Stop Jordan Cove

Our next big fight with Trump and his fossil fuel cronies is coming to a head this week in Oregon.

Jordan Cove is a proposed gas terminal in Oregon that would be responsible for more than 36 million tons of global warming pollution. It would be fed by the Pacific Connector pipeline, which will require a 95-foot-wide clear-cut through southwest Oregon’s forests and farms.

In May the Oregon Department of Environmental Quality (DEQ) pipeline denied the Clean Water Act permit for this dirty and dangerous project. But that’s exactly the kind of state permit that Trump hopes to overrule with his pro-pipeline executive orders. Trump’s executive order is only triggered if a federal agency says yes after a state agency has said no, and that brings us back to, you guessed it, FERC (the Federal Energy Regulatory Commission).

FERC is reviewing Jordan Cove now, and their comment period closes this week. We’ve got a plan to deliver all the signatures on this petition at their next meeting in DC. Can you sign on now to say you oppose Jordan Cove and all fracked gas infrastructure?

It’s a showdown in the Pacific Northwest between our movement to stop fossil fuels and climate change, and the Trump team and their dirty power grab. But this isn’t event eh first time – Jordan cove has been proposed two other times, in 2005 and 2013, and we’ve defeated it before. That’s how we know we can win.

And we have to win: Jordan Cove and the connected Pacific Connector Pipeline would cut through private and public lands — including traditional hunting and fishing areas important to local tribes. All to deliver fracked gas, a global warming pollutant up to 80 times more potent than carbon dioxide, for export.

But even elected officials like Governor Brown, Congressman Defazio and Senator Ron Wyden, who claim to believe in climate science and support a Green New Deal, have been slow to come out against Jordan Cove. These are the things that give us trust issues and led us to run whole campaigns critiquing the Green New Deal RESOLUTION for not saying the words “fossil fuels”, “Pipelines” or “exports”.

The IPCC and the Trump Administration’s own National Climate Assessment give us less than 12 years to make massive changes in our economy and energy sector before we face devastating and irreversible climate chaos.
Politicians at FERC and in Congress need to act now on a Green New Deal that invests in renewable energy and puts communities on the front lines of environmental destruction at the center of the solutions. There isn’t a moment to waste on Jordan Cove and other gas export terminals and pipelines, as we’ve been telling them for months.

Now, it’s time for our leaders to choose. Jordan Cove and the Pacific Connector would be a climate disaster. Sign now to tell FERC to #StopJordanCove and all LNG exports.

Trump appointees at FERC are reviewing Jordan Cove’s application now. They’ve already held public hearings across Oregon, which mostly tried to ignore the overwhelming public opposition. That same blind ignorance has led them to approve several new gas export facilities in the last few weeks and is why acting FERC chair Neal Chatterjee expressed enthusiastic support when the Trump Administration’s touted gas exports as #freedomgas.

And if FERC rules against Oregon’s communities, tribes and climate they can use eminent domain enforced by armed federal marshals to seize Oregon Tribes’ and landowners’ property.

This is a dangerous moment – and our elected officials, including our senators and members of Congress, need to stand up to Trump and his fossil fuel agenda. Sign now to make sure they get the message and say NO to Jordan Cove and the Pacific Connector Pipeline NOW.

What are we going to eat under the Green New Deal?

Ok, you’ve heard the hype: The Green New Deal is going to ban hamburgers (it doesn’t); the Green New Deal will force vegan soylant green on the unwilling masses (nope); The Green New Deal doesn’t care about farmers — actually, on that last one, it could do a better job helping farmers, but not because it’s an evil socialist plot. The Green New Deal RESOLUTION is just a little vague on the whole food and agriculture thing, and that’s a problem because we can’t solve the climate crisis without changing our food and agriculture system.

A few weeks ago, we were proud to join more than 300 other groups in sending a letter to Congress demanding that they take on food and agriculture as part of a Green New Deal. But the House committees where this could be considered have been busy with disaster relief, or worse, wasting time on big bailouts to corporate agriculture as part of the 2019 farm bill.

Will you help us give them a kick by signing this petition demanding congress tackle food and agriculture issues in the Green New Deal?

Farming and food is the biggest overall employer in the United States, employing some 23.5 million people. If you have a brother, sister, mother, daughter, father, son, friend or neighbor, odds are that one of them works in food and farming.

