"Providing an informed, reasoned and dispassionate

voice to the global public debate..."

 Aug. 2014



​ITSSD Letter to the U.S. Senate Foreign Relations Committee Objecting to the Nomination of Harold Koh as the Next U.S. State Department Legal Adviser
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​Annex to ITSSD Letter to the U.S. Senate Foreign Relations Committee Objecting to the Nomination of Harold Koh as the Next U.S. State Department Legal Adviser


​Summary:  This ITSSD correspondence and accompanying Annex cites nominee Koh's views on three different international law issues and concludes that such views could arguably threaten U.S. legal, political and economic sovereignty, U.S. individual including private property) rights, and ultimately, U.S. national security. 


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ITSSD Letter to the U.S. Mission to the United Nations
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​Summary:  This ITSSD correspondence to U.S. Ambassador John Bolton identified and explained the practice of legal 'regime shifting' undertaken by certain UN member states within various UN agencies as a supplement to 'soft' law development for the purpose of establishing new global regulatory standards potentially inimical to U.S. national interests.



Letter from U.S. Senator James Inhofe Supporting ITSSD Research Efforts Concerning the Environmental Regulatory Dimensions of the UN Convention on the Law of the Sea ("UNCLOS")
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Summary: This correspondence from U.S. Senator James Inhofe expresses interest and support for ITSSD research efforts to examine how other countries are reading a broader than agreed upon version of the Precautionary Principle into the UNCLOS text, and the likely impact that such interpretation, coupled with U.S. UNCLOS accession, would have on U.S. national security and economic and technological competitiveness.



ITSSD President's Post-Hearing Written Testimony Prepared Upon Request for U.S. House Science Committee, Subcommittee on Environment, Technology and Standards


​ITSSD Cover Letter to Hon. Vernon J. Ehlers, Chairman, House Science Committee

​Summary:  This testimony describes the various ways in which the European Union is employing and exporting around the world regional environment, health and safety (sustainable development-focused) regulations guided by the hazard-based Precautionary Principle to gain geopolitical leverage and a regulatory, and thus, economic comparative (trade-competitive) advantage vis-a-vis the U.S.


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ITSSD Letter to U.S. State Department Office of the Legal Adviser, Attorney-Adviser
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Summary: This correspondence identifies and describes the international dimensions of the Northeast Regional Greenhouse Gas Initiative ("RGGI"), in particular, how the European Union was invited to provide 'lessons learned' and assistance in shaping said regime.



ITSSD Comments in Response to American National Standards Institute ("ANSI") Five-Year U.S. Standards Strategy Review


Summary:  These comments respond to the seven proposed ANSI initiatives to promote transparent voluntary, consensus-based, market-driven international industry-based standards, and discusses cross-cutting issues which, though not addressed in the USSS, must be carefully reviewed to protect and preserve U.S. international economic interests.

     Issue Date                                                 Description

​Library - Public Correspondences

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ITSSD Files Supplement to Previously Filed Comments on EPA's Proposed Power Plant Rule - Filed 12-1-14 -   Word Version (here)

​ITSSD Prepares, Files Public Comments Evaluating the Scientific Foundations of EPA's Proposed Power Plant Carbon Pollution Guidelines - Docket No. EPA-HQ-OAR-2013-0602 - Filed 8-13-14 -   Word Version (here) 


Summary:  EPA failed to properly validate the "major scientific assessments" underlying EPA's 2009 GHG CAA Section 202(a)(1) Endangerment Findings and the Third National Climate Assessment which EPA now relies upon as primary support for its proposed power plant rule.  Since the peer reviews of these assessments did not conform with the Information Quality Act and relevant binding OMB and EPA IQA-implementing guideline conflicts-of-interest, financial and intellectual independence and peer review panel balance standards, the agency is precluded from relying up them until they are peer reviewed again.
Dec. 2014

​ITSSD Prepares Hearing Questions for the U.S. House of Representatives Committee on Science, Space and Technology


Summary:  To assist the House Science Committee professional staff support the Committee members during the May 29, 2014 Full Committee Hearing Entitled, "Examining the UN Intergovernmental Panel on Climate Change Process," ITSSD prepared a series of questions for their consideration and use. The Hearing Charter is available here.
May 2014
April 2005
April 2005
June 2005
Dec. 2005
Jan. 2006
April 2009
The ITSSD has engaged in public outreach via disclosed correspondence to the following governmental and nongovernmental entities: the U.S. House of Representatives Committee on Science, Space and Technology (113th Cong.); the Senate Committee on Foreign Relations (111th Cong.); the U.S. Mission to the United Nations; the U.S. Senate Committee on Environment and Public Works (109th, 113th Cong.); the U.S. House Committee on Science, Subcommittee on Environment, Technology and Standards (109th Cong.); the U.S. Environmental Protection Agency, U.S. Department of State, Office of the Legal Adviser; and the American National Standards Institute ("ANSI").