding at scale when approved FDA-reviewed alternatives exist. This
action will help preserve the integrity of the drug approval system and, most importantly, reduce patient
exposure to potentially substandard or unsafe compounded versions.
The AMA commends the Agency's leadership on this important issue and its ongoing efforts to safeguard
patient safety and the quality of the nation's drug supply. Please reach out to me directly at 312-464-5288
or John.Whyte@ama-assn.org if you have questions or need further information.
Sincerely,
John Whyte, MD, MPH
*
Original text of letter here: https://www.regulations.gov/comment/FDA-2018-N-3240-2357
June 23, 2026
The Honorable Kyle Diamantas
Acting Commissioner
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Re: FDA Proposal to Exclude GLP-1 Receptor Agonist Products from the 503B Bulks List
Dear Acting Commissioner Diamantas:
On behalf of the physician and medical student members of the American Medical Association (AMA), I am writing to express our support for the U.S. Food ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. June 23, 2026 The Honorable Kyle Diamantas Acting Commissioner U.S. Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 Re: FDA Proposal to Exclude GLP-1 Receptor Agonist Products from the 503B Bulks List Dear Acting Commissioner Diamantas: On behalf of the physician and medical student members of the American Medical Association (AMA), I am writing to express our support for the U.S. Foodand Drug Administration's (FDA) proposal (docket FDA-2018-N-3240) to exclude semaglutide, tirzepatide, and liraglutide from the list of bulk drug substances that may be used for compounding under section 503B of the Federal Food, Drug, and Cosmetic Act.
The AMA appreciates the FDA's commitment to ensuring that patients have access to safe, effective, and
high-quality medications that have undergone rigorous evaluation. Protecting patient safety must remain
paramount. Allowing GLP-1 receptor agonist products to be compounded from bulk substances by
outsourcing facilities risks exposing patients to products that have not been evaluated under the FDA's
drug approval standards. Compounding presents significant patient safety concerns, particularly given
documented variability in potency, purity, and labeling of compounded GLP-1 products.
The AMA affirms that an FDA decision to approve a new drug, to withdraw a drug's approval, or to
change the indications for use of a drug must be based on sound scientific and medical evidence.
Furthermore, such evidence should be evaluated by the FDA in consultation with its Advisory
Committees and expert extramural advisory bodies. We believe the Agency's proposal is consistent with
these principles and reflects an evidence-based approach to protecting patients and public health.
We also emphasize that it is longstanding AMA policy that the preparation of medications by a physician
for administration to patients treated within the physician's office constitutes the practice of medicine.
Physicians must retain the ability to exercise their professional judgment in tailoring treatments to
individual patients, including the appropriate use of compounded medications when clinically necessary
and in accordance with applicable law. This principle is distinct from large-scale compounding activities
and reinforces the importance of this appropriate regulatory oversight.
Excluding GLP-1 receptor agonists from the 503B bulks list appropriately recognizes that these products
are not suitable for routine compounding at scale when approved FDA-reviewed alternatives exist. This
action will help preserve the integrity of the drug approval system and, most importantly, reduce patient
exposure to potentially substandard or unsafe compounded versions.
The AMA commends the Agency's leadership on this important issue and its ongoing efforts to safeguard
patient safety and the quality of the nation's drug supply. Please reach out to me directly at 312-464-5288
or John.Whyte@ama-assn.org if you have questions or need further information.
Sincerely,
John Whyte, MD, MPH
*
Original text of letter here: https://www.regulations.gov/comment/FDA-2018-N-3240-2357
AI and Social Media Create Perfect Storm for Climate Change Misinformation
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
REPORT
AI could create a
perfect storm of
climate misinformation
Victor Galaz, Hannah Metzler, Stefan Daume,
Andreas Olsson, Bjorn Lindstrom and Arvid Marklund
Lead authors:
Victor Galaz, Stockholm Resilience Centre, Stockholm University
Hannah Metzler, Medical University of Vienna, Complexity Science Hub Vienna
Stefan Daume, Stockholm Resilience Centre, Stockholm University
Andreas Olsson, Department of Clinical ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. REPORT AI could create a perfect storm of climate misinformation Victor Galaz, Hannah Metzler, Stefan Daume, Andreas Olsson, Bjorn Lindstrom and Arvid Marklund Lead authors: Victor Galaz, Stockholm Resilience Centre, Stockholm University Hannah Metzler, Medical University of Vienna, Complexity Science Hub Vienna Stefan Daume, Stockholm Resilience Centre, Stockholm University Andreas Olsson, Department of ClinicalNeurosciences, Karolinska Institutet
Bjorn Lindstrom, Department of Clinical Neurosciences, Karolinska Institutet
Arvid Marklund, Beijer Institute of Ecological Economics, Royal Swedish
Academy of Sciences
Cover photo: iStockphoto
Layout and graphics: Julia Rende, Elsa Wikander - Azote.
Suggested citation: Galaz, V., H. Metzler, S. Daume, A. Olsson, B. Lindstrom,
A. Marklund (2023). Climate misinformation in a climate of misinformation.
Research brief. Stockholm Resilience Centre (Stockholm University) and the
Beijer Institute of Ecological Economics (Royal Swedish Academy of Sciences).
http://arxiv.org/abs/2306.12807
Version: 2023-06-16
With support from:
2
Content
AI could create a perfect storm of
climate misinformation 4
What is climate mis- and disinformation
- and why should we care? 6
The neuroscience of false beliefs 8
How algorithms diffuse and
amplify misinformation 10
Emotions and group dynamics around
misinformation on social media 13
When health and climate
misinformation overlap 15
A game changer for misinformation:
The rise of generative AI 17
Keeping up with a fast-moving
digital environment 21
3
AI could create a perfect storm
of climate misinformation
We are in the midst of a transformation of the digital news ecosystem.
The expansion of online social networks, the influence of recommender
systems, increased automation, and new generative artificial intelligence
(AI) tools are rapidly changing the speed and the way misinformation
about climate change and sustainability issues moves around the world.
Policymakers, researchers and the public need to combine forces to
address the dangerous combination of opaque social media algorithms,
polarizing social bots, and a new generation of AI-generated content.
When OpenAI released their version of the artificial The following synthesis explores the increasing
intelligence ChatGPT to the public in November 2022, influence of digital media, AI and algorithmic systems
the playing ground for false news and misinformation on the creation, diffusion and amplification of
online changed completely. Suddenly, anyone could misinformation about climate and environmental
with relatively little effort produce seemingly human- sustainability issues. We combine insights from various
written text and highly realistic images - regardless of research strands ranging from computational social
their truthfulness. sciences, to sustainability sciences and neurosciences,
to explore what we know about how such information
Misinformation and disinformation campaigns are not is amplified, and to what extent recent advances in AI
new, and topics such as climate change have been in pose new challenges for our ability to act collectively
the line of fire more than once. But over time, the on our planetary crisis.
digital aspects of these phenomena have become
increasingly important for those interested in This synthesis brief has been put together as an
understanding and tackling the harmful effects of mis- independent contribution to the Nobel Prize Summit
and disinformation. 2023, "Truth, Trust and Hope", Washington D.C., 24-26
of May 2023.
Information and communications technologies have
made the world increasingly connected, allowing
information to move almost effortlessly around the
world in the blink of an eye. What we see on our
screens everyday is increasingly determined by
recommender systems, systems designed to maximize
engagement, at times favoring whatever creates
engagement over truth. Sometimes, this information
movement is affected by social bots. Often, the
diffusion of information is shaped by how people
engage with it by sharing, commenting, remaking it and
moving it across digital media platforms and between
social and conventional media. This, in combination
with the capacities of generative AI to create synthetic
content, may very well result in a perfect storm of
misinformation. The time to act on these risks is now. Image: Canva
4
Box 1. Key terms
Artificial intelligence - we use the ('precision farming'), electricity ('smart particular user. Recommender systems
terms "artificial intelligence" and "AI" grids'), and housing ('smart homes'), are widely used in social media
to refer to technologies that employ do not necessarily use AI for their platforms, but also other digital
machine learning including deep operations. services like music streaming, video
learning methods. services, and for online shopping (Ricci
Generative AI - refers to AI based on et al., 2015). Such systems can deploy
Algorithmic systems - refer to advanced neural networks with the AI-analysis to guide their
assemblages of multiple algorithms ability to produce highly realistic recommendations (Engstrom and
(i.e., a finite sequence of well-defined, synthetic text, images, video and audio Strimling, 2021).
computer-implementable instructions, (including fictional stories, poems, and
typically to solve a class of problems or programming code) with little, to no Social bots - are automated social
to perform a computation), databases, human intervention. The most known media accounts with the ability to build
and interfaces that interact, as well as example is the Generative Pre-trained social communication networks and
the social practices that people Transformer 3 (GPT-3, GPT-4) that create online content. Such bots can be
develop to interact with them (Wagner underpins OpenAI's GPTChat (OpenAI, used for beneficial or malicious
et al., 2021; Ada Lovelace Institute, 2023). Note however that GPT is only purposes ranging from news
2021). one of many existing generative AI aggregation, user assistance or
models (e.g., Gibney, 2022). entertainment, to spam and
Digitalization - is here used to sophisticated influence campaigns
describe the adoption and use of Recommender systems - refer to (Stieglitz et al., 2017).
digital technologies, including societal, techniques that offer suggestions for
organizational, and individual impact information (e.g., other users, text,
(Legner et al., 2017). Digital articles, videos or social media posts)
technologies for e.g., food production that are likely to be of interest to a
5
What is climate mis- and
disinformation - and why
should we care?
By Victor Galaz
Our living planet is facing a multitude of interacting crises. Climate
change, the loss of biodiversity, inequality, pandemics, and war and
conflict are just a few of them. In these times of turbulence, it is vital that
decisions about our common future are well-grounded in science. False
information and intentional attempts to manipulate public opinion pose
serious risks to our joint capacities to create a safe and just future for all.
Mis- and disinformation play a crucial role in forming is not a direct result of human activity.' In Brazil, 30%
public opinion and thus influencing the actions taken at believe that climate change is not caused mainly by
all levels of society, from individuals to central policy- human activity, and 24% believe that the "temperature
making. Misinformation about covid-19 vaccines for record is unreliable or rigged". In the United Kingdom,
example, has notable impacts on whether people are 29% believe that a significant number of scientists
willing to take the vaccine (Loomba et al., 2021). A disagree on the cause of climate change (Climate
growing body of work also explores to what extent Action Against Disinformation and Conscious
misinformation has affected political elections around Advertising Network, 2022). Misinformation and
the world (for example, Howard, 2020; Machado et al., conspiracy theories about wind energy farms are
2019). Scientists engaged in science communication already affecting the expansion of renewable energy
also face an increased number of attacks in social negatively, and thus the prospects for achieving a
media as they struggle to inform the public to mitigate transition to zero-carbon energy sources (Winter et al.,
the spread of fake news and misinformation (Nogrady, 2022).
2021).
One key and challenging issue is how to define and
It is becoming increasingly clear that misinformation is identify mis- and disinformation. Here we refer to
taking its toll on public opinion on climate and misinformation as information whose inaccuracy is
sustainability issues as well. A recent study shows that unintentional. Disinformation on the other hand, refers
U.S. citizens, partly due to biased and incorrect media to information that is deliberately false or misleading
reporting, systematically underestimate public support (Jack, 2017). While the definitions of mis- and
for ambitious climate policies, thus falsely assuming disinformation might seem straightforward, their
that a vocal minority who dismiss climate change are differences in the real world are not (Jerit and Zhao,
representative of the broader public opinion 2020; Treen et al., 2020).
(Sparkman et al., 2022). A cross-national study
conducted by the Climate Action Against Climate mis- and disinformation has a long history, and
Disinformation and Conscious Advertising Network its underlying motivations and strategies have become
(2022) shows a considerable spread of serious increasingly visible in the last years (e.g., Supran et al.,
misconceptions about climate change in the surveyed 2023; Franta, 2018). Attempts to sow confusion about
countries. 33% of the surveyed population in the US the science of climate change include lobbying
and Australia believe that 'the climate has always campaigns by vested interests (Brulle, 2018), the
changed, global warming is a natural phenomenon and funding of climate change denialist think tanks
6
(Farrell, 2019), and corporate climate "skeptic"
campaigns in conventional media (Dunlap &
McCright, 2011; Supran & Oreskes, 2017).
Climate change
In parallel to this type of coordinated
and the loss of disinformation activities there are other much more
fluid and complex self-organized patterns of
biodiversity require information sharing and engagements on digital
platforms. In the case of fossil fuel companies'
collective action and documented attempts to influence public opinion
on climate change issues their agency is
public deliberations straightforward (Supran and Oreskes, 2017; Supran
et al., 2023). But the type of mis-and disinformation
that are global in that flows effortlessly across social media platforms
like Twitter, TikTok and Youtube, is another type of
scope, ambitious beast. The former has a clear intent, plan and
coordinating agent, while the latter form tends to
in its goals, and emerge and evolve as information, algorithmic
systems and digital social networks interact in
over very extended complex ways. These two forms of mis- and
disinformation are of course, often combined in
periods of time. reality (Starbird and Wilson, 2019).
Digital media plays a key role in this regard (Pearce
et al., 2019; Treen et al., 2020). Five hundred million
tweets, 294 billion emails, 4 petabytes of content
on Facebook, 65 billion messages on WhatsApp,
and 5 billion searches on Google are conducted
every day (from Howard, 2020, p. 4). Social media
like Facebook, Twitter and Instagram is particularly
important in this context. Survey data shows that
between 40% and 60% of adults in most developed
countries, receive their news from social media
(Nic, 2017). The fact that social media platforms are
participatory by design allows them to shape
individual attitudes, feelings and behaviors
(Williams et al., 2015), and facilitates social
mobilization and protests (Steinert-Threlkeld et al.,
2015).
Climate change and the loss of biodiversity require
collective action and public deliberations that are
global in scope, ambitious in its goals, and over very
extended periods of time (Galaz 2020). Polarization,
mistrust in science, and incorrect climate and
environmental information amplified through
digital media could undermine such much-needed
collective action in detrimental ways.
Image: Canva
7
The neuroscience of
false beliefs
By Andreas Olsson and Bjorn Lindstrom
What we believe is not only a result of our own reasoning, but also
of the beliefs of people around us. Our brains are wired to consume
information that is liked by our peers. That way, social reinforcers online
- in the form of likes, comments and shares - can build a basis for what
individuals believe to be true or false.
