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D.C.’s Constituent Service Funds: Misused, Inequitable and Ethically Fraught

Over the past seven years D.C. Councilmember Jack Evans spent close to $163,000 on professional sports tickets. He has paid more than $14,000 to the Economic Club of Washington, D.C., in annual membership dues. Evans also spent thousands on print advertisements that largely promoted himself.

To make all these purchases, Evans did not use his own money, campaign funds, or taxpayer dollars. He used funds from his constituent service program or what is commonly referred to as a constituent service fund (CSF).

Under current D.C. campaign finance law, the mayor and members of the D.C. Council can establish constituent service funds for purposes such as “emergency housing,” “funeral arrangements,” “utility payments” and “other necessities of life.” The funds can also be used for food and refreshments and community events. All expenditures made must be done for the “primary benefit of residents of the District of Columbia.” Those who support the CSFs argue that they are needed to address constituents’ needs quickly when traditional programs might not be as easy to access.

But a look at the CSF expenditures of the District’s elected officials over the last seven years suggests that for many elected officials, meeting the emergency needs of constituents is not the primary use of those funds. D.C’s elected officials have spent tens of thousands of dollars from the funds on calendars and holiday cards, as well as campaign-style t-shirts, banners and print advertisements that do far more to publicize the elected officials than provide any constituent services. Councilmember Jack Evans, who has spent by far the most from such funds, has spent $162,816 on professional sports tickets.

Further, those elected officials who raise and spend the bulk of constituent services funds represent D.C.’s wards where residents have higher incomes. While elected officials representing the lowest income wards spend significantly less. Jack Evans represents a ward with a median household income of $104,504. Councilmember Trayon White represents a ward in which the median household income is $31,954. In 2018, Evans spent close to $58,000 in constituent service funds. In 2018, White spent about $10,000 in constituent service funds. Evans spent more on just Washington Wizards tickets in 2018 than White spent on all of his constituent services.

Washington, D.C., has one of the highest rates of income inequality in the country. In a city with so many residents struggling to make ends meet in the midst of enormous wealth and privilege, calling the distribution of D.C.’s CSFs inequitable would be an understatement.

The constituent service funds in D.C. have long been controversial and have been the subject of multiple scandals. The editorial board of The Washington Post has at least twice – first in 2011 and again in 2015 – called for the funds to be eliminated. The Post described the funds as “private slush funds” and “second campaign accounts that can be used with broad discretion.” The Washington City Paper called the funds “a joke.”

Currently, nine of D.C.’s elected officials operate a constituent service fund: Mayor Muriel Bowser, Council Chairman Phil Mendelson, and Councilmembers Kenyan McDuffie, Anita Bonds, Jack Evans, Mary Cheh, Brandon Todd, Vincent Gray and Trayon White. Five D.C. Council members choose not to operate CSFs.

Public Citizen examined more than 3,800 CSF itemized expenditures and close to $1.1 million in spending from January 2012 through December 2018. Elected officials categorize the same types of purchases in different ways – sometimes writing just one word, other times writing a short sentence. To make comparisons, Public Citizen coded the expenditures using 14 different categories. Many of the categorizations used by Public Citizen map closely with what elected officials listed on their disclosures. Further details about how Public Citizen categorized CSF expenditures appear in Appendix I.

Public Citizen analyzed constituent service fund data from 2012 through 2018 and found:

[Read the Full Report Here]


Only About a Quarter of CSF Money was Spent on Immediate Constituent Needs & Gifts

Overall, just 13 percent of the expenditures were for utility payments, rental assistance, funeral support and flowers, and other constituent assistance. Public Citizen defined the foregoing as “immediate constituent needs.” Other expenditures that plausibly fit in the broad category of assisting constituents with unmet needs are gift cards and other gifts (coats, turkeys, toys, etc.). If one combines the necessity-based expenditure categories described above – immediate constituent needs plus gift cards and other gifts – the total spending on plausible constituent needs still would only account for 24 percent of all the spending.

