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| Tipoffs: Public Comments on Proposed Federal Rules Newsletter for 2026-07-06 ( 42 items ) |
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11 Environmental Groups Challenge EPA Plan to Relax Coal Plant Wastewater Rules (10)
WASHINGTON, July 5 -- A coalition of 11 environmental organizations have submitted a public comment letter to the U.S. Environmental Protection Agency opposing the agency's proposed rule to weaken wastewater treatment standards for coal-fired power plants, particularly regarding "unmanaged" combustion residual leachate discharges.
The letter contends that the EPA's proposal to relax effluent limitations for unmanaged combustion residual leachate violates the Clean Water Act's requirement for the best available technology (BAT) to control water more ST
12 Advocacy Organizations Urge EPA to Withdraw Proposal Weakening Air Pollution Construction Permits (10)
WASHINGTON, July 6 (TNScap) -- A coalition of 12 advocacy organizations submitted a public comment letter to the U.S. Environmental Protection Agency opposing the agency's proposed revision to the definition of "begin actual construction" and the addition of a new definition of "pollutant-emitting activities" under the nonattainment new source review and prevention of significant deterioration =programs.
The groups stress that these changes would undermine public health protections by allowing construction of polluting facilities to proceed b more ST
13 State Attorneys General Urge DOE to Withdraw Rule Adding Sunset Dates to Critical Energy Regulations (10)
WASHINGTON, July 6 -- Attorneys general in 13 states submitted a public comment letter to the U.S. Department of Energy expressing objections to the agency's notice of proposed rulemaking entitled "Zero-Based Regulating."
The letter challenges DOE's proposal to add conditional sunset dates to regulations across 28 parts of Title 10 of the Code of Federal Regulations pursuant to Executive Order No. 14270, issued on April 9, 2025, which directs agencies to include expiration provisions in specific energy-related regulations.
The letter argue t more ST
17 Osteopathic Organizations Urge CMS to Strengthen Prior Authorization Reforms for Medicare and Medicaid Drugs (10)
WASHINGTON, July 5 -- A coalition of 17 osteopathic organizations submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare & Medicaid Services. The organizations expressed support for CMS's proposed 2026 interoperability standards and prior authorization for drugs rule but recommended enhancements to further reduce administrative burdens and improve patient care.
The group praised CMS for expanding prior authorization reforms to include drugs, noting that streamlining electronic prior authoriza more ST
35 Healthcare Advocacy Groups Urge Improvements to CMS Prior Authorization Proposed Rule (10)
WASHINGTON, July 6 -- The Partnership to Protect Coverage, a coalition of 35 healthcare advocacy organizations, submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services addressing the 2026 interoperability standards and prior authorization for drugs proposed rule. The letter reflects the collective interests of millions of patients living with serious, acute, and chronic health conditions, including individuals who rely on protections under the Affordable Care Act.
The let more ST
6 Energy, Consumer Groups Urge DOE to Uphold Energy Conservation Standards (10)
WASHINGTON, July 6 -- Six energy and consumer advocacy organizations submitted a public comment letter to the U.S. Department of Energy regarding the agency's proposed rulemaking on zero-based regulating. The letter addresses the department's plan to introduce sunset provisions in its energy conservation regulations pursuant to Executive Order 14270.
The organizations assert that the Energy Policy and Conservation Act (EPCA) prohibits the Department of Energy from rescinding or weakening existing energy conservation standards.
The letter sta more ST
Academy of Managed Care Pharmacy Recommends FDA Prioritize Human-Supervised AI Applications in Early-Phase Clinical Trials Pilot (10)
WASHINGTON, July 6 -- The Academy of Managed Care Pharmacy, Alexandria, Virginia, has provided comprehensive feedback to the U.S. Food and Drug Administration regarding the agency's AI-Enabled Optimization of Early-Phase Clinical Trials Pilot Program.
The AMCP letter, written by Geni Tunstall, Associate Vice President, Regulatory Affairs, emphasized the importance of thoughtful and responsible application of artificial intelligence in clinical trial processes, advocating for the pilot program to focus on applications that augment human judgme more ST
American Association of Nurse Practitioners Urges Bureau of Alcohol, Tobacco, Firearms, and Explosives to Update Controlled Substance Definition (10)
WASHINGTON, July 5 -- The American Association of Nurse Practitioners, Austin, Texas, submitted a public comment letter to the U.S. Department of Justice Bureau of Alcohol, Tobacco, Firearms, and Explosives advocating for a revision in the interim final rule concerning the definition of an unlawful user of or addicted to controlled substances.