"
Why do people adopt beliefs, such as that the earth is
flat, which are clearly incompatible with established
Research has shown
truth? Like with other beliefs, it depends on the nature
of their prior beliefs, goals, as well as learning and
that the orbitofrontal
reasoning processes. Our knowledge about the
psychological and neural mechanisms that promote
cortex, a brain region
false beliefs is still nascent, but existing research in
psychology and neuroscience has described how
located just behind
people process information that is unexpected,
emotional, and politically divisive - features typical of the eyes, is critical for
false information encountered on social media.
computing the value
First, information that is unexpected and emotionally
(especially negatively) loaded, tends to grasp our of different goals.
attention, which depends on visual cortices and
attentional networks in parietal and frontal brain
regions. In addition, attention also depends on activity politically divisive facts. At first glance, one could think
in deep brain nuclei that are sensitive for events that that this is due to politically motivated reasoning.
can be threatening and important goals of the However it can also be viewed as rational inferences
individual. considering the individual's prior belief system
(Botvinik-Netzer et al., 2023). Networks of brain
Various goals of the individual can be important. For regions linked to memory retrieval and belief updating,
example, if social goals, such as promoting one's own are likely to support these processes.
social status or belonging to a particular group, are
more important than the goal to seek and represent Recent research shows that simple learning
the truth, then attention is biased towards whatever mechanisms, known to engage regions in the brain's
promotes the more important goals. Research has system that run on dopamin, can explain how humans
shown that the orbitofrontal cortex, a brain region are motivated to increase the consumption of
located just behind the eyes, is critical for computing information that is liked by others - in particular by
the value of different goals. Other prefrontal regions those belonging to the same group as the individual
serve to monitor information that deviates from what identifies with. For example, models of instrumental
is in line with one's own moral or political convictions. learning explain why people engage with social media
People who strongly identify with different political (Lindstrom et al., 2021, Ceylan et al., 2023) and how
ideologies tend to distort their conclusions in line with morally outraged messages become viral (Brady et al.,
their political identities when asked to reason about 2021). The social reinforcers that are at play in social
8
media might thus provide a basis for what individuals
believe to be true. Indeed, research has shown that
social forms of learning can be at least as powerful,
and draw on many of the same neural principles as
learning based on own, personal experiences (Olsson
et al., 2020). The importance of understanding the
power of social influences is further underscored by
recent findings showing that the more a statement is
"liked" by others, the more the statement is
subsequently rated as true (Granwald et al., 2023).
In sum, although much is known about the
psychological and brain bases of acquiring and
updating beliefs in general, much less is known about
how we process false beliefs encountered online.
Because the lack of a shared knowledge about what
is true can fuel polarization, conflicts and other
destructive behaviors (Brady et al., 2023), we need
to increase efforts to understand the basic
psychology and neuroscience of false beliefs.
"
Our brains are
wired to consume
information that is
liked by our peers.
Image: iStockphoto / Canva
9
How algorithms diffuse and
amplify misinformation
By Victor Galaz and Stefan Daume
Digital platforms are designed to maximize engagement. Recommender
systems play a key role as they shape digital social networks, and the
flow of information. Weaknesses in their underlying algorithmic systems
are already today being exploited to try to influence public opinion on
climate and sustainability issues. Automation through social bots also
play a role, although their impacts are contested.
In 2010, a team of political scientists in collaboration Second, the way information moves in these vastly
with researchers at Facebook conducted a gigantic spanning digital social networks is not random. Its
experiment on the platform. It included "all users of at movement is fundamentally affected by the way digital
least 18 years of age in the United States who media platforms such as recommender systems are
accessed the Facebook website on 2 November 2010, designed to maximize engagement and induce other
the day of the US congressional elections". This forms of behavioral responses amongst its users
61-million-person experiment tested whether a (Kramer et al., 2014; Coviello et al., 2014). The
simple tweak in the newsfeed of users - adding a "I diffusion of such information can also be exploited by
Voted" button and information about friends who had external attempts to manipulate public opinion online.
voted - could impact voting behavior. Three common approaches include (1) specifically
targeting the way algorithmic systems operate, (2)
The results were clear: this small design change led to carefully crafting viral messages to sow confusion, and
higher real-world voting turnout. Facebook-users who (3) through the use of automation tools like 'social bots'.
saw a message about one of their close friends on
Facebook having voted were 2.08% more likely to Social bots mimic human behavior online, and can be
vote themselves (Bond et al., 2012). used in ways to amplify certain types of information -
say, climate denialism -, or operate in ways that widen
This controversial experiment illustrates a number of social divisions online (Gorwa and Guilbeault, 2018;
issues that are key if we are to understand how digital Shao et al., 2018). Our own work (Daume et al., 2023)
platforms interplay with the creation and diffusion of shows that social bots play an unignorable role in
mis- and disinformation, and their impacts. climate change conversation. They amplify information
that supports and opposes climate action at the same
First, digitalization and the expansion of social media time, especially information appealing to emotions,
has not only fundamentally expanded the scale, but such as sympathy or humor.
also transformed the properties of social networks.
3,6 billion people use social media today. Through it, Recommender systems play a key role for the dynamics
they access a digital media environment where of information diffusion and the evolution of digital
language barriers slowly but surely are eroding as new social networks (Narayanan, 2023), and they have
digital tools make communication across borders increasingly become infused with deep learning-based
increasingly frictionless. These new connections are AI (Engstrom and Strimling, 2020). People-
transforming the structures of social networks in ways recommender systems for example (like "People You
that allow for immediate communication across vast May Know" on Facebook or "Who to Follow" on
geographical space (Bak-Coleman et al., 2021). Twitter) shape social network structures, thus
10
Figure 1. The figure illustrates how social bots influenced the diffusion of different climate change frames via Tweets about the 2019/2020
Australia bushfires. The results indicate that different framings of climate change are associated with distinctive automation signatures.
"
influencing the information and the opinions a user is
exposed to online (Cinus, 2021). Content-recommender
systems (like "Trends for you") can reinforce the human People-recommender
preference for content that aligns with a user's ideology
(Bakshy et al., 2015). systems for example
Figure 2 below illustrates four highly simplified models (like "People You May
of information propagation of one individual post. The
expansion of digital social networks, the influence of Know" on Facebook or
recommender systems and social bots change the reach
of mis- and disinformation. This diffusion has complex "Who to Follow" on
secondary effects on perceptions, on the formation of
Twitter) shape social
online communities, on collective action, and on identity
formation.
network structures,
Lastly, the 61-million-user experiment also illustrates
thus influencing the
another feature of today's digital ecosystem - the
capacity to mass produce and test online material to
information and the
maximize impact. Online material and digital platforms
provide the perfect setting to conduct randomized
opinions a user is
controlled experiments as a means to systematically
compare two versions of something - say, a news article
exposed to online.
or ad - to figure out which performs better,sometimes
referred to as A/B testing. In combination with a growing
capacity to cheaply and quickly mass produce synthetic
text, images and videos using generative AI (see chapter
6), this is pushing us into uncharted and dangerous
territory for the future of mis- and disinformation on
climate and environmental sustainability issues.
11
Figure 2. The figure illustrates four models of information propagation of one individual post through: a) network, b) algorithm,
c) affective, and d) automated amplification. In a) the post cascades through the network as long as other users choose to further
propagate it by e.g., sharing or liking. In the algorithmic model b) propagation unfolds as users with similar interests (as
determined by recommendation algorithms based on for example past engagement) are more likely to be recommended the
post. In (c), users comment and reshare posts much more if they elicit strong emotions, and recommender systems pick up highly
engaging posts and amplify them even further. In d) automated accounts ('social bots') purposefully share content that elicits
strong emotions to further increase propagation. Figure based on (Narayanan, 2023).
12
Emotions and group dynamics
around misinformation on
social media
By Hannah Metzler
Nuanced views and clean facts don't generate clicks. Social networks
are designed to speak to our emotions, and the more extreme the
emotions, the better the content. But that does not mean that good
arguments, education, and science communication are futile.
"
Emotions attract our attention, and provide us with
information about actions we should take: When you Humans are social
feel fear, it's best not to ignore the danger, and protect
yourself from it. When you are angry, it's probably animals, and things
because someone has treated you or a group you
belong to unfairly, and it's time to step up against the that make us feel
injustice.
part of a group, that
News agencies, politicians, and creators of fake news
increase our group's
know this, and use it to create content that attracts
attention and is likely to be shared on digital and social
status, or decrease
media. Algorithms on social media are optimized to
increase engagement with content (Narayanan, 2023;
the status of an out-
Metzler & Garcia, 2022), and content that provokes
strong emotional reactions is a powerful means to do
group, are highly
so. Negative moral-emotional messages about groups
we do not like seem to particularly increase
motivating for us.
engagement (Brady et al., 2017, Rathje et al. 2021,
Marie et al., 2023). Humans are social animals, and
things that make us feel part of a group, that increase
our group's status, or decrease the status of an out- rhetoric (Lewandowsky, 2021). Polarized conversations
group, are highly motivating for us (Robertson et al., between these different sides on social media grow
2022). around events like climate protests, or releases of
climate change reports, such as the reports from the
We can regularly observe such emotional group Intergovernmental Panel on Climate Change, (Sanford,
dynamics around the topic of climate change on social 2021). And political polarization fuels the spread of
media. On the one hand, there are people who think we misinformation (Osmundsen et al., 2021, Marie et al.,
are not doing enough and need to urgently take action: 2023).
social movements like Fridays for Future or Extinction
Rebellion, and political parties like the Green parties in Because more outrageous content attracts more
Europe, or Democrats in the US. On the other side, attention, and individuals with stronger opinions are
climate skepticism and denial are more common in far- more motivated to persuade others, extreme voices
right, populist or libertarian parties, who oppose and toxic content are more visible on social media (Bail,
economic regulation and benefit from using anti-elite 2021). Individuals with more nuanced views, who can
13
relate to both sides of a debate, are much less
visible. A large majority of individuals who are not
interested enough to participate in discussions, but
generally agree with a nuanced perspective, is Explaining how
entirely invisible. This way, digital media make
polarization seem stronger than it actually is in we know climate
society, and this in turn fuels hate and
misunderstanding between parties (Brady et al. change is happening,
2023). Redesigning platforms so that nuanced
majorities and overlap in the views of different how it works,
groups become more visible, could therefore help
to decrease the spreading of misinformation how solutions can
(Metzler & Garcia, 2022). Redesigning social media
algorithms could be one way to do so. integrate economic
Fortunately, people do not uncritically believe any and environmental
emotional information that comes their way
(Mercier, 2020). Key questions such as who shares needs, for example,
news, whether they know and trust the source, and
if it fits with what they already know and believe takes time and effort.
about the world, crucially determine if we find
information plausible. People's anger after reading
false news, for example, can occur because they
recognize it as misinformation and disagree
(Luhring et al., 2023). So, strong emotions do not
automatically mean people will believe a message
and continue to share it. That people judge new
information based on trust in sources, and their
knowledge about the world, means that good
arguments, education, and science communication
are not futile. Explaining how we know climate
change is happening, how it works, how solutions
can integrate economic and environmental needs,
for example, takes time and effort. But it will also
help to increase trust in science, and politics that
implements such evidence-based solutions, and
thereby decrease polarization and misinformation.
"
People's anger
after reading false
news, for example,
can occur because
they recognize it as
misinformation and
disagree.
Image: Canva
14
When health and climate
misinformation overlap
By Victor Galaz and Stefan Daume
Health and climate are two topics that often are affected by mis-
and disinformation. Where the two overlap, a perfect storm for
false claims can grow. Experiences from the "digital backlash" that
followed the launch of the "planetary health diet" can teach us
important lessons about what happens when health and climate
misinformation act in tandem.
Early in 2019, an international team of scientists The wider reception of the study was positive and its
published a groundbreaking study in The Lancet on how findings were covered in major news outlets around
humanity can eat to both be healthy and live within the world.
planetary boundaries. One of the key take-aways of the
paper was that eating less meat and dairy can improve But on social media a storm raged as the study was
human health and drastically reduce the ecological published. Under the hashtag #yes2meat, accounts
footprint of food production, at the same time. gathered to circulate misinformation and defamatory
Figure 3. Social media community structures related to the planetary health and the social media campaign
#yes2meat. Red shows replies by users in the "yes2meat" community, blue is the "pro-EATLancet" community,
yellow is an ambiguous community, and green is a vegan community. Based on "EAT-Lancet vs. yes2meat:
Understanding the digital backlash to the 'planetary health diet'".
15
"
The #yes2meat
backlash is just one
example of how mis-
and disinformation
transgresses from
one topic to the
other.
material. A later analysis showed that this storm
was a concerted effort of a pro-meat social media
campaign that started its workings weeks before
the study was released (Garcia et al., 2019).
The digital backlash created by the campaign
continued over months and successfully swayed
undecided users.
The majority of the accounts involved in the
campaign were not driven by social bots, but by
actual humans. On Twitter, these critics managed to
reach 26 million people - compared to 25 million
from academics and others that engaged in science
communication. The campaigners achieved this,
despite having much fewer followers, likely with the
help of social media platforms' amplification
mechanisms (see chapter 3).
The #yes2meat backlash is just one example of how
mis- and disinformation transgresses from one
topic to the other. Such overlap is the rule rather
than the exception. For example, climate denialism
often overlap with opposition to renewable energy
projects (Winter et al., 2022), conspiracy theories
around geoengineering (Debnath et al., 2023),
xenophobia and false claims that link forest fires
with islamic terrorism (Daume et al., 2023). In some
instances, climate misinformation drives waves of
aggressive, sexist and toxic online comments (Park
et al., 2021; Nogrady, 2021), often with their roots
in far-right political environments (Vowles and
Hultman, 2022).
As a reminder: the digital backlash following from
the launch of the "planetary health diet" unfolded in
2019. With the new powers of generative AI, it
would be possible to amplify such campaigns in
novel ways, contributing further to confusion and
the erosion of trust to science. Image: Canva
16
A game changer for
misinformation: The rise
of generative AI
By Victor Galaz, Stefan Daume and Arvid Marklund
New generative AI tools make it increasingly easy to produce sophisticated
texts, images and videos that are basically indistinguishable from human-
generated content. These technological advances in combination with
the amplification properties of digital platforms pose tremendous risks of
accelerated automated climate mis- and disinformation.
The year of 2023 will be mentioned in history books Accessibility
as the point in time when advances in artificial
Accessibility refers to the fact that generative AI tools
intelligence became everyday news - everywhere.
that produce highly realistic synthetic content, that is
The decision by OpenAI to offer the general public
not necessarily accurate, are rapidly becoming easily
access to their deep learning-based Generative Pre-
available.
trained Transformer (GPT) model opened up a
floodgate of experimentation by journalists,
While the most capable models remain either private
designers, developers, teachers, researchers and
or behind monitorable application programming
artists.
interfaces (APIs), some advanced models are publicly
accessible, either in open code repositories or through
Generative AI-systems such as these have the ability
public APIs including OpenAI, Google, Microsoft and
to produce highly realistic synthetic text, images,
Hugging Face (Table 1). In addition, the open source
video and audio - including fictional stories, poems,
community has quickly managed to create much
and programming code - with little to no human
smaller versions of large language models that are
intervention. The combination of increased
almost equally powerful, and can be run on laptops or
accessibility, sophistication and capabilities for
even phones (Dickson, 2023). All of these tools can, in
persuasion may very well supercharge the dynamics
principle, be prompted to deliberately generate false
of climate mis- and disinformation.
information, both in the form of text (McGuffie and
Images from: Generative AI images credit Diego Galafassi.
17
Table 1: Selection of generative language models released between 2018 and 2023.
NLP Model Year Developing Parameters Training Access Reference
organization tokens
GPT-4 2023 OpenAI 1000B1 Not API (waitlist) (OpenAI, 2023)
specified
PaLM 2022 Alphabet (Google) 540B 780B API (early access) (Chowdhery et al. 2022)
Chinchilla 2022 Alphabet 70B 1400B None (Hoffmann et al. 2022)
(DeepMind)
Megatron- 2022 Microsoft, NVIDIA 530B 270B API (early access) (Smith et al. 2022)
Turing NLG
DALL-E 2021 OpenAI 12B 250M2 Public API (Ramesh et al. 2021)
ERNIE 3.0 2021 Baidu 10B 375B Public model (Github) (Wang et al. 2021)
GPT-3 2020 OpenAI 175B 499B Public API (Brown et al. 2020)
GPT-2 2019 OpenAI 1.5B ~10B Public model (Github) (Radford et al. 2019)
BERT 2018 Alphabet (Google) 0.34B ~3.3B Public model (HuggingFace) (Devlin et al. 2018)
Table 1: Selection of generative language models released between
2018 and 2023. Language models are accelerating in parameter size,
utilize growing training datasets, support multiple languages, and
have the capacity to generate both text as well as images in response
to text 'prompts'. (1). Estimated. The report does not specify the
number of parameters or training tokens. (2). For DALL-E the training
set consists of text/image pairs. Table compiled by Stefan Daume.