Partly because of its size, food and agriculture are also one of our biggest contributors to climate change. Meanwhile, the agricultural industry that we all depend upon — as well as the farmers, fishers, farmworkers, food-chain workers, and communities that make up our entire agricultural economy — are harmed by the impacts of weather-related disasters and disruptions as the effects of climate change come to pass.

For the Green New Deal to be truly effective, the workers who grow, cook and care for our food — from the immigrant picking vegetables in the field, to the truck driver who transports them, to the chef or line-cook who prepares your meal, and everyone in between — needs to be part of the solution.

Our petition lays out four key demands for a Green New Deal that makes food more delicious, the agricultural sector more fair, and fights climate change at the same time:

  • Carbon reduction, sequestration and climate resilience via a rapid, just transition that empowers farmers and ranchers to adopt ecologically regenerative, organic and agroecological practices;
  • Fair prices for farmers, ranchers and fishers, anti-trust measures that help reverse food sector consolidation, and healthy working conditions with family-sustaining living wages for workers;
  • Diversified, resilient local and regional food economies anchored by family farmers, ranchers and fishers that ensure healthy, sustainable food for all, combat consolidation in the food and farming sector and reverse the rapid loss of farmers and deterioration of farmland;
  • Avoid “false solutions” and agribusiness-sponsored proposals that do nothing to address the systemic causes of our climate crisis and delay progress.

Making fundamental changes to our food and farming system is urgent and central to reducing the impacts of  climate change , and is crucial to ensuring food and agricultural justice for the most vulnerable for current and future generations. Sign now to support a Green New Deal that respects the role food and agriculture play in addressing our climate crisis. Science shows that we have no time to lose.

Taking the fight to #fossilbanks

Get Excited — It’s shareholder meeting (AGM to our friends in Europe) season; And this year we’re taking the fight to some of the biggest #FossilBanks and investors on the planet.

You may remember a few weeks ago when a coalition of friends (including 198 methods) released a big report showing that global banks have invested $1.9 trillion in fossil fuels. Now, those same banks, and the pipeline companies they finance are holding annual shareholder meetings and we’re ramping up the pressure to demand they #Divest from fossil fuels and climate chaos as part of a Green New Deal.

The first events start this week in Seattle and Charlotte (amongst other places) check it out and sign up to join and event near you.

OR – if you can’t make it to an event or there isn’t one planned near you right now – click here to chip in $1.98 or more to help us challenge these banks and corporate frackers in front of their shareholders with daring and creative protests.

These protests are part of a big, international, coalition that’s working to make the climate crisis a real, immediate concern for big banks and investors. Because to stop a further climate chaos, we urgently need to bring the fossil fuel era to an end. But only massive public pressure will make banks divest from pipelines, fracking wells and other climate-wrecking industries. So we need your help and participation to build that pressure on the Fossil Banks.

So what’s our plan? We’ll be all over this spring protesting at shareholder meetings. Check out some of the upcoming events or visit our Facebook page to see and RSVP:

  • April 10 – Charlotte NC and all over the Country protesting at Chase and Wells Fargo branches, in particular.
  • April 24 – Bank of America Shareholder meeting in Charlotte NC; and
  • May 7 – Dominion Shareholder Meeting Columbia SC

Lots more events are being planned – so stay tuned and drop us a line on Facebook, on Twitter, or right here on the good old fashioned website if you have an AGM/Shareholder meeting you want help planning!

Image courtesy of Fund Our Future

Talk about the Green New Deal, not this Senate vote

Let’s get one thing clear about this week’s Senate vote on a Green New Deal: Mitch McConnell is a twerp.

The resolution that was voted on this week was not the non-binding Green New Deal resolution introduced by Sen. Edward Markey (D-Mass.) and Rep. Alexandria Ocasio-Cortez (D-N.Y.), which we’ve talked. a lot. about.

That resolution would need to be referred to committee, where it would have committee hearings and consideration and debate – the kind of stuff that might address the concerns we and others have raised about banning fossil fuels, stopping pipelines, and the like. It also would give time and space to fill in details that are missing.

McConnell doesn’t want that debate, so he introduced this binding resolution making “it is the sense of the Senate” that the Green New Deal should become “the policy of the United States.” Like I said, he’s a twerp.

