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Tipoffs: Public Comments on Proposed Federal Rules Newsletter for 2026-05-06 ( 89 items )  
114 State Legislators Urge Labor Department to Withdraw Proposed Worker Classification Rule (10)
WASHINGTON, May 6 -- A coalition of 114 state legislators submitted a public comment letter to the U.S. Department of Labor opposing its Notice of Proposed Rulemaking on employee versus independent contractor status under several federal labor laws. The letter argues that the proposed rule, which would replace the current federal test with a modified 2021 standard, threatens the fiscal integrity of state programs reliant on accurate worker classification. The legislators, representing states with a combined population of over 176 million, emph more ST

14 Mass. State Senators Urge Withdrawal of HUD Proposed Rule on Housing Work Requirements and Term Limits (10)
WASHINGTON, May 6 -- A group of 14 Massachusetts state senators submitted a public comment letter to the U.S. Department of Housing and Urban Development urging it to withdraw its proposed rule titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The letter expresses concern over the potential impacts of the rule on families receiving federal rental assistance in Massachusetts, a state already experiencing a severe housing shortage and extended waitlists for subsidized housing. The letter criticizes the pr more ST

1Money Co. Urges Targeted Refinements to OCC Stablecoin Rulemaking Emphasizing Innovation and Clarity (10)
WASHINGTON, May 6 -- 1Money Co., a financial technology holding company specializing in regulated payment stablecoin infrastructure, has submitted a public comment letter to the Office of the Comptroller of the Currency addressing the Proposal to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025. The letter provides detailed feedback on the OCC's framework for issuing stablecoins by entities under its jurisdiction. 1Money Co., New York, operates a licensed multi-jurisdictional stablecoin  more ST

4 Associations Urge Department of Labor to Restore 2021 Independent Contractor Rule (10)
WASHINGTON, May 6 -- A group of four associations submitted a public comment letter to the U.S. Department of Labor addressing a Notice of Proposed Rulemaking on independent contractor classification. The NPRM proposes rescinding the 2024 independent contractor rule and reinstating a modified version of the 2021 rule under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act. The associations emphasized the importance of independent contractor relationships to their members acr more ST

55 Advocacy Organizations Opposes HUD Proposal on Work Requirements and Time Limits in Federal Housing Assistance (10)
WASHINGTON, May 6 -- A coalition of 55 advocacy organizations has submitted a public comment letter to the U.S. Department of Housing and Urban Development expressing opposition to the agency's proposed rule titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The letter outlines widespread concerns about the potential negative impacts of allowing Public Housing Authorities and Project-Based Rental Assistance owners to impose work requirements and time limits on recipients of federal housing assistance prog more ST

7 Real Estate Organizations Urge HUD to Revoke 30-Day Eviction Notice Requirement (10)
WASHINGTON, May 6 -- A group of seven national real estate organizations has submitted a public comment letter to the U.S. Department of Housing and Urban Development urging it to proceed with its proposed rule to revoke the 30-day notification requirement prior to lease termination for nonpayment of rent. The associations, which include major industry groups involved in affordable, conventional, military, student, and senior housing, emphasize that the revocation is necessary to reduce federal interference in eviction processes traditionally g more ST

Able South Carolina Opposes DOE's Proposal to Rescind Section 504 Accessibility Regulations (10)
WASHINGTON, May 6 -- Able South Carolina, a disability-led Center for Independent Living, submitted a public comment letter opposing the U.S. Department of Energy proposed direct final rule to rescind accessibility-related provisions under Section 504 of the Rehabilitation Act. The organization, established in 1994 with over 30 years of experience advocating for disability justice, serves thousands of individuals with disabilities annually and emphasized that the proposed rule would undermine critical civil rights protections and harm millions  more ST

Agroforestry Coalition Proposes Tiered Pre-Harvest Intervals for Organic Orchards (10)
WASHINGTON, May 6 -- The Agroforestry Coalition, Madison, Wisconsin, has submitted a public comment letter to the U.S. Department of Agriculture National Organic Standards Board addressing the pre-harvest intervals for livestock grazing in organic orchards. The Coalition, a network of organizations and individuals advocating for agroforestry, urged the NOSB to revise the current 90/120-day manure interval rule, which it characterizes as a barrier to organic certification for silvopasture practitioners. In its letter, the Coalition emphasized t more ST

Alliance for Automotive Innovation Urges Revisions to NHTSA Crash Reporting for Automated Driving Systems (10)
WASHINGTON, May 6 -- The Alliance for Automotive Innovation submitted a public comment letter to the National Highway Traffic Safety Administration addressing the Standing General Order on Crash Reporting related to Automated Driving Systems and Level 2 Advanced Driver Assistance Systems. Auto Innovators, representing a broad spectrum of the automotive industry including manufacturers, suppliers, and technology developers, raised concerns about the current data collection practices and their impact on the industry. The organization highlighted more ST

American Association of University Women Opposes DOE Regulation Rescission on Disability Accessibility (10)
WASHINGTON, May 6 -- The American Association of University Women has submitted a public comment letter to the U.S. Department of Energy opposing a proposal to rescind certain regulations related to nondiscrimination in federally assisted programs or activities. The letter specifically targeting 10 C.F.R. Sec. 1040.73, which mandates that all new or altered facilities financed with DOE funds be accessible to people with disabilities. AAUW expressed concerns that the proposed rule would eliminate critical standards enforcing accessibility in DO more ST

American Council of the Blind Government Employees Opposes DOE Rule Rescinding Accessibility Standards (10)
WASHINGTON, May 6 -- The American Council of the Blind Government Employees, Alexandria, Virginia, has submitted a public comment letter to the U.S. Department of Energy expressing opposition to the agency's Direct Final Rule rescinding 10 C.F.R. Sec. 1040.73. This provision has long required facilities receiving DOE funding to be designed and constructed with accessibility features for individuals with disabilities, including tactile signage, Braille indicators, and auditory cues. The ACBGE argues that the DOE's rationale, which characterizes more ST