Newhouse 2020; Buchanan et al. 2021) and photo-
realistic but fake images (Mansimov et al., 2016;
Goldstein et al., 2023).
A simple prompt in GPT-3, for example ("write a tweet
expressing climate denying opinions in response to the
Australia bushfires"), results in short and snappy
climate denial pieces of text within seconds, like
"Australia isn't facing any impending doom or gloom
because of climate change, the bushfire events are just
a part of life here. There's no need to be alarmist about
it." By including real-world examples of impactful
tweets in the prompt with the writing style you'd like
to replicate (say, formulated in the style of an alt-right
user or QAnon conspiracy theorist), large language
models like GPT are able to produce synthetic text
that is well adapted to the language and world-views
of a specific audience (Buchanan et al., 2021) or even
individuals (Brundage et al., 2018).
In a similar way, generative AI models like DALL-E and
Midjourney can be used by anyone with limited prior
knowledge to produce realistically looking synthetic
images of, say, high-profile political figures being
arrested, like in the case of former U.S. president
Donald Trump in March, 2023.1
1 Fake AI images of Putin, Trump being arrested spread online
PBS NewsHour, March 23, 2023. Online. AI-generated images of Greta Thunberg. Credit: Diego Galafassi.
18
"
Sophistication
Generating
Sophistication refers to how sophisticated
AI-generated mis- and disinformation is. Social media
personalized content
users are more literate than sometimes assumed, and
are able to detect and pushback on too simplistic mis-
for chatbots that
and disinformation tactics (Jones-Jang et al., 2021).
engage with users in
There is no need to utilize advanced AI to coordinate a
disinformation campaign of course. For example, real-time becomes
simply cut-and-pasting misinformation content to push
a certain hashtag and issue online does not require practically possible at
advanced AI applications - especially if the text is short.
Generative AI however, can easily create longer pieces scale with limited
of synthetic text, like blog posts and authoritative
sounding articles. Such texts can be generated by human manpower.
including more specific prompts. Ben Buchanan and
colleagues (2021) for example, tested the ability of
GPT-3 to reproduce headlines in the style of the Anyone with enough resources can increase the
disreputable newspaper The Epoch Times, simply scalability of a disinformation operation by replacing
providing a couple of real headlines from the human writers (or at least some tedious writing tasks)
newspaper as prompts. In a more advanced test, the with language models. Flooding social media platforms
team managed to generate convincing news stories with a diversity of messages promoting one specific
with sensationalist or clearly biased headlines, and also narrative (say, false rumors about climate scientists
generate messages with the explicit intention to manipulating data for an upcoming IPCC-report), is one
amplify existing social divisions (Buchanan et al., 2021). possible application.
But text is not the only type of synthetic media that has Generating personalized content for chatbots that
become increasingly sophisticated lately. The increased engage with users in real-time becomes practically
sophistication of synthetic video and voice is also likely possible at scale with limited human manpower.
to create new mis- and disinformation challenges, Human-like messages including long-form content like
although such tools are not publicly available yet. Using news articles can be crafted, adapted to specific
satire for political campaigning seems to form the audiences (for example based on demographic
frontier for what has become known as "deepfakes"- information, or known political preferences), and the
highly convincing video and audio that has been altered language tweaked continuously in ways that make
and manipulated to misrepresent someone as doing or disinformation attempts much more difficult to detect
saying something that was not actually done or said. (examples from Goldstein et al., 2023).
Digital artist Bill Posters collaborated with anonymous
Persuasion
Brazilian activists to create a fake promotional video
that shows Amazon CEO Jeff Bezos announcing his Influencing public opinion is a matter of persuasion.
future commitment to protecting the Amazon False digital information and destructive narratives like
rainforest on the occasion of the company's 25th conspiracy theories are problematic, but will only have
anniversary (Gregory and Cizek, 2023). In the 2018 tangible impacts on perceptions, opinions and behavior
Belgian Election, a deep fake video of former U.S. if they manage to actually persuade a reader.
president Trump calling on the country to exit the Paris Persuasion is harder than simple amplification of a
climate agreement was widely distributed despite the message, and requires well-formed and well-tailored
video's poor quality.2 arguments to be effective (Buchanan et al., 2021: 30).
Large language models integrated in AI agents like
Generative AI can also result in increasingly Cicero, are already today able to engage in elaborate
sophisticated tactics (Goldstein et al., 2023). Tactics conversations and dialogue with humans in highly
that previously were computationally too heavy and persuasive ways (FAIR et al., 2022).
manually expensive, become suddenly possible.
2 Belgian socialist party circulates 'deep fake' Donald Trump video,
POLITICO, May 21th, 2018. Online.
19
One of the strengths of generative AI models is their For example, people often associate first-person
ability to automate the generation of content that is "as pronouns, use of contractions, or family topics with
varied, personalized, and elaborate as human- text produced by humans. As a result, it is easy to
generated content". Such content would go undetected exploit such heuristics to produce text that is "more
with current bot detection tools, which rely for human than human."
example on detecting identical repeated messages. It
also allows small groups to make themselves look much To what extent generative AI will allow persuasion at
larger online than they actually are (Goldstein et al., scale is too early to assess. But the landscape is
2023). changing rapidly. In April 2023, the organization
NewsGuard identified 49 websites that appear to be
Recent experimental studies indicate that created using generative AI and designed to look like
AI-generated messages were as persuasive as human typical news websites in seven languages - Chinese,
messages. To some extent, AI-generated messages Czech, English, French, Portuguese, Tagalog, and Thai.
were even perceived as more persuasive (i.e, more
factual and logical) than those produced by humans, The ability of generative AI to produce synthetic
even on polarized policy issues (Bai et al., 2023). Kreps material at scale; its nascent abilities to undermine
and colleagues (2022) note that individuals are largely automated detection systems and design messages in
incapable of distinguishing between AI- and human- ways that increase their persuasiveness; combined
generated text, but could not find evidence that with amplification via recommender systems and
AI-generated texts are able to shift individuals' policy automated accounts (previous chapter/part), are all
views. Jakesch and colleagues (2023) however, note worrying signs of the rapidly growing risks of
that people tend to use simple heuristics to automated mis- and disinformation. It would be naive
differentiate human- from AI-generated text. to assume that these tectonic shifts will not affect the
prospects for forceful climate and sustainability action.
A failed AI-generated headline that appeared on TNewsNetwork.com, an anonymously-run news site that was registered in February 2023.
Screenshot via NewsGuard. Online.
20
Keeping up with a fast-moving
digital environment
AI-supported recommender systems, social bots, and generative AI
provide fertile soil for a new generation of level of climate mis- and
disinformation. But digital media can also become a powerful tool for
collaboration and innovation for sustainability, if current trends of
misinformation are addressed.
Digital technologies, including social media and Nonetheless, these issues are key if we want to address
applications of AI, are rapidly changing the global the root social and algorithmic mechanisms that
information landscape. Digital media allows people to amplify digital climate mis- and disinformation.
connect at a speed and at scales that are
unprecedented in human history. This expansion offers Second, climate misinformation does not develop in
immense opportunities for collective problem solving isolation from other polarized social issues. On the
and accelerated innovation for sustainability. contrary, misinformation is largely a symptom of
deeper societal problems, including increasing
But the surge in connectivity also creates new risks as affective polarization between political groups or
it allows for the extensive spread and proliferation of decreasing trust in democratic institutions
misinformation, false news and malicious attempts to (Osmundsen, 2021, Altay 2022). This is increasingly
manipulate public opinion. Digital platforms and their visible in the overlap of climate misinformation with
embedded recommender systems, automation through issues like the opposition to renewable energy projects
social bots, and a new generation of generative (Winter et al., 2022), conspiracy theories around
AI-systems are fertile soil for new forms of automated geoengineering (Debnath et al., 2023), controversies
climate mis- and disinformation. Scientists, the public around healthy diets (Garcia et al., 2019), xenophobia
and policy-makers must keep a close eye on these and false claims that link forest fires with islamic
rapidly unfolding developments. The following issues terrorism (Daume et al., 2023) - just to mention a few.
are of central importance to properly analyze and This means that the proliferation of mis- and
respond to these risks based on best available evidence disinformation not only unfolds across platforms
(Bail, 2022): (Wilson and Starbird, 2020), but also across social
issues and political communities. Scholars need to
First, there is an urgent need to advance new methods expand their focus to this more complex reality
and multidisciplinary approaches to better assess the (Lorenz-Spreen et al., 2023). Policy-makers and
interplay between algorithmic systems (such as developers of digital platforms should also act
recommender systems), the diffusion of online proactively to respond to these clusters of mis- and
misinformation, and its impacts on opinion formation, disinformation, rather than treat them in isolation.
behavior and emotional well-being (Metzler & Garcia,
2023). For example, we need to understand how the Third, access to social media APIs and thus public data
current practice of optimizing algorithms to maximize for researchers is a key prerequisite for independent
engagement and reach on most social media platforms research. That independent researchers and journalists
affects the spread of climate misinformation. A uncovered the Cambridge Analytica scandal at
growing number of digital media users, altered social Facebook in 2016 is an example of the importance of
network properties, and algorithmic feedbacks are allowing access to APIs for academics as a means to
challenging issues to investigate (Wagner et al., 2021; hold powerful social media companies accountable
Bak-Coleman et al., 2021; Narayanan, 2023) and (Bruns, 2019). The dramatic recent changes in API
require standardization efforts (van der Linden, 2023). access for researchers following Twitter's takeover is
21
therefore highly problematic. Limitations in API
access by large social media companies are a
serious obstacle for such research (Morstatter &
Digital platforms Liu, 2017). Independent research studying the
diffusion of misinformation, or dynamics of hate
and their embedded speech and polarization using Twitter as a use-case
is at risk. Widely used and publicly available tools to
recommender help detect automated misinformation activities
like Botometer could become unavailable (Politico,
systems, automation 2023). Emergency managers have also warned of
threats to public safety during emergencies due to
through social bots, the erosion of the platform's verification system
and the consequential risks of increases of
and a new generation misinformation as fake users become verified, and
public crisis management organizations lose their
of generative AI- verified account status (Thompson, 2022).
systems are fertile Restricted access, in combination with the
emergence of new popular digital platforms like
soil for new forms TikTok, may very well make it impossible for
misinformation research to keep up with rapid
of automated technological and social developments. Terms and
conditions can also prove to become problematic.
climate mis- and For example TikTok can require researchers to
delete data from already analyzed datasets and also
disinformation. have the right to receive a copy of the researcher's
work 30 days prior to publication (Bak-Coleman,
2023). Regulatory efforts are therefore required.
The planned implementation of the EU Digital
Service Act in 2024 is one example of legal
responses that could help ensure critical future
independent social media research (Politico, 2023,
European Commission, 2023). Other countries
should follow suit. Without secure data access for
independent research, society and current
ambitions to reform social media will indeed "fly
blind" (Bail, 2022).
Image: Canva
22
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*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OPPT-2026-1387-0009
REPORT
AI could create a
perfect storm of
climate misinformation
Victor Galaz, Hannah Metzler, Stefan Daume,
Andreas Olsson, Bjorn Lindstrom and Arvid Marklund
Lead authors:
Victor Galaz, Stockholm Resilience Centre, Stockholm University
Hannah Metzler, Medical University of Vienna, Complexity Science Hub Vienna
Stefan Daume, Stockholm Resilience Centre, Stockholm University
Andreas Olsson, Department of Clinical ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. REPORT AI could create a perfect storm of climate misinformation Victor Galaz, Hannah Metzler, Stefan Daume, Andreas Olsson, Bjorn Lindstrom and Arvid Marklund Lead authors: Victor Galaz, Stockholm Resilience Centre, Stockholm University Hannah Metzler, Medical University of Vienna, Complexity Science Hub Vienna Stefan Daume, Stockholm Resilience Centre, Stockholm University Andreas Olsson, Department of ClinicalNeurosciences, Karolinska Institutet
Bjorn Lindstrom, Department of Clinical Neurosciences, Karolinska Institutet
Arvid Marklund, Beijer Institute of Ecological Economics, Royal Swedish
Academy of Sciences
Cover photo: iStockphoto
Layout and graphics: Julia Rende, Elsa Wikander - Azote.
Suggested citation: Galaz, V., H. Metzler, S. Daume, A. Olsson, B. Lindstrom,
A. Marklund (2023). Climate misinformation in a climate of misinformation.
Research brief. Stockholm Resilience Centre (Stockholm University) and the
Beijer Institute of Ecological Economics (Royal Swedish Academy of Sciences).
http://arxiv.org/abs/2306.12807
Version: 2023-06-16
With support from:
2
Content
AI could create a perfect storm of
climate misinformation 4
What is climate mis- and disinformation
- and why should we care? 6
The neuroscience of false beliefs 8
How algorithms diffuse and
amplify misinformation 10
Emotions and group dynamics around
misinformation on social media 13
When health and climate
misinformation overlap 15
A game changer for misinformation:
The rise of generative AI 17
Keeping up with a fast-moving
digital environment 21
3
AI could create a perfect storm
of climate misinformation
We are in the midst of a transformation of the digital news ecosystem.
The expansion of online social networks, the influence of recommender
systems, increased automation, and new generative artificial intelligence
(AI) tools are rapidly changing the speed and the way misinformation
about climate change and sustainability issues moves around the world.
Policymakers, researchers and the public need to combine forces to
address the dangerous combination of opaque social media algorithms,
polarizing social bots, and a new generation of AI-generated content.
When OpenAI released their version of the artificial The following synthesis explores the increasing
intelligence ChatGPT to the public in November 2022, influence of digital media, AI and algorithmic systems
the playing ground for false news and misinformation on the creation, diffusion and amplification of
online changed completely. Suddenly, anyone could misinformation about climate and environmental
with relatively little effort produce seemingly human- sustainability issues. We combine insights from various
written text and highly realistic images - regardless of research strands ranging from computational social
their truthfulness. sciences, to sustainability sciences and neurosciences,
to explore what we know about how such information
Misinformation and disinformation campaigns are not is amplified, and to what extent recent advances in AI
new, and topics such as climate change have been in pose new challenges for our ability to act collectively
the line of fire more than once. But over time, the on our planetary crisis.
digital aspects of these phenomena have become
increasingly important for those interested in This synthesis brief has been put together as an
understanding and tackling the harmful effects of mis- independent contribution to the Nobel Prize Summit
and disinformation. 2023, "Truth, Trust and Hope", Washington D.C., 24-26
of May 2023.
