Comment Letters

 2025

RE: Multistate Letter Urging Costco to End Unlawful DEI Policies

A coalition of 19 state Attorneys General is urging Costco’s President and CEO, Ron Vachris, to end the company's DEI policies, which they argue are discriminatory and unlawful, and to align with the Supreme Court’s recent rulings on racial preferences and equality.

 2024

RE: Concerns Over COVID-19 Vaccine Injury Compensation Program

The Attorneys General of 14 states expressed concerns about the handling of claims for individuals injured by COVID-19 vaccines, highlighting issues with transparency, due process, and the insufficient compensation provided through the Countermeasures Injury Compensation Program (CICP).

RE: Comment on the Department of Education’s Proposed Rule for Student Debt Relief

The letter from Kansas, Missouri, and 21 other states expresses strong opposition to the U.S. Department of Education's proposed rule for student debt relief, arguing that it exceeds statutory authority, violates separation of powers, misestimates costs, and fails to follow proper rulemaking procedures.

RE: Objections to the U.S. Military’s Use of Racial Quotas in Officer Recruitment and Military Academy Admissions

A group of state Attorneys General express concerns over the use of racial quotas in military recruitment and academy admissions, arguing that such practices violate the Constitution and undermine military effectiveness, calling for an immediate cessation of racial discrimination within the U.S. military.

RE: Letter Concerning Bank of America's Discriminatory De-banking Practices and Threat to Free Speech

Attorneys General address concerns to Brian T. Moynihan regarding Bank of America's alleged discriminatory de-banking practices, citing its political and religious biases in terminating customer accounts, including those of conservative and religious organizations, and its cooperation with government surveillance.

RE: Opposition to Proposed Rule on VOCA Victim Compensation Grant Program

The Attorneys General of 18 states oppose the Office for Victims of Crime’s proposed rule that would condition federal funding on states not denying or reducing claims based on contributory conduct, arguing the rule exceeds statutory authority and undermines state discretion.

RE: Opposition to EPA's Proposed Rule on Wastewater Discharges from Meat and Poultry Processing Facilities

The Attorneys General of 24 states submitted comments opposing the EPA's proposed rule regulating indirect wastewater discharges from meat and poultry processing facilities, arguing that the rule exceeds the agency’s authority under the Clean Water Act, is economically burdensome, and conflicts with federal efforts to strengthen food supply chains.

RE: Concerns Over FAA Hiring Practices and Safety Priorities

The Attorneys General of Kansas and 23 other states submitted a letter to Administrator Michael Whitaker criticizing the FAA for prioritizing diversity over safety and expertise in its hiring practices, warning that this misalignment could jeopardize the safety of American air travel.

RE: Objections to the Liquefied Natural Gas Export Pause

The Attorneys General of Kansas, Indiana, Louisiana, and 21 other states submitted a letter urging President Biden and Secretary Granholm to end the pause on LNG exports, arguing that it is unlawful, harmful to the economy, and detrimental to national security, particularly by empowering adversarial countries like Russia and Iran.

RE: Opposition to Proposed EPA Rule on Lead and Copper Pipe Replacements

The Attorneys General of Kansas and 13 other states submitted a public comment opposing the EPA’s proposed rule for mandatory nationwide lead pipe replacements, arguing it is unworkable, underfunded, unnecessary, and exceeds the EPA’s authority.

RE: Opposition to Proposed SEC Rule Allowing Listing of Natural Asset Companies

The Attorneys General of Utah, Kansas, and 23 other states submitted a public comment urging the SEC to disapprove a proposed NYSE rule that would allow the listing of Natural Asset Companies, arguing that the rule is unlawful, facilitates unprofitable and ideologically driven environmental initiatives, and undermines federal land use laws and constitutional principles.

RE: Opposition to the US DOC's Proposed Business Diversity Principles Advocating Race-Based Employment Practices

The Attorneys General of Kansas, Montana, Tennessee, and 16 other states argue that the Department's proposed DEIA-based Business Diversity Principles promote unlawful race-based employment practices that violate the Constitution and federal civil rights laws.

January 5th, 2024

 2023

RE: Opposition to Proposed ATF Rule on Firearm Sales

The Attorneys General from 26 states and the Arizona State Legislature formally oppose the Bureau of Alcohol, Tobacco, Firearms, and Explosives' proposed rule redefining "engaged in the business" of firearm sales, arguing it is unconstitutional, arbitrary, and imposes undue burdens on private gun owners while failing to address violent crime.

December 7th, 2023

RE: Objection to Proposed Rule Granting Collective Bargaining Rights to H-2A Workers

The letter, signed by 22 state attorneys general, opposes the Department of Labor's proposed rule granting unionization rights to H-2A agricultural workers, arguing it exceeds the agency’s authority, contradicts federal law, and unfairly prioritizes foreign workers over American farmworkers.

RE: Opposition to Proposed Rule Expanding “Lawfully Present” Definition Under ACA

A coalition of state attorneys general opposes an HHS proposed rule redefining “lawfully present” to include DACA and other deferred action recipients, arguing it violates federal law by extending public benefits to individuals Congress deemed ineligible.

RE: Objection to Department of Education Title IX Policy

A coalition of state attorneys general writes in opposition to the Department of Education's new Title IX non-discrimination policy on the basis of sex in education or activities receiving federal financial assistance.

RE: Concern Over Loan-Level Pricing Adjustments (LLPAs)

A coalition of state attorneys general opposes the Federal Housing Finance Agency’s new LLPAs, arguing they unfairly penalize responsible borrowers with good credit to subsidize riskier homebuyers, potentially leading to economic instability and a repeat of past mortgage crises.