But Whatever McConnell’s shady motivations, this week’s vote was a slap-in-the-face loss to the climate community. The vote was 57-to-0, with 4 Dems, 1 Independent and every Republican voting “no” and all other dems voting “present.”

That’s especially galling because the oil, gas, & coal industries contributed more than $55 MILLION to senators who voted “no” on the #GreenNewDeal resolution – 11x more than to those who voted “present”.

It’s also hard to swallow because after 3 months of a new Congress, thousands of media stories, hundreds of lobby visits, sit ins, protests, and press conference galore we’ve actually managed to convince a majority of Americans that this is a crisis worth tackling – and tackling this way.

Which is why I’m sticking to my guns on this 198-methods strategy: We need outside action, especially direct action, that slows or stops the buildout of fossil fuel infrastructure. AND we need an inside-strategy that presses politicians and regulators to take actions (like a real, fossil-free, Green New Deal), because only big policy solutions will change the dynamic fast enough.

What’s the big deal?

Don’t get me wrong, the Green New Deal has re-shaped the debate on climate change and gotten politicians to talk about the scope and severity of the crisis in a serious way for the first time in a long time.

But the conversation is still stuck in false assumptions that will not keep fossil fuels in the ground or address the systemic racism and injustice of sacrifice zones. In the House of Representatives (outside Mitch the twerp-turtle’s jurisdiction), at least 3 committees are considering climate legislation. But all those bills, and even the actual resolution from Markey and AOC still talk about “net zero emissions” or set the timeline to end fossil fuels and nuclear power way too far in the future (like 2050 or later).

And I’m not just being a stick-in-the-mud: The decision to leave fossil fuels and nuclear on the table in the Green new Deal is shaping the 2020 conversation already: Beto O’Rourke said he supports a Green New Deal, and fracked gas, when Friends of the Earth questioned him in New Hampshire. A few days later, Sen Cory Booker said “I already support the Green New Deal. This resolution of bold vision is what we need. … And I agree with you. Nuclear has to be part of this solution.”

As a side-note, Booker was at a South Carolina town hall meeting organized by CNN that night. If he’d read the local paper, he might have seen that a few miles away another nuclear waste site was caught leaking tritium into the ground water in Barnwell, SC.

If we leave fossil fuels and nuclear on the table, what we’re really saying is that we’re ok with sacrifice zones. Because if we don’t start phasing out dirty energy NOW then they will keep building them, and people will keep getting sick, having their land stolen, and worse.

The 5 biggest oil companies (BP, Exxon, Shell etc) are planning to spend $110 BILLION on new oil & gas projects THIS YEAR (2019) & just 3% as much on clean alternatives.

Wall Street, the fossil fuel companies, the utilities, every single Republican in the Senate and a shockingly large number Democrats are committed to that same vision: another 20-50 years of drilling, spilling, pipelines, genocide, and ecological devastation.

So, now what?

The Senate vote was a sham and a stunt — not least of all because it distracted everyone (effectively) from the real action in the House where this week Nancy Pelosi introduced HR 9 . to keep the US in the Paris climate agreement.

Paris is not a panacea — It’s non-binding, like the AOC/Markey resolution. But it creates a framework to debate bills that have a lot more force and effect.

It’s like agreeing on the playing field, the rules, and saying that we’re in the game. We still need to do all the things to win (in this case stop climate change before it kills us all). And none of that will be possible if we slash our own achilles’ tendons — which is what building 12 new gas export facilities, millions of acres of fracking and drilling rigs, and millions of miles of new pipelines would do to our chances.

But, it’s a start. So this April we’re encouraging you to work on those two tracks: You can join a local Promise to Protect training stop and learn how you can turn up to stop the Keystone Pipeline, and stay tuned for updates on other actions targeting Dominion and the Atlantic Coast Pipeline. At the same time, keep the pressure on Congress to keep debating climate solutions, and make sure they #KeepItInTheGround and say #nonukes as part of those solutions. A great action this week is to call your Senators and tell them to oppose Trump’s choice to lead the Interior Department, David Bernhardt, a former oil lobbyist who is exactly as corrupt as you think he is.

Fossil Banks invest $1.9 trillion in climate change

It’ll come as no surprise to regular 198 methods readers and activists that since the Paris climate agreement was signed in late 2015, global banks have invested $1.9 trillion in fossil fuels. About half of it going to companies like Energy Transfer Partners, Transcanada, and others investing in a massive expansion of fossil fuel projects at exactly the moment climate scientists tell us we have 12 years to radically reduce emissions.