Information and communications technologies have
made the world increasingly connected, allowing
information to move almost effortlessly around the
world in the blink of an eye. What we see on our
screens everyday is increasingly determined by
recommender systems, systems designed to maximize
engagement, at times favoring whatever creates
engagement over truth. Sometimes, this information
movement is affected by social bots. Often, the
diffusion of information is shaped by how people
engage with it by sharing, commenting, remaking it and
moving it across digital media platforms and between
social and conventional media. This, in combination
with the capacities of generative AI to create synthetic
content, may very well result in a perfect storm of
misinformation. The time to act on these risks is now. Image: Canva
4
Box 1. Key terms
Artificial intelligence - we use the ('precision farming'), electricity ('smart particular user. Recommender systems
terms "artificial intelligence" and "AI" grids'), and housing ('smart homes'), are widely used in social media
to refer to technologies that employ do not necessarily use AI for their platforms, but also other digital
machine learning including deep operations. services like music streaming, video
learning methods. services, and for online shopping (Ricci
Generative AI - refers to AI based on et al., 2015). Such systems can deploy
Algorithmic systems - refer to advanced neural networks with the AI-analysis to guide their
assemblages of multiple algorithms ability to produce highly realistic recommendations (Engstrom and
(i.e., a finite sequence of well-defined, synthetic text, images, video and audio Strimling, 2021).
computer-implementable instructions, (including fictional stories, poems, and
typically to solve a class of problems or programming code) with little, to no Social bots - are automated social
to perform a computation), databases, human intervention. The most known media accounts with the ability to build
and interfaces that interact, as well as example is the Generative Pre-trained social communication networks and
the social practices that people Transformer 3 (GPT-3, GPT-4) that create online content. Such bots can be
develop to interact with them (Wagner underpins OpenAI's GPTChat (OpenAI, used for beneficial or malicious
et al., 2021; Ada Lovelace Institute, 2023). Note however that GPT is only purposes ranging from news
2021). one of many existing generative AI aggregation, user assistance or
models (e.g., Gibney, 2022). entertainment, to spam and
Digitalization - is here used to sophisticated influence campaigns
describe the adoption and use of Recommender systems - refer to (Stieglitz et al., 2017).
digital technologies, including societal, techniques that offer suggestions for
organizational, and individual impact information (e.g., other users, text,
(Legner et al., 2017). Digital articles, videos or social media posts)
technologies for e.g., food production that are likely to be of interest to a
5
What is climate mis- and
disinformation - and why
should we care?
By Victor Galaz
Our living planet is facing a multitude of interacting crises. Climate
change, the loss of biodiversity, inequality, pandemics, and war and
conflict are just a few of them. In these times of turbulence, it is vital that
decisions about our common future are well-grounded in science. False
information and intentional attempts to manipulate public opinion pose
serious risks to our joint capacities to create a safe and just future for all.
Mis- and disinformation play a crucial role in forming is not a direct result of human activity.' In Brazil, 30%
public opinion and thus influencing the actions taken at believe that climate change is not caused mainly by
all levels of society, from individuals to central policy- human activity, and 24% believe that the "temperature
making. Misinformation about covid-19 vaccines for record is unreliable or rigged". In the United Kingdom,
example, has notable impacts on whether people are 29% believe that a significant number of scientists
willing to take the vaccine (Loomba et al., 2021). A disagree on the cause of climate change (Climate
growing body of work also explores to what extent Action Against Disinformation and Conscious
misinformation has affected political elections around Advertising Network, 2022). Misinformation and
the world (for example, Howard, 2020; Machado et al., conspiracy theories about wind energy farms are
2019). Scientists engaged in science communication already affecting the expansion of renewable energy
also face an increased number of attacks in social negatively, and thus the prospects for achieving a
media as they struggle to inform the public to mitigate transition to zero-carbon energy sources (Winter et al.,
the spread of fake news and misinformation (Nogrady, 2022).
2021).
One key and challenging issue is how to define and
It is becoming increasingly clear that misinformation is identify mis- and disinformation. Here we refer to
taking its toll on public opinion on climate and misinformation as information whose inaccuracy is
sustainability issues as well. A recent study shows that unintentional. Disinformation on the other hand, refers
U.S. citizens, partly due to biased and incorrect media to information that is deliberately false or misleading
reporting, systematically underestimate public support (Jack, 2017). While the definitions of mis- and
for ambitious climate policies, thus falsely assuming disinformation might seem straightforward, their
that a vocal minority who dismiss climate change are differences in the real world are not (Jerit and Zhao,
representative of the broader public opinion 2020; Treen et al., 2020).
(Sparkman et al., 2022). A cross-national study
conducted by the Climate Action Against Climate mis- and disinformation has a long history, and
Disinformation and Conscious Advertising Network its underlying motivations and strategies have become
(2022) shows a considerable spread of serious increasingly visible in the last years (e.g., Supran et al.,
misconceptions about climate change in the surveyed 2023; Franta, 2018). Attempts to sow confusion about
countries. 33% of the surveyed population in the US the science of climate change include lobbying
and Australia believe that 'the climate has always campaigns by vested interests (Brulle, 2018), the
changed, global warming is a natural phenomenon and funding of climate change denialist think tanks
6
(Farrell, 2019), and corporate climate "skeptic"
campaigns in conventional media (Dunlap &
McCright, 2011; Supran & Oreskes, 2017).
Climate change
In parallel to this type of coordinated
and the loss of disinformation activities there are other much more
fluid and complex self-organized patterns of
biodiversity require information sharing and engagements on digital
platforms. In the case of fossil fuel companies'
collective action and documented attempts to influence public opinion
on climate change issues their agency is
public deliberations straightforward (Supran and Oreskes, 2017; Supran
et al., 2023). But the type of mis-and disinformation
that are global in that flows effortlessly across social media platforms
like Twitter, TikTok and Youtube, is another type of
scope, ambitious beast. The former has a clear intent, plan and
coordinating agent, while the latter form tends to
in its goals, and emerge and evolve as information, algorithmic
systems and digital social networks interact in
over very extended complex ways. These two forms of mis- and
disinformation are of course, often combined in
periods of time. reality (Starbird and Wilson, 2019).
Digital media plays a key role in this regard (Pearce
et al., 2019; Treen et al., 2020). Five hundred million
tweets, 294 billion emails, 4 petabytes of content
on Facebook, 65 billion messages on WhatsApp,
and 5 billion searches on Google are conducted
every day (from Howard, 2020, p. 4). Social media
like Facebook, Twitter and Instagram is particularly
important in this context. Survey data shows that
between 40% and 60% of adults in most developed
countries, receive their news from social media
(Nic, 2017). The fact that social media platforms are
participatory by design allows them to shape
individual attitudes, feelings and behaviors
(Williams et al., 2015), and facilitates social
mobilization and protests (Steinert-Threlkeld et al.,
2015).
Climate change and the loss of biodiversity require
collective action and public deliberations that are
global in scope, ambitious in its goals, and over very
extended periods of time (Galaz 2020). Polarization,
mistrust in science, and incorrect climate and
environmental information amplified through
digital media could undermine such much-needed
collective action in detrimental ways.
Image: Canva
7
The neuroscience of
false beliefs
By Andreas Olsson and Bjorn Lindstrom
What we believe is not only a result of our own reasoning, but also
of the beliefs of people around us. Our brains are wired to consume
information that is liked by our peers. That way, social reinforcers online
- in the form of likes, comments and shares - can build a basis for what
individuals believe to be true or false.
"
Why do people adopt beliefs, such as that the earth is
flat, which are clearly incompatible with established
Research has shown
truth? Like with other beliefs, it depends on the nature
of their prior beliefs, goals, as well as learning and
that the orbitofrontal
reasoning processes. Our knowledge about the
psychological and neural mechanisms that promote
cortex, a brain region
false beliefs is still nascent, but existing research in
psychology and neuroscience has described how
located just behind
people process information that is unexpected,
emotional, and politically divisive - features typical of the eyes, is critical for
false information encountered on social media.
computing the value
First, information that is unexpected and emotionally
(especially negatively) loaded, tends to grasp our of different goals.
attention, which depends on visual cortices and
attentional networks in parietal and frontal brain
regions. In addition, attention also depends on activity politically divisive facts. At first glance, one could think
in deep brain nuclei that are sensitive for events that that this is due to politically motivated reasoning.
can be threatening and important goals of the However it can also be viewed as rational inferences
individual. considering the individual's prior belief system
(Botvinik-Netzer et al., 2023). Networks of brain
Various goals of the individual can be important. For regions linked to memory retrieval and belief updating,
example, if social goals, such as promoting one's own are likely to support these processes.
social status or belonging to a particular group, are
more important than the goal to seek and represent Recent research shows that simple learning
the truth, then attention is biased towards whatever mechanisms, known to engage regions in the brain's
promotes the more important goals. Research has system that run on dopamin, can explain how humans
shown that the orbitofrontal cortex, a brain region are motivated to increase the consumption of
located just behind the eyes, is critical for computing information that is liked by others - in particular by
the value of different goals. Other prefrontal regions those belonging to the same group as the individual
serve to monitor information that deviates from what identifies with. For example, models of instrumental
is in line with one's own moral or political convictions. learning explain why people engage with social media
People who strongly identify with different political (Lindstrom et al., 2021, Ceylan et al., 2023) and how
ideologies tend to distort their conclusions in line with morally outraged messages become viral (Brady et al.,
their political identities when asked to reason about 2021). The social reinforcers that are at play in social
8
media might thus provide a basis for what individuals
believe to be true. Indeed, research has shown that
social forms of learning can be at least as powerful,
and draw on many of the same neural principles as
learning based on own, personal experiences (Olsson
et al., 2020). The importance of understanding the
power of social influences is further underscored by
recent findings showing that the more a statement is
"liked" by others, the more the statement is
subsequently rated as true (Granwald et al., 2023).
In sum, although much is known about the
psychological and brain bases of acquiring and
updating beliefs in general, much less is known about
how we process false beliefs encountered online.
Because the lack of a shared knowledge about what
is true can fuel polarization, conflicts and other
destructive behaviors (Brady et al., 2023), we need
to increase efforts to understand the basic
psychology and neuroscience of false beliefs.
"
Our brains are
wired to consume
information that is
liked by our peers.
Image: iStockphoto / Canva
9
How algorithms diffuse and
amplify misinformation
By Victor Galaz and Stefan Daume
Digital platforms are designed to maximize engagement. Recommender
systems play a key role as they shape digital social networks, and the
flow of information. Weaknesses in their underlying algorithmic systems
are already today being exploited to try to influence public opinion on
climate and sustainability issues. Automation through social bots also
play a role, although their impacts are contested.
In 2010, a team of political scientists in collaboration Second, the way information moves in these vastly
with researchers at Facebook conducted a gigantic spanning digital social networks is not random. Its
experiment on the platform. It included "all users of at movement is fundamentally affected by the way digital
least 18 years of age in the United States who media platforms such as recommender systems are
accessed the Facebook website on 2 November 2010, designed to maximize engagement and induce other
the day of the US congressional elections". This forms of behavioral responses amongst its users
61-million-person experiment tested whether a (Kramer et al., 2014; Coviello et al., 2014). The
simple tweak in the newsfeed of users - adding a "I diffusion of such information can also be exploited by
Voted" button and information about friends who had external attempts to manipulate public opinion online.
voted - could impact voting behavior. Three common approaches include (1) specifically
targeting the way algorithmic systems operate, (2)
The results were clear: this small design change led to carefully crafting viral messages to sow confusion, and
higher real-world voting turnout. Facebook-users who (3) through the use of automation tools like 'social bots'.
saw a message about one of their close friends on
Facebook having voted were 2.08% more likely to Social bots mimic human behavior online, and can be
vote themselves (Bond et al., 2012). used in ways to amplify certain types of information -
say, climate denialism -, or operate in ways that widen
This controversial experiment illustrates a number of social divisions online (Gorwa and Guilbeault, 2018;
issues that are key if we are to understand how digital Shao et al., 2018). Our own work (Daume et al., 2023)
platforms interplay with the creation and diffusion of shows that social bots play an unignorable role in
mis- and disinformation, and their impacts. climate change conversation. They amplify information
that supports and opposes climate action at the same
First, digitalization and the expansion of social media time, especially information appealing to emotions,
has not only fundamentally expanded the scale, but such as sympathy or humor.
also transformed the properties of social networks.
3,6 billion people use social media today. Through it, Recommender systems play a key role for the dynamics
they access a digital media environment where of information diffusion and the evolution of digital
language barriers slowly but surely are eroding as new social networks (Narayanan, 2023), and they have
digital tools make communication across borders increasingly become infused with deep learning-based
increasingly frictionless. These new connections are AI (Engstrom and Strimling, 2020). People-
transforming the structures of social networks in ways recommender systems for example (like "People You
that allow for immediate communication across vast May Know" on Facebook or "Who to Follow" on
geographical space (Bak-Coleman et al., 2021). Twitter) shape social network structures, thus
10
Figure 1. The figure illustrates how social bots influenced the diffusion of different climate change frames via Tweets about the 2019/2020
Australia bushfires. The results indicate that different framings of climate change are associated with distinctive automation signatures.
"
influencing the information and the opinions a user is
exposed to online (Cinus, 2021). Content-recommender
systems (like "Trends for you") can reinforce the human People-recommender
preference for content that aligns with a user's ideology
(Bakshy et al., 2015). systems for example
Figure 2 below illustrates four highly simplified models (like "People You May
of information propagation of one individual post. The
expansion of digital social networks, the influence of Know" on Facebook or
recommender systems and social bots change the reach
of mis- and disinformation. This diffusion has complex "Who to Follow" on
secondary effects on perceptions, on the formation of
Twitter) shape social
online communities, on collective action, and on identity
formation.
network structures,
Lastly, the 61-million-user experiment also illustrates
thus influencing the
another feature of today's digital ecosystem - the
capacity to mass produce and test online material to
information and the
maximize impact. Online material and digital platforms
provide the perfect setting to conduct randomized
opinions a user is
controlled experiments as a means to systematically
compare two versions of something - say, a news article
exposed to online.
or ad - to figure out which performs better,sometimes
referred to as A/B testing. In combination with a growing
capacity to cheaply and quickly mass produce synthetic
text, images and videos using generative AI (see chapter
6), this is pushing us into uncharted and dangerous
territory for the future of mis- and disinformation on
climate and environmental sustainability issues.
11
Figure 2. The figure illustrates four models of information propagation of one individual post through: a) network, b) algorithm,
c) affective, and d) automated amplification. In a) the post cascades through the network as long as other users choose to further
propagate it by e.g., sharing or liking. In the algorithmic model b) propagation unfolds as users with similar interests (as
determined by recommendation algorithms based on for example past engagement) are more likely to be recommended the
post. In (c), users comment and reshare posts much more if they elicit strong emotions, and recommender systems pick up highly
engaging posts and amplify them even further. In d) automated accounts ('social bots') purposefully share content that elicits
strong emotions to further increase propagation. Figure based on (Narayanan, 2023).
12
Emotions and group dynamics
around misinformation on
social media
By Hannah Metzler
Nuanced views and clean facts don't generate clicks. Social networks
are designed to speak to our emotions, and the more extreme the
emotions, the better the content. But that does not mean that good
arguments, education, and science communication are futile.