American Indian Higher Education Consortium Urges OPM to Exempt Federally Operated Tribal Colleges From Reduction-In-Force Regulations (10)
WASHINGTON, May 6 -- The American Indian Higher Education Consortium, representing 35 accredited Tribal Colleges and Universities across 16 states, submitted a public comment letter to the U.S. Office of Personnel Management regarding its proposed revisions to reduction-in-force regulations. AIHEC, based in Alexandria, Virginia, specifically urged the agency to exempt employees of the two federally operated TCUs-Haskell Indian Nations University (HINU) and Southwestern Indian Polytechnic Institute-from future RIF notices. AIHEC emphasized that more ST

American Network of Community Options & Resources Urges DOE to Withdraw Direct Final Rule Impacting Disability Accessibility Protections (10)
WASHINGTON, May 6 -- The American Network of Community Options and Resources, a national nonprofit representing providers of long-term services and supports for individuals with intellectual and developmental disabilities, has submitted a public comment letter to the U.S. Department of Energy expressing opposition to the department's direct final rule concerning new construction requirements related to nondiscrimination in federally assisted programs. ANCOR criticizes DOE's use of the direct final rulemaking process for a measure the organizat more ST

American Petroleum Institute Requests Extension for Public Comment Period on OCS Lease Risk Management Rule (10)
WASHINGTON, May 6 -- The American Petroleum Institute has submitted a public comment letter to the U.S. Department of the Interior Marine Minerals Administration requesting a 60-day extension to the existing comment period for the Risk Management and Financial Assurance for Outer Continental Shelf Lease and Grant Obligations. The rulemaking outlines proposed changes affecting risk management and financial assurance requirements for OCS leaseholders. API represents the full spectrum of the U.S. oil and natural gas industry, encompassing around  more ST

Association of Medical Illustrators Urges Copyright Office to Reconsider Fee Increases for Visual Artists (10)
WASHINGTON, May 6 -- The Association of Medical Illustrators, Lexington, Kentucky, has submitted a public comment letter to the U.S. Copyright Office expressing concerns over proposed fee increases for copyright registrations, particularly those affecting visual art works and motion picture/audio-visual works. AMI represents biomedical illustrators, animators, and interactive designers who rely heavily on copyright registration as a prerequisite for legal protection and enforcement. AMI highlighted that many professional independent artists al more ST

Attion Consulting Urges Clarity and Flexibility in OCC's Stablecoin Regulatory Framework (10)
WASHINGTON, May 6 -- Attion Consulting LLC, a strategic advisory firm specializing in financial services regulation, submitted a public comment letter to the Office of the Comptroller of the Currency regarding the agency's proposed rulemaking on implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The firm outlined several considerations aimed at refining the regulatory approach to payment stablecoins under OCC jurisdiction. Attion, New York, emphasized the importance of a clear, principles-based framework, e more ST

Bank Policy Institute Urges OCC to Reject Lorum National Trust Bank Charter Application Citing Legal and Systemic Risks (10)
WASHINGTON, May 6 -- The Bank Policy Institute has submitted a public comment letter to the Office of the Comptroller of the Currency opposing the national trust bank charter application filed by Lorum National Trust Bank, N.A. The BPI raised concerns that approval of the application would exceed the OCC's statutory authority, increase risks to the U.S. financial system, and undermine competitive equity among banks. The BPI detailed that the OCC's authority under 12 U.S.C. 27(a) requires national trust banks to be predominantly engaged in trus more ST

Bay Area Legal Aid Opposes HUD Revocation of 30-Day Eviction Notice Rule (10)
WASHINGTON, May 6 -- Bay Area Legal Aid submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing an Interim Final Rule that revokes the 30-day notification requirement prior to lease termination for nonpayment of rent. The letter urges HUD to maintain the rule, which mandates that public housing and project-based rental assistance providers give tenants 30 days' notice before filing eviction proceedings for nonpayment. The organization states that the 30-day notice rule provides time to correct errors  more ST

Center for Law & Social Policy Opposes HUD Proposed Work Requirements and Time Limits on Housing Assistance (10)
WASHINGTON, May 6 -- The Center for Law and Social Policy, a national nonprofit advocating anti-poverty policies, has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the agency's proposed rule that would permit Public Housing Authorities and certain subsidized housing owners to implement work reporting requirements and time limits for residents. CLASP warns that the rule would deepen housing instability and hardship without increasing employment or economic security. According to CLASP, the pr more ST

Certara Provides Comprehensive Feedback on FDA Draft Guidance for Individualized Genetic Therapies (10)
WASHINGTON, May 6 -- Certara, a biopharmaceutical consulting firm, has submitted a public comment letter to the U.S. Food and Drug Administration addressing the draft guidance titled "Considerations for the Use of the Plausible Mechanism Framework to Develop Individualized Therapies that Target Specific Genetic Conditions with Known Biological Cause." The firm offers extensive recommendations aimed at clarifying and enhancing the guidance to support development programs focused on individualized genetic therapies. Certara, Radnor, Pennsylvania more ST

Circle Internet Group Urges OCC to Refine Stablecoin Regulations for Operational Efficiency and Global Compatibility (10)
WASHINGTON, May 6 -- Circle Internet Group Inc., the largest regulated global issuer of stablecoins, submitted a comprehensive public comment letter to the Office of the Comptroller of the Currency regarding the agency's proposed rules for implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act. Circle's letter addresses numerous operational, prudential, and supervisory aspects of the OCC's proposed regulatory framework aimed at ensuring financial stability, consumer protection, and market integrity in the emergin more ST

Coinbase Global Urges OCC to Maintain Statutory Limits While Implementing GENIUS Act on Stablecoin Issuance (10)
WASHINGTON, May 6 -- Coinbase Global Inc., Wilmington, Delaware, has submitted a public comment letter to the Office of the Comptroller of the Currency addressing the agency's proposed rulemaking on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The letter emphasizes the importance of adhering strictly to the statute's text and limits, cautioning against the agency exceeding its authority by imposing rules beyond those Congress prescribed, particularly on yield restrictions and reserve requireme more ST