Councilmember Vincent Gray spent 72 percent of his CSF funds on immediate constituent needs, gift cards and gifts, the most of any elected official in this analysis. Gray is followed by Councilmember Phil Mendelson, who spent 43 percent of the CSF funds on immediate constituent needs, gift cards and gifts. At the other end of the spectrum, Councilmember Evans spent just 3 percent of his constituent service funds on immediate constituent needs, gift cards and other gifts from 2012 through 2018.

The vast majority of constituent service expenditures were on donations (which includes fundraisers, sponsorships and dues), catering and refreshments, professional sports tickets, community events, or advertising and outreach.

  • Evans spent $162,816 on professional sports tickets – amounting to 52 percent of all the money spent from his constituent service fund over the total period studied. Evans spent more on professional sports tickets in 2018 ($26,400) than every other D.C. elected official individually spent in total constituent service funds in 2018. Evans spent more on just Washington Wizards tickets in 2018 ($11,050) than Vincent Gray, Trayon White, Anita Bonds and Mary Cheh each spent on all constituent services in 2018.
  • D.C. elected officials reported spending $100,679 on various advertising and outreach (based on Public Citizen’s analysis). This total includes thousands of dollars spent on holiday cards, t-shirts, banners and print advertising. Many of these expenditures did far more to publicize the elected officials than to assist their constituents.
  • Vincent Gray and Phil Mendelson purchased large banners that dedicated the vast majority of space to their names. Mary Cheh, Gray and Mendelson all used constituent service funds to buy t-shirts that do not appear to be much different than campaign t-shirts.

D.C. elected officials also spent tens of thousands of dollars helping their constituents, but these expenditures only accounted for about a quarter of the constituent service expenditures from 2012 through 2018. Phil Mendelson spent tens of thousands of dollars on rental and utility assistance. Muriel Bowser gave away hundreds of coats. Brandon Todd has done the same. Vincent Gray and Trayon White have given away hundreds of Thanksgiving turkeys. Kenyan McDuffie and Bowser have given away thousands of dollars’ worth of grocery store gift cards. And Mendelson, Gray, Mary Cheh and others have given away Christmas toys.

CSF Money is Not Distributed Equitably; More Money is Spent in Higher Income Wards

D.C.’s Ward 8 has the lowest median household income, the highest unemployment rate, and the largest share of families in poverty. But Councilmember Trayon White, who represents Ward 8, spends approximately $32,000 less in constituent service funds each year than Jack Evans, who represents a ward with a median income more than triple that of White’s Ward 8.

  • On average, Jack Evans annually spends three and a half times as much as Trayon White in total constituent service funds. But Trayon White actually spends $881 more than Evans on immediate constituent needs, gifts and gift cards each year.
  • While current law prohibits elected officials from raising any more than $40,000 in aggregate each calendar year for their CSFs, elected officials may transfer leftover money from their campaign accounts to their CSFs. Trayon White has been able to win his elections raising relatively small amounts of money, putting him at a huge disadvantage in terms of access to funds to help his constituents.
  • Unless changes are made, the vast majority of CSF money will continue to be spent in the higher income wards. Evans’ most recent CSF financial statement (as of January 1, 2019) reports $143,152 in cash on hand. Trayon White’s CSF has just $1,088. It would take Evans 2.4 years just to spend his cash on hand, under the $60,000 per year expenditure level.

Maxed Out Campaign Contributors, Government Contractors and Lobbyists Contribute to CSFs

D.C. constituent service funds covered in this analysis accrued $1.2 million from 2012 through 2018. Close to half of the money has come from the campaign account of the elected official. The bulk of the remaining funds were raised from corporations and individuals.