It’s all in the new report Banking on Climate Change: Fossil Fuel Finance Report Card 2019 by Rainforest Action Network, BankTrack, Indigenous Environmental Network, Sierra Club, Oil Change International and Honor the Earth, and endorsed by more than 160 organizations ― including us!

Can you help us fight back? Click here to host or attend one of dozens of protests at local bank branches on April 10 and call out banks dirty investment in climate chaos.

In 2015, J.P. Morgan Chase CEO Jamie Dimon supported the Paris Climate agreement and pledged and investment strategy “consistent with a pathway toward low greenhouse gas emissions.” But the report shows he’s been anything but consistent. In fact, Chase is the number one bank investing in fossil fuels with $196 billion invested in coal, Arctic oil and gas, fracking, tar sands, and other fossil fuels ― in the last 3 years alone!

Lots of European banks like BNP Paribas and ING Bank have taken steps to limit their funding of new fossil fuel projects. But US Banks are continuing to spend $1.9 Trillion on new fossil fuel projects ― and what’s worse, their investment in climate chaos is actually increasing.  

But if we act together, we can make a difference. The Dakota Access pipeline got $2.5 billion of its $3.8 billion in total funding from banks like Chase and Wells Fargo. Without those loans, they simply wouldn’t have enough money to build new pipelines, coal terminals or fracked gas facilities.

So thousands of us joined forces to move our money, demand better banking and #DefundDAPL. Now, I need your help to take action again. Here’s how:

  1. Check out the report and share it with your friends online.
  2. You can share it on Facebook, on Twitter, or email this page to your friends.
  3. Join us as we take action across the country to deliver the message loud and clear that funding climate disaster will not be tolerated.
US Banks are the worlds biggest funders of Dirty Fossil Fuels

Call now for a Green New Deal

It’s here! A joint Resolution for a Green New Deal was just released.

As had been reported many many times, the resolution does not mention fossil fuels or pipelines, and leaves the door open to nuclear power, some kinds of fracking, and more.

Most important the resolution is a starting gun – an official letter introduced in Congress that you can call your members about and tell them why the Green New Deal matters to you.

Pick up the phone right now and dial (833) 768-7693 to tell Congress to be Real Climate Leaders by supporting a strong Green New Deal.

Not sure what to say? Here are some simple talking points based on the demands that more than 1000 activists have been delivering at more than 100 congressional offices this week:

  • This week activists are meeting with congressional offices from coast to coast urging Congress to transform our economy and energy systems through a Green New Deal.
  • More than a thousand activists are meeting with more than 100 members of Congress.
  • We’re delivering more than 100,000 signatures to support a Green New Deal.
  • Specifically, we’re demanding that
    • You support a Green New Deal that halts all new fossil fuel extraction, infrastructure and subsidies, and transitions power generation to 100% renewable energy by 2035 or sooner.
    • This must be a bold, progressive policy that ensures a Fair & Just Transition led by impacted communities and workers and one that passes a national jobs guarantee.
    • To tackle climate change, we need to decarbonize the agriculture and transportation sectors and expand access to public transportation.
    • And we must respect and uphold the rights of Indigenous peoples.
    • Add your own local concerns too – about pipelines, nuclear power, or any other local issue you’re working on!

I wrote earlier this week about why I’m worried this could be another “all of the above” plan. And as more and more news reports came out, it was clear that was a real danger. To re-cap that argument:

Under the All of the Above plan from Obama, the US dramatically increased production of Renewable energy at the same time we even more dramatically increased fossil fuel production and especially fossil fuel exports. Donald Trump even bragged on it at his state of the Union on Tuesday – and when Trump brags about something, you know it’s just the worst. Some of the places that got hit first and worst by this boom in fossil fuels:

  • The Gulf of Mexico, especially poor, black or brown communities in places like Louisiana and Texas who are also on the frontlines of climate-fueled super storms.
  • Indigenous communities in Canada and the plains, where a boom in tar sands and shale oil brought crime, pollution and pipelines.
  • California communities – again usually poor or black or brown or all of the above – that saw a massive expansion of fracking for oil and gas even as state leaders touted 100% renewable goals and carbon trading markets.
  • And the shale-fields of Pennsylvania, where a boom economy in fracking left behind pollution, bomb-trains, pipelines and chemical plants, but failed to deliver lasting economic stability.