"
Emotions attract our attention, and provide us with
information about actions we should take: When you Humans are social
feel fear, it's best not to ignore the danger, and protect
yourself from it. When you are angry, it's probably animals, and things
because someone has treated you or a group you
belong to unfairly, and it's time to step up against the that make us feel
injustice.
part of a group, that
News agencies, politicians, and creators of fake news
increase our group's
know this, and use it to create content that attracts
attention and is likely to be shared on digital and social
status, or decrease
media. Algorithms on social media are optimized to
increase engagement with content (Narayanan, 2023;
the status of an out-
Metzler & Garcia, 2022), and content that provokes
strong emotional reactions is a powerful means to do
group, are highly
so. Negative moral-emotional messages about groups
we do not like seem to particularly increase
motivating for us.
engagement (Brady et al., 2017, Rathje et al. 2021,
Marie et al., 2023). Humans are social animals, and
things that make us feel part of a group, that increase
our group's status, or decrease the status of an out- rhetoric (Lewandowsky, 2021). Polarized conversations
group, are highly motivating for us (Robertson et al., between these different sides on social media grow
2022). around events like climate protests, or releases of
climate change reports, such as the reports from the
We can regularly observe such emotional group Intergovernmental Panel on Climate Change, (Sanford,
dynamics around the topic of climate change on social 2021). And political polarization fuels the spread of
media. On the one hand, there are people who think we misinformation (Osmundsen et al., 2021, Marie et al.,
are not doing enough and need to urgently take action: 2023).
social movements like Fridays for Future or Extinction
Rebellion, and political parties like the Green parties in Because more outrageous content attracts more
Europe, or Democrats in the US. On the other side, attention, and individuals with stronger opinions are
climate skepticism and denial are more common in far- more motivated to persuade others, extreme voices
right, populist or libertarian parties, who oppose and toxic content are more visible on social media (Bail,
economic regulation and benefit from using anti-elite 2021). Individuals with more nuanced views, who can
13
relate to both sides of a debate, are much less
visible. A large majority of individuals who are not
interested enough to participate in discussions, but
generally agree with a nuanced perspective, is Explaining how
entirely invisible. This way, digital media make
polarization seem stronger than it actually is in we know climate
society, and this in turn fuels hate and
misunderstanding between parties (Brady et al. change is happening,
2023). Redesigning platforms so that nuanced
majorities and overlap in the views of different how it works,
groups become more visible, could therefore help
to decrease the spreading of misinformation how solutions can
(Metzler & Garcia, 2022). Redesigning social media
algorithms could be one way to do so. integrate economic
Fortunately, people do not uncritically believe any and environmental
emotional information that comes their way
(Mercier, 2020). Key questions such as who shares needs, for example,
news, whether they know and trust the source, and
if it fits with what they already know and believe takes time and effort.
about the world, crucially determine if we find
information plausible. People's anger after reading
false news, for example, can occur because they
recognize it as misinformation and disagree
(Luhring et al., 2023). So, strong emotions do not
automatically mean people will believe a message
and continue to share it. That people judge new
information based on trust in sources, and their
knowledge about the world, means that good
arguments, education, and science communication
are not futile. Explaining how we know climate
change is happening, how it works, how solutions
can integrate economic and environmental needs,
for example, takes time and effort. But it will also
help to increase trust in science, and politics that
implements such evidence-based solutions, and
thereby decrease polarization and misinformation.
"
People's anger
after reading false
news, for example,
can occur because
they recognize it as
misinformation and
disagree.
Image: Canva
14
When health and climate
misinformation overlap
By Victor Galaz and Stefan Daume
Health and climate are two topics that often are affected by mis-
and disinformation. Where the two overlap, a perfect storm for
false claims can grow. Experiences from the "digital backlash" that
followed the launch of the "planetary health diet" can teach us
important lessons about what happens when health and climate
misinformation act in tandem.
Early in 2019, an international team of scientists The wider reception of the study was positive and its
published a groundbreaking study in The Lancet on how findings were covered in major news outlets around
humanity can eat to both be healthy and live within the world.
planetary boundaries. One of the key take-aways of the
paper was that eating less meat and dairy can improve But on social media a storm raged as the study was
human health and drastically reduce the ecological published. Under the hashtag #yes2meat, accounts
footprint of food production, at the same time. gathered to circulate misinformation and defamatory
Figure 3. Social media community structures related to the planetary health and the social media campaign
#yes2meat. Red shows replies by users in the "yes2meat" community, blue is the "pro-EATLancet" community,
yellow is an ambiguous community, and green is a vegan community. Based on "EAT-Lancet vs. yes2meat:
Understanding the digital backlash to the 'planetary health diet'".
15
"
The #yes2meat
backlash is just one
example of how mis-
and disinformation
transgresses from
one topic to the
other.
material. A later analysis showed that this storm
was a concerted effort of a pro-meat social media
campaign that started its workings weeks before
the study was released (Garcia et al., 2019).
The digital backlash created by the campaign
continued over months and successfully swayed
undecided users.
The majority of the accounts involved in the
campaign were not driven by social bots, but by
actual humans. On Twitter, these critics managed to
reach 26 million people - compared to 25 million
from academics and others that engaged in science
communication. The campaigners achieved this,
despite having much fewer followers, likely with the
help of social media platforms' amplification
mechanisms (see chapter 3).
The #yes2meat backlash is just one example of how
mis- and disinformation transgresses from one
topic to the other. Such overlap is the rule rather
than the exception. For example, climate denialism
often overlap with opposition to renewable energy
projects (Winter et al., 2022), conspiracy theories
around geoengineering (Debnath et al., 2023),
xenophobia and false claims that link forest fires
with islamic terrorism (Daume et al., 2023). In some
instances, climate misinformation drives waves of
aggressive, sexist and toxic online comments (Park
et al., 2021; Nogrady, 2021), often with their roots
in far-right political environments (Vowles and
Hultman, 2022).
As a reminder: the digital backlash following from
the launch of the "planetary health diet" unfolded in
2019. With the new powers of generative AI, it
would be possible to amplify such campaigns in
novel ways, contributing further to confusion and
the erosion of trust to science. Image: Canva
16
A game changer for
misinformation: The rise
of generative AI
By Victor Galaz, Stefan Daume and Arvid Marklund
New generative AI tools make it increasingly easy to produce sophisticated
texts, images and videos that are basically indistinguishable from human-
generated content. These technological advances in combination with
the amplification properties of digital platforms pose tremendous risks of
accelerated automated climate mis- and disinformation.
The year of 2023 will be mentioned in history books Accessibility
as the point in time when advances in artificial
Accessibility refers to the fact that generative AI tools
intelligence became everyday news - everywhere.
that produce highly realistic synthetic content, that is
The decision by OpenAI to offer the general public
not necessarily accurate, are rapidly becoming easily
access to their deep learning-based Generative Pre-
available.
trained Transformer (GPT) model opened up a
floodgate of experimentation by journalists,
While the most capable models remain either private
designers, developers, teachers, researchers and
or behind monitorable application programming
artists.
interfaces (APIs), some advanced models are publicly
accessible, either in open code repositories or through
Generative AI-systems such as these have the ability
public APIs including OpenAI, Google, Microsoft and
to produce highly realistic synthetic text, images,
Hugging Face (Table 1). In addition, the open source
video and audio - including fictional stories, poems,
community has quickly managed to create much
and programming code - with little to no human
smaller versions of large language models that are
intervention. The combination of increased
almost equally powerful, and can be run on laptops or
accessibility, sophistication and capabilities for
even phones (Dickson, 2023). All of these tools can, in
persuasion may very well supercharge the dynamics
principle, be prompted to deliberately generate false
of climate mis- and disinformation.
information, both in the form of text (McGuffie and
Images from: Generative AI images credit Diego Galafassi.
17
Table 1: Selection of generative language models released between 2018 and 2023.
NLP Model Year Developing Parameters Training Access Reference
organization tokens
GPT-4 2023 OpenAI 1000B1 Not API (waitlist) (OpenAI, 2023)
specified
PaLM 2022 Alphabet (Google) 540B 780B API (early access) (Chowdhery et al. 2022)
Chinchilla 2022 Alphabet 70B 1400B None (Hoffmann et al. 2022)
(DeepMind)
Megatron- 2022 Microsoft, NVIDIA 530B 270B API (early access) (Smith et al. 2022)
Turing NLG
DALL-E 2021 OpenAI 12B 250M2 Public API (Ramesh et al. 2021)
ERNIE 3.0 2021 Baidu 10B 375B Public model (Github) (Wang et al. 2021)
GPT-3 2020 OpenAI 175B 499B Public API (Brown et al. 2020)
GPT-2 2019 OpenAI 1.5B ~10B Public model (Github) (Radford et al. 2019)
BERT 2018 Alphabet (Google) 0.34B ~3.3B Public model (HuggingFace) (Devlin et al. 2018)
Table 1: Selection of generative language models released between
2018 and 2023. Language models are accelerating in parameter size,
utilize growing training datasets, support multiple languages, and
have the capacity to generate both text as well as images in response
to text 'prompts'. (1). Estimated. The report does not specify the
number of parameters or training tokens. (2). For DALL-E the training
set consists of text/image pairs. Table compiled by Stefan Daume.
Newhouse 2020; Buchanan et al. 2021) and photo-
realistic but fake images (Mansimov et al., 2016;
Goldstein et al., 2023).
A simple prompt in GPT-3, for example ("write a tweet
expressing climate denying opinions in response to the
Australia bushfires"), results in short and snappy
climate denial pieces of text within seconds, like
"Australia isn't facing any impending doom or gloom
because of climate change, the bushfire events are just
a part of life here. There's no need to be alarmist about
it." By including real-world examples of impactful
tweets in the prompt with the writing style you'd like
to replicate (say, formulated in the style of an alt-right
user or QAnon conspiracy theorist), large language
models like GPT are able to produce synthetic text
that is well adapted to the language and world-views
of a specific audience (Buchanan et al., 2021) or even
individuals (Brundage et al., 2018).
In a similar way, generative AI models like DALL-E and
Midjourney can be used by anyone with limited prior
knowledge to produce realistically looking synthetic
images of, say, high-profile political figures being
arrested, like in the case of former U.S. president
Donald Trump in March, 2023.1
1 Fake AI images of Putin, Trump being arrested spread online
PBS NewsHour, March 23, 2023. Online. AI-generated images of Greta Thunberg. Credit: Diego Galafassi.
18
"
Sophistication
Generating
Sophistication refers to how sophisticated
AI-generated mis- and disinformation is. Social media
personalized content
users are more literate than sometimes assumed, and
are able to detect and pushback on too simplistic mis-
for chatbots that
and disinformation tactics (Jones-Jang et al., 2021).
engage with users in
There is no need to utilize advanced AI to coordinate a
disinformation campaign of course. For example, real-time becomes
simply cut-and-pasting misinformation content to push
a certain hashtag and issue online does not require practically possible at
advanced AI applications - especially if the text is short.
Generative AI however, can easily create longer pieces scale with limited
of synthetic text, like blog posts and authoritative
sounding articles. Such texts can be generated by human manpower.
including more specific prompts. Ben Buchanan and
colleagues (2021) for example, tested the ability of
GPT-3 to reproduce headlines in the style of the Anyone with enough resources can increase the
disreputable newspaper The Epoch Times, simply scalability of a disinformation operation by replacing
providing a couple of real headlines from the human writers (or at least some tedious writing tasks)
newspaper as prompts. In a more advanced test, the with language models. Flooding social media platforms
team managed to generate convincing news stories with a diversity of messages promoting one specific
with sensationalist or clearly biased headlines, and also narrative (say, false rumors about climate scientists
generate messages with the explicit intention to manipulating data for an upcoming IPCC-report), is one
amplify existing social divisions (Buchanan et al., 2021). possible application.
But text is not the only type of synthetic media that has Generating personalized content for chatbots that
become increasingly sophisticated lately. The increased engage with users in real-time becomes practically
sophistication of synthetic video and voice is also likely possible at scale with limited human manpower.
to create new mis- and disinformation challenges, Human-like messages including long-form content like
although such tools are not publicly available yet. Using news articles can be crafted, adapted to specific
satire for political campaigning seems to form the audiences (for example based on demographic
frontier for what has become known as "deepfakes"- information, or known political preferences), and the
highly convincing video and audio that has been altered language tweaked continuously in ways that make
and manipulated to misrepresent someone as doing or disinformation attempts much more difficult to detect
saying something that was not actually done or said. (examples from Goldstein et al., 2023).
Digital artist Bill Posters collaborated with anonymous
Persuasion
Brazilian activists to create a fake promotional video
that shows Amazon CEO Jeff Bezos announcing his Influencing public opinion is a matter of persuasion.
future commitment to protecting the Amazon False digital information and destructive narratives like
rainforest on the occasion of the company's 25th conspiracy theories are problematic, but will only have
anniversary (Gregory and Cizek, 2023). In the 2018 tangible impacts on perceptions, opinions and behavior
Belgian Election, a deep fake video of former U.S. if they manage to actually persuade a reader.
president Trump calling on the country to exit the Paris Persuasion is harder than simple amplification of a
climate agreement was widely distributed despite the message, and requires well-formed and well-tailored
video's poor quality.2 arguments to be effective (Buchanan et al., 2021: 30).
Large language models integrated in AI agents like
Generative AI can also result in increasingly Cicero, are already today able to engage in elaborate
sophisticated tactics (Goldstein et al., 2023). Tactics conversations and dialogue with humans in highly
that previously were computationally too heavy and persuasive ways (FAIR et al., 2022).
manually expensive, become suddenly possible.
2 Belgian socialist party circulates 'deep fake' Donald Trump video,
POLITICO, May 21th, 2018. Online.
19
One of the strengths of generative AI models is their For example, people often associate first-person
ability to automate the generation of content that is "as pronouns, use of contractions, or family topics with
varied, personalized, and elaborate as human- text produced by humans. As a result, it is easy to
generated content". Such content would go undetected exploit such heuristics to produce text that is "more
with current bot detection tools, which rely for human than human."
example on detecting identical repeated messages. It
also allows small groups to make themselves look much To what extent generative AI will allow persuasion at
larger online than they actually are (Goldstein et al., scale is too early to assess. But the landscape is
2023). changing rapidly. In April 2023, the organization
NewsGuard identified 49 websites that appear to be
Recent experimental studies indicate that created using generative AI and designed to look like
AI-generated messages were as persuasive as human typical news websites in seven languages - Chinese,
messages. To some extent, AI-generated messages Czech, English, French, Portuguese, Tagalog, and Thai.
were even perceived as more persuasive (i.e, more
factual and logical) than those produced by humans, The ability of generative AI to produce synthetic
even on polarized policy issues (Bai et al., 2023). Kreps material at scale; its nascent abilities to undermine
and colleagues (2022) note that individuals are largely automated detection systems and design messages in
incapable of distinguishing between AI- and human- ways that increase their persuasiveness; combined
generated text, but could not find evidence that with amplification via recommender systems and
AI-generated texts are able to shift individuals' policy automated accounts (previous chapter/part), are all
views. Jakesch and colleagues (2023) however, note worrying signs of the rapidly growing risks of
that people tend to use simple heuristics to automated mis- and disinformation. It would be naive
differentiate human- from AI-generated text. to assume that these tectonic shifts will not affect the
prospects for forceful climate and sustainability action.
A failed AI-generated headline that appeared on TNewsNetwork.com, an anonymously-run news site that was registered in February 2023.
Screenshot via NewsGuard. Online.
20
Keeping up with a fast-moving
digital environment
AI-supported recommender systems, social bots, and generative AI
provide fertile soil for a new generation of level of climate mis- and
disinformation. But digital media can also become a powerful tool for
collaboration and innovation for sustainability, if current trends of
misinformation are addressed.