  • Contributions to CSFs are counted separately from campaign contributions, meaning an individual can contribute the maximum amount to both a CSF and a campaign account. Public Citizen analyzed a hypothetical scenario in which contributions to CSFs would count towards campaign contribution limits. If that were the case, there would have been 189 excessive contributions totaling $84,655 during the time period we studied. Jack Evans would have received the most excessive contributions by far – 118 contributions totaling $54,200.
  • D.C. government contractors like Blue Skye Construction, Fort Myer Construction and EastBanc Technologies contributed thousands to the constituent service funds of D.C. elected officials from 2012 through 2018. These companies also received millions in D.C. government contracts. Some of these contributions will be banned in the future with the recent passage of legislation.
  • Prominent D.C. lobbying firms like Manatt, Phelps & Phillips, and powerful D.C. lobbyists including Kerry Pearson, Thorn Pozen and David Wilmot have contributed tens of thousands of dollars to D.C.’s CSFs.

Proposed Reforms

While it is Public Citizen’s belief that these funds should be abolished, currently there appears to be little appetite among the D.C. Council to do so. A provision that would have abolished the funds was removed from the Campaign Finance Reform Amendment Act of 2018 to ensure the bill’s passage. If the CSFs are to continue, serious reforms are needed. Some suggested reforms are listed below:

  • Ban private contributions to CSFs. Budget – using taxpayer funds – $10,000 to $20,000 per calendar year for each elected official to use to help constituents with immediate needs. This would give all elected officials equal opportunity to help constituents. Under the current system, the fundraising prowess, political power and connections of each elected official largely dictates how much help constituents receive.
  • Create tighter restrictions on how the money can be spent. Advertisements and outreach using constituent service funds should be strictly limited to alerting constituents that help is available through these funds. References to elected officials should be prohibited in advertisements. Sports tickets, are not a good use of constituent service funds and should be prohibited.
  • Ensure that when CSF financial disclosures are submitted each expenditure is described in enough detail to ensure that one can gain an understanding of how the money was spent by reading the disclosures, without additional follow up.

On average, from 2012 through 2018, the D.C. elected officials with CSFs spent about $160,000 per year in total in CSF money. Mayor Bowser recently proposed a $15.5 billion annual budget for fiscal year 2020. If it is decided that $160,000 or $200,000 more a year is needed to help D.C. residents afford their rent or utilities, it won’t bust the budget, and it can be targeted towards those who need it most.

Currently, what constituent service funds are spent on largely depends on whatever the elected official deems to be reasonable (within the bounds of the regulations). It’s clear that Jack Evans has a much different view of what constitutes a reasonable expenditure than Anita Bonds or Kenyan McDuffie.

If constituent service funds are going to continue to exist, serious reform is needed and safeguards need to be put in place. Hoping elected officials use the money wisely is not good policy. Requiring them to do so is.

Voting line

The Ballot Box vs. Campaign Cash

The Report
Contribution Map
The Data


WASHINGTON, D.C. – On June 19, D.C. voters approved Initiative 77 by a margin of 55 to 45 percent. The initiative called for workers who receive tips to receive a minimum wage equal to the minimum wage for other workers by 2026. At the time of the vote, the minimum wage for tipped workers was $3.33 per hour, which was just one-third of the minimum wage for other employees. While many of these workers earn more than the minimum wage through tips, many do not.

Download a PDF of the full report.

Almost immediately, restaurant-industry lobbying groups went to work to persuade D.C. Mayor Muriel Bowser and members of the D.C. Council to annul the results of the ballot initiative by legislation.

And on July 9, 2018, seven D.C. councilmembers – a majority of the Council – introduced legislation to repeal Initiative 77. A hearing on the bill is scheduled for September 17, 2018.

This report explores the role that campaign contributions play in giving those in the restaurant industry opposed to Initiative 77 an outsized voice that threatens to drown out the voices of the voters who approved the measure on election day.

This report also exposes the hypocrisy of leaders of the anti-Initiative 77 movement who have violated current wage and hour laws while arguing that the remedy that voters approved is unnecessary.

Along with the report, Public Citizen released a detailed data map of all of the contributions from anti-Initiative 77 individuals and entities.