That’s not the Green New Deal we hoped for or need. But even if it’s imperfect, the resolution introduced today is an important place to start conversation. We need to begin changing everything, and we can. But only if EVERYONE shows up right now to tell Congress: This is the moment to call – Congress just started to hold hearings yesterday on climate change, and this new Resolution for a Green New Deal is like a starting gun being fired. Now we race towards solutions, with only 10 years to make the big changes we need.

Last week before comments go BOEM!

I recorded a short video to explain what we’ve been doing for the last 50+ days as part of the comment on the Bureau of Ocean Energy management (BOEM) comment period on the Trump administration’s proposal to open more than 90% of US Coastal waters to offshore oil and gas drilling. I wanted to explain what we’ve been doing for two reasons: the first is that there’s still time to submit a comment to BOEM (before March 9, 2018), and we’ve got a new way for you to do it that ensures you comment gets heard when you submit it through this super cool new action portal we set up with friends. The second reason is that this is a really great example of the kind of work 198 methods does, how we’re different from other environmental groups, and why it matters.

A quick recap

Early this year, Ryan Zinke, Trump’s Interior Secretary, announced a new plan that would open more than 90% of US coastal waters to oil and gas drilling. It’s a really really bad plan, since offshore oil drilling always leads to more spills and accidents.And if anything, Trump’s other actions to roll back protections for the environment and worker safety will make accidents even MORE likely. Plus, there’s simply no way to manage the decline of fossil fuels and create the 100% renewable powered economy we need to stop climate change if we open up millions of new acres to offshore drilling. Which is why the Obama administration just banned all drilling off the Atlantic and pacific coasts 2 years ago after a HUGE public comment period in which more than 3 million people, dozens of governors, hundreds of mayors and just about everyone who lives along the coast clearly said #NoDrilling. Loads more footnotes and references in this pst from early in the comment period. As usual for this White House, the rollout was chaotic and ham-handed, and the whole thing may not even be legal because Zinke tried to exempt just the state of Florida as an explicit political favor to Governor Rick Scott who wants to run for US Senate. More on that later.

Our plan in action

BOEM is required by law to hold a 60 day public comment period on any new offshore drilling plan like this. But it was clear from the rollout, and from Zinke & Trump’s past actions, that they weren’t going to be talked out of drilling just because a majority of Americans oppose it. Which brings us to the first part of our plan: We didn’t just want you to comment online – though more than 14,000 of you did, and that’s awesome – we wanted to deliver the comments through direct action speak outs at the hearings, and that’s just what we did. Drew got up on a chair and shouted down the Columbia SC BOEM hearing, earning him a mention in the Washington Post. We did a similar action a few weeks later in Raleigh NC with friends from NC APPPL, who we’ve been working with to fight the pipeline. And once it got going, we weren’t alone: There were public disruptions and refusals to play along with BOEM’s process at hearings in Washington DC, New Jersey, and lots of other places. One of my favorite’s was the action in Rhode Island where our friend and frequent ally Tim DeChristopher, succeeded in turning the whole hearing on its head with citizen after citizen getting on a literal soap-box to speak out about offshore drilling and (eventually) dragging the BOEM staff into a debate on the issues.

