[Date Prev][Date Next][Date Index]
E-M:/ Stop Susan Dudley at OMB
- Subject: E-M:/ Stop Susan Dudley at OMB
- From: "Alex J. Sagady & Associates" <firstname.lastname@example.org>
- Date: Thu, 19 Oct 2006 14:47:50 -0400
- Delivered-to: email@example.com
- Delivered-to: firstname.lastname@example.org
- List-name: Enviro-Mich
- Reply-to: "Alex J. Sagady & Associates" <email@example.com>
Subject: Stop Susan Dudley Now!
PLEASE Circulate to Others!Dear Friend of
The Bush administration has nominated Susan Dudley, an extremist from an
industry-funded think tank, to oversee all of our government's regulatory
A Senate committee hearing on Dudley's nomination to run the Office of
Information and Regulatory Affairs (OIRA) is scheduling for Nov. 13, the
first day the Senate returns after elections. We need your help to make
sure that the lame-duck Senate doesn't confirm Dudley. Her confirmation
would send a signal that it is okay to put public protections in the
hands of powerful special interests - sacrificing a safer, healthier,
more just America at the behest of industry lobbyists, corporate campaign
contributions, and professional ideologues. We cannot let that
(Even if you are not representing an organization -
we still need you help! We've set up an
action alert for you to
send a note to your Senators to let them know you oppose the nomination
of Susan Dudley. Just click
here to email your Senators.)
- Help us send a clear message on the Dudley nomination,
by signing your organization onto the following letter to the
Friday, Nov. 3, at 5:00 pm Eastern time; provide your name, organization,
- We welcome organizations at the national, state, and local
In this position, Dudley would have the power to weaken or eliminate
important safeguards - public protections dealing with the water we
drink, the air we breathe, and the food we eat. Dudley would also be able
to influence rules on auto safety, workplace safety, and product safety -
from teddy bears to baby clothes. Dudley would oversee all this, and
much, much more as the Regulatory Czar.
OMB Watch and Public Citizen recently concluded, after
research into her background and positions, that Dudley cannot be
trusted in such a powerful position. Dudley:
- Opposed EPA's attempts to keep arsenic out of drinking water and
enforce lower levels of disease-causing smog;
- Questioned life-saving air bag regulations and the Department of
Transportation's hours-of-service rules to keep sleep-deprived truck
drivers off the roads;
- Has standards that would make it nearly impossible for agencies to
justify public health, safety, civil rights, environmental, or other
public interest protections - a special interest dream come true;
- Supports regulatory sunsets that force agencies to stop everything
and re-justify the need for every rule on the books; and
- Is viewed as extreme even by her conservative colleagues.
More information on Dudley is available at
Under the Bush administration, crucial safeguards have been swept aside
or watered down; emerging problems ignored; and enforcement eviscerated.
Enough is enough. Let?s make a stand by saying no to the Susan Dudley
confirmation as Regulatory Czar.
Gary D. Bass
P.S. All nonprofit organizations have the right to support or oppose
nominees. While OMB Watch seldom takes positions on nominations, we
believe this candidate is so extreme it warrants taking a strong position
of opposition. We hope you will agree and join us in opposing this threat
to our public protections.
TEXT OF LETTER TO SENATE
We are writing to oppose the nomination of Susan Dudley to the position
of administrator of the Office of Information and Regulatory Affairs
(OIRA) in the Office of Management and Budget.
As the OIRA administrator, Susan Dudley would be granted enormous power
over regulatory policy, which she will abuse to promote corporate special
interests over the public interest. OIRA has the ability to weaken or
eliminate safeguards of the public health, safety, civil rights, privacy
rights, and environment through oversight power the White House has
granted it under Executive Order No. 12,866, and it can distort or
suppress needed information through its information management powers
under the Paperwork Reduction Act. We know from Dudley's writings and
past positions that she is deeply hostile to regulatory safeguards and
that she brings a radical agenda to this obscure but incredibly powerful
Dudley's record is one of unrelenting hostility to protective standards
for the public interest. The following is just a sample of her extreme
- Smog is good for you - and all those poor asthmatic children who
would suffer in peak ozone periods should just stay indoors.
- There is no economic justification for protecting workers through the
Davis-Bacon Act or the Occupational Safety and Health Act.
- Improved standards lowering the levels of arsenic in our drinking
water were an "unwelcome distraction."
- We are too irrational to exercise our right to know about the toxic
hazards to which we are exposed.
- Advanced air bag designs should not be mandatory in all vehicles,
because if the public truly wanted them the market would have already
These positions are just the tip of the iceberg. Our reasons for opposing
Dudley are more fully explained in the recent report by Public Citizen
and OMB Watch, The Cost Is Too High: How Susan Dudley Threatens Public
Protections. There are three main objections to Dudley's
- She would block needed safeguards for the public health, safety,
civil rights, the environment, or other public interest needs by making
it impossible for agencies to ever justify a new protective standard.
Dudley insists that the only justification for a regulatory protection is
to correct a "market failure" - but, as she has unilaterally
redefined this macroeconomic term of art, there never is such a thing as
market failure. Moreover, she would demand impossible levels of
scientific proof that would block any precautionary measures intended to
protect the public before it has suffered irreversible harm.
Additionally, she has argued against national standards from the federal
government, even in the case of preserving wild spaces in national
forests owned by the federal government.
- She comes to the office with a radical agenda that would put the
public at risk. Dudley has called for such radical policies as
regulatory "sunsets," or drop-dead dates by which agencies
would be forced to review all the rules on the books and re-establish the
need for them (even such proven protections as the ban on lead in
gasoline), or else the safeguards would be erased. She has also called
for the distortion of safety-first laws such as the Occupational Safety
and Health Act and the Mine Safety and Health Act, which forbid the use
of bean-counting cost-benefit analysis as the dispositive test for public
protections. This proposal is especially troubling given that the Mine
Safety and Health Administration is currently working on new protections
for miners, which Congress required after the fatal mine tragedy in Sago.
- She has deep and troubling ties to regulated industry. Dudley
has spent the last several years as a mouthpiece for corporate special
interests at the industry-funded think tank Mercatus Center. There, she
penned regulatory comments attacking proposed safeguards and coordinated
industry demands for regulatory rollbacks. OIRA has already set itself up
as one-stop shopping for corporate special interests seeking to stall,
weaken, or eliminate regulatory safeguards; Dudley would take that role
to new extremes.
For these reasons, we believe that Susan Dudley is the least appropriate
nominee ever submitted since OIRA was created, and we urge you to oppose
Visit the web address below to tell your friends about this.
If you received this message from a friend, you can
sign up for
Alex J. Sagady & Associates
Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
657 Spartan Ave, East Lansing, MI 48823
(517) 332-6971; (517) 332-8987 (fax); firstname.lastname@example.org