The letter, from CEO Jon Fanning, recommends that the ATF replace terms like "licensed physician" and "prescribing physician" with "licensed practitioner" and "prescribing practitioner" to include nurse more ST
Association of Air Medical Services Urges FAA to Broaden Unmanned Aircraft Systems Restrictions Near Healthcare Facilities (10)
WASHINGTON, July 6 -- The Association of Air Medical Services has submitted a public comment letter to the U.S. Department of Transportation Federal Aviation Administration concerning a Notice of Proposed Rulemaking on restricting unmanned aircraft systems operations near fixed site facilities. The proposed rule aims to reduce risks in low-altitude airspace, impacting helicopter air ambulance operations which frequently share these airspace layers with drones.
AAMS acknowledges the FAA's efforts to develop a framework that balances airspace ac more ST
Bilak Security Solutions Backs Proposed Federal Acquisition Regulation Overhaul, Cites Benefits for Cybersecurity Maturity Model Certification and Cybersecurity Compliance (10)
WASHINGTON, July 5 -- Bilak Security Solutions, Conyers, Georgia, has submitted a public comment letter to the U.S. Federal Acquisition Regulatory Council concerning the proposed Federal Acquisition Regulation overhaul. The letter offers insights from the perspective of a cybersecurity risk and compliance professional working extensively with defense contractors and entities subject to Cybersecurity Maturity Model Certification requirements. The comments primarily address provisions related to controlled unclassified information, incident repor more ST
Birkinbine Logistical Support Services Urges FTA to Adopt USABahn Framework for Integration of Transit Systems (10)
WASHINGTON, July 6 -- Birkinbine Logistical Support Services Co. LLC, Columbia, Missouri, submitted a public comment letter to the Federal Transit Administration urging the agency to embrace the USABahn framework to enhance interoperability across national, regional, and local transit networks.
The letter states: "The proposed metrics currently evaluate transit agencies as isolated data silos. A transit system cannot be truly safe, reliable, or accessible if it treats passengers like cargo that resets at every jurisdictional boundary."
The or more ST
Boston Red Sox Advocate for Flexible Drone Flight Restrictions at Sports Venues (10)
WASHINGTON, July 5 -- The Boston Red Sox submitted a public comment letter to the Federal Aviation Administration regarding the agency's proposed rule on unmanned aircraft flight restrictions near fixed site facilities.
The comments, by David S. Friedman, Executive Vice President, Legal and Government Affairs, express support for the FAA's approach to restricting unauthorized drone flights while urging modifications to increase flexibility for sports and entertainment venues.
In their letter, the Red Sox emphasize that outdoor sports venues more ST
California Fresh Fruit Association Highlights Regional Concerns in EPA Fungicide Strategy Comments (10)
WASHINGTON, July 6 -- The California Fresh Fruit Association, Fresno, submitted a public comment letter to the U.S. Environmental Protection Agency regarding the agency's Draft Endangered Species Act Fungicide Strategy. As a representative of California fresh fruit growers and shippers, including significant table grape producers, the association expressed support for EPA's goal of creating a transparent and workable ESA compliance framework while emphasizing the need for regional and crop-specific considerations.
The association letter, signe more ST
California Strawberry Commission Urges EPA to Balance Fungicide Strategy With Agricultural Needs (10)
WASHINGTON, July 6 -- The California Strawberry Commission, Watsonville, submitted a public comment letter to the U.S. Environmental Protection Agency regarding the agency's draft Fungicide Strategy to Protect Endangered Species from Fungicides. The CSC represents all strawberry growers, shippers, and processors in California, whose production constitutes about 90 percent of the strawberries consumed in the United States.