Digital technologies, including social media and Nonetheless, these issues are key if we want to address
applications of AI, are rapidly changing the global the root social and algorithmic mechanisms that
information landscape. Digital media allows people to amplify digital climate mis- and disinformation.
connect at a speed and at scales that are
unprecedented in human history. This expansion offers Second, climate misinformation does not develop in
immense opportunities for collective problem solving isolation from other polarized social issues. On the
and accelerated innovation for sustainability. contrary, misinformation is largely a symptom of
deeper societal problems, including increasing
But the surge in connectivity also creates new risks as affective polarization between political groups or
it allows for the extensive spread and proliferation of decreasing trust in democratic institutions
misinformation, false news and malicious attempts to (Osmundsen, 2021, Altay 2022). This is increasingly
manipulate public opinion. Digital platforms and their visible in the overlap of climate misinformation with
embedded recommender systems, automation through issues like the opposition to renewable energy projects
social bots, and a new generation of generative (Winter et al., 2022), conspiracy theories around
AI-systems are fertile soil for new forms of automated geoengineering (Debnath et al., 2023), controversies
climate mis- and disinformation. Scientists, the public around healthy diets (Garcia et al., 2019), xenophobia
and policy-makers must keep a close eye on these and false claims that link forest fires with islamic
rapidly unfolding developments. The following issues terrorism (Daume et al., 2023) - just to mention a few.
are of central importance to properly analyze and This means that the proliferation of mis- and
respond to these risks based on best available evidence disinformation not only unfolds across platforms
(Bail, 2022): (Wilson and Starbird, 2020), but also across social
issues and political communities. Scholars need to
First, there is an urgent need to advance new methods expand their focus to this more complex reality
and multidisciplinary approaches to better assess the (Lorenz-Spreen et al., 2023). Policy-makers and
interplay between algorithmic systems (such as developers of digital platforms should also act
recommender systems), the diffusion of online proactively to respond to these clusters of mis- and
misinformation, and its impacts on opinion formation, disinformation, rather than treat them in isolation.
behavior and emotional well-being (Metzler & Garcia,
2023). For example, we need to understand how the Third, access to social media APIs and thus public data
current practice of optimizing algorithms to maximize for researchers is a key prerequisite for independent
engagement and reach on most social media platforms research. That independent researchers and journalists
affects the spread of climate misinformation. A uncovered the Cambridge Analytica scandal at
growing number of digital media users, altered social Facebook in 2016 is an example of the importance of
network properties, and algorithmic feedbacks are allowing access to APIs for academics as a means to
challenging issues to investigate (Wagner et al., 2021; hold powerful social media companies accountable
Bak-Coleman et al., 2021; Narayanan, 2023) and (Bruns, 2019). The dramatic recent changes in API
require standardization efforts (van der Linden, 2023). access for researchers following Twitter's takeover is
21
therefore highly problematic. Limitations in API
access by large social media companies are a
serious obstacle for such research (Morstatter &
Digital platforms Liu, 2017). Independent research studying the
diffusion of misinformation, or dynamics of hate
and their embedded speech and polarization using Twitter as a use-case
is at risk. Widely used and publicly available tools to
recommender help detect automated misinformation activities
like Botometer could become unavailable (Politico,
systems, automation 2023). Emergency managers have also warned of
threats to public safety during emergencies due to
through social bots, the erosion of the platform's verification system
and the consequential risks of increases of
and a new generation misinformation as fake users become verified, and
public crisis management organizations lose their
of generative AI- verified account status (Thompson, 2022).
systems are fertile Restricted access, in combination with the
emergence of new popular digital platforms like
soil for new forms TikTok, may very well make it impossible for
misinformation research to keep up with rapid
of automated technological and social developments. Terms and
conditions can also prove to become problematic.
climate mis- and For example TikTok can require researchers to
delete data from already analyzed datasets and also
disinformation. have the right to receive a copy of the researcher's
work 30 days prior to publication (Bak-Coleman,
2023). Regulatory efforts are therefore required.
The planned implementation of the EU Digital
Service Act in 2024 is one example of legal
responses that could help ensure critical future
independent social media research (Politico, 2023,
European Commission, 2023). Other countries
should follow suit. Without secure data access for
independent research, society and current
ambitions to reform social media will indeed "fly
blind" (Bail, 2022).
Image: Canva
22
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Robertson, C. E., Pretus, C.
*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OPPT-2026-1387-0009
AFL-CIO Requests 60 Day Extension for EPA Legacy Asbestos Comment Period
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 16, 2026
Douglas Troutman
Assistant Administrator
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington D.C. 20460
Re: Docket No. EPA-HQ-OPPT-2025-0036 - Request for 60 Day Extension of Comment Period
Dear Assistant Administrator Troutman,
The American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) requests a 60-day ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 16, 2026 Douglas Troutman Assistant Administrator Office of Chemical Safety and Pollution Prevention Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington D.C. 20460 Re: Docket No. EPA-HQ-OPPT-2025-0036 - Request for 60 Day Extension of Comment Period Dear Assistant Administrator Troutman, The American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) requests a 60-dayextension of the comment period for the Environmental Protection Agency's Request for Information on Legacy Uses of Asbestos for TSCA Section 6 (a) Risk Management for Asbestos, Part 2.
Additional time is needed to ensure we can adequately represent our wide-ranging membership, especially among many federal agency deadlines regarding worker safety and health exposures in the same 45 day time frame. During the middle to the end of August, the Occupational Safety and Health Administration is holding public hearings on modifying 19 existing standards and the Nuclear Regulatory Commission has a deadline for submitting comments on modifying occupational exposures to radiation. The AFL-CIO and unions are participating in all of these rulemaking efforts simultaneously, while coordinating with summer vacations and the nature of shiftwork among our members affected by this proposal on the ground.
The AFL-CIO represents 65 national labor unions with more than 15 million working people across a broad spectrum of industries where workers continue to be exposed to asbestos during renovation, demolition, maintenance, repair, manufacturing waste-handling and other work activities involving materials containing legacy asbestos. Collecting data and information from these workers and their union representatives necessitates outreach across multiple organizations to assure the Agency obtains the most comprehensive and accurate information on exposures, existing controls, workplace practices and the impact of future risk management requirements. More time is needed for careful review and coordination across our affiliates to establish thorough and informed comments.
Providing additional time will improve both the quality and completeness of the information we can submit to the Agency and will better enable EPA to develop a scientifically supported and practical risk management rule that protects workers and their communities from asbestos exposures.
Thank you for your consideration of this important request for a 60-day extension. Please do not hesitate to reach out with any questions.
Respectfully submitted,
Rebecca L. Reindel, MS, MPH
*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OPPT-2025-0036-0005
July 16, 2026
Douglas Troutman
Assistant Administrator
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington D.C. 20460
Re: Docket No. EPA-HQ-OPPT-2025-0036 - Request for 60 Day Extension of Comment Period
Dear Assistant Administrator Troutman,
The American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) requests a 60-day ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 16, 2026 Douglas Troutman Assistant Administrator Office of Chemical Safety and Pollution Prevention Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington D.C. 20460 Re: Docket No. EPA-HQ-OPPT-2025-0036 - Request for 60 Day Extension of Comment Period Dear Assistant Administrator Troutman, The American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) requests a 60-dayextension of the comment period for the Environmental Protection Agency's Request for Information on Legacy Uses of Asbestos for TSCA Section 6 (a) Risk Management for Asbestos, Part 2.
Additional time is needed to ensure we can adequately represent our wide-ranging membership, especially among many federal agency deadlines regarding worker safety and health exposures in the same 45 day time frame. During the middle to the end of August, the Occupational Safety and Health Administration is holding public hearings on modifying 19 existing standards and the Nuclear Regulatory Commission has a deadline for submitting comments on modifying occupational exposures to radiation. The AFL-CIO and unions are participating in all of these rulemaking efforts simultaneously, while coordinating with summer vacations and the nature of shiftwork among our members affected by this proposal on the ground.
The AFL-CIO represents 65 national labor unions with more than 15 million working people across a broad spectrum of industries where workers continue to be exposed to asbestos during renovation, demolition, maintenance, repair, manufacturing waste-handling and other work activities involving materials containing legacy asbestos. Collecting data and information from these workers and their union representatives necessitates outreach across multiple organizations to assure the Agency obtains the most comprehensive and accurate information on exposures, existing controls, workplace practices and the impact of future risk management requirements. More time is needed for careful review and coordination across our affiliates to establish thorough and informed comments.
Providing additional time will improve both the quality and completeness of the information we can submit to the Agency and will better enable EPA to develop a scientifically supported and practical risk management rule that protects workers and their communities from asbestos exposures.
Thank you for your consideration of this important request for a 60-day extension. Please do not hesitate to reach out with any questions.
Respectfully submitted,
Rebecca L. Reindel, MS, MPH
*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OPPT-2025-0036-0005
Affordable Housing Advocates Call for HUD Exemption From Build America Buy America Mandate
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
855 Boylston Street, Suite 701
Boston, MA 02116
dgasson@housingadvisorygroup.org
housingadvisorygroup.org
Submission to Department of Housing and Urban Development -
Request for Information: Docket No. FR-6616-N-01
On behalf of the Housing Advisory Group, an association of affordable housing developers, state associations and practitioners founded in 1993, we would like to thank the Department of Housing and Urban Development ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. 855 Boylston Street, Suite 701 Boston, MA 02116 dgasson@housingadvisorygroup.org housingadvisorygroup.org Submission to Department of Housing and Urban Development - Request for Information: Docket No. FR-6616-N-01 On behalf of the Housing Advisory Group, an association of affordable housing developers, state associations and practitioners founded in 1993, we would like to thank the Department of Housing and Urban Developmentfor issuing this request for information related to the availability of domestically manufactured materials and products that conform to the requirements of the Build America, Buy America Act.
While we support the original goal of BABA, which was to increase and facilitate the manufacture of domestically produced materials for use in infrastructure projects, we have consistently taken exception to the decision by the previous administration to include housing, and specifically HUD housing assistance programs, under the BABA mandate. Comments and subsequent actions by Congress have demonstrated that this was not the intent of the legislation, which was focused on large scale infrastructure projects such as highways, bridges, transportations hubs, water treatment facilities and other public use and publicly assessable facilities. Housing constructed with assistance from programs at HUD are not public buildings, but instead privately owned and managed structures.
The inclusion of HUD housing assistance programs under the BABA mandate, have exposed the flaws by the previous administrations' premature rationale. That decision has exposed the following shortcomings in the program as it relates to housing production:
No central database for identifying compliant products and materials
No incentive for manufacturers to verifying BABA certifications
Costly and often fatal delays in product certification
An inefficient waiver process at HUD and OMB resulting is costly delays and loss of housing incentives.
Additional costs of compliance including adding BABA consultants to comply with product sourcing and certification
Prevention of housing production due to additional BABA related costs and excessive delays in waiver processing.
While it is apparent both HUD and OMB acknowledge there are issues with the BABA program as it relates to housing programs, evidenced by this RFI, it begs the question what can be done in the interim to encourage housing production while the BABA program is being evaluated. We would ask OMB to take the following actions:
Temporarily stay the BABA mandate for HUD housing programs until the RFI may be evaluated and programmatic changes made remedying the issues identified by the RFI.
Expedite the waiver process at HUD and OMB so that developments seeking waivers are not unduly delayed and are able to begin and complete construction in a timeframe commensurate with the deadlines attached to the housing incentives associated with the project.
Develop program-wide category-based waivers for products HUD identifies as necessary for construction but not produced domestically, not produced in adequate supply or not economically viable versus non-BABA compliant products.
Consider issuing waivers for developments where the HUD resources constitute a small portion of the funding sources.
Once the evaluation of the RFI is complete and recommendations prepared, we would suggest the following based on our experience with the program and conversations with our members that are dealing with BABA compliance:
HUD should produce a national database of BABA compliant materials and products that may be sourced in volume and economically priced compared to non-BABA compliant products.
HUD should provide general waivers for products that cannot be sourced domestically, creating greater efficiency in the waiver process and allowing for the timely construction of affordable housing.
Consider whether the public is better served by exempting HUD housing programs from the BABA mandate, taking into consideration the cost of BABA compliance (products, compliance costs, delays in construction) and how many units are sacrificed due to the added compliance cost.
We appreciate the opportunity to comment on the efficacy of the Build America, Buy America program as it relates to affordable housing production. Based on the experience of the affordable housing community, we believe President Trump's stated desire to produce more affordable housing would be best served by addressing the deficiencies in the BABA program in a timely fashion, including considering whether its application to HUD housing programs by the previous administration was a misstep that needs correcting.
Thank you,
David Gasson
Executive Director
Housing Advisory Group
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0078
855 Boylston Street, Suite 701
Boston, MA 02116
dgasson@housingadvisorygroup.org
housingadvisorygroup.org
Submission to Department of Housing and Urban Development -
Request for Information: Docket No. FR-6616-N-01
On behalf of the Housing Advisory Group, an association of affordable housing developers, state associations and practitioners founded in 1993, we would like to thank the Department of Housing and Urban Development ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. 855 Boylston Street, Suite 701 Boston, MA 02116 dgasson@housingadvisorygroup.org housingadvisorygroup.org Submission to Department of Housing and Urban Development - Request for Information: Docket No. FR-6616-N-01 On behalf of the Housing Advisory Group, an association of affordable housing developers, state associations and practitioners founded in 1993, we would like to thank the Department of Housing and Urban Developmentfor issuing this request for information related to the availability of domestically manufactured materials and products that conform to the requirements of the Build America, Buy America Act.
While we support the original goal of BABA, which was to increase and facilitate the manufacture of domestically produced materials for use in infrastructure projects, we have consistently taken exception to the decision by the previous administration to include housing, and specifically HUD housing assistance programs, under the BABA mandate. Comments and subsequent actions by Congress have demonstrated that this was not the intent of the legislation, which was focused on large scale infrastructure projects such as highways, bridges, transportations hubs, water treatment facilities and other public use and publicly assessable facilities. Housing constructed with assistance from programs at HUD are not public buildings, but instead privately owned and managed structures.
The inclusion of HUD housing assistance programs under the BABA mandate, have exposed the flaws by the previous administrations' premature rationale. That decision has exposed the following shortcomings in the program as it relates to housing production:
No central database for identifying compliant products and materials
No incentive for manufacturers to verifying BABA certifications
Costly and often fatal delays in product certification
An inefficient waiver process at HUD and OMB resulting is costly delays and loss of housing incentives.
Additional costs of compliance including adding BABA consultants to comply with product sourcing and certification
Prevention of housing production due to additional BABA related costs and excessive delays in waiver processing.
While it is apparent both HUD and OMB acknowledge there are issues with the BABA program as it relates to housing programs, evidenced by this RFI, it begs the question what can be done in the interim to encourage housing production while the BABA program is being evaluated. We would ask OMB to take the following actions:
Temporarily stay the BABA mandate for HUD housing programs until the RFI may be evaluated and programmatic changes made remedying the issues identified by the RFI.
Expedite the waiver process at HUD and OMB so that developments seeking waivers are not unduly delayed and are able to begin and complete construction in a timeframe commensurate with the deadlines attached to the housing incentives associated with the project.
Develop program-wide category-based waivers for products HUD identifies as necessary for construction but not produced domestically, not produced in adequate supply or not economically viable versus non-BABA compliant products.
Consider issuing waivers for developments where the HUD resources constitute a small portion of the funding sources.
Once the evaluation of the RFI is complete and recommendations prepared, we would suggest the following based on our experience with the program and conversations with our members that are dealing with BABA compliance:
HUD should produce a national database of BABA compliant materials and products that may be sourced in volume and economically priced compared to non-BABA compliant products.
HUD should provide general waivers for products that cannot be sourced domestically, creating greater efficiency in the waiver process and allowing for the timely construction of affordable housing.
Consider whether the public is better served by exempting HUD housing programs from the BABA mandate, taking into consideration the cost of BABA compliance (products, compliance costs, delays in construction) and how many units are sacrificed due to the added compliance cost.
We appreciate the opportunity to comment on the efficacy of the Build America, Buy America program as it relates to affordable housing production. Based on the experience of the affordable housing community, we believe President Trump's stated desire to produce more affordable housing would be best served by addressing the deficiencies in the BABA program in a timely fashion, including considering whether its application to HUD housing programs by the previous administration was a misstep that needs correcting.