Key Findings

  • Anti-Initiative 77 entities contributed $236,013 to D.C.’s current 14 elected officials during their two most recent campaigns. Nearly all of the money went to officials who came out against Initiative 77.
  • The average contribution to D.C.’s elected officials over their two most recent campaigns by anti-Initiative 77 entities has been $733, about double the $388 average contribution by other donors.
  • Anti-Initiative 77 entities have contributed $130,270 to the seven D.C. councilmembers who have signed on to legislation to repeal the initiative. That is three times more than the $40,693 that they have given to the six councilmembers who have not signed on to the repeal legislation.
  • Mayor Muriel Bowser has received the most from anti-Initiative 77 individuals and entities, more than $65,000.
  • During the 2018 cycle thus far, Bowser and Council Chairman Phil Mendelson, the two most important elected officials in deciding the fate of Initiative 77, have received 80 percent of the money from anti-Initiative 77 forces.
  • Anti-Initiative 77 forces contributed $25,900 to D.C. elected officials in March 2018. Of this, $20,250 went to Mendelson.
  • Mendelson has received $31,500 from anti-Initiative 77 forces during the 2018 election cycle. During his last campaign, in 2014, he received only $2,500 from these contributors.
  • More anti-Initiative 77 contributions came from corporations, LLCs, and corporate PACs than people. In total, 56 percent of the money ($131,743) came from corporations, LLCs or corporate PACs.
  • Opponents of Initiative 77 claim that it is not necessary because restaurants are required to ensure that tipped employees’ wages at least equal the minimum wage. Several restaurants in Washington, D.C., have faced allegations of violating wage and hour laws. A few cases resulted in class-action settlements:
    • Farmers Restaurant Group, which opposes Initiative 77 and contributed $6,000 to the anti-Initiative 77 committee, recently settled – without admitting wrongdoing – a class-action lawsuit for $1.49 million for allegedly failing to pay overtime and failing to pay the minimum wage. Rather than pass a minimum wage increase, Farmers’ co-owner Dan Simons proposed allowing an employee to work “60 hours or 55 hours” a week with no overtime pay in order to raise wages.
    • Clyde’s Restaurant Group, which opposed Initiative 77, settled two lawsuits. In 2010 and 2011, Clyde’s was sued in D.C. and Virginia for, among other things, allegedly failing to pay its tipped employees the minimum wage and for altering time clock entries in order to avoid paying overtime. Both lawsuits settled without Clyde’s admitting liability, one for $345,000 and the other for an undisclosed amount. Clyde’s corporations and executives have contributed $57,600 to the campaigns of the elected officials covered in this analysis and contributed another $16,000 to the to the anti-Initiative 77 committee.

Workers of color are disproportionately affected by the low tipped wage, and within the tipped worker community, women are twice as likely to live in poverty as their male colleagues.

Undoubtedly, some servers in D.C. make more than the minimum wage. For example, servers working at places like Ghibellina, the restaurant owned by outspoken anti-Initiative 77 restaurateur Ari Gejdenson where patrons can dine on $110 porterhouse steaks, are likely making well above the minimum wage (Gejdenson and his associated corporations contributed $6,000 to the anti-Initiative 77 committee). But for restaurants where menu items are far less than $110, one can envision a scenario where a slow night could leave tipped workers with less than minimum wage. Further, it is not just servers and bartenders affected by the lower tipped minimum wage. The law would increase the wages of nail salon workers, bellhops, parking lot attendants, hair stylists and pizza delivery drivers.

One has to wonder if D.C. elected officials – who are no stranger to advocating for greater representation for their constituents (i.e., “taxation without representation”) – would have moved so quickly to nullify the will of the voters had they not received campaign support from anti-Initiative 77 individuals and entities.

The optics alone are enough to call into question whose interests are being represented by the Council: the 44,353 voters who approved Initiative 77, or the 163 anti-Initiative 77 individuals and entities that contributed large sums of money to their campaigns.