The letter, signed by Amrith Gunasekara, Director of Regulatory Affairs, addresses concerns about how the draft strategy m more ST
Chicago Department of Water Management Supports FAA Proposal to Restrict Drone Operations Near Water Facilities (10)
WASHINGTON, July 6 -- The Chicago Department of Water Management, Illinois, issued a public comment letter to the U.S. Department of Transportation Federal Aviation Administration regarding a proposed rulemaking on restricting unmanned aircraft system operations near fixed-site facilities.
The letter, written by Ralph Chiczewski, Assistant Commissioner/Security and Safety, said the agency is responsible for supplying safe drinking water to most of Northeast Illinois. He emphasized the critical need to protect water infrastructure from potenti more ST
Concept Solutions Submits Public Comment Supporting Proposed FAA Drone Flight Restrictions (10)
WASHINGTON, July 5 -- Concept Solutions, Reston, Virginia, has submitted a public comment letter to the U.S. Department of Transportation Federal Aviation Administration supporting the agency's proposed rulemaking to restrict unmanned aircraft system operations near fixed site facilities.
The proposal aims to implement Section 2209 of the FAA Extension, Safety, and Security Act of 2016 by establishing Unmanned Aircraft Flight Restrictions (14 CFR Part 74).
Concept Solutions detailed how its AvenGIS Virtual Drone Management (VDM) Platform is more ST
Consortium for Constituents with Disabilities Opposes DOJ Extension of Compliance Dates for Web Accessibility Rule (10)
WASHINGTON, July 6 -- A group of 68 disability advocacy organizations operating as Consortium for Constituents with Disabilities has voiced opposition in a public comment letter to the U.S. Department of Justice's interim final rule that extends compliance deadlines for the 2024 regulation on nondiscrimination concerning web content and mobile applications accessibility. The rule impacts recipients of Departmental financial assistance and was designed to ensure equitable access for people with disabilities.
The Consortium contends that the Dep more ST
Consumer Reports Highlights Dangers of Counterfeit Certification Marks on Consumer Products (10)
WASHINGTON, July 5 -- Consumer Reports, Yonkers, New York, has submitted comments to the Consumer Product Safety Commission addressing the issue of counterfeit certification markings on consumer products.
The public comment letter, from Gabe Knight, Senior Safety Policy Analyst, responds to the commission's May 6, 2026, request for information aimed at understanding and combating misleading safety certification claims amidst a rising tide of counterfeit use especially prevalent in online marketplaces.
CR emphasized that product certification more ST
DALS Credit Solutions Urges Oversight on Sole-Source Federal Contracts (10)
WASHINGTON, July 5 -- Lynette T. Stevenson, owner of DALS Credit Solutions Co., submitted a public comment letter to the U.S. General Services Administration regarding proposed changes (FAR Case 2026-002). The letter addresses concerns about the Federal Acquisition Regulation revisions affecting part 6, which governs awards made without full and open competition, specifically focusing on sole-source and single-offer contracts. DALS Credit Solutions represents individually owned small businesses that typically lack in-house legal or compliance r more ST
Defenders of Wildlife Raises Concerns Over Expansion of Hunting and Fishing on National Wildlife Refuges (10)
WASHINGTON, July 6 -- Defenders of Wildlife has submitted a public comment letter to the U.S. Fish and Wildlife Service regarding the 2026-2027 Station-Specific Hunting and Sport Fishing Regulations. The organization expressed concern that the proposed expansion of hunting and fishing access on National Wildlife Refuges could undermine wildlife conservation goals due to chronic staffing shortages.
The letter, signed by Nathan Marcy, Senior Federal Lands Policy Analyst, highlights that staffing levels have declined by approximately 40 percent s more ST
Delta Waterfowl Supports U.S. Fish and Wildlife Service Hunting and Fishing Regulations (10)
WASHINGTON, July 6 -- Delta Waterfowl, a conservation organization in Bismarck, North Dakota, expressed support for the U.S. Fish and Wildlife Service's 2026-2027 Station-Specific Hunting and Sport Fishing Regulations in a public comment letter. The organization, representing waterfowl hunters and conservationists, emphasized the importance of the rule in expanding hunting access on National Wildlife Refuge System lands.
The Delta Waterfowl letter, written by Cyrus Hunter Baird, Vice President of Government Affairs, praised the agency for its more ST
Environmental Justice Group Opposes EPA Plan to Ease Coal Ash Waste Rules (10)
WASHINGTON, July 5 -- Young, Gifted & Green, a national civil rights and environmental justice organization based in Memphis, Tennessee, has submitted a public comment letter to the U.S. Environmental Protection Agency opposing the agency's proposed amendments to coal combustion residuals disposal regulations.
