Zero-Based Regulating

The Conservation Law Foundation, Environmental Defense Fund, and Natural Resources Defense Council submitted joint comments opposing the "Zero-Based Regulating" direct final rule. They argue the rule is unlawful because it fails to provide adequate notice and comment under the Administrative Procedure Act, lacks statutory authority for mass regulatory sunsetting, and is arbitrary and capricious.

The Western Small Miners Association, a mining trade organization, opposes the proposed rule to "sunset" the Uranium Leasing Program (ULP). They argue that the rule unfairly terminates existing leaseholder rights without compensation and fails to provide a plan for maintaining the nation's strategic uranium reserves.

The Institute for Policy Integrity at New York University School of Law opposes the Department of Energy's Sunset Rule, arguing that it is arbitrary, capricious, and violates the Administrative Procedure Act. They contend that the rule bypasses meaningful public input, ignores statutory mandates, and fails to consider the costs, benefits, and security implications of sunsetting specific programs.

Premier American Uranium Inc. opposes the Direct Final Rule to sunset the Uranium Leasing Program, arguing that it extinguishes their valid lease rights without just compensation and contradicts U.S. policy to increase domestic uranium production. The company requests that the Department of Energy withdraw the rule or, at minimum, extend the comment period due to the short notice and errors in the notification.

Don Coram, President of Gold Eagle Mining, Inc., supports the "Zero-Based Regulatory" approach to streamline mining regulations and improve coordination between federal agencies. He advocates for the use of memoranda of understanding (MOUs) to reduce overlapping regulations and argues that the Department of Energy should prioritize "Unleashing American Energy" over jurisdictional boundaries.

Radiation Free Lakeland, a nuclear safety group, endorses a comment from Nuclear Free Hawaii opposing the proposed rule. They argue that the rule's "sunset" mechanism is an attempt to bypass the Administrative Procedure Act's notice-and-comment requirements for repealing regulations and that it arbitrarily threatens worker protections and cleanup obligations.

Attorneys General from 14 states and the Commonwealth of Massachusetts oppose the Department of Energy's "Zero-Based Regulating" rule, arguing it is procedurally defective and arbitrary. They contend that the rule fails to provide adequate notice, lacks a reasoned explanation for sunsetting hundreds of regulations, and violates the Administrative Procedure Act's requirements for meaningful public comment.

The commenter opposes the "Zero-Based Regulating" Direct Final Rule, arguing that it is a controversial action that should not be handled through expedited rulemaking. They contend that the rule illegally bypasses statutory requirements, threatens nuclear safety and worker protections, and lacks the necessary transparency and cost-benefit analysis required for such significant regulatory changes.

The commenter is requesting that the Department of Energy extend the public comment period for the "Zero-Based Regulating" Direct Final Rule. They argue that the 30-day window is insufficient given the complexity of the rule and the scope of the underlying Executive Order, noting that the DOE itself missed its own deadline for responding to the order.

Sherry Pollack, Co-Founder of 350Hawaii.org, opposes the Department of Energy's "Zero-Based Regulating" rule. The organization argues that the rule constitutes an illegal rollback of congressionally mandated environmental regulations and demands that the DOE withdraw the proposal.