Zero-Based Regulating

The Colorado Mining Association (CMA) opposes the proposal to establish conditional sunset dates for regulations administering the Uranium Leading Program (ULP). They argue that sunsetting these provisions could compromise significant investments made by leaseholders and negatively impact the domestic supply of critical minerals.

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.

Battelle Memorial Institute, the operator of the Pacific Northwest National Laboratory (PNNL), opposes the proposed sunsetting of several Department of Energy regulations. They argue that removing these regulations would create uncertainty, increase liability, stifle research innovation, and lead to inconsistent standards and pricing across the DOE complex.

Tri-Valley CAREs, a nonprofit organization, opposes the "Zero-Based Regulating" rule because it could lead to the automatic expiration of critical safety, security, and whistleblower protection regulations. They argue that any changes or repeals of such rules should occur through a transparent, public process rather than an automatic sunset mechanism.

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.

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.

A pediatric nurse opposes the proposed action, arguing that it bypasses congressional oversight and eliminates critical safety protections, whistleblower protections, and environmental regulations. The commenter expresses concern that the rule allows for the reallocation of funds intended for Superfund site cleanups and the removal of guidelines for nuclear waste disposal.

Ace and Sharon Hoffman oppose the proposed rule, arguing that it bypasses congressional oversight and eliminates critical protections for public health, environmental safety, and whistleblower rights. They specifically criticize the reallocation of Superfund cleanup funds and the removal of nuclear waste siting guidelines as dangerous and illegal actions.