Thank you,
David Gasson
Executive Director
Housing Advisory Group
*
Original text of letter here: https://www.regulations.gov/comment/HUD-2026-0826-0078
AAP Urges EPA To Maintain Strong PFAS Drinking Water Standards To Protect Children
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
AAP Headquarters July 16, 2026
345 Park Blvd
Itasca, IL 60143
Phone: 630/626-6000 The Honorable Lee Zeldin
Fax: 847/434-8000
E-mail: kidsdocs@aap.org Administrator
www.aap.org U.S. Environmental Protection Agency
Reply to 1200 Pennsylvania Ave., NW
AAP Washington Office Washington, D.C. 20460
601 13th St NW, Suite 400N
Washington, DC 20005
Phone: 202/347-8600
E-mail: kids1st@aap.org
Dear Administrator Zeldin:
President-Elect
Terri ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. AAP Headquarters July 16, 2026 345 Park Blvd Itasca, IL 60143 Phone: 630/626-6000 The Honorable Lee Zeldin Fax: 847/434-8000 E-mail: kidsdocs@aap.org Administrator www.aap.org U.S. Environmental Protection Agency Reply to 1200 Pennsylvania Ave., NW AAP Washington Office Washington, D.C. 20460 601 13th St NW, Suite 400N Washington, DC 20005 Phone: 202/347-8600 E-mail: kids1st@aap.org Dear Administrator Zeldin: President-Elect TerriD. McFadden, MD, MPH, FAAP
Immediate Past President On behalf of the American Academy of Pediatrics (AAP), a non-profit professional organization
Susan J. Kressly, MD, FAAP of more than 67,000 primary care pediatricians, pediatric medical subspecialists, and pediatric
Secretary/Treasurer surgical specialists dedicated to the health, safety, and well-being of all infants, children,
Joelle N. Simpson, MD, FAAP adolescents, and young adults, I am writing to express our opposition to the Environmental
CEO/Executive Vice President Protection Agency's (EPA) proposed rule "Rescission of Regulatory Determinations and
Mark Del Monte, JD
Removal of Related Provisions for Four PFAS Substances (PFHxS, PFNA, HFPO-DA (GenX), and
the Mixture of These Three PFAS Plus PFBS)" (docket number: EPA-HQ-OW-2025-0654) and to
urge you to rescind this proposal.
Board of Directors
District I
Patricia Flanagan, MD, FAAP The Administration has expressed its goal of addressing toxic environments that contribute to
District II chronic disease in childreni; PFAS contributes to these toxic environments and not adequately
Jeffrey Kaczorowski, MD, FAAP
addressing the harms of PFAS undercuts this goal.ii Due to ongoing concerns regarding PFAS
District III
exposure for children, the AAP urges the EPA to set the strongest possible public health-based
Lenore R. Jarvis, MD, MEd, FAAP
limits on PFAS, including maintaining and strengthening the Maximum Contaminant Level
District IV
Patricia Purcell, MD, MBA, FAAP Goals (MCLGs) for PFAS.
District V
Christopher B. Peltier, MD, FAAP PFAS and Child Health
District VI
Claudia Preuschoff, MD, FAAP
Children are not little adults, and they are susceptible to the health risks posed by PFAS
District VII
substances.iii Children and infants are exposed to PFAS through drinking water if using a
Susan Buttross, MD, FAAP
contaminated municipal water system or well water, as PFAS can contaminate 'source water'
District VIII
Greg Blaschke, MD, MPH, FAAP including surface water and ground water. iv They can also be exposed through a variety of
District IX other sources, including certain food, especially those from water like fish and seafood;
Eric H. Ball, MD, FAAP contaminated soil; food packaging; indoor dust; and other sources.v
District X
Madeline M. Joseph, MD, FAAP
PFAS are a group of persistent toxic pollutants that can accumulate in human bodies. Research
At Large has shown concerning possible links between PFAS exposure and health issues such as higher
Angela M. Ellison, MD, MSc, FAAP
cholesterol levels, decreased immune system responses, adverse effects on the liver, and
At Large elevated risk of certain cancers.vi, vii The AAP is committed to protecting children and the public
Kristina W. Rosbe, MD, FAAP
from these potential harms from PFAS, and we urge you to retain provisions that will protect
At Large children from exposure to PFAS to the extent possible. Accordingly, we urge you to rescind this
Joelle N. Simpson, MD, FAAP
proposed rule and instead move forward in implementing the EPA's 2024 PFAS National
Primary Drinking Water Regulations (NPDWR).
Furthermore, we urge EPA to continue to study PFAS from the standpoint of quantifying residual risks from
exposures below the 2024 levels and/or to PFAS that were not covered by the rule, as well as of developing
more cost-efficient and effective technologies for removing PFAS from drinking water. While there is no new
scientific information that justifies weakening the 2024 rule, EPA may in fact need to continue to strengthen
the NPDWR as we learn more about the negative health effects of PFAS.
Maximum Contaminant Levels Should be Health-Based and Science-Based
Access to clean drinking water is important for the health and well-being of children. Children drink more
water per kilogram of body weight compared to adults. For example, in general, infants aged 6 to 12 months
consume 4 times the amount of water per unit of body weight compared with the average adult.viii
Additionally, PFAS have been shown "to be transferred from mother to the developing fetus, and nursing
infants can be exposed through human milk." ix
The AAP is concerned that EPA's proposal to withdraw both the MCLG for PFAS of zero parts per trillion (ppt)
and the NPDWR that included the Maximum Contaminant Level (MCL) of 4.0 ppt will harm child health. Given
the potential health issues for children related to PFAS exposure and the particular vulnerability of children
and pregnant women, the MCLG and MCL should both be based on careful, science-based analysis to prevent
risks to health. Additionally, the same exposure to an environmental toxin, like PFAS, has differential impacts
depending upon the developmental stage of a human being. Accordingly, the thresholds must be set at the
level that is protective for children as opposed to adults since there is no way to differentially separate the
exposure of one set of the population from another.
The EPA should set an MCLG and an MCL that are health-based, accounting for the totality of evidence of
potential harm to protect public health. The AAP is concerned that this proposal underestimates the health
risks of PFAS for vulnerable populations and sets a precedent that does not adequately protect public health.
Furthermore, withdrawing regulations based only on cost, and without a health-based and science-based
justification, is deeply concerning and would set a dangerous precedent. The AAP urges the EPA to maintain a
strong MCLG and MCL for PFAS that are based on all available evidence of potential harms to protect public
health. Any concerns about costs should be resolved by EPA providing the funds that some community water
systems need in order to comply with the 2024 standards; EPA's grants to help small and disadvantaged
communities deploy PFAS removal systems need to be sustained.
Conclusion
Thank you again for providing this opportunity to comment on EPA's PFAS proposed rule and share our
concerns with this proposed rule. We welcome the opportunity to work with you to ensure that children are
protected from the harms of PFAS exposure through drinking water and other sources. If we can be of further
assistance, please contact our Washington, D.C. office at kids1st@aap.org.
Sincerely,
Andrew D. Racine, MD, PhD, FAAP
President
i The White House. Establishing the President's Make America Healthy Again Commission. February 13, 2025.
https://www.whitehouse.gov/presidential-actions/2025/02/establishing-the-presidents-make-america-healthy-again-
commission/
ii AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
iii Id.
iv AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 627-630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-
and-Polyfluoroalkyl-Substances-PFAS
v AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 627-630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-
and-Polyfluoroalkyl-Substances-PFAS
vi AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 631. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
vii Zajac L. PFAS: Limiting Children's Exposure to "Forever Chemicals". HealthyChildren.org. October 2022.
https://www.healthychildren.org/English/safety-prevention/all-around/Pages/Limiting-Childrens-Exposure-to-Forever-
Chemicals.aspx
viii AAP Council on Environmental Health. Drinking Water. Pediatric Environmental Health. 4th ed. October 2018; 281.
https://publications.aap.org/aapbooks/book/524/chapter-abstract/5808591/Drinking-Water
ix AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OW-2025-0654-0063
AAP Headquarters July 16, 2026
345 Park Blvd
Itasca, IL 60143
Phone: 630/626-6000 The Honorable Lee Zeldin
Fax: 847/434-8000
E-mail: kidsdocs@aap.org Administrator
www.aap.org U.S. Environmental Protection Agency
Reply to 1200 Pennsylvania Ave., NW
AAP Washington Office Washington, D.C. 20460
601 13th St NW, Suite 400N
Washington, DC 20005
Phone: 202/347-8600
E-mail: kids1st@aap.org
Dear Administrator Zeldin:
President-Elect
Terri ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. AAP Headquarters July 16, 2026 345 Park Blvd Itasca, IL 60143 Phone: 630/626-6000 The Honorable Lee Zeldin Fax: 847/434-8000 E-mail: kidsdocs@aap.org Administrator www.aap.org U.S. Environmental Protection Agency Reply to 1200 Pennsylvania Ave., NW AAP Washington Office Washington, D.C. 20460 601 13th St NW, Suite 400N Washington, DC 20005 Phone: 202/347-8600 E-mail: kids1st@aap.org Dear Administrator Zeldin: President-Elect TerriD. McFadden, MD, MPH, FAAP
Immediate Past President On behalf of the American Academy of Pediatrics (AAP), a non-profit professional organization
Susan J. Kressly, MD, FAAP of more than 67,000 primary care pediatricians, pediatric medical subspecialists, and pediatric
Secretary/Treasurer surgical specialists dedicated to the health, safety, and well-being of all infants, children,
Joelle N. Simpson, MD, FAAP adolescents, and young adults, I am writing to express our opposition to the Environmental
CEO/Executive Vice President Protection Agency's (EPA) proposed rule "Rescission of Regulatory Determinations and
Mark Del Monte, JD
Removal of Related Provisions for Four PFAS Substances (PFHxS, PFNA, HFPO-DA (GenX), and
the Mixture of These Three PFAS Plus PFBS)" (docket number: EPA-HQ-OW-2025-0654) and to
urge you to rescind this proposal.
Board of Directors
District I
Patricia Flanagan, MD, FAAP The Administration has expressed its goal of addressing toxic environments that contribute to
District II chronic disease in childreni; PFAS contributes to these toxic environments and not adequately
Jeffrey Kaczorowski, MD, FAAP
addressing the harms of PFAS undercuts this goal.ii Due to ongoing concerns regarding PFAS
District III
exposure for children, the AAP urges the EPA to set the strongest possible public health-based
Lenore R. Jarvis, MD, MEd, FAAP
limits on PFAS, including maintaining and strengthening the Maximum Contaminant Level
District IV
Patricia Purcell, MD, MBA, FAAP Goals (MCLGs) for PFAS.
District V
Christopher B. Peltier, MD, FAAP PFAS and Child Health
District VI
Claudia Preuschoff, MD, FAAP
Children are not little adults, and they are susceptible to the health risks posed by PFAS
District VII
substances.iii Children and infants are exposed to PFAS through drinking water if using a
Susan Buttross, MD, FAAP
contaminated municipal water system or well water, as PFAS can contaminate 'source water'
District VIII
Greg Blaschke, MD, MPH, FAAP including surface water and ground water. iv They can also be exposed through a variety of
District IX other sources, including certain food, especially those from water like fish and seafood;
Eric H. Ball, MD, FAAP contaminated soil; food packaging; indoor dust; and other sources.v
District X
Madeline M. Joseph, MD, FAAP
PFAS are a group of persistent toxic pollutants that can accumulate in human bodies. Research
At Large has shown concerning possible links between PFAS exposure and health issues such as higher
Angela M. Ellison, MD, MSc, FAAP
cholesterol levels, decreased immune system responses, adverse effects on the liver, and
At Large elevated risk of certain cancers.vi, vii The AAP is committed to protecting children and the public
Kristina W. Rosbe, MD, FAAP
from these potential harms from PFAS, and we urge you to retain provisions that will protect
At Large children from exposure to PFAS to the extent possible. Accordingly, we urge you to rescind this
Joelle N. Simpson, MD, FAAP
proposed rule and instead move forward in implementing the EPA's 2024 PFAS National
Primary Drinking Water Regulations (NPDWR).
Furthermore, we urge EPA to continue to study PFAS from the standpoint of quantifying residual risks from
exposures below the 2024 levels and/or to PFAS that were not covered by the rule, as well as of developing
more cost-efficient and effective technologies for removing PFAS from drinking water. While there is no new
scientific information that justifies weakening the 2024 rule, EPA may in fact need to continue to strengthen
the NPDWR as we learn more about the negative health effects of PFAS.
Maximum Contaminant Levels Should be Health-Based and Science-Based
Access to clean drinking water is important for the health and well-being of children. Children drink more
water per kilogram of body weight compared to adults. For example, in general, infants aged 6 to 12 months
consume 4 times the amount of water per unit of body weight compared with the average adult.viii
Additionally, PFAS have been shown "to be transferred from mother to the developing fetus, and nursing
infants can be exposed through human milk." ix
The AAP is concerned that EPA's proposal to withdraw both the MCLG for PFAS of zero parts per trillion (ppt)
and the NPDWR that included the Maximum Contaminant Level (MCL) of 4.0 ppt will harm child health. Given
the potential health issues for children related to PFAS exposure and the particular vulnerability of children
and pregnant women, the MCLG and MCL should both be based on careful, science-based analysis to prevent
risks to health. Additionally, the same exposure to an environmental toxin, like PFAS, has differential impacts
depending upon the developmental stage of a human being. Accordingly, the thresholds must be set at the
level that is protective for children as opposed to adults since there is no way to differentially separate the
exposure of one set of the population from another.
The EPA should set an MCLG and an MCL that are health-based, accounting for the totality of evidence of
potential harm to protect public health. The AAP is concerned that this proposal underestimates the health
risks of PFAS for vulnerable populations and sets a precedent that does not adequately protect public health.
Furthermore, withdrawing regulations based only on cost, and without a health-based and science-based
justification, is deeply concerning and would set a dangerous precedent. The AAP urges the EPA to maintain a
strong MCLG and MCL for PFAS that are based on all available evidence of potential harms to protect public
health. Any concerns about costs should be resolved by EPA providing the funds that some community water
systems need in order to comply with the 2024 standards; EPA's grants to help small and disadvantaged
communities deploy PFAS removal systems need to be sustained.
Conclusion
Thank you again for providing this opportunity to comment on EPA's PFAS proposed rule and share our
concerns with this proposed rule. We welcome the opportunity to work with you to ensure that children are
protected from the harms of PFAS exposure through drinking water and other sources. If we can be of further
assistance, please contact our Washington, D.C. office at kids1st@aap.org.
Sincerely,
Andrew D. Racine, MD, PhD, FAAP
President
i The White House. Establishing the President's Make America Healthy Again Commission. February 13, 2025.
https://www.whitehouse.gov/presidential-actions/2025/02/establishing-the-presidents-make-america-healthy-again-
commission/
ii AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
iii Id.
iv AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 627-630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-
and-Polyfluoroalkyl-Substances-PFAS
v AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 627-630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-
and-Polyfluoroalkyl-Substances-PFAS
vi AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 631. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
vii Zajac L. PFAS: Limiting Children's Exposure to "Forever Chemicals". HealthyChildren.org. October 2022.
https://www.healthychildren.org/English/safety-prevention/all-around/Pages/Limiting-Childrens-Exposure-to-Forever-
Chemicals.aspx
viii AAP Council on Environmental Health. Drinking Water. Pediatric Environmental Health. 4th ed. October 2018; 281.
https://publications.aap.org/aapbooks/book/524/chapter-abstract/5808591/Drinking-Water
ix AAP Council on Environmental Health. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Pediatric Environmental
Health. 4th ed. October 2018; 630. https://publications.aap.org/aapbooks/book/524/chapter/5808636/Perfluoroalkyl-and-
Polyfluoroalkyl-Substances-PFAS
*
Original text of letter here: https://www.regulations.gov/comment/EPA-HQ-OW-2025-0654-0063
4 Trade Associations Urge NCUA to Coordinate Stablecoin Rules With Other Regulators to Ensure Consistency and Protect Financial Stability
Carter Struck
WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site.