The group, in a letter signed by LaTricea D. Adams, Founder, CEO and President, urges the EPA to withdraw its proposal and maintain the May 8, 2024 Legacy Final Rule that sets stricter closure and monitoring standards for legacy coal as more ST
Everytown for Gun Safety Raises Concerns Over Bureau of Alcohol, Tobacco, Firearms and Explosives Interim Final Rule on Drug Use and Firearm Purchases (10)
WASHINGTON, July 5 -- Everytown for Gun Safety Support Fund, New York, has criticized the U.S. Department of Justice Bureau of Alcohol, Tobacco, Firearms and Explosives for an interim final rule revising the definition of "unlawful user of or addicted to any controlled substance" under federal gun laws. The rule changes, released in January 2026, have sparked concern over public safety risks and procedural issues related to regulatory implementation.
The letter, from Justin Wagner, Senior Vice President for Law and Policy, ATF highlights alarm more ST
Exponential Technologies Calls for Broad Food and Drug Administration Pilot on AI in Early-Phase Clinical Trials (10)
WASHINGTON, July 6 -- Exponential Technologies Corp., Boston, Massachusetts, has communicated support for the U.S. Food and Drug Administration's proposal to initiate a pilot program evaluating artificial intelligence-enabled technologies in early-phase clinical trials.
The letter, written by Octavian Boca, Founder & CEO, emphasized the importance of thoughtfully designed AI tools that enhance protocol quality, improve decision-making efficiency, and boost patient safety while maintaining stringent regulatory oversight and fostering trustwort more ST
FLINT Network Calls for Inclusion of Verifiable Credentials in Stablecoin Customer Identification Rules (10)
WASHINGTON, July 6 -- KillChain Inc., San Francisco, California, operating as FLINT Network, has submitted a public comment letter to the U.S. Department of the Treasury Financial Crimes Enforcement Network regarding the joint proposed rulemaking on customer identification programs for permitted payment stablecoin issuers under the GENIUS Act.
The letter, written by Joseph Taylor, Founder and Chief Executive Officer, addresses related inputs requested by the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve more ST
Friends of Animals Urges Reevaluation of Hunting and Lead Ammunition Policies on National Wildlife Refuges (10)
WASHINGTON, July 6 -- Friends of Animals, a non-profit international advocacy organization based in New York, has submitted a public comment letter to the U.S. Department of the Interior Fish and Wildlife Service opposing a proposed rule to expand hunting and sport fishing across 111 units of the National Wildlife Refuge System for 2026-2027. The organization warns that the proposal contradicts the conservation mission of the NWRS and could jeopardize numerous wildlife species and their habitats.
The U.S. Fish and Wildlife Service oversees the more ST
Giffords and Brady Criticize Bureau of Alcohol, Tobacco, Firearms, and Explosives Interim Rule on Controlled Substance Users and Firearms (10)
WASHINGTON, July 5 -- Giffords Law Center to Prevent Gun Violence and Brady United Against Gun Violence submitted a public comment letter to the Bureau of Alcohol, Tobacco, Firearms, and Explosives criticizing the agency's interim final rule revising the definition of "unlawful user of or addicted to controlled substance."
The organizations expressed serious concerns regarding the rulemaking process and potential public safety impacts.
The letter highlights that the ATF did not follow the required notice-and-comment procedures outlined in th more ST
Healthy Aging Coalition Urges CMS to Improve Prior Authorization Transparency and Extend Drug Coverage Reporting (10)
WASHINGTON, July 5 (TNScap) -- The Healthy Aging Coalition has submitted public comments to the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services addressing the 2026 interoperability standards and prior authorization for drugs proposed rule.
The coalition represents a broad alliance of stakeholders, including researchers, clinicians, advocacy groups, and industry leaders, united in promoting policies that advance healthy aging and independence for older adults.