Copyright Alliance Opposes U.S. Copyright Office's Proposed Fee Hikes Citing Harm to Creators and Registration Decline (10)
WASHINGTON, May 6 -- The Copyright Alliance, representing over 2 million individual creators and 15,000 organizations, submitted a public comment letter to the U.S. Copyright Office expressing opposition to a proposal to increase registration fees across various copyright services. The U.S. Copyright Office issued the proposed fee schedule in a notice of proposed rulemaking published on March 20, 2026, which includes average fee increases of 43%, with some spikes as high as 268% for certain registration categories. The organization highlighted more ST

Del. Council for Persons With Disabilities Opposes DOE's Proposed Accessibility Regulation Changes (10)
WASHINGTON, May 6 -- The Delaware State Council for Persons with Disabilities has submitted a public comment letter to the U.S. Department of Energy opposing a proposed regulatory changes regarding nondiscrimination in federally assisted programs or activities. The letter raises concerns about the DOE's use of a direct final rule approach to amend facility accessibility requirements under Section 504. The SCPD argues that the DOE's approach limits public engagement by circumventing the standard regulatory process, which may be unlawful given t more ST

Democracy Forward Foundation Challenges DOE's Use of Direct Final Rule to Rescind Disability Access Requirements (10)
WASHINGTON, May 6 -- The Democracy Forward Foundation, a national nonprofit legal organization, submitted a public comment letter to the U.S. Department of Energy expressing opposition to a recent Direct Final Rule aimed at rescinding longstanding construction requirements that protect individuals with disabilities in federally assisted programs. The letter outlines multiple legal and procedural concerns regarding DOE's rulemaking process and the content of the rule itself. DFF criticizes the DOE's adoption of a Direct Final Rule that deletes  more ST

Digital Chamber Urges Clarity and Flexibility in OCC Stablecoin Rulemaking (10)
WASHINGTON, May 6 -- The Digital Chamber has submitted a public comment letter to the Office of the Comptroller of the Currency regarding the OCC's proposed rulemaking on implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The letter offers detailed feedback on definitions, redemption procedures, and general regulatory considerations for stablecoins issued by entities under OCC jurisdiction. In the submission, the Digital Chamber emphasizes the importance of aligning definitions across the primary prudential more ST

Disability Rights Groups Oppose DOE's Proposed Changes to Title VI Regulations (10)
WASHINGTON, May 6 -- The Disability Rights Education and Defense Fund and Disability Rights California have submitted a public comment letter to the Department of Energy opposing a proposed amendments to its regulations implementing Title VI of the Civil Rights Act of 1964. The letter addresses a DOE "direct final rule" proposal that would rescind certain nondiscrimination requirements related to race, ethnicity, and national origin in federally assisted programs or activities. DREDF, a national nonprofit dedicated to advancing civil and human more ST

Education Law Center Opposes DOE Plan to Remove Disability Accessibility Rules in New Construction (10)
WASHINGTON, May 6 -- Education Law Center, a nonprofit focused on ensuring equitable and nondiscriminatory education for public school students, submitted a public comment letter to the U.S. Department of Energy opposing its direct final rule to rescind new construction requirements tied to nondiscrimination under federally assisted programs. The rule aims to eliminate standards for accessibility in new building projects funded by the federal government. The organization stressed that the proposed change contradicts civil rights protections an more ST

Environmental Defense Fund Urges EPA to Retain Pyrolysis/Combustion Units in Waste Incineration Standards (10)
WASHINGTON, May 6 -- The Environmental Defense Fund submitted a public comment letter to the U.S. Environmental Protection Agency addressing the proposed rule on Standards for Air Curtain Incinerators That Only Burn Wood Wastes, Yard Wastes and Clean Lumber, as well as provisions for commercial and industrial solid waste incineration units, including temporary use incinerators and air curtain incinerators used in disaster recovery. EDF emphasized that EPA's request for comment does not constitute a proposal and that the agency would need to is more ST

FGA Action Urges Office of Personnel Management to Finalize Rule Prioritizing Performance in Federal Workforce Reductions (10)
WASHINGTON, May 6 -- FGA Action, Tallahassee, Florida, has submitted a public comment letter to the U.S. Office of Personnel Management endorsing a proposed rule that seeks to rebalance the criteria used for employee retention in federal workforce reductions. The organization expressed support for OPM's effort to prioritize employee efficiency and performance over tenure and other factors during Reduction in Force decisions, urging the agency to finalize the rule as a step toward greater meritocracy in federal employment. In its letter, FGA Ac more ST

Fireblocks Urges OCC to Enhance GENIUS Act Stablecoin Custody Rules With Technical Standards (10)
WASHINGTON, May 6 -- Fireblocks Inc., New York, has submitted a public comment letter to the Office of the Comptroller of the Currency in response to the agency's Notice of Proposed Rulemaking implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The letter addresses the proposed custody provisions under Subpart C and urges the OCC to incorporate detailed technical standards aligned with industry practices in its final rule. Fireblocks, which operates a proprietary software-as-a-service platform managing over  more ST

Freepoint Eco-Systems Urges EPA to Exclude Pyrolysis From Municipal Waste Combustion Regulations (10)
WASHINGTON, May 6 -- Freepoint Eco-Systems Holdings LLC, Stamford, Connecticut, has submitted a public comment letter to the U.S. Environmental Protection Agency opposing the classification of pyrolysis units as "municipal waste combustion units" under the agency's Other Solid Waste Incinerators regulations. The company, which develops advanced plastic recycling technologies, advocates for EPA to remove references to pyrolysis from all regulations promulgated under Section 129 of the Clean Air Act that currently regulate pyrolysis as a combusti more ST

Global Legal Entity Identifier Foundation Urges Integration of Legal Entity Identifiers in OCC Stablecoin Regulations (10)
WASHINGTON, May 6 -- The Global Legal Entity Identifier Foundation, Jersey City, New Jersey, submitted a public comment letter to the Office of the Comptroller of the Currency advocating for the incorporation of Legal Entity Identifiers and their cryptographically verifiable counterpart, verifiable LEIs, into the regulatory framework for stablecoin issuers overseen by the OCC. GLEIF emphasized the role of LEIs in promoting transparency, enhancing fraud detection, and supporting innovation in stablecoin markets. GLEIF outlined that LEIs, standa more ST