July 17, 2026
Via Electronic Submission
Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, Virginia 22314-3428
Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (RIN 3133-AG10)
To Whom it May Concern:
The ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 17, 2026 Via Electronic Submission Melane Conyers-Ausbrooks Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, Virginia 22314-3428 Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (RIN 3133-AG10) To Whom it May Concern: Theundersigned trade associations (the "Associations")1 appreciate the opportunity to comment on the notice of proposed rulemaking issued by the National Credit Union Administration regarding the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act.2 We also appreciate the NCUA's careful consideration of the regulations that it is required to issue under the GENIUS Act, particularly given the numerous significant policy questions that implementation of the GENIUS Act raises.
The proposal addresses a broad range of prudential and risk management
requirements for permitted payment stablecoin issuers ("PPSIs") within the NCUA's remit, including
governance, reserve management, operational resilience, compliance risk management, and Bank
Secrecy Act/anti-money laundering and sanctions compliance. The way in which the GENIUS Act is
implemented, and the prudential and compliance requirements that will apply to payment stablecoin
issuers, could have significant effects on financial stability, credit creation, consumer protection, illicit
finance risk, and the broader economy. Changes and clarifications to the proposed rule are important to
help to ensure the GENIUS Act is implemented in a manner that, as Congress envisioned, appropriately
balances the benefits and innovative potential of payment stablecoins with the broader economic,
consumer protection, and illicit finance risks that these instruments may pose.
To that end, the Associations urge the NCUA to coordinate closely with the Board of Governors
of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit
Insurance Corporation to ensure that requirements for PPSIs are substantially similar and appropriately
rigorous across the primary Federal payment stablecoin regulators. The OCC and FDIC have issued
1 Please see Annex A for a description of the Associations.
2 NCUA, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of
Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration, Notice of Proposed
Rulemaking, 91 Fed. Reg. 28956 (May 18, 2026).
proposed rules to implement the requirements for PPSIs within their respective remits (and the
comment periods for these proposals have now closed), while the Board has not yet issued its related
proposal.3 Such coordination is not only required by the GENIUS Act,4 it is also critical to ensure that the
PPSI regulatory framework does not create an unlevel playing field or opportunities for regulatory
arbitrage, unintended policy consequences, or unworkable or incongruous requirements. The primary
Federal payment stablecoin regulators therefore should repropose for comment any aspects of their
respective proposals that are inconsistent or in conflict with one another to ensure that the
comprehensive regulatory framework implementing the GENIUS Act is appropriately robust, transparent,
and consistent across the various agencies with rule-writing authority under the statute.
The primary Federal payment stablecoin regulators also should coordinate with the Treasury
Department and state payment stablecoin regulators to create a robust regulatory framework that
provides a level playing field for all types of payment stablecoin issuers, appropriately balances
promoting innovation with preserving safety and soundness and financial stability, protects against illicit
finance, and explicitly discourages regulatory arbitrage. For example, the Financial Crimes Enforcement
Network and Office of Foreign Assets Control have issued proposed regulations addressing PPSI
compliance obligations under the BSA and U.S. sanctions laws, which further underscores the need for
close interagency coordination and a holistic implementation framework. Further, the NCUA and other
primary Federal payment stablecoin regulators should clarify the application of federal consumer
protection requirements to payment stablecoins, payment stablecoin transactions, and PPSIs, and should
ensure that PPSIs are examined for compliance with applicable consumer protection laws.
In addition, the primary Federal payment stablecoin regulators should coordinate their
rulemakings in terms of process in addition to substantive requirements for PPSIs. We have requested
an extension of the comment period for various other proposals to implement the GENIUS Act, which
have compressed 60-day comment periods and varying comment deadlines.5 The rulemakings to
implement the GENIUS Act represent an interrelated body of regulatory work of extraordinary scope and
complexity, implementing a wholly new statute that is the first federal legislation governing payment
stablecoins. A fragmented comment process with staggered deadlines across (at least) six
interdependent proposals issued by (at least) five different agencies (i) undermines the agencies' own
stated goal of ensuring regulatory consistency across the GENIUS Act implementation framework; (ii)
3 Many of the Associations have separately responded to the OCC and FDIC proposals. Our recommendations in
those letters apply equally to the NCUA's proposal in many respects. We therefore encourage the NCUA to adopt
our recommendations on those topics as appropriate. See responses to Implementing the GENIUS Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of the OCC (OCC Docket ID OCC-2025-0372; March 2,
2026) by BPI, CBA, and the Financial Services Forum, https://bpi.com/joint-trades-comment-on-occ-genius-act-
implementation/; ABA, https://www.aba.com/advocacy/policy-analysis/genius-act-implementation-letter; and
ICBA, https://www.icba.org/w/icba-comment-letter-occ-genius-implementation-npr-5.1.26-. See also responses to
GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured
Depository Institutions (RIN 3064-AG19; April 10, 2026) by BPI and CBA, https://bpi.com/bpi-and-cba-comment-
on-fdic-stablecoin-rule-under-genius-act/; ABA, https://www.aba.com/advocacy/policy-analysis/letter-to-the-fdic-
on-genius-act-requirements-and-standards; and ICBA, https://www.icba.org/w/icba-comment-letter-on-proposed-
rulemaking-to-implement-genius-act-requirements.
4 12 U.S.C. Sec. 5903(h)(2).
5 See ABA, BPI, CBA and ICBA, Joint Letter Regarding Request for Extension of Comment Period,
https://www.fdic.gov/federal-register-publications/american-bankers-association-aba-and-3-other-trade-
associations-kaye.2
prevents the public from adequately evaluating the proposals individually or holistically; and (iii) raises
questions about whether the agencies have adequately coordinated in promulgating these rules, as
required by section 4(h)(2), and encouraged by section 13(b), of the GENIUS Act.6
If you have any questions, please contact Drew Ruben at drew.ruben@bpi.com.
* * *
Sincerely,
American Bankers Association
Consumer Bankers Association
Bank Policy Institute
Independent Community Bankers of America
* * *
Annex A
American Bankers Association: The American Bankers Association is the voice of the nation's $25 trillion
banking industry, which is composed of small, regional and large banks that together employ
approximately 2.1 million people, safeguard $19.7 trillion in deposits and extend $13.1 trillion in loans.
The Bank Policy Institute: The Bank Policy Institute is a nonpartisan public policy, research and advocacy
group that represents universal banks, regional banks, and the major foreign banks doing business in the
United States. BPI produces academic research and analysis on regulatory and monetary policy topics,
analyzes and comments on proposed regulations, and represents the financial services industry with
respect to cybersecurity, fraud, and other information security issues.
Consumer Bankers Association: The Consumer Bankers Association is a member-driven trade association,
and the only national financial trade group focused exclusively on retail banking-banking services
geared toward consumers and small businesses. As the recognized voice on retail banking issues, CBA
provides leadership, education, research, and federal representation for its members. CBA members
operate in all 50 states. They include the nation's largest bank holding companies as well as regional and
super-community banks. Eighty-three percent of CBA's members are financial institutions holding more
than $10 billion in assets.
Independent Community Bankers of America: The Independent Community Bankers of America(R) has
one mission: to create and promote an environment where community banks flourish. We power the
potential of the nation's community banks through effective advocacy, education, and innovation. As
local and trusted sources of credit, America's community banks leverage their relationship-based
business model and innovation offerings to channel deposits into the neighborhoods they serve, creating
jobs, fostering economic prosperity, and fueling their customers' financial goals and dreams. For more information, visit ICBA's website at icba.org.
*
Organization Name: Bank Policy Institute
Category: Trade association
*
Original text of letter here: https://www.regulations.gov/comment/NCUA-2026-1024-0019
July 17, 2026
Via Electronic Submission
Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, Virginia 22314-3428
Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (RIN 3133-AG10)
To Whom it May Concern:
The ... Show Full Article WASHINGTON, July 21 -- In response to a federal agency request for information, the following public comment letter was submitted electronically to the regulations.gov site. July 17, 2026 Via Electronic Submission Melane Conyers-Ausbrooks Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, Virginia 22314-3428 Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration (RIN 3133-AG10) To Whom it May Concern: Theundersigned trade associations (the "Associations")1 appreciate the opportunity to comment on the notice of proposed rulemaking issued by the National Credit Union Administration regarding the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act.2 We also appreciate the NCUA's careful consideration of the regulations that it is required to issue under the GENIUS Act, particularly given the numerous significant policy questions that implementation of the GENIUS Act raises.
The proposal addresses a broad range of prudential and risk management
requirements for permitted payment stablecoin issuers ("PPSIs") within the NCUA's remit, including
governance, reserve management, operational resilience, compliance risk management, and Bank
Secrecy Act/anti-money laundering and sanctions compliance. The way in which the GENIUS Act is
implemented, and the prudential and compliance requirements that will apply to payment stablecoin
issuers, could have significant effects on financial stability, credit creation, consumer protection, illicit
finance risk, and the broader economy. Changes and clarifications to the proposed rule are important to
help to ensure the GENIUS Act is implemented in a manner that, as Congress envisioned, appropriately
balances the benefits and innovative potential of payment stablecoins with the broader economic,
consumer protection, and illicit finance risks that these instruments may pose.
To that end, the Associations urge the NCUA to coordinate closely with the Board of Governors
of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit
Insurance Corporation to ensure that requirements for PPSIs are substantially similar and appropriately
rigorous across the primary Federal payment stablecoin regulators. The OCC and FDIC have issued
1 Please see Annex A for a description of the Associations.
2 NCUA, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of
Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration, Notice of Proposed
Rulemaking, 91 Fed. Reg. 28956 (May 18, 2026).
proposed rules to implement the requirements for PPSIs within their respective remits (and the
comment periods for these proposals have now closed), while the Board has not yet issued its related
proposal.3 Such coordination is not only required by the GENIUS Act,4 it is also critical to ensure that the
PPSI regulatory framework does not create an unlevel playing field or opportunities for regulatory
arbitrage, unintended policy consequences, or unworkable or incongruous requirements. The primary
Federal payment stablecoin regulators therefore should repropose for comment any aspects of their
respective proposals that are inconsistent or in conflict with one another to ensure that the
comprehensive regulatory framework implementing the GENIUS Act is appropriately robust, transparent,
and consistent across the various agencies with rule-writing authority under the statute.
The primary Federal payment stablecoin regulators also should coordinate with the Treasury
Department and state payment stablecoin regulators to create a robust regulatory framework that
provides a level playing field for all types of payment stablecoin issuers, appropriately balances
promoting innovation with preserving safety and soundness and financial stability, protects against illicit
finance, and explicitly discourages regulatory arbitrage. For example, the Financial Crimes Enforcement
Network and Office of Foreign Assets Control have issued proposed regulations addressing PPSI
compliance obligations under the BSA and U.S. sanctions laws, which further underscores the need for
close interagency coordination and a holistic implementation framework. Further, the NCUA and other
primary Federal payment stablecoin regulators should clarify the application of federal consumer
protection requirements to payment stablecoins, payment stablecoin transactions, and PPSIs, and should
ensure that PPSIs are examined for compliance with applicable consumer protection laws.
In addition, the primary Federal payment stablecoin regulators should coordinate their
rulemakings in terms of process in addition to substantive requirements for PPSIs. We have requested
an extension of the comment period for various other proposals to implement the GENIUS Act, which
have compressed 60-day comment periods and varying comment deadlines.5 The rulemakings to
implement the GENIUS Act represent an interrelated body of regulatory work of extraordinary scope and
complexity, implementing a wholly new statute that is the first federal legislation governing payment
stablecoins. A fragmented comment process with staggered deadlines across (at least) six
interdependent proposals issued by (at least) five different agencies (i) undermines the agencies' own
stated goal of ensuring regulatory consistency across the GENIUS Act implementation framework; (ii)
3 Many of the Associations have separately responded to the OCC and FDIC proposals. Our recommendations in
those letters apply equally to the NCUA's proposal in many respects. We therefore encourage the NCUA to adopt
our recommendations on those topics as appropriate. See responses to Implementing the GENIUS Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of the OCC (OCC Docket ID OCC-2025-0372; March 2,
2026) by BPI, CBA, and the Financial Services Forum, https://bpi.com/joint-trades-comment-on-occ-genius-act-
implementation/; ABA, https://www.aba.com/advocacy/policy-analysis/genius-act-implementation-letter; and
ICBA, https://www.icba.org/w/icba-comment-letter-occ-genius-implementation-npr-5.1.26-. See also responses to
GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured
Depository Institutions (RIN 3064-AG19; April 10, 2026) by BPI and CBA, https://bpi.com/bpi-and-cba-comment-
on-fdic-stablecoin-rule-under-genius-act/; ABA, https://www.aba.com/advocacy/policy-analysis/letter-to-the-fdic-
on-genius-act-requirements-and-standards; and ICBA, https://www.icba.org/w/icba-comment-letter-on-proposed-
rulemaking-to-implement-genius-act-requirements.
4 12 U.S.C. Sec. 5903(h)(2).
5 See ABA, BPI, CBA and ICBA, Joint Letter Regarding Request for Extension of Comment Period,
https://www.fdic.gov/federal-register-publications/american-bankers-association-aba-and-3-other-trade-
associations-kaye.2
prevents the public from adequately evaluating the proposals individually or holistically; and (iii) raises
questions about whether the agencies have adequately coordinated in promulgating these rules, as
required by section 4(h)(2), and encouraged by section 13(b), of the GENIUS Act.6
If you have any questions, please contact Drew Ruben at drew.ruben@bpi.com.
* * *
Sincerely,
American Bankers Association
Consumer Bankers Association
Bank Policy Institute
Independent Community Bankers of America
* * *
Annex A
American Bankers Association: The American Bankers Association is the voice of the nation's $25 trillion
banking industry, which is composed of small, regional and large banks that together employ
approximately 2.1 million people, safeguard $19.7 trillion in deposits and extend $13.1 trillion in loans.
The Bank Policy Institute: The Bank Policy Institute is a nonpartisan public policy, research and advocacy
group that represents universal banks, regional banks, and the major foreign banks doing business in the
United States. BPI produces academic research and analysis on regulatory and monetary policy topics,
analyzes and comments on proposed regulations, and represents the financial services industry with
respect to cybersecurity, fraud, and other information security issues.
Consumer Bankers Association: The Consumer Bankers Association is a member-driven trade association,
and the only national financial trade group focused exclusively on retail banking-banking services
geared toward consumers and small businesses. As the recognized voice on retail banking issues, CBA
provides leadership, education, research, and federal representation for its members. CBA members
operate in all 50 states. They include the nation's largest bank holding companies as well as regional and
super-community banks. Eighty-three percent of CBA's members are financial institutions holding more
than $10 billion in assets.
Independent Community Bankers of America: The Independent Community Bankers of America(R) has
one mission: to create and promote an environment where community banks flourish. We power the
potential of the nation's community banks through effective advocacy, education, and innovation. As
local and trusted sources of credit, America's community banks leverage their relationship-based
business model and innovation offerings to channel deposits into the neighborhoods they serve, creating
jobs, fostering economic prosperity, and fueling their customers' financial goals and dreams. For more information, visit ICBA's website at icba.org.
*
Organization Name: Bank Policy Institute
Category: Trade association
*
Original text of letter here: https://www.regulations.gov/comment/NCUA-2026-1024-0019