Groups Oppose Trump’s Two-Out-One-In Executive Order on Regulations

February 28, 2017 | Download PDF

Dear President Trump:

We, the undersigned consumer, small business, labor, good government, financial protection, community, health, environmental, civil rights and public interest groups, write in strong opposition to your Jan. 30, 2017 executive order that purports to establish a regulatory budget and to require two regulations to be eliminated for each new one adopted. This sweeping, unlawful and arbitrary directive cannot be justified on any rational grounds. If implemented, its flawed reasoning and vague drafting would leave Americans more vulnerable to financial, safety, health, and environmental hazards.

Americans rely on public safeguards to preserve human health, safety, financial stability, quality of life, and combat discrimination. The benefits of regulations are the reason that we have them. Despite this, your executive order strives to establish a regulatory budget that focuses entirely on the cost of compliance to the exclusion of benefits created or harm avoided.

We all know that pollution-induced disease, contaminated food, unsafe workplaces, and dangerous consumer products inflict real economic and human tolls, just as we know that the shoddy financial practices that caused the Great Recession had devastating economic impacts to consumers and small businesses everywhere. Yet your executive order completely ignores the economic and social benefits that come from preventing such harms. Furthermore, the directive does not even acknowledge that major rules that most benefit the public already undergo thorough cost-benefit analysis. Analyses from administrations of both political parties have consistently found that the net impact of federal regulations is vastly more financial and social benefits than compliance costs.

If implemented, the executive order’s “pay-go” provision would set an arbitrary and blanket requirement that two regulations must be repealed for each new one adopted. It is premised on the erroneous notion that most existing protections serve no purpose or that underlying hazards vanish when a protection is revoked. It also fails to account for the enormous due diligence that agencies undertake when the law compels regulatory action. Nothing in the language of the order requires thoughtful evaluation of a rule’s merit. In fact, the previous administration – building on prior efforts by administrations of both parties – already instituted a review process that has eliminated many obsolete rules and, if allowed to run its course, would be more than equal to the task of eliminating any obsolete rules that remain.  There is no reason to believe there are enough obsolete regulations on the books to sustain the order’s draconian requirement for offsetting even the steady flow of basic regulatory actions that American businesses need to keep the pharmaceutical market working or our transportation infrastructure functional.

Americans did not vote to be exposed to more health, safety, environmental and financial dangers, yet this is precisely the effect that your executive order would have, if implemented. Its biased design virtually ensures that critical protections would be abandoned. Its sole focus on compliance costs would also ensure that protections with enormous net benefits would be passed up.

As organizations that protect the public against a broad spectrum of dangers, we strongly oppose this order, and urge its immediate withdrawal.

Thank you,

350 Maine

9to5, National Association of Working Women

AFL-CIO

African American Health Alliance

Alaska Wilderness League

Alliance for Nurses for Healthy Environments

American Association for Justice

American Association of University Women (AAUW)

American Family Voices

American Federation of Teachers

American-Arab Anti-Discrimination Committee

Americans for Financial Reform

Amigos Bravos

And All Her Ways Are Peace

Association of Asian Pacific Community Health Organizations (AAPCHO)

Bend the Arc Jewish Action

Beyond Nuclear

BlueGreen Alliance

Bluestem Communications

Center for Accessible Technology

Center for Biological Diversity

Center for Digital Democracy

Center For Food Safety

Center for Medicare Advocacy, Inc.

Center for Progressive Reform

Center for Responsible Lending

Center for Science in the Public Interest

Citizens’ Environmental Coalition

Clean Water Action

ClimateMama

Coalition For A Safe Environment

Coalition on Human Needs

Communications Workers of America

Connecticut Fair Housing Center

Consumer Action

Consumer Federation of America

Consumers for Auto Reliability and Safety

DC Consumer Rights Coalition

Defenders of Wildlife

Earthjustice

Earthworks

Ecology Center

Economic Policy Institute

Endangered Habitats League

Endangered Species Coalition

Environmental Defense Fund

Environmental Integrity Project

Environmental Working Group

Equal Justice Society

Family Equality Council

Food & Water Watch

Free Press

Friends of the Earth

Gasp

Global Witness

GreenLatinos

Health Professionals and Allied Employees, AFT/AFL-CIO

Human Rights Campaign

Institute for Agriculture and Trade Policy

Institute for Science and Human Values

International Center for Technology Assessment

International Fund for Animal Welfare (IFAW)

Iowa Environmental Council

Jean-Michel Cousteau’s Ocean Futures Society

Labadie Environmental Organization (LEO)

Labor & Employment Committee of National Lawyers Guild

Lake Champlain Committee

League of Conservation Voters

League of Women Voters of the United States

Legal Aid at Work (formerly Legal Aid Society-Employment Law Center)

Louisiana Environmental Action Network

Lower Mississippi River Foundation

Lower Mississippi Riverkeeper

Main Street Alliance

MassCOSH (Massachusetts Coalition for Occupational Safety & Health)

Milwaukee Riverkeeper

Mississippi River Network

Mobile Law Center

NAACP

National Association for College Admission Counseling

National Association of Consumer Advocates

National Center for Law and Economic Justice

National Center for Lesbian Rights

National Center for Transgender Equality

National Consumer Law Center (on behalf of its low income clients)

National Consumers League

National Education Association

National Employment Law Project

National Employment Lawyers Association

National Health Law Program

National Law Center on Homelessness & Poverty

National LGBTQ Task Force

National Organization for Women

National Parks Conservation Association

National Partnership for Women & Families

National Women’s Law Center

Natural Resources Defense Council

NETWORK Lobby for Catholic Social Justice

New York Lawyers for the Public Interest

Northwest Consumer Law Center

Occupational Health Clinical Centers

Occupational Safety & Health Law Project

Ocean Conservancy

Ohio Citizen Action

OVEC-Ohio Valley Environmental Coalition

Pesticide Action Network

Prairie Rivers Network

Progressive Congress Action Fund

Public Citizen

Public Justice Center

Public Knowledge

Puget Soundkeeper Alliance

Racial and Ethnic Health Disparities Coalition

Sargent Shriver National Center on Poverty Law

Sierra Club

SouthWings

Sugar Law Center for Economic & Social Justice

Tennessee Clean Water Network

The Leadership Conference on Civil and Human Rights

The Trevor Project

The Voter Participation Center

The Wilderness Society

Turtle Island Restoration Network

U.S. PIRG

Union of Concerned Scientists

Unitarian Universalist Congregation of Princeton NJ

United Church of Christ, OC Inc.

United Steelworkers

Utah Physicians for a Healthy Environment

Voices for Progress

Western Watersheds Project

Women’s Voices for the Earth

Women’s Voices Women Vote Action Fund

Woodstock Institute

Workers’ Center of Central New York

Worksafe

Young Progressives Demanding Action