Greater Boston Legal Services Opposes HUD's Proposed Flexibility on Work Requirements and Term Limits for Subsidized Housing (10)
WASHINGTON, May 6 -- Greater Boston Legal Services, Massachusetts, has submitted a public comment letter to the Department of Housing and Urban Development opposing a proposed rule that would allow local housing authorities to impose work requirements and term limits on residents of federally subsidized housing. GBLS, a nonprofit legal aid organization serving thousands of low- and moderate-income families in the Greater Boston area, argues that the rule would destabilize families, deepen the housing crisis, and fail to promote economic self-su more ST

Gulf of America Reef Fish Shareholders' Alliance Challenges NOAA Fisheries on Amendment 58B Proposal (10)
WASHINGTON, May 6 -- The Gulf of America Reef Fish Shareholders' Alliance submitted a public comment letter to the National Oceanic and Atmospheric Administration Fisheries Southeast Regional Office regarding the proposed rule for Amendment 58B to the Reef Fish Fishery Management Plan. The Shareholders' Alliance, which represents commercial reef fish fishermen in the Gulf, expressed serious concerns about the rule's impact on commercial fishermen and questioned the scientific and legal basis of the proposal. The Alliance criticized the proposa more ST

Healthy Environment Alliance Raises Concerns Over NRC Proposed Rule on Reactor Design Reviews (10)
WASHINGTON, May 6 -- The Healthy Environment Alliance of Utah, Salt Lake City, submitted a public comment letter to the U.S. Nuclear Regulatory Commission expressing concerns about the agency's proposed rule titled "NRC Reviews of Reactor Designs Previously Authorized by the U.S. Department of Energy or Department of War." HEAL Utah criticizes the proposal as a move that weakens regulatory oversight, reduces transparency, and escalates risks to public health. The organization warns that the proposal could narrow the scope and depth of the NRC' more ST

HGP Intelligent Energy Advocates Technical Clarifications in NRC Proposed Rule on Reactor Design Reviews (10)
WASHINGTON, May 6 -- HGP Intelligent Energy LLC, a Dallas, Texas, based reactor developer, has submitted a public comment letter to the U.S. Nuclear Regulatory Commission regarding the proposed rule on NRC reviews of reactor designs previously authorized by the U.S. Department of Energy or Department of War. The company expressed support for the rulemaking effort but emphasized the need for clarifications in the companion Draft Interim Staff Guidance to enhance the rule's practical application for reactor designs like those developed by HGP. I more ST

Homeless Action Center Opposes HUD Proposal on Work Requirements and Time Limits for Rental Assistance (10)
WASHINGTON, May 6 -- Homeless Action Center, Berkeley, California, has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the proposed rulemaking titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The organization urges HUD to withdraw the proposal, which would permit Public Housing Authorities and owners of HUD-assisted housing to impose strict work requirements and time limits on rental assistance recipients. Homeless Action Center, which assists over one more ST

Housing Opportunities Made Equal Opposes HUD Proposal to Implement Work Requirements and Time Limits on Housing Assistance (10)
WASHINGTON, May 6 -- Housing Opportunities Made Equal of Virginia has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a proposed rule to establish flexibility for the implementation of work requirements and term limits on HUD-assisted housing programs. HOME of VA, the only statewide fair housing nonprofit in Virginia, warns that such changes could lead to widespread evictions and homelessness, undermining housing stability for vulnerable populations. The organization argues that allowing Publi more ST

International Consortium for Innovation Offers Recommendations on FDA Draft Guidance for Individualized Therapies Targeting Genetic Conditions (10)
WASHINGTON, May 6 -- The International Consortium for Innovation and Quality in Pharmaceutical Development, a non-profit organization representing pharmaceutical and biotechnology companies, submitted a public comment letter to the U.S. Food and Drug Administration on the agency's draft guidance titled "Considerations for the Use of the Plausible Mechanism Framework to Develop Individualized Therapies that Target Specific Genetic Conditions with Known Biological Cause." The consortium provided extensive feedback aimed at clarifying and enhancin more ST

International Food Additives Council Urges USDA to Relist Key Substances on National Organic Standards List (10)
WASHINGTON, May 6 -- The International Food Additives Council submitted a public comment letter to the U.S. Department of Agriculture National Organic Standards Board emphasizing support for the relisting of several handling substances critical to organic food production. IFAC, which represents manufacturers and end-users of food ingredients worldwide, addressed the Sunset Reviews and proposals under consideration by the NOSB, highlighting the safety, essential functionality, and lack of adequate organic alternatives for these substances. IFAC more ST

Justice in Aging Opposes Over Proposed Work Requirements and Time Limits for Housing Assistance (10)
WASHINGTON, May 6 -- Justice in Aging, a national legal advocacy organization focused on improving the lives of low-income older adults, has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a proposed rule aimed at establishing flexibility for implementing work requirements and time limits for HUD housing assistance programs. The organization argues that the rule would unlawfully allow public housing authorities and HUD-assisted property owners to impose onerous work-related conditions and restr more ST

Kresge Foundation Urges IRS to Simplify Expenditure Responsibility Reporting on Form 990-PF (10)
WASHINGTON, May 6 -- The Kresge Foundation, Troy, Michigan, has submitted a public comment letter to the Internal Revenue Service urging revisions to the reporting requirements for expenditure responsibility under Form 990-PF as part of the 2026-2027 Priority Guidance Plan. The foundation stresses that the current reporting procedures impose excessive administrative burdens and produce redundant information that offers limited practical utility to the IRS. The foundation highlighted that its compliance efforts for the 2024 tax year alone requi more ST

Land of Lincoln Legal Aid Opposes HUD's Proposed Work Requirements and Term Limits for Subsidized Housing (10)
WASHINGTON, May 6 -- Land of Lincoln Legal Aid Inc., Champaign, Illinois, has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the agency's proposed rule entitled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The nonprofit organization, which provides legal services to low-income and senior residents in central and southern Illinois, argues that the proposed rule undermines HUD's mission to provide safe, decent, and affordable housing to vulnerable populatio more ST

