[PAA-Discuss] FW: Stop Susan Dudley Now!

[zappa2004]

Stop Susan Dudley Now!
-----Original Message-----
From: ombwatch at ombwatch.org [mailto:ombwatch at ombwatch.org]
Sent: Thursday, October 19, 2006 10:07 AM
To: Kathryn Melton
Subject: Stop Susan Dudley Now!


            PLEASE Circulate to Others!

            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 at 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:


              a.. Opposed EPA's attempts to keep arsenic out of drinking
water and enforce lower levels of disease-causing smog;
              b.. Questioned life-saving air bag regulations and the
Department of Transportation's hours-of-service rules to keep sleep-deprived
truck drivers off the roads;
              c.. Has standards that would make it nearly impossible for
agencies to justify public health, safety, civil rights, environmental, or
other public interest protections - a special interest dream come true;
              d.. Supports regulatory sunsets that force agencies to stop
everything and re-justify the need for every rule on the books; and
              e.. Is viewed as extreme even by her conservative colleagues.

            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.


            Sincerely,





            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.



            *****************************

            TEXT OF LETTER TO SENATE



            *****************************


            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:


              a.. Smog is good for you - and all those poor asthmatic
children who would suffer in peak ozone periods should just stay indoors.
              b.. There is no economic justification for protecting workers
through the Davis-Bacon Act or the Occupational Safety and Health Act.
              c.. Improved standards lowering the levels of arsenic in our
drinking water were an "unwelcome distraction."
              d.. We are too irrational to exercise our right to know about
the toxic hazards to which we are exposed.
              e.. Advanced air bag designs should not be mandatory in all
vehicles, because if the public truly wanted them the market would have
already provided them.


            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.



            Sincerely,





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