Public Comments

Strategy and analysis consulting
in regulation, risk, economics, and information quality

Public Comments

Administrative Conference of the United States

Comments on The Paperwork Reduction Act: Research on Current Practices and Recommendations for Reform (Draft Report to the Committee on Administration and Management), by Stuart Shapiro, March 20, 2012
Comments on Midnight Rules Report Outline (Committee on Rulemaking), by Jack M. Beermann, November 10, 2011
Comments on Regulatory Analysis Requirements Draft Outline (Committee on Rulemaking), by Curtis W. Copeland, November 9, 2011
Letter to Chairman Paul Verkuil Regarding ACUS Public Participation Policies and Procedures, November 9, 2011 [RESPONSE]

California Department of Public Health

California Environmental Protection Agency

Comments on January 3, 2013 draft California Communities Environmental Health Screening Tool (CalEnviroScreen), February 1, 2013
Comments on July 30, 2012 draft California Communities Environmental Health Screening Tool (CalEnviroScreen), October 16, 2012
Comments on July 30, 2012 draft California Communities Environmental Health Screening Tool (CalEnviroScreen), OEHHA Academic Workshop slides, September 7, 2012
Green Chemistry: Cornerstone to a Sustainable California: A Critical Analytic Review, February 28, 2008

California State Water Resources Control Board

Independent Review of California State Water Quality Control Board Regulatory Impact Analysis for the Proposed 1,2,3-Trichloropropane
Primary Drinking Water Standard, April 20, 2017

U.S. Department of Agriculture

Public Interest Comment on the Food Safety and Inspection Service’s Proposed Rule: Egg Products Inspection Regulations. George Washington University Regulatory Studies Center, June 12, 2018

U.S. Department of Homeland Security

Comments on DHS’ Safe-Harbor Interim Regulatory Flexibility Analysis, April 18, 2008

U.S. Environmental Protection Agency

Comments on National Primary Drinking Water Regulations: Proposed Lead and Copper Rule Revisions; Notice of Proposed Rulemaking (NPRM, Docket ID No.EPA-HQ-OW-2017-0300), George Washington University Regulatory Studies Center, January 12.
Comments on Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process (ANPRM; Docket ID No. EPA–HQ–OA–2018–0107), August 13, 2018
Second Comments on Assessment Factors for Evaluating the Quality of Information from External Sources (9/6/02 external review draft, Docket ID OEI-10014), September 27, 2002
First Comments on Assessment Factors for Evaluating the Quality of Information from External Sources (9/6/02 external review draft, Docket ID OEI-10014), September 19, 2002

U.S. National Toxicology Program

Comments on Proposed Revisions to the Process for the 13th Report on Carcinogens, November 30, 2011

U.S. Nuclear Regulatory Commission

Comments on Cost-Benefit Analysis in the NRC’s Draft EIS (DEIS) for the Holtec Int’l CISF (NUREG-2237), September 17, 2020

U.S. Office of Management and Budget

Comment on Interim Guidance Implementing Section 2 of the Executive Order of January 30, 2017, Titled “Reducing Regulation and Controlling Regulatory Costs" [EO 13711], February 10, 2017
Comment on ICR Reference No. 201306-2070-003 ("Addendum for the Second List of Chemicals; Tier 1 Screening of Certain Chemicals Under the Endocrine Disruptor Screening Program (EDSP); EPA ICR No. 2488.01, OMB Control No. 2070-[new] — “Tier 1 List 2 ICR"), August 1, 2013
Comment #2 on ICR Reference No. 201305-0651-002 ("Grace Period Study"), June 12, 2013
Comment #1 on ICR Reference No. 201305-0651-002 ("Grace Period Study"), June 5, 2013
Comments on ICR 0651-0031 (“Patent Processing (Updating)”), March 29, 2013
Letter to Jeffrey Zients, Eight Recently Proposed U.S. Patent and Trademark Office Regulations Misclassified by OMB as Merely “Significant”. June 26, 2012
Comments on Improving Implementation of the Paperwork Reduction Act, December 28, 2009
An Analysis of EPA’s Information Collection Request Seeking OMB Approval to Impose Mandatory Tier 1 Assay Testing in Support of the Endocrine Disruptor Screening Program, May 21, 2009
Comments on Proposed Revisions to Executive Order 12,866, March 16, 2009