Leadership Conference on Civil and Human Rights Urges DOE to Withdraw Rule Rescinding Accessibility Requirements (10)
WASHINGTON, May 6 -- The Leadership Conference on Civil and Human Rights, representing more than 240 national organizations, together with 59 undersigned groups, submitted a public comment letter to the U.S. Department of Energy opposing a direct final rule titled "Rescinding New Construction Requirements Related to Nondiscrimination in Federally Assisted Programs or Activities." The coalition expressed concerns that this rule, published in the Federal Register on May 16, 2025, undermines civil rights protections and fails to comply with proper more ST

Legal Action Center Opposes HUD's Proposed Work Requirements and Term Limits for Housing Assistance (10)
WASHINGTON, May 6 -- The Legal Action Center submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a Notice of Proposed Rulemaking titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The organization criticized the proposal, arguing that it would destabilize families and marginalize vulnerable populations by allowing Public Housing Agencies and owners of HUD-assisted housing to terminate assistance for residents who fail to meet stringent time limits or work req more ST

Legal Aid Chicago Urges HUD to Rescind Proposed Work Requirements and Time Limits for Housing Assistance (10)
WASHINGTON, May 6 -- Legal Aid Chicago submitted a public comment letter to the U.S. Department of Housing and Urban Development expressing opposition to HUD's Proposed Rule titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The organization cautioned that the rule would jeopardize housing stability for low-income families, especially women, children, and individuals with disabilities, and urged HUD to rescind the proposal entirely. Legal Aid Chicago emphasized that HUD lacks the legal authority to impos more ST

Legal Aid DC, Washington Lawyers' Committee, Legal Clinic for the Homeless Oppose HUD Rule Reducing Eviction Notice Period (10)
WASHINGTON, May 6 -- Legal Aid DC, Washington Lawyers' Committee for Civil Rights and Urban Affairs and Washington Legal Clinic for the Homeless have submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the Interim Final Rule that revokes the 30-day notification requirement before eviction for nonpayment of rent. The organizations represent tens of thousands of tenants living in public and project-based rental assistance housing in D.C. and argue the rule change undermines HUD's mission to create su more ST

Legal Services NYC Urges HUD to Abandon Work Requirements Rule for Public Housing (10)
WASHINGTON, May 6 -- Legal Services NYC, an organization dedicated to fighting poverty and promoting racial, social, and economic justice for low-income New Yorkers, has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the agency's proposed rule titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." LSNYC expressed concerns that the rule would harm HUD-assisted residents across New York City, particularly by imposing a stringent 40-hour-per-week work requireme more ST

Living Resources Corp. Opposes DOE Proposal to Roll Back Disability Accessibility Protections (10)
WASHINGTON, May 6 -- Living Resources Corp, a nonprofit disability services provider based in Albany, New York, has submitted a public comment letter to the U.S. Department of Energy opposing proposed direct final rules related to nondiscrimination in federally assisted programs or activities. The letter seeks to rescind key regulations enforcing accessibility standards. Living Resources Corp. emphasized that these proposed rules would dismantle nearly 50 years of established accessibility protections that ensure individuals with disabilities  more ST

Los Angeles Disability Dept. Opposes DOE's Proposed Changes to Accessibility Rules (10)
WASHINGTON, May 6 -- The Los Angeles Department on Disability, California, has submitted a public comment letter opposing proposed direct final rules issued by the U.S. Department of Energy related to nondiscrimination in federally assisted programs or activities. The letter addresses concerns which propose rescinding sections of the agency's regulations that implement Section 504 of the Rehabilitation Act. The Department's proposals would remove 10 C.F.R. Sec. 1040.73, which mandates full accessibility for people with disabilities in new cons more ST

Main Street Foundation Urges Clearer Risk Framework for Artichoke Imports to USDA (10)
WASHINGTON, May 6 -- The Main Street Foundation Center for Regulatory Analysis and Engagement submitted a public comment letter to the U.S. Department of Agriculture Animal and Plant Health Inspection Service concerning the agency's proposal to authorize the importation of fresh globe artichokes from Sardinia, Italy. CRAE endorsed the move to allow imports but stressed the need for APHIS to enhance the analytical clarity and proportionality of its regulatory framework. In its letter, CRAE praised APHIS's Pest Risk Assessment (PRA) for identify more ST

Maryland Legal Aid Opposes HUD Proposal to Revoke 30-Day Pre-Lease Termination Notice (10)
WASHINGTON, May 6 -- Maryland Legal Aid, Baltimore, submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing the proposed revocation of the 30-day notification requirement prior to lease termination for nonpayment of rent in HUD-subsidized housing. Maryland Legal Aid emphasized that the 2024 Final Rule, which mandates this notice, enhances housing stability and access to justice for tenants by providing critical time and information necessary to address complex failure to pay rent cases. The advocacy o more ST

Maryland Legal Aid Opposes HUD Proposed Rule on Work Requirements for Housing Assistance (10)
WASHINGTON, May 6 -- Maryland Legal Aid, Baltimore, submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a Notice of Proposed Rulemaking titled Establishing Flexibility for Implementation of Work Requirements and Term Limits. The organization expressed concerns about the impact of instituting work reporting requirements and time limits on tenants receiving HUD-subsidized housing assistance programs such as Project-Based Rental Assistance, Project-Based Vouchers, Housing Choice Vouchers, and units op more ST

Medicare Payment Advisory Commission Urges CMS to Modernize Inpatient Rehabilitation Facility Payment System and Improve Wage Index Accuracy (10)
WASHINGTON, May 6 -- The Medicare Payment Advisory Commission submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing the proposed rule on the Medicare Program's Inpatient Rehabilitation Facility Prospective Payment System for fiscal year 2027 and updates to the IRF Quality Reporting Program. MedPAC expressed support for CMS's consideration of constructing an IRF-specific wage index and offered recommendations to improve geographic labor cost adjustments. MedPAC highlighted long-standing concerns about flaw more ST

Mexican American Legal Defense & Educational Fund Opposes DOE Direct Final Rule Rescinding Language Access and Anti-Discrimination Protections (10)
WASHINGTON, May 6 -- The Mexican American Legal Defense and Educational Fund, Los Angeles, California, has submitted a public comment letter to the U.S. Department of Energy opposing a Direct Final Rule. The rule proposes to rescind regulations related to nondiscrimination in federally assisted programs or activities, specifically targeting provisions that ensure language access and prohibit discriminatory effects, commonly known as disparate impact, under Title VI of the Civil Rights Act. In its comment, MALDEF, a leading Latino legal civil r more ST

