PCTC submitted comments to the Department of Commerce (DoC) in response to DoC’s request for information about the impact of federal regulations on manufacturing. PCTC’s comments focused on the impacts of “regulation by [mis]information” and the limited procedures available to stakeholders to respond to actions taken by ostensibly non-regulatory agencies attempting to influence regulation by others. PCTC summarized the advocacy research undertaken by the US Geological Survey and requested that the Department of Commerce investigate the matter:
PCTC believes that the USGS, as an agency of the U.S. government, has the responsibility not to use its perceived authority, or allow that authority to be used, to make false representations about a product that has been used safely for over 50 years, and to recognize that the science promulgated in its name does not comport either with the findings of scientists with expertise that the USGS does not have or with good scientific practice. PCTC believes that the USGS has the responsibility to correct the public record and to explain to those state and local governments that have already banned or are thinking about banning RTS that there is no sound scientific basis for those bans. Finally, PCTC believes that USGS must comply with FOIA and produce the information withheld from PCTC which, consistent with every recognized scientific practice, would allow PCTC to attempt fully to replicate and reproduce the conclusions reached by USGS in its studies.
PCTC requests the Department to investigate this matter, and to work with USGS or DOI to evaluate, independently and externally and with stakeholder involvement, the entire body of RTS-related research that the USGS has generated over the past decade-plus.