Boyden Gray & Associates partner Jonathan Berry, formerly head of rulemaking at the United States Department of Labor, filed a letter commenting on the DOL’s proposed Employee Retirement Income Security Act (ERISA) regulation on December 13, 2021. In the letter, Berry decries the rule’s privileging of so-called “Environmental, Social, Governance (ESG)” factors as unlawful and undermining the retirement security of…
Boyden Gray & Associates filed a comment yesterday on behalf of Consumers’ Research opposing the FCC’s Universal Service Fund (USF). The comment argues that the Universal Service Fund is an unconstitutional tax raised and spent by an unaccountable federal agency. What’s more, this unaccountable federal agency–the FCC– has delegated all authority over this revenue-raising scheme to a private company registered…
Boyden Gray & Associates filed a comment yesterday on behalf of Urban Air Initiative and Consumers’ Research opposing the EPA’s proposed reinstatement of a waiver for California vehicle emission standards. The comment argues that the reinstatement of the waiver would be improper because California’s greenhouse gas emissions standards have been amended since the initial waiver was granted without EPA approval….
BG&A submitted comments submitted on behalf of The Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Missouri, Nebraska, and Wisconsin Corn Growers Associations, Ohio Corn & Wheat Growers Association, Texas Corn Producers, Urban Air Initiative, Inc., Clean Fuels Development Coalition, and American Coalition for Ethanol.