Movimiento Vivienda Digna Urges HUD to Revoke Rule Eliminating Eviction Notice Protections (10)
WASHINGTON, May 6 -- Movimiento Vivienda Digna, a coalition of diverse organizations based in Puerto Rico focused on defending housing rights, submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a revised rule that eliminates the 30-day notification requirement before terminating leases due to nonpayment of rent. This rule change affects approximately 2.2 million households nationwide, placing vulnerable renters at increased risk of eviction and homelessness. According to Movimiento Vivienda Digna more ST

N.D. Protection & Advocacy Project Opposes DOE Rule Changes Affecting Disability Access (10)
WASHINGTON, May 6 -- The North Dakota Protection and Advocacy Project, Bismarck, has submitted a public comment letter to the U.S. Department of Energy expressing opposition to proposed rule changes. The letter addresses concerns about the DOE's plan to rescind portions of regulations designed to ensure nondiscrimination and accessibility in federally assisted programs or activities, specifically regulations implementing Section 504 of the Rehabilitation Act. The proposed rule would eliminate 10 C.F.R. Sec. 1040.73, which requires new construc more ST

National Alliance for Caregiving Opposes DOE Proposed Rollback of Accessibility Regulations (10)
WASHINGTON, May 6 -- The National Alliance for Caregiving, a national organization advocating for family caregivers, submitted a public comment letter opposing proposed direct final rules by the U.S. Department of Energy that seek to rescind key nondiscrimination regulations related to accessibility in federally assisted programs or activities. The opposition which would eliminate requirements for new construction and alteration projects to be fully accessible to individuals with disabilities and dismantle obligations for existing facilities  more ST

National Association of Councils on Developmental Disabilities Opposes DOE Accessibility Rule Rescission (10)
WASHINGTON, May 6 -- The National Association of Councils on Developmental Disabilities submitted a public comment letter to the U.S. Department of Energy. The DOE's proposals seek to rescind longstanding accessibility provisions under Section 504 of the Rehabilitation Act of 1973, which require federally funded facilities to be accessible to individuals with disabilities. The NACDD represents 56 State and Territorial Councils on Developmental Disabilities across the United States and its territories. It strongly objects to eliminating 10 C.F. more ST

National Association of Counties Warns of Unfunded Mandates in HUD's Proposed Work Requirements for Public Housing (10)
WASHINGTON, May 6 -- The National Association of Counties has submitted a public comment letter to the U.S. Department of Housing and Urban Development regarding the agency's proposed rule that would permit Public Housing Authorities to implement term limits and work requirements as conditions for public housing assistance. Representing over 3,000 counties, parishes, and boroughs nationwide, NACo expressed concerns that the proposal may shift substantial administrative and service coordination burdens onto local governments without providing th more ST

National Association of Government Employees Opposes OPM Proposed Rulemaking on Reduction in Force Procedures (10)
WASHINGTON, May 6 -- The National Association of Government Employees, Quincy, Massachusetts, submitted a public comment letter to the U.S. Office of Personnel Management opposing its proposed rulemaking. NAGE urged the agency to withdraw the rule that significantly alters Reduction in Force procedures, arguing the changes undermine merit system principles and employee fairness. NAGE's letter criticized the rule's emphasis on making performance the primary factor in RIF retention standings, replacing the current balanced approach that prioriti more ST

National Association of Independent Colleges & Universities Urges Withdrawal of DOE Direct Final Rules on Civil Rights Regulations (10)
WASHINGTON, May 6 -- The National Association of Independent Colleges and Universities, representing 1,700 private, nonprofit colleges and universities across the United States, has expressed concerns in a public comment letter to the U.S. Department of Energy regarding five direct final rules. NAICU's comments echo those submitted by the American Council on Education and focus on the potential impact these rules pose on civil rights protections in education. NAICU, serving as the unified voice for private, nonprofit higher education on public more ST

National Disability Institute Opposes DOE Proposal to Rescind Accessibility Regulations (10)
WASHINGTON, May 6 -- The National Disability Institute, a disability rights organization dedicated to improving the financial security and independence of people with disabilities and their families, has submitted a public comment letter to the U.S. Department of Energy opposing proposed direct final rules. These rules would rescind key parts of the DOE's regulations implementing Section 504 of the Rehabilitation Act, which ensures nondiscrimination in federally assisted programs and activities for individuals with disabilities. NDI's comment  more ST

National Housing Law Project Urges DOE to Withdraw Proposed Accessibility Rule Rescissions (10)
WASHINGTON, May 6 -- The National Housing Law Project, a legal advocacy organization dedicated to improving affordable housing and protecting the rights of low-income tenants and homeowners, has submitted a public comment letter to the U.S. Department of Energy. The letter responds to the DOE's proposed direct final rules regarding new construction requirements and the rescission of certain regulations related to nondiscrimination in federally assisted programs or activities. NHLP strongly opposes the proposed rules, arguing that they would re more ST

National Labor Relations Board Union Opposes OPM Proposed Reduction in Force Rule (10)
WASHINGTON, May 6 -- The National Labor Relations Board Union has submitted a public comment letter to the U.S. Office of Personnel Management expressing opposition to the agency's proposed Reduction in Force rule. Representing approximately 519 bargaining unit employees at the National Labor Relations Board, the union criticized several aspects of the proposed rule for undermining longstanding federal employment protections and the stability of the civil service. The NLRBU specifically condemns the proposed addition of a subsection to exclude more ST

National Laboratory of the Rockies Highlights Safety Concerns for Heavy-Duty EV Hazardous Materials Transport (10)
WASHINGTON, May 6 -- The National Laboratory of the Rockies, Applewood, Colorado, submitted a public comment letter to the Pipeline and Hazardous Materials Safety Administration addressing safety risks, operational challenges, and regulatory considerations related to transporting hazardous materials using heavy-duty electric vehicles. The letter provides technical feedback aimed at informing PHMSA's research plans on these emerging concerns. According to the National Laboratory of the Rockies, electric vehicle fires differ from those in intern more ST