Comments on U.S. Patent and Trademark Office, "Information Collection Request (ICR) 0651-00xx [renumbered as 0651-0063] Information Collections and Burden Estimates", November 17, 2008
Comments on U.S. Patent and Trademark Office, "Examination of Patent Applications That Include Claims Containing Alternative Language," RIN 0651-AC00, October 30, 2008
Comments on U.S. Patent and Trademark Office, "Examination of Patent Applications That Include Claims Containing Alternative Language," RIN 0651-AC00, October 16, 2008
Comments on U.S. Patent and Trademark Office, "ICR 0651-00xx [renumbered as 0651-0063]", October 14, 2008
"Cost of Complying with the U.S Patent and Trademark Office's Proposed IDS Rule," October 18, 2007
Comments on U.S. Patent and Trademark Office, Information Collection Request (ICR) 0651-00xx, October 14, 2008
Letter to Susan E. Dudley, Administrator of the Office of Information and Regulatory Affairs, RE: U.S. Patent and Trademark Office ICR 0651-0032, January 16, 2008
Letter to Susan E. Dudley, RE: Follow-up to October 18, 2007 Meeting Regarding U.S. Patent and Trademark Office Draft Regulation on Information Disclosure Statements, October 26, 2007
Comments on Proposed Bulletin for Good Guidance Practices, January 9, 2006
Letter to John D. Graham, Follow-up Comments to OMB on OMB’s Revised Draft Bulletin on Peer Review (CDC's exaggeration of the mortality from obesity), December 16, 2004
Comments on Office of Management and Budget's Revised Information Quality Bulletin on Peer Review, May 28, 2004
Comments on Office of Management and Budget Proposed Information Quality Bulletin on Peer Review, December 15, 2003
Comments on 2003 Draft Report to Congress on the Benefits and Costs of Federal Regulation and Proposed Revision to OMB's Regulatory Impact Analysis Guidelines, April 30, 2003
Comments on 2002 Draft Report to Congress on the Benefits and Costs of Federal Regulation, May 27, 2002

U.S. Patent and Trademark Office

Second Comment and Second Information Quality Act Information Collection Request on U.S. Patent and Trademark Office, Patent Processing (Updating) [ICR 0651-0031]; Proposed collection; comment request, 77 Fed. Reg. 16813, May 27, 2012
Comment and Information Quality Act Information Collection Request on U.S. Patent and Trademark Office, Patent Processing (Updating) [ICR 0651-0031]; Proposed collection; comment request, 77 Fed. Reg. 16813, May 21, 2012
Comments on U.S. Patent and Trademark Office, (1) Rules of Practice for Trials Before the Patent Trial and Appeal Board and Judicial Review of Patent Trial and Appeal Board Decisions, 77 Fed. Reg. 6879; and (2) Practice Guide for Proposed Trial Rules, 77 Fed. Reg. 6868, April 9, 2012
Comments on U.S. Patent and Trademark Office, Preliminary Plan for Retrospective Analysis of Existing Rules (Docket No. PTO–C–2011–0, 76 Fed. Reg. 39796), September 6, 2011
Comments on “Improving Regulation and Regulatory Review; Request for information” (76 Fed. Reg. 15891), April 14, 2011
Comments on U.S. Patent and Trademark Office, Rules of Practice Before the Board of Patent Appeals and Interferences in Ex Parte Appeals and Error Correction Request Submitted Pursuant to USPTO's Information Quality Guidelines and Error Correction Request Submitted Pursuant to USPTO's Information Quality Guidelines, Notice of Proposed Rulemaking, 75 Fed. Reg. 69828, January 14, 2011
Comments on U.S. Patent and Trademark Office, Proposed Changes to Restriction Practice in Patent Applications, 75 Fed. Reg. 33584, June 14, 2010
Comments on U.S. Patent and Trademark Office, Methodology for Conducting an Independent Study of the Burden of Patent‐Related Paperwork, 75 Fed. Reg. 8649, April 12, 2010
Comments on U.S. Patent and Trademark Office, Rules of Practice in Ex Parte Appeals Before the Board of Patent Appeals and Interferences in Ex Parte Appeals, Advanced Notice of Proposed Rule Making, 74 Fed. Reg. 67987, February 25, 2010
Request to Extend the Public Comment Period on U.S. Patent and Trademark Office, Rules of Practice Before the Board of Patent Appeals and Interferences in Ex Parte Appeals; Request for Comments on Potential Modifications to Final Rule and Notice of Roundtable During Comment Period, 74 Fed. Reg. 67987, January 8, 2010