Regulatory Comments


Independent Contractor Status Under the Fair Labor Standards Act, Regulatory Information Number (RIN) 1235-AA34
Eli Lehrer

To: Amy DeBisschop
Director, Division of Regulations, Legislation and Interpretation
Department of Labor
Wage and Hour Division

From: The R Street Institute,…

Defense Spectrum Sharing Request for Information
Jeffrey Westling

I. Introduction
The R Street Institute has long advocated for policies that promote efficient radio operations in the United States, including spectrum sharing and innovative allocation and…

Post-Technical Conference Comments Hybrid Resources
Beth Garza

I. Issue Summary
On July 23, 2020, the staff of the Federal Energy Regulatory Commission (Commission or FERC) convened a technical conference to discuss hybrid resources. 1 In this context, hybrid…

Comments of R Street Institute Opposing the National Telecommunications and Information Administration’s Petition for Rulemaking
Jeffrey Westling

 I.     Introduction & Summary
As society continues to adapt to the digital world, the Federal Communications Commission (FCC) stands at the forefront to facilitate the development and…

RE: R Street Institute and Taxpayers for Common Sense Response to RIN 2590-AA95
R.J. Lehmann

Our organizations welcome the opportunity to provide comment on the FHFA’s 2020 Proposed Capital Rule. The R Street Institute and Taxpayers for Common Sense are both 501c3 research organizations…

USDA Dietary Guidelines on Alcohol Comments
C. Jarrett Dieterle & Chelsea Boyd

Secretary Sonny Perdue
United States Department of Agriculture
1280 Maryland Ave SW
Washington, DC 20250

Dear Secretary Perdue:

The following comments are respectfully submitted in response…

Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process
Devin Hartman


On June 11, 2020, the U.S. Environmental Protection Agency (EPA) published a notice of proposed rulemaking (NOPR) to increase the consistency and transparency in considering benefits…

RE: CAS Task Force Draft White Paper, Exposed 6-12-2020
R.J. Lehmann

I write you as director of finance, insurance and trade policy at the R Street Institute, a nonprofit, nonpartisan public policy research organization (“think tank”). We appreciate the…

Petition to Expand Marketing Opportunities for Innovative Technologies
Jeffrey Westling

I. Introduction
As technology advances, so too must the Federal Communications Commission (“FCC” or “Commission”) and its regulatory regime. Over the last four years, the Commission has…

CTIA-US Telecom Petition for Rulemaking and Declaratory Ruling Regarding Certain Pro Forma Transactions
Jeffrey Westling

I. Introduction
Transactions involving radio operating rights often involve significant administrative costs for both the parties involved and the Commission. As only a limited number of operators…