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On Mondays, Rogan’s List features a listing of proposed rule and regulation changes that are currently accepting public comment.  Commenting is the way to show government agencies how we feel about these proposed changes. Our comments also become part of a record that will be reviewed by courts if and when a reg change is contested. Courts use comments to judge whether an agency is acting arbitrarily and capriciously.

Comments and actions week ending


Closing Soon
Section I - ICE, DHS, DOL, NLRB
Section II - everything environmental - EPA, BLM, DOE
Section III - Civil rights, housing, education, healthcare


1.      Comments due 9/9/2019. USCIS Tip Form on immigrants who are possibly using benefits/services. "The USCIS Tip Form will facilitate the collection of information from the public regarding credible and relevant claims of immigration benefit fraud impacting both open adjudications as well as previously approved benefit requests where the benefit remains valid." Basically asking Americans to become informers for ICE. Read it and comment here;\

2.      Comments due September 9, 2019. Request for Information: Concerning Commercial Motor Vehicle Driver Detention Times During Loading and Unloading Truckers are weighing in - the comments are interesting. Read more about it here: “The request for information comes after a 2018 report found that detention time is costing individual             truck drivers thousands of dollars each year-- and increasing crashes.”

3.      Comments due Sept. 16, 2019. 2019-07-16 Energy Conservation Program: Energy Conservation Standards for Dishwashers, Grant of Petition for Rulemaking; Proposed rule. . Creates “a new class of less efficient dishwashers – the latest in DOE’s series of energy efficiency rollbacks” -

4.     Comments due September 9, 2019. 2019-07-11 “Energy Conservation Program for Appliance Standards: Energy Conservation Standards for Residential Furnaces and Commercial Water Heaters.”  Will reduce or eliminate energy-efficiency standards. Read more here:

5.     Comments due Sept. 21, 2o19. Port Access Route Study: Alaskan Arctic Coast  Read this comment from Audubon Society and Ocean Conservancy, among other organizations:

7.      Closing Sept. 23, 2019. Notice. Hazardous Materials: Washington Crude Oil By Rail-Vapor Pressure Requirement. This deals with a transporting Bakken heavy crude oil through Washington State, which protested. Montana and North Dakota are suing to allow transport of the extremely volatile crude. Comment here: Read an instructive comment here from a Washington resident:

8.      Comments due Sept. 15, 2019. Proposed Rule. Implementing Legal Requirements Regarding the Equal Opportunity Clause's Religious Exemption.  Allows Federal contractors to discriminator on religious grounds. Read it and comment here: Read about it here:

9.      Comments due 9/18/2019. Debt collection practices. . “The breadth of the planned rulemaking, however, could fundamentally change how third-party debt collectors, first-party creditors collecting consumer debts, debt buyers, and vendors providing material assistance to collectors (such as payment system or technology providers) collect mortgage, credit card, student loan, auto, medical, and other consumer debt.”

10. Comments due 9/22/2019. “Financial Responsibility Requirements Under CERCLA Section 108(b) for Facilities in the Electric Power Generation, Transmission, and Distribution Industry. “ EPA proposes not holding electric power generating companies financially responsible. Could impact fiscal responsibility in events like the California wildfires - several attributed to power company transmission lines. Read it and comment here: . Read preliminary report here:

12.   Comments due Sept 16, 2019. Massive changes to Long-term care facilities proposed. Not much comment yet, just this:

13.   Comments due Sept 26, 2019. Major changes to Medicare Part B payments including a tiered fee schedule. “Medicare Program: CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; etc.” Read it and comment here: and read about it here: CMS fee schedule here:

Closing Soon

1.      New beta site - is easier to read.

2.      9/6/2019 EPA and DOJ threaten California Air Resources Board and automakers for auto-emissions standard, politicizing EPA and DOJ in anti-environment move. EPA letter to CA: › documents › epa.dot_puts_california_on_notice.pdf and DOJ story here: “California officials, who have repeatedly asserted the state’s rights under the 1970 Clean Air Act, criticized the inquiry as politicization to impose the Republican president’s policies.”

3.     To be published 9/9/2019. Removal of 30-Day Processing Provision for Asylum Applicant-Related Form I-765 Employment Authorization Applications USCIS will issue a proposed rule Monday that would eliminate a requirement to process initial work permit applications by asylum seekers within 30 days.  Read about it here:

4.      To be published 9/10/2019. Dark money allowed to be hidden in new proposed rule.  IRS proposes regulations allowing tax-exempt groups to keep donor identities secret .The proposed regulations are likely to generate comments critical of political groups using tax-exempt entities for fundraising without disclosing the identities of their donors, effectively using so-called "dark money" to finance their causes and preferred candidates. The rules would also apply to groups such as the National Rifle Association, labor unions and trade associations. and

5.     Comments due 11/4/2019. Relaxing energy-efficiency standards. Energy Conservation Program: Energy Conservation Standards for General Service Incandescent Lamps  Read it and comment here: and read about it here:

6.     Posted 8/30/2019 Notice. Land Management Plan: Chugach National Forest; Alaska - opens up national forest to roads -This national forest is "a truly wild and roadless landscape that also includes the highest concentration of tidewater glaciers in North America, this area deserves the highest level of permanent protection in the new forest plan. Alternative D recommends full Wilderness designation for 97% of the Nellie Juan-College Fjord WSA!" - information that can be used in commenting following the instructions below can be found at Comment at or or

7.     8/30/2019 Notice. Agency Information Collection Activities; Revision of a Currently Approved Collection: Immigration Bond - connected to public charge rule - “Form No. I-352, Immigration Bond, has not been substantively revised since 2008. Changes to the form are now necessary because U.S. Citizenship and Immigration Services (USCIS) intends to issue a different form for public charge bonds and Form I-352 will no longer be used for that type of bond."

8.      Posted 8/26/2019. Rule, but allows comments, sweeping changes to immigration review system. “ and “In an unprecedented attempt at agency overreach to dismantle the Immigration Court, the Department of Justice, Executive Office for Immigration Review (EOIR) today published a new interim rule, effective next Monday, which takes steps to dismantle the Immigration Court system. DOJ’s action ends any transparency and assurance of independent decision making over individual cases” Read more here: and read the statement - and

9.      To be published 9/3/2019, with comments due 9/20/2019. New round of China trade tariffs. Includes items other than intellectual property, despite the title.  Related and also to be published 9/3/2019 Request for Comments on 2020 National Trade Estimate - used in determining trade policy.  You can read the 2019 estimate here:

10.  8/29/2019 Relaxing methane leaks rule. Not yet published, docket no. EPA-HQ-OAR-2017-0757. A link to the pdf of the proposed regulation included in this article: Read more here:

11.    Comments due October 18, 2019. Proposed rule, titled HUD's Implementation of the Fair Housing Act's Disparate Impact Standard.  Comment - How HUD Could Dismantle a Pillar of Civil Rights Law: "The Trump administration will introduce a new rule on Monday that may reshape the way the government enforces fair housing law, making it harder for people to bring forward discrimination complaints under the Fair Housing Act." Read it and comment here:

12.   Tongass National Forest EPA site - proposal to open up Tongass National Forest to logging, roads, etc. Not on yet. You have to download the documents to read them but the first six pages of the first document confirm the intent. and and

13. 9/3/2019. Relaxing standards for hazardous air pollutants.  EPA regulatory summary  see Read about it here:

14.   8/29/2019. Never posted - further citizenship restrictions. USCIS failed to provide advance public notice of this shift. USCIS’s Elimination of Non-Military Deferred Action at Local USCIS Offices - "This shift puts lives in danger, including the lives of children facing serious medical conditions like cancer, epilepsy, cystic fibrosis, and HIV. USCIS's actions threaten such individuals with deportation and loss of access to essential treatment. USCIS's failure to provide advance public notice of this policy change epitomizes the agency's growing disregard for transparency and accountability." Write your legislators.

15. Protect Utah and Hovenweep National Monument from Oil and Gas Drilling!

Section I - ICE, DHS, DOL, NLRB

1.       Posted July 22, 2019 Notice. Submission to the Secretary of Agriculture: Pesticides; Agricultural Worker Protection Standard; Revision of the Application Exclusion Zone Requirements affecting “Agricultural worker, employer, environmental protection, farms, forests, greenhouses pesticides, nurseries, pesticide handler, worker protection standard.” No comments as it is “merely a submission to the Secretary of Agriculture.” Given this administration’s track record, this doesn’t bode well.


1.       Posted August 12, 2019. Allowing more toxic substances. Notice. Certain New Chemicals or Significant New Uses; Statements of Findings for June 2019 EPA proposed significant new uses of toxic chemicals, including isocynates, used in polyurethane. Comments not accepted. Read more here:

2.     July 14, 2019 Multiple BLM Notices and Proposed Rules with links to comment pages. Constantly updated.

3.     July 14, 2019 Multiple Ozone Standards - EPA is doing this state-by-state.

4.      Comments must be received on or before midnight EDT September 25, 2020. Exposure of Underground Miners to Diesel Exhaust Request for Information; reopening of the rulemaking record for public comments. Because of comments, comment period extended to Sept. 25 2020. Federal Register version comment period ends 09/25/2020  Update - “The comment period for the request for information, published on June 8, 2016 (81 FR 36826), which was scheduled to close on March 26, 2019 (58 FR 12904) is extended. An important comment here: "This reopened RFI takes into account information originally gathered and shared from NIOSH, NCI, and the International Agency for Research on Cancer (IARC) which shows a correlation to exposure to diesel exhaust, a classified human carcinogen, and negative impact on miners health (Exposure of Underground Miners to Diesel Exhaust, 81 Fed. Reg. 110, 36826-36827 (June 8, 2016). On page 36827, stakeholders, MSHA, and the Diesel Exhaust Health Effects Partnership (Partnership) decided that more research and complex questions needed to be gathered and answered before allowing miners to continue working in DPM in the air. Potential for new technology and stricter standards that are in compliance with EPA DPM standards. And this study:

5.      5/20/2019. EPA Plan to change method of reporting pollution deaths. "E.P.A. Plans to Get Thousands of Pollution Deaths Off the Books by Changing Its Math".  Not posted yet as a proposal. Several people with knowledge of the EPA plan told the New York Times that using a new analytical model to calculate air pollution deaths could make it easier for the federal government to move forward with eliminating the Clean Power Plan, a key climate change rule put into place under the Obama administration.  Read more:

6.      2019 BLM oil and gas lease sales - still for sale. Document listing all projects : listing upcoming sales:
7.     And the site doing the selling where you can buy leases starting at $2 and acre: the calendar of government leases sales here:  BLM’s own e-planningsite:


2.      Posted August 12, 2019: On violence against native women. Agency Information Collection Activities: Proposed New Information Collection Activity; Comment Request, Proposed Study Entitled “The National Baseline Study on Public Health, Wellness, & Safety” Study of violence against women in tribal communities. Affected public who will be asked or required to respond, as well as a brief abstract: Title IX, Section 904(a) of the Violence Against Women and Department of Justice Reauthorization Act of 2005 (VAWA 2005), Public Law 109-162 (codified at 42 U.S.C. 3796gg-10 note), as amended by Section 907 of the Violence Against Women Reauthorization Act, Public Law 113-4, mandates that the National Institute of Justice (NIJ), in consultation with the U.S. Department of Justice's Office on Start Printed Page 39881Violence Against Women (OVW), conduct a National Baseline Study (NBS) on violence against American Indian (AI) and Alaska Native (AN) women living in tribal communities. NIJ's NBS will examine violence against AI and AN women (including domestic violence, dating violence, sexual assault, and stalking) and identify factors that place AI and AN women at risk for victimization and propose recommendations to improve effectiveness of these responses.

3.      Coming as a proposed regulation. From June: Proposal to recalculate how the Federal government calculates poverty rates so as to reduce benefits to poor people. This was a notice - proposed rule will follow sometime. I'm putting this here as a place-holder because it’s coming.  Article about it here:

4.      May-June 2019 Concerted Attack on Civil Rights. Learn more about the proposed regulation and how to fight it here (you can submit a comment).:

5.      Extending Medicaid provisions: Some include work-requirements. These are by state. Some have comments open - usual time period is one month. Those with open comments are at the top of the list.

7.     Not posted as a regulation but followed as policy.  State Medicaid block grants. Many view this as a way to cut Medicaid to individuals. Also see link to state updates above.

9.      Kaiser Health News take here:

Other (more on regulations, tracking the trackers, and general information)


3.     Overview of Trump Regulatory actions: See White House Complete Government “Reform” plan - it is sweeping and alarming:  and their regulations office:

4.    Trump’s regulatory agenda - status, challenges, enforcement or lack of, etc.

5.     Tracking regulations by Agency and Industry:

6.    Discussion of ongoing and upcoming issues from Yale Law and ABA - and for discussion of banking, commerce, and energy regulation -

7.     Department of Transportation. Employment - hours of service - tracking trucking driver regulations:

11.  Tracking Alaska Oil and Gas drilling:

12. Environmental regulation rollback tracking:

13. Brookings Institution “Tracking Deregulation in the Trump Era.” and Rules at Risk:  For state impact - listed by state:

15. EPA Dozens of proposals for significant new uses of chemicals. Too many to list here but this link will take you to the current proposals.  This is an article on the EPA rush to reclassify chemicals and toxic substances from the Environmental Defense Fund:

16.Upcoming Public Federal Meetings and Comment opportunities on the environment/ecology:

17. Law of the Land Project from Center for American Progress. Tracks regulations and litigation with status updates.

18.EPA’s own Inspector General report critical of EPA biosludge policy and public health risks:

22.Federal Facilities Environmental Stewardship Center - where the Feds deal seriously with climate change:

23.See American Institute of Physics Report on Trump admin. plan for research and development - and DOE 2019 plan -

24.Healthcare: Overview of Medicare financial plans for hospitals for 2019-2020.

25. HHS healthcare rollbacks, proposed regulations and proposed legislation from Congress.

28. Immigration - good summary of all public charge rules at several government agencies - USCIS, DOJ, DOS:

29.Immigration law resources - great resource:

31. Native American issues.

32.Public Lands Tracking legal battles over the future of America’s public lands:

33. SEC Regulatory site: for information on proposed changes to financial rule and markets.

34.Department of Transportation New and pending rules.

35.For effective Commenting on Regulations, please read and “How to Comment on EPA dockets”:

36.Proposed “Regulatory Reform Agenda”:

37. Search and track all Federal regulations at

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