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E-M:/ Stop Susan Dudley at OMB

Subject: Stop Susan Dudley Now!

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Dear Friend of OMB Watch,

The Bush administration has nominated Susan Dudley, an extremist from an industry-funded think tank, to oversee all of our government's regulatory policy.

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 happen.

Help us send a clear message on the Dudley nomination, by signing your organization onto the following letter to the Senate.

Email stopdudley@citizen.org by Friday, Nov. 3, at 5:00 pm Eastern time; provide your name, organization, and address.

We welcome organizations at the national, state, and local level.

(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.)

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 extensive research into her background and positions, that Dudley cannot be trusted in such a powerful position. Dudley:

More information on Dudley is available at www.citizen.org/dudley and www.ombwatch.org/regs/dudley .

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
Executive Director

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.




Dear Senator:

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 office.

Dudley's record is one of unrelenting hostility to protective standards for the public interest. The following is just a sample of her extreme positions:

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 nomination:

  1. 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.

  2. 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.

  3. 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 her nomination.


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Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
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