by NCLA | Dec 21, 2019 | Kara Rollins, Uncategorized
The New Civil Liberties Alliance (NCLA) submits the following commentary in response to the Department of Energy’s (DOE) request for comment on NCLA’s August 2, 2019 petition for rulemaking. See Regulations Prohibiting Issuance, Reliance,or Defense of Improper Agency...
by nclaadmin | Nov 6, 2019 | Michael P. DeGrandis, Uncategorized
Re: FCC 19-86, EB Docket No. 19-214: Procedural Streamlining of Administrative Hearings Document No. 2019-20568 In NCLA’s view, The Streamlining Rule proposes to convert live-testimony hearings into written-record proceedings. Such a conversion would fundamentally...
by nclaadmin | Oct 21, 2019 | Caleb Kruckenberg, Uncategorized
Re: Revisions to Safety Standard for Infant Bath Seats, Docket Number CPSC-2009-0064In NCLA’s view, the Proposed Rule continues an odious trend of incorporating private standards into the law only by reference, thereby hiding the binding law behind a paywall. The...
by nclaadmin | Oct 21, 2019 | Harriet Hageman, Uncategorized
Re: Updating Regulations on Water Quality CertificationDocket ID No.: EPA-HQ-OW-2019-0405NCLA commends EPA’s efforts to provide more certainty and stability in relation to implementing Section 401 of the Clean Water Act. While NCLA appreciates the importance of state...
by nclaadmin | Sep 3, 2019 | Michael P. DeGrandis, Uncategorized
Re: I.D. No. EDU-27-19-00010-P: Substantially Equivalent Instruction for Nonpublic School StudentsIn NCLA’s view, the Department must withdraw the Substantial Equivalency Rule because it violates the New York State and United States Constitutions in at least two...
by nclaadmin | Aug 13, 2019 | Harriet Hageman, Uncategorized
Re: Nondiscrimination in Health and Health Education Programs or Activities, Docket No.: HHS-OCR-2019-0007According to the Executive Summary published in the Federal Register related to the Proposed Rule, “Section 1557 of the Patient Protection and Affordable Care Act...
