March 3, 1998

The Honorable Diane Feinstein
United States Senate
Washington, D.C.  20510-0504

Dear Senator Feinstein,

As a a participant to several members of a broad-based coalition of organizations representing working men and women, the environment, consumer concerns, public 
health, human needs, education, civil rights and other public interest issues, 
I urge you to oppose S. 981, the "Regulatory Improvement Act," and the proposed
substitute vehicle for that legislation, released by Senator Thompson on 
February 4, 1998.

As you may know, many citizens as well as health, safety, and environmental
organizations have vigorously objected to S. 981 because it would make it much 
harder for government agencies to protect the public. While the bill's sponsors 
assert the new substitute corrects the major flaws in the bill, I must disagree. 
Indeed, in a number of specific respects discussed in the attached analysis, the
substitute bill increases the difficulties that agencies would face in attempting 
to safeguard the public. The bill, if enacted, would severely damage the 
government's ability to protect us all from serious harm to our health, safety, 
and the environment. For these reasons I beg you to oppose its passage.

The substitute would hamstring health, safety, and environmental agencies and 
threaten the public in five major ways. 

The bill would: 

1) Delay agency decision-making with new red tape that creates a thicket of 
complex procedures for adopting new protective rules.

2) Create major new opportunities for regulated interests to attack protective 
rules in the courts.

3) Establish a sweeping, time-consuming program allowing industry scientists to 
suppress new protections in a secret "peer review" process.

4) Hamper agency efforts to address current threats by diverting scarce resources 
to unnecessary mandatory reviews of thousands of existing safeguards, without 
regard to the need for such review (a newly added provision that did not appear 
in the bill as introduced).

5) Place a priority on reducing compliance costs for regulated industries rather 
than achieving needed protections.

These provisions of the substitute bill, separately and in combination, would harm
the public's interest in safe food, safe water, safe workplaces and a healthy
environment. They would create tests that emphasize costs rather than safety, 
procedures that delay action, new tools for industry lawyers to attack rules 
in court, unfair review panels, and impossible demands to review existing rules 
that have been critical to progress we have made in improving the quality of 
life over the last 25 years. I therefore respectfully urge you to oppose 
this legislation.

The disability community is one of the largest and most underrepresented groups 
in the State as well in the nation.
 
Thank you very much for your time to read this letter and I anticipate your 
response.

Sincerely,

Richard Roehm
Deaf Watch Newsletter
(Address Snipped)