National Motor Freight Traffic Association Highlights Hazmat Risks of Heavy-Duty Electric Vehicles to DOT (10)
WASHINGTON, May 6 -- The National Motor Freight Traffic Association Inc. has submitted a public comment letter to the U.S. Department of Transportation addressing safety and cybersecurity concerns related to transporting hazardous materials using heavy-duty electric vehicles compared to internal combustion engine motor carriers. The NMFTA emphasized the need for updated regulations and extensive research to keep pace with evolving vehicle technologies and associated risks. The association raised alarms about potential electromagnetic interfere more ST

National Organic Standards Board Advocates Risk-Based Residue Testing and Transparency Enhancements (10)
WASHINGTON, May 6 -- The Organic Trade Association has submitted a public comment letter to the U.S. Department of Agriculture National Organic Program regarding a proposal by the National Organic Standards Board on Residue Testing for a Global Supply Chain. The association expressed support for the NOSB's efforts to modernize and make the residue testing process more transparent and risk-based, aiming to uphold the integrity of organic products for consumers and stakeholders across complex supply chains. The letter emphasized the need to mand more ST

National Press Photographers Association Urges Delay in Copyright Registration Fee Increases (10)
WASHINGTON, May 6 -- The National Press Photographers Association has submitted a public comment letter to the U.S. Copyright Office expressing opposition to the proposed fee increases for copyright registration, particularly for group registration of photographs. The NPPA, which represents thousands of visual journalists including staff photographers, freelancers, and small publishers, argues that the fee hikes are premature given the ongoing delay in modernization of the Office's registration processes. The association highlighted that the C more ST

National Women's Law Center Opposes HUD Proposed Rule on Work Requirements and Time Limits for Housing Assistance (10)
WASHINGTON, May 6 -- The National Women's Law Center has submitted a public comment letter to the U.S. Department of Housing and Urban Development opposing a proposed rule that would establish work requirements and time limits for housing programs. The NWLC urges HUD to withdraw the Proposed Rule entirely, arguing that it would harm women, families, and marginalized communities by arbitrarily restricting access to housing assistance. The NWLC highlights that the Proposed Rule allowing public housing agencies and HUD-assisted owners to require  more ST

NHP Foundation Urges HUD to Address Key Concerns Before Finalizing Work Requirements Rule (10)
WASHINGTON, May 6 -- The NHP Foundation, a mission-driven owner and operator of affordable housing, submitted a public comment letter to the U.S. Department of Housing and Urban Development regarding the proposed rule titled "Establishing Flexibility for Implementation of Work Requirements and Term Limits." The proposal would allow Public Housing Agencies and certain owners to implement work requirements of up to 40 hours per week and term limits of at least two years for some non-elderly, non-disabled households in specific HUD-assisted housin more ST

Northwest Horticultural Council Urges USDA to Maintain Critical Organic Tree Fruit Materials (10)
WASHINGTON, May 6 -- The Northwest Horticultural Council, Yakima, Washington state, submitted a public comment letter to the U.S. Department of Agriculture National Organic Standards Board regarding the sunset reviews, proposals, and discussion documents for organic crop and handling materials. Representing organic apple, pear, and sweet cherry growers, packers, and shippers in Idaho, Oregon, and Washington, the NHC emphasized the importance of continued access to certain synthetic and nonsynthetic substances vital to organic tree fruit product more ST

Nuclear Innovation Alliance Urges NRC to Clarify Rule on Reactor Design Reviews to Enhance Licensing Efficiency and Transparency (10)
WASHINGTON, May 6 -- The Nuclear Innovation Alliance, an independent non-profit organization focused on advancing nuclear energy innovation, submitted a public comment letter to the U.S. Nuclear Regulatory Commission regarding the proposed rule on NRC reviews of reactor designs previously authorized by the U.S. Department of Energy or Department of War. The letter emphasizes the importance of balancing efficiency in licensing pathways with maintaining NRC's independence, credibility, and transparency. NIA expressed support for the NRC's aim to more ST

Organic Produce Association Urges Inclusivity and Innovation in National Organic Standards Board Policies (10)
WASHINGTON, May 6 -- The Organic Produce Association, representing a broad spectrum of stakeholders in the organic produce supply chain, submitted a public comment letter to the National Organic Standards Board advocating for policies that support diverse organic production systems and encourage growth in the sector. OPA highlighted priorities such as the advancement of organic seed availability, the integration of technology in organic farming, improved transition pathways for producers, and an inclusive framework that considers various growin more ST

Organic Trade Association Urges Consistent Digital and Physical USDA Organic Labeling Standards (10)
WASHINGTON, May 6 -- The Organic Trade Association, a business association representing a wide range of participants in the organic agriculture and product industry in North America, has submitted a public comment letter to the U.S. Department of Agriculture National Organic Program. The letter addresses the Certification, Accreditation, and Compliance Subcommittee's discussion document on eCommerce Organic Labeling Requirements. OTA conveyed its appreciation for the subcommittee's attention to stakeholder feedback and acknowledged the ongoin more ST

OrganicEye Urges National Organic Standards Board to Remove Carrageenan From Organic Foods (10)
WASHINGTON, May 6 -- OrganicEye, La Farge, Wisconsin, has submitted a public comment letter to the National Organic Standards Board urging it to remove carrageenan from the list of approved materials for organic food production. The organization, acting on behalf of its members nationwide, expressed concerns over the safety of carrageenan, citing numerous independent scientific studies that link the seaweed-derived additive to health risks including cancer, diabetes, and gastrointestinal diseases. The letter outlines a long history of attempts more ST

PCC Community Markets Calls for Strengthened Organic Standards and E-Commerce Labeling Regulations (10)
WASHINGTON, May 6 -- PCC Community Markets, the largest community-owned food market in the U.S., submitted a public comment letter to the U.S. Department of Agriculture National Organic Program and the National Organic Standards Board. The mission-driven cooperative, with over 120,000 members and 16 stores across the Puget Sound region, urged the agency to take decisive action on several key issues affecting the organic food supply system. In the letter, PCC emphasized the need to delist outdated references to Environmental Protection Agency ( more ST

