Rogan’s List for 06/22/2020

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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.


Closing Soon
Section I – ICE, DHS, DOL, NLRB
Section II – everything environmental – EPA, BLM, DOE
Section III – Civil rights, housing, education, healthcare
Other: More on regulations (tracking the trackers/general information)

(Note: After a couple of weeks items are moved from “Recent” and “Closing soon” into the Roman numeral sections. A note on regulatory processes: there are three stages – Notice, Proposed Rule, and Rule. There’s usually a time lag of a few months to a few years between them, and they must be published in the Federal Register before appearing on Comment time varies from 10 days to 2 months, sometimes with extensions.)

Moving target – a lot of proposed regs – many using the pandemic as cover – are allowing only a couple of weeks for comment. There are some huge EPA ones. Closing and new this week – EPA overall guidance documents and regulatory procedure. Trump admin’s rush to use the pandemic emergency to codify and solidify anti-environment regulatory actions and make them harder to undo. Eliminating many work visas – coming soon. Inspectors General – proposed rule on HHS IG oversight, and DOJ IG criticism of dangerous training for federal prison employees (some were used in BOP crisis management groups deployed to Miami and Washington, D.C., during the recent protests against police brutality and racial injustice in response to the death of George Floyd in police custody on May 25th.

This week’s list.

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