Public Comments
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CPAW submits formal comments to federal agencies, translating economic insights into actionable guidance for policymakers.
Recent Comments
To: National Marine Fisheries Service, National Oceanic and Atmospheric Administration, U.S. Department of Commerce
Re: Implementation of Fish and Fish Product Import Provisions of the Marine Mammal Protection Act, 91 Fed. Reg. 47798 (July 29, 2026) (Docket No. 260723–0179; RIN 0648–BO43)
September 4, 2026
The Center for Policy and Animal Welfare respectfully submitted comments to the National Marine Fisheries Service regarding seven of the questions posed in its Advance Notice of Proposed Rulemaking. The questions raise two issues that are related but distinct: first, whether the cost of achieving marine mammal bycatch reduction should affect a comparability finding; second, how NMFS can ease its own administrative burden without changing the standard a fishery must meet to receive a comparability finding. Our answer to the first question is negative based on the statute’s text and purpose. Our answer to the second is that the relief NMFS needs can be achieved via other means without altering the baseline standard itself.
To: Food Safety and Inspection Service, U.S. Department of Agriculture
Re: Maximum Line Speed Rates for Young Chicken and Turkey Establishments Operating under the New Poultry Inspection System, 91 Fed. Reg. 7926 (proposed Feb. 19, 2026) (Docket No. FSIS 2025-0012)
April 21, 2026
CPAW submitted a comment to the Food Safety and Inspection Service challenging its proposed rule to raise line speed limits for chicken and turkey slaughterhouses operating under the New Poultry Inspection System. We argue that FSIS's justifications are arbitrary and capricious, relying on narrow violation-rate data that misses the full range of animal welfare harms from faster line speeds, and misreading a recent Supreme Court decision to dodge analysis of worker safety impacts. CPAW also contends that the rule's projected $184 million in net benefits is inflated by systematically excluding both animal welfare costs and worker musculoskeletal injury risks from the regulatory impact analysis.
To: Food Safety and Inspection Service, U.S. Department of Agriculture
Re: Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. 7905 (proposed Feb. 19, 2026) (Docket No. FSIS-2025-0009)
April 21, 2026
CPAW submitted a comment to the Food Safety and Inspection Service challenging its proposed rule to eliminate the 1,106 head-per-hour line speed cap for hog slaughterhouses under the New Swine Slaughter Inspection System. We argue that FSIS's justifications are arbitrary and capricious, relying on narrow violation-rate data that misses the full range of animal welfare harms and misreading a recent Supreme Court decision to dodge analysis of worker safety impacts. CPAW also contends that the rule's projected $253 million in net benefits is inflated by systematically excluding both animal welfare costs and worker musculoskeletal injury risks from the regulatory impact analysis.
To: Fish and Wildlife Service, Interior
Re: Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat, 90 Fed. Reg. 52,592 (proposed Nov. 21, 2025) (FWS–HQ–ES–2025–0048)
December 8, 2025
CPAW submitted a comment to the Fish and Wildlife Service challenging its proposed approach to weighing economic impacts when excluding areas from critical habitat designation under the Endangered Species Act. We argue that FWS's framework is too narrow, ignoring both the economic benefits of including areas in critical habitat and the value Americans place on recovering threatened and endangered species. CPAW urges FWS to adopt a broader, statutorily grounded interpretation of "economic impact" that accounts for the full range of costs and benefits on both sides of the exclusion calculus.
To: Office of Information and Regulatory Affairs
Re: Proposed Revisions to Circular A-4, Regulatory Analysis
June 21, 2023
Mark Budolfson and Bob Fischer submitted a comment to the Office of Information and Regulatory Affairs urging that Circular A-4 be amended to include animal welfare effects in federal benefit-cost analysis. They argue that Americans demonstrably care about animal welfare—in surveys, at the ballot box, and in their willingness to pay for higher-welfare products—and that emerging valuation tools make it tractable to incorporate these effects into regulatory analysis. They further argue that zero willingness-to-pay does not warrant exclusion, since US livestock bear the consequences of our policy choices just as humans with zero WTP do, and their well-being is counted all the same.
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