The good news is it doesn’t have to be like this in the future. In 2018, the D.C. Council unanimously passed the Fair Elections Act of 2017, which created a public campaign finance program where individuals running for office would no longer have to rely on large sums of corporate money to finance their campaigns. Candidates can participate in the program beginning in 2020.

The people had their say at the ballot box. Corporations had their say with campaign cash. The will of wealthy contributors should not trump the will of the people.

 

7

It is Time to Protect Millions of Workers From Extreme Heat

Washington, D.C. – Over the July 4, 2018, holiday week, an average of more than 2.2 million workers in the agriculture or construction industries worked in extreme heat each day.

The blistering holiday week was yet another reminder of what we face as temperatures continue to rise and heat waves become more frequent. Seventeen of the 18 hottest years on record have occurred since 2001.

The Occupational Safety and Health Administration (OSHA), the agency responsible for protecting workers, has repeatedly failed to act on the topic of unsafe heat – despite overwhelming evidence that it should. Over the past 30 years, heat has been the leading cause of weather fatalities, according to the National Weather Service.

Public Citizen and more than 130 co-petitioners are asking that OSHA develop a standard that would require employers to undertake measures to prevent employees’ heat loads from exceeding maximum thresholds.

In conjunction with the submission of this petition, Public Citizen issued a report quantifying the numbers of employees who are laboring in unsafe heat.

[Read the full report HERE.]

We analyzed temperatures for both July 2017 and for the recent July 4, holiday week for counties covering about 80 percent of the nation’s workforce. Among other things, we found:

  • At least 201 U.S. counties experienced extreme heat each day on average in during July 2017. On July 21 and July 22, 2017, two of the warmest days that month, more than 570 counties experienced extreme heat.
  • An average of 1.1 million agriculture and construction workers labored in extreme conditions each day in July 2017. (These included 265,000 agriculture workers in the agriculture, 851,000 workers in the construction industry.)
  • OSHA concluded that extreme heat was a factor in the deaths of at least six workers July 2017.

The Average Number of Workers Experiencing Extreme Heat
July 2017, by Date (Weekends Shaded)

During the recent July Fourth 2018 holiday week, when heat records were set around the world:

  • At least 322 counties a day experienced extreme heat. On July 5, 2018, 430 counties experienced extreme heat – the most of any day that week.
  • More than 2.2 million workers in the agriculture or construction industries worked in extreme heat during an average day during the holiday week. (These included 374,000 agriculture workers in the agriculture, 1.8 million workers in the construction industry.)
  • Nearly 5.1 million workers in these industries experienced extreme heat at least one day during the week of July Fourth.

The Average Number of Workers Experiencing Extreme Heat
By Date, July 1 to 7, 2018 (Weekends Shaded)

OSHA’s job is to protect every worker. The nature of work done by many of the workers described in our report already places them at risk. Making matters worse, the socio-economic status of many people who work outdoors leaves them especially vulnerable.

The current system does not account for the fact that workers have very little control over their ability to rest, drink water, find shade or otherwise seek relief from excessive heat. As a report in Mother Jones notes, “heat sickness is a symptom of an agricultural system where laborers can’t speak up against unsafe field conditions, in part because many are undocumented.”

This fear is likely greater under the Trump administration, as Immigration and Custom Enforcement raids at workplaces with large numbers of immigrants are on the rise.

Compounding all of this is the fact that climate change is going to lead to warmer temperatures in the future, putting workers at even greater risk. At the current trajectory, by 2100, summers in Boston will resemble today’s summers in Miami Beach. St. Paul, Minn., will feel like Mesquite, Texas. Las Vegas will become the new Riyadh, Saudi Arabia.

OSHA needs to act.

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Deregulatory Frenzy: How Trump Has Stopped or Delayed More Than 1,500 Rules In Process

The Trump administration has withdrawn or paused more than 1,500 rulemakings. This total vastly exceeds the number under President Obama at this period of his administration, and roughly parallels the number under President George W. Bush. Trump has blocked more rulemakings deemed “significant” due to their economic impact or other factors than Bush. These findings are the focus of a new Public Citizen report.