Why we did it and why it works

All of which brings me back to why I wanted 198 to work on offshore drilling plan in the first place, and how your actions with us really make a difference: First – It’s about an important concept in Gene Sharp’s writings and teachings called ‘withholding consent’. When we fight climate change, we’re fighting a really BIG system. It involves money and power at a lot of different levels. Fundamentally, it’s also an autocratic system – meaning it’s accountable to a ruling elite, not to the people or the planet. At 198 methods, we’re convinced that fighting climate change requires a specifically anti-authoritarian approach. Like what we did at the BOEM hearings: by standing up speaking out in ways that BOEM didn’t condone (and threatened to throw us out or shut down the hearings over) we put the staff of this administrative agency in a bind. We’re asking them to consciously choose NOT to do their jobs, if that’s what it takes, in order to stop the greater harms of offshore drilling. We’re demonstrating, in a really physical, in-your-face way, that there will be a reckoning — we know most of the people are commenting in opposition to offshore drilling. We know that the consequences of this offshore drilling plan will threaten us all through climate chaos, oil spills and more. And we’re asking them to pick a side: with us or with the polluters. Second – It’s about inspiring people who are already part of the process to realize they have more power than just typing a comment into a laptop — including our allies in groups like the Sierra Club and Oceana that did not support our efforts to stand up and disrupt the hearings in advance. I noted after the SC hearing that I saw a lot of groups advocating a sort of NIMBY (Not In My backyard) strategy. Basically, they were trying to convince BOEM to give them the same exemption Zinke gave Florida (which, again, may not hold up in court). They did this either through explicit argument, like by siting the value of their coastal tourism economies, for example; Or through an implicitly political argument, like by having lots of Republicans or state-wide officials testify that they are opposed to drilling, which helps make the argument that Trump & Co. will lose support in the mid-term elections if they push forward with the plan. But I think that’s the wrong approach for two reasons: one, as outlined below, it fails to move the media narrative and focusses attention on our weakest and least reliable partners. More importantly, it uses a NIMBY argument when what we need is a NIABY argument – Not in ANYBODY’s Back Yard. We don’t just want to ban offshore drilling in South Carolina, or California, or in places that have Republican Governor’s, or in places with coastal tourism: We want to ban offshore drilling – ALL of it – because it’s way to dangerous for our communities and our planet. Third – It’s about inspiring everyone who’s not part of the process yet. Two years ago, more than 3 million people and hundreds of academics, researchers, churches, and all kinds of organizations commented in opposition to offshore drilling (all of it). Obama responded by banning drilling off the Atlantic and mainland US Pacific coasts, but allowed it to continue in the “sacrifice zones” of the Gulf of Mexico and much of Alaska. That was basically what the conventional wisdom in the media expected, and so it was ‘enough’ to turn out lots and lots of comments so that Obama would feel empowered to do that. But there is no conventional wisdom for what Trump is doing. He’s already given away more land to fossil fuels, and more brazenly, than anyone imagined a few years ago. And, dazzled by the sheer, crazy, deluge of horribleness, the main stream media (like that Washington post story) default to covering this as a ‘normal’ political story where there are people for drilling, and people against it, and BOEM is a sort of neutral mediator. To stop Trump and team’s plan we need to be bigger, more powerful, and reach more people. That means working outside of the conventional wisdom of what works in the media and political wisdom. We can’t wait for Trump to come to his senses, or be satisfied with incremental NIIMBY victories any longer. Honestly, it will probably mean more of us lining up on roads and paddling our kayaks in front of drilling rigs to stop them. That’s movement building work – not lobbying and media work. And to inspire people, a LOT of people to rise up against big authoritarian power of the petro-state as represented by this offshore drilling plan, we need to inspire people. And that, fundamentally, is why we do digitally supported direct actions JUST LIKE THIS! Look, there are enough of us, in America, to stop offshore drilling, reverse climate change and build the 100% renewable fossil free world we need. What’s more, we’ll all have more jobs, more money, more political power and more control over our daily lives when we do.  What’s holding us back is the raw political power (fueled by money, fear, and a lot of other things) of the fossil fuel industry and their allies in power – like the Trump administration. but to mobilize those people, we need to show them that resistance is possible, that it works, that it feels good (if I can’t dance I don’t want to be in your revolution) and most importantly that they have the power.

So, what next?

Glad you asked. First of all, if you liked our actions and the ideas in this post, please chip in to support us. If everybody who sent in a public comment with us gave $1.98, we’d have more than enough money to fund our entire operation for 6 months. Of Course, not everyone can donate, so if you’re in a position to give a little, please consider a weekly donation of $1.98, or a gift of $19.80 to support our ongoing work. Second – it’s not too late to submit your comment, and even if you already sent one in with us, or with another group, hang on and consider this new tool as well. Working with our friends at Daily Kos and Action Network, we’ve set up a new comment form that delivers your comments directly to the BOEM staff in charge of this docket. I’ll still deliver all the 14,000+ signatures you sent in through the in-person deliveries, and I’ll submit them as evidence before the March 9 deadline. But by also submitting a comment through this new form, you’ll essentially get two comments — and that can be really helpful for when our friends in the legal community go to court to challenge this rule. Being able to cite the fact that there were a LOT of comments, and also to pull out individual voices of opposition from the public record, will be really helpful. So, if you haven’t commented, please do so now. And if you already have, comment again!