The coalition emphasized the need for data more ST
Humane World for Animals, Action Fund Oppose Expanded Hunting and Lead Ammunition on National Wildlife Refuges (10)
WASHINGTON, July 6 -- Humane World for Animals and Humane World Action Fund submitted a public comment letter to the U.S. Fish and Wildlife Service expressing opposition to the proposed rule to open or expand more than 1,450 hunting opportunities across 107 units of the National Wildlife Refuge System and four units of the National Fish Hatchery System for the 2026-2027 season.
The proposal, announced on May 27, 2026, includes the first-time opening of hunting in fourteen National Wildlife Refuges and three National Fish Hatcheries. Humane Wo more ST
Insurance Watchdog Coalition Urges Stronger Enforcement in CMS Drug Prior Authorization Rule (10)
WASHINGTON, July 5 -- The Insurance Watchdog Coalition has submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare & Medicaid Services urging the federal agency to strengthen its proposed Interoperability Standards and Prior Authorization for Drugs rule.
The coalition letter, from Executive Director Mark Merritt, advocates for measures that would reduce insurance barriers delaying access to medications, emphasizing the need for firm timelines, transparency, and enforcement mechanisms in prior more ST
LONGBOW Group Urges FAA to Establish Structured Airspace Protections for UAS Near Critical Infrastructure (10)
WASHINGTON, July 5 -- The LONGBOW Group, Hampton, Virginia, submitted a public comment letter to the Federal Aviation Administration concerning the agency's Notice of Proposed Rulemaking (14 CFR Part 74). This proposed rule seeks to restrict the operation of unmanned aircraft systems in close proximity to fixed-site critical infrastructure through a framework of Unmanned Aircraft Flight Restrictions, said CEO Marco Sterk.
LONGBOW, with expertise in airspace operations platforms for UAS and experience as an FAA-designated Low Altitude Authoriza more ST
Mass. Union of Public Housing Tenants, Law Reform Institute Urge HUD to Withdraw Proposed Rule Harmful to LGBTQ+ Public Housing Residents (10)
WASHINGTON, July 6 -- The Massachusetts Union of Public Housing Tenants, Dorchester, and the Massachusetts Law Reform Institute, Boston, have submitted a public comment letter to the U.S. Department of Housing and Urban Development. The letter expresses opposition to HUD's proposed revisions to the Equal Access to Housing in HUD Programs rule, raising concerns that these changes would harm LGBTQ+ families in federally funded public and subsidized housing.
Mass Union and MLRI assert that the proposed rule reflects an attack on LGBTQ+ families r more ST
McKesson Suggests Risk-Based AI Governance for Early-Phase Clinical Trials Pilot Program (10)
WASHINGTON, July 6 -- McKesson Corp., Irving, Texas, a healthcare distribution and technology company, provided detailed recommendations to the U.S. Department of Health and Human Services Food and Drug Administration regarding its proposed AI-Enabled Optimization of Early-Phase Clinical Trials Pilot Program. The public comment letter emphasized the importance of trustworthy, scalable artificial intelligence paired with high-quality data as foundational to improving early clinical trial efficiency, safety, and decision-making.
The McKesson let more ST
National Shooting Sports Foundation Urges BATF to Remove Chief Law Enforcement Officer Notification Requirement Under National Firearms Act (10)
WASHINGTON, July 5 -- The National Shooting Sports Foundation, a trade association based in Newtown, Connecticut, representing the firearms, ammunition, hunting, and shooting sports industry, has submitted a public comment letter to the U.S. Department of Justice Bureau of Alcohol, Tobacco, Firearms and Explosives regarding a proposed rulemaking to remove the Chief Law Enforcement Officer notification requirement under the National Firearms Act. The Bureau is part of the U.S. Department of Justice.
The NSSF, through a letter by Lawrence G. Kea more ST
Noetik Proposes FDA Pilot Priorities for Early-Phase Clinical Trials (10)
WASHINGTON, July 6 -- Noetik, an AI-native clinical-stage oncology company in Boston, Massachusetts, submitted a public comment letter to the U.S. Department of Health and Human Services Food and Drug Administration regarding its pilot program for AI-enabled optimization of early-phase clinical trials. The company urged the agency to prioritize first-in-human and early-phase biomarker-driven oncology trials, emphasizing AI's potential to improve patient selection and trial efficiency in cancer therapies.