The Trump administration has bragged that it has eliminated “nearly 1,000 regulations.” This claim is somewhat misleading. In fact, most of the regulations that the administration claims to have scuttled were rulemakings in progress that had yet to be finalized, as opposed to regulations already on the books that have been eliminated.

The status of ongoing rulemakings is reported by the Office of Management and Budget in a document called the Unified Agenda that is published twice a year. The Unified Agenda tracks a rulemaking’s progress, essentially from the proposed or prerule rule stage to its completion. Rulemakings can be categorized as “long term actions,” which generally means that they are not progressing very rapidly. Rulemakings can also be categorized as “withdrawn,” meaning that they have been cancelled prior to completion. (In a somewhat recent development, rulemakings may be put on an “inactive list,” which the Trump administration publishes separately from the Unified Agenda.)

This report examines nearly 20 years of Unified Agenda data to determine how the number of halted or delayed rulemakings on Trump’s first three agendas compares to the number of delayed or withdrawn rulemakings on the first three agendas of the Obama and George W. Bush administrations. It also examines changes to the list of inactive regulations. Rulemakings that have been halted or delayed make up the bulk of regulations to which Trump Press Secretary Sarah Sanders was referring when she bragged about the administration had “gotten rid of 1,000 regulations.”

We count rulemakings that have been halted as those listed as withdrawn on the Unified Agenda. We count as delayed those rulemakings that are listed for the first time on the “long-term actions” stage or moved to the inactive list.

The entire report can be read here. These are our findings at a glance:

1 – Withdrawn rulemakings – The Trump administration has withdrawn more than 780 rulemakings. That is an 85 percent increase compared to the Obama administration’s first three agendas and a 3 percent decrease compared to the first three agendas submitted by the George W. Bush administration.

Of Trump’s withdrawn rulemakings, 279 were deemed “significant.” Rulemakings are given the status of “economically significant” if they are projected to have an economic impact of more than $100 million and are given “other significant” status if they meet certain criteria, such as raising novel policy issues or affecting multiple agencies. The Trump administration’s number of significant rulemakings withdrawn by this point in the president’s term was 77 percent more than the Obama administration and 26 percent more than the George W. Bush administration.

2 – Active rulemakings moved to long-term – The Trump administration moved 583 rulemakings to long-term actions over its first three agendas. The total is 28 percent more than the Obama administration but 16 percent less than the Bush administration.

Of these, 209 were significant. That total is 7 percent more than the Obama administration total but 12 percent less than the Bush administration’s.

3 – Rulemakings moved to inactive – The Trump administration moved 328 rulemakings to inactive status. Of these, 41 percent were significant.

Examples of rulemakings that the Trump administration has terminated or postponed include one that would have addressed the hazards that led to the 2010 Upper Big Branch mine disaster, which killed 29 people.

Others would have protected workers from vehicles backing up, which are one of the top causes of workplace fatalities, prevent explosions from combustible dust and reduce emissions of the potent greenhouse gas methane, to name a few.

The data in this report show that Trump has already scuttled hundreds public protections. The data are telling. But what the data do not convey is the human cost. As a result of the administration’s deregulatory fervor, there will be no combustible dust standard anytime soon. The hazards exposed in the Upper Big Branch mine disaster won’t be addressed. Efforts to prevent backover deaths in the workplace, to make trains safer, and to reduce greenhouse gases have all been blocked, for now.

This regulatory inaction will lead to preventable death and disease. While we may not yet know the names of those needlessly killed or injured by the administration’s determined inaction, we do know that people will die and suffer needlessly.