Public Justice Opposes DOE's Rescission of Nondiscrimination Regulations (10)
WASHINGTON, May 6 -- Public Justice, a nonprofit legal advocacy organization, has submitted a public comment letter to the U.S. Department of Energy opposing a direct final rule to rescind certain regulations related to nondiscrimination in federally assisted programs or activities. The letter criticizes the Department's effort to eliminate longstanding provisions intended to prevent discrimination based on race, color, and national origin among recipients of federal financial assistance. Public Justice, which combines litigation and advocacy  more ST

Quality Assurance International Provides Public Comment to National Organic Standards Board on 2028 Sunset Review and Handling Subcommittee Proposals (10)
WASHINGTON, May 6 -- Quality Assurance International, a USDA-accredited organic certification agency and member of the NSF family of companies, submitted a public comment letter to the National Organic Standards Board regarding the Handling Subcommittee proposals and the 2028 Sunset Review. QAI detailed its usage data of various National List materials among its certified organic operations and provided perspectives on specific substances under evaluation. QAI emphasized the role of chlorine materials, noting they are the most widely used subs more ST

Solana Policy Institute, DeFi Education Fund Urge Technology-Neutral Stablecoin Regulations From Office of the Comptroller of the Currency (10)
WASHINGTON, May 6 -- The Solana Policy Institute and DeFi Education Fund submitted a public comment letter to the Office of the Comptroller of the Currency addressing the proposed rulemaking under the Guiding and Establishing National Innovation for U.S. Stablecoins Act. Both organizations, focused on decentralized finance education and advocacy, emphasized the importance of a regulatory framework that supports innovation and legal clarity for payment stablecoins under the OCC's jurisdiction. The letter expressed support for the OCC's efforts  more ST

Stellar Development Foundation Encourages Clear Definitions and Flexible Regulations for Stablecoin Issuance (10)
WASHINGTON, May 6 -- The Stellar Development Foundation, a U.S.-based non-profit organization focused on equitable access to the global financial system, submitted a public comment letter to the U.S. Department of the Treasury Office of the Comptroller of the Currency. The letter addresses the OCC's Proposed Rule Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act, and underscores key considerations for the regulatory framework governing stablecoin issuers. SDF supports the proposed t more ST

Strengthening Organic Systems Emphasizes Enhanced Residue Testing for Global Organic Supply Chains (10)
WASHINGTON, May 6 -- Strengthening Organic Systems LLC submitted a public comment letter to the U.S. Department of Agriculture National Organic Program regarding the Certification, Accreditation, and Compliance Subcommittee's proposal on residue testing and unavoidable residual environmental contamination under Sec. 205.670. The organization highlighted the necessity of evolving residue testing into a comprehensive verification and deterrence tool amid expanding global organic supply chains. In responding to the proposal, Strengthening Organic more ST

Tesla Urges PHMSA to Support Heavy-Duty Electric Vehicles for Hazmat Transportation (10)
WASHINGTON, May 6 -- Tesla Inc., Austin, Texas, submitted a public comment letter to the Pipeline and Hazardous Materials Safety Administration of the U.S. Department of Transportation advocating for the safety and efficiency of heavy-duty electric vehicles, specifically the Tesla Semi, in the transport of hazardous materials. Tesla highlighted their substantial investment in EV technology and infrastructure as evidence that their trucks can safely replace internal combustion engine vehicles in this sector. In its letter, Tesla detailed the de more ST

Tobii Dynavox Urges CMS to Enhance 2028 HCBS Quality Measure Set With Assistive Technology Focus (10)
WASHINGTON, May 6 -- Tobii Dynavox LLC has submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding the proposed 2028 Medicaid Home and Community-Based Services Quality Measure Set. The company highlights opportunities to improve the measure set by emphasizing communication access and assistive technology, which it sees as fundamental to person-centered planning, community integration, and beneficiary safety. Tobii Dynavox encourages CMS to include the National Core Indicators-Adult Developmental Disabilities more ST

U.S. Internet Preservation Society Urges Higher Copyright Office Fees to Address Cost Recovery Gap (10)
WASHINGTON, May 6 -- The U.S. Internet Preservation Society, a nonprofit organization focused on internet infrastructure preservation and copyright reform, has submitted a public comment letter to the U.S. Copyright Office supporting the proposed fee adjustments. USIPS stresses the importance of increasing fees beyond the current proposal to address the Office's declining cost recovery and rising operational costs. The letter highlights a troubling decrease in cost recovery from approximately 60 percent to only 41 percent in fiscal year 2024.  more ST

Vermont Organic Farmers Endorse Chlorine Use Limits and Support National Organic Standards Board Material Relistings (10)
WASHINGTON, May 6 -- Vermont Organic Farmers LLC, Richmond, recently submitted a public comment letter to the U.S. Department of Agriculture National Organic Standards Board. VOF also collaborated with the Northeast Organic Farming Association of Vermont, which represents more than 1,700 members, to provide input on various NOSB agenda items scheduled for review in May 2026. In their letter, VOF expressed support for the Livestock Subcommittee's proposal to amend the annotation for the use of chlorine materials in livestock drinking water. The more ST

Wholesum Farms Arizona Advocates for Key Organic Inputs in USDA Organic Program Review (10)
WASHINGTON, May 6 -- Wholesum Farms Arizona LLC, an organic tomato grower operating under 24 acres of greenhouses since 2012, submitted a public comment letter to the U.S. Department of Agriculture National Organic Program regarding matters discussed at the National Organic Standards Board's Spring 2026 meeting. The company reaffirmed its commitment to USDA organic standards and addressed several proposals critical to organic crop production and certification processes. WFA highlighted support for adding pear ester to the National List of Allo more ST

Wolf & Associates Supports USDA Proposal on Organic Residue Testing and Calls for E-Commerce Labeling Rules (10)
WASHINGTON, May 6 -- Wolf and Associates Inc., a consultancy specializing in organic sector compliance and certification, has submitted a public comment letter to the U.S. Department of Agriculture National Organic Program regarding the Certification, Accreditation, Compliance Subcommittee's proposals on residue testing and e-commerce labeling. In their letter, Wolf & Associates expresses general support for the CACS recommendation to change mandatory residue testing requirements by balancing random testing with a risk-based approach that targ more ST