The letter states: "What criteria shoul more ST
North American Fungicide Resistance Action Committee Raises Concern Over EPA's Draft Fungicide Strategy Impact on Resistance Management (10)
WASHINGTON, July 6 -- The North American Fungicide Resistance Action Committee submitted a public comment letter to the Environmental Protection Agency regarding the Draft Fungicide Strategy to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Fungicides. NA-FRAC expressed support for protecting threatened species but highlighted concerns that some mitigation measures in the draft could unintentionally accelerate fungicide resistance and undermine the more ST
Northern Indiana Public Service Advocates for Revisions to EPA's Coal Combustion Residuals Regulations (10)
WASHINGTON, July 6 -- Northern Indiana Public Service Co., Merrillville, has submitted a public comment letter to the U.S. Environmental Protection Agency concerning the agency's proposed amendments to the hazardous and solid waste management regulations governing disposal of coal combustion residuals. The comments address the April 13, 2026, proposed rule titled "Disposal of Coal Combustion Residuals From Electric Utilities; Legacy/CCRMU Amendments," published in the Federal Register at 91 Fed. Reg. 18968.
NIPSCO, as an owner and operator of more ST
Peace Ridge Sanctuary Urges U.S. Fish and Wildlife Service to Protect Wildlife Refuges From Expanded Hunting and Lead Use (10)
WASHINGTON, July 6 -- Peace Ridge Sanctuary, a nonprofit animal advocacy and conservation organization in Brooks, Maine, submitted a public comment letter to the U.S. Fish and Wildlife Service opposing the proposed 2026-2027 station-specific hunting and sport fishing rule.
The letter, signed by Peter J. McKosky, Legal & Policy Administrator & Advocate, called for the withdrawal of provisions that would expand hunting and fishing opportunities within National Wildlife Refuges and National Fish Hatcheries and urged the retention and strengtheni more ST
Safari Club International Urges Expanded Hunting Opportunities in National Wildlife Refuges (10)
WASHINGTON, July 6 -- Safari Club International, a nonprofit organization representing over 100,000 hunters and advocates worldwide, has expressed support for the U.S. Fish and Wildlife Service's 2026-2027 Station-Specific Hunting and Sport Fishing Regulations.
The proposed rule seeks to open and expand hunting on 103 National Wildlife Refuges and four National Fish Hatcheries across 32 states, including opening hunting for the first time on ten refuges and three hatcheries. If finalized, the proposal would make more than 92 million acres-ove more ST
Teamsters California Advocates for Reversal of Commercial Driver's Licenses Ban Impacting DACA Recipients (10)
WASHINGTON, July 6 -- Teamsters California, Los Angeles, has submitted a public comment letter to the Federal Motor Carrier Safety Administration challenging a new federal rule that prohibits most noncitizens, including Deferred Action for Childhood Arrivals holders, from obtaining or renewing commercial driver's licenses. The organization represents 250,000 workers across multiple industries and asserts that the rule unfairly harms thousands of experienced drivers without improving road safety.
The letter supports an exemption application fil more ST
Virginia Maritime Association Urges Careful Review of Offshore Mineral Leasing Near Virginia Ports (10)
WASHINGTON, July 5 -- The Virginia Maritime Association, Norfolk, has submitted a public comment letter to the U.S. Department of the Interior Bureau of Ocean Energy Management regarding commercial leasing for Outer Continental Shelf minerals off the coast of Virginia.
The association letter, from Executive Director David White, highlighted concerns about potential impacts on maritime commerce and navigation safety due to proposed leasing areas overlapping key shipping routes.
Representing nearly 400 businesses involved in waterborne commerc more ST
Wave Life Sciences Urges Clarification on FDA AI Clinical Trials Pilot Program (10)
WASHINGTON, July 6 -- Wave Life Sciences, a biotechnology company in Cambridge, Massachusetts, submitted a public comment letter to the U.S. Food and Drug Administration regarding the Request for Information on the AI-Enabled Optimization of Early-Phase Clinical Trials Pilot Program.
The letter, signed by Victoria Hayes, Vice President Regulatory and Policy, focused on advancing RNA medicine therapeutics across rare and chronic diseases, expressed overall support for the program while emphasizing the need for clear guidelines to ensure safe a more ST
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