[pdf-embedder url=”https://citizenvox.org/wp-content/uploads/2018/06/deregulatory_frenzy_final.pdf”]
39865681692_3523f2b132_c

Deregulatory Frenzy

,

New Report: Trump Has Stopped or Delayed More Than 1,500 Rulemakings, Including Those to Protect Workers From Mine Disasters, Combustible Dust Explosions and Backover Accidents

The Trump administration has withdrawn or paused more than 1,500 rulemakings. This total vastly exceeds the number under President Obama at this period of his administration, and roughly parallels the number under President George W. Bush. Trump has blocked more rulemakings deemed “significant” due to their economic impact or other factors than Bush. These findings are the focus of a new Public Citizen report released today.

The Trump administration has bragged that it has eliminated “nearly 1,000 regulations.” This claim is somewhat misleading. In fact, most of the regulations that the administration claims to have scuttled were rulemakings in progress that had yet to be finalized, as opposed to regulations already on the books that have been eliminated.

The status of ongoing rulemakings is reported by the Office of Management and Budget in a document called the Unified Agenda that is published twice a year. The Unified Agenda tracks a rulemaking’s progress, essentially from the proposed or prerule rule stage to its completion. Rulemakings can be categorized as “long term actions,” which generally means that they are not progressing very rapidly. Rulemakings can also be categorized as “withdrawn,” meaning that they have been cancelled prior to completion. (In a somewhat recent development, rulemakings may be put on an “inactive list,” which the Trump administration publishes separately from the Unified Agenda.)

This report examines nearly 20 years of Unified Agenda data to determine how the number of halted or delayed rulemakings on Trump’s first three agendas compares to the number of delayed or withdrawn rulemakings on the first three agendas of the Obama and George W. Bush administrations. It also examines changes to the list of inactive regulations. Rulemakings that have been halted or delayed make up the bulk of regulations to which Trump Press Secretary Sarah Sanders was referring when she bragged about the administration had “gotten rid of 1,000 regulations.”

We count rulemakings that have been halted as those listed as withdrawn on the Unified Agenda. We count as delayed those rulemakings that are listed for the first time on the “long-term actions” stage or moved to the inactive list.

The entire report can be read here. These are our findings at a glance:

1 – Withdrawn rulemakings – The Trump administration has withdrawn more than 780 rulemakings. That is an 85 percent increase compared to the Obama administration’s first three agendas and a 3 percent decrease compared to the first three agendas submitted by the George W. Bush administration.

Of Trump’s withdrawn rulemakings, 279 were deemed “significant.” Rulemakings are given the status of “economically significant” if they are projected to have an economic impact of more than $100 million and are given “other significant” status if they meet certain criteria, such as raising novel policy issues or affecting multiple agencies. The Trump administration’s number of significant rulemakings withdrawn by this point in the president’s term was 77 percent more than the Obama administration and 26 percent more than the George W. Bush administration.

2 – Active rulemakings moved to long-term – The Trump administration moved 583 rulemakings to long-term actions over its first three agendas. The total is 28 percent more than the Obama administration but 16 percent less than the Bush administration.

Of these, 209 were significant. That total is 7 percent more than the Obama administration total but 12 percent less than the Bush administration’s.

3 – Rulemakings moved to inactive – The Trump administration moved 328 rulemakings to inactive status. Of these, 41 percent were significant.

Examples of rulemakings that the Trump administration has terminated or postponed include one that would have addressed the hazards that led to the 2010 Upper Big Branch mine disaster, which killed 29 people.

Others would have protected workers from vehicles backing up, which are one of the top causes of workplace fatalities, prevent explosions from combustible dust and reduce emissions of the potent greenhouse gas methane, to name a few.

The data in this report show that Trump has already scuttled hundreds public protections. The data are telling. But what the data do not convey is the human cost. As a result of the administration’s deregulatory fervor, there will be no combustible dust standard anytime soon. The hazards exposed in the Upper Big Branch mine disaster won’t be addressed. Efforts to prevent backover deaths in the workplace, to make trains safer, and to reduce greenhouse gases have all been blocked, for now.

This regulatory inaction will lead to preventable death and disease. While we may not yet know the names of those needlessly killed or injured by the administration’s determined inaction, we do know that people will die and suffer needlessly.

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