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How to fix higher education

March 18, 2014, 10:14 AM

America’s elite higher education institutions are the envy of the world. Foreign students flock to the oldest and wealthiest U.S. research universities to take advantage of resources that are unparalleled, thanks to the deep pockets of many centuries’ worth of captains of industry.

Yet when we consider the post-secondary institutions that educate the typical American high school grad, we see a very different picture. While the share of Americans who enroll in higher education has grown substantially in recent decades, graduation rates have been stagnant.

Community colleges promise an affordable education to millions of students, but they often fail to offer the courses students need to complete a degree in a reasonable amount of time. Public colleges and universities churn out graduates who are forced to take jobs that don’t actually require a four-year post-secondary education. Most private non-profits do the same, and they’re also notorious for charging obscene tuition that their graduates can scarcely afford. And private for-profits, which have grown enormously by taking on some of the hardest-to-accommodate students, stand accused of loading up their students with debt without offering them marketable skills.

It is hard not to sympathize with the Obama administration, which last week launched a new effort to ensure that career training programs are meeting the needs of their students. The problem with the new White House push, however, is that it focuses on a too-narrow aspect of America’s higher education crisis: about 8,000 vocational programs at community colleges, state universities, and for-profit colleges, which train students in subjects like business administration, nursing and automotive repair.

The basic problem that the Obama administration hopes to tackle is that, while a large and growing number of students enroll in vocational post-secondary schools, most of whom make use of federal grant aid and subsidized loans to meet the cost of tuition, an alarmingly high share of them are failing to find well-paying jobs. And students who can’t find well-paying jobs struggle to meet the cost of servicing their loans, let alone pay them off.

The Department of Education plans to identify vocational programs that leave their average graduate paying a high share of their earnings in loan payments (8 percent or more of total earnings, 20 percent or more of discretionary earnings) as well as those with a high average loan default rate (of 30 percent or more). Programs that cross these red lines in two out of three years will lose the right to offer their students federal financial aid.

Curbing the abuses of this sector could do some good. But career training programs represent a small subset of the higher education universe. If we take a somewhat wider view, it seems pretty puzzling that, say, business or engineering majors at four-year colleges and universities aren’t being treated as enrollees in vocational programs.

Why not? Given the epidemic of underemployment among recent college graduates, it might make sense to apply the same standard to all post-secondary institutions, not just those that are explicitly labeled career training colleges.

Steve Gunderson, president of the Association of Private Sector Colleges and Universities, the trade association that represents the for-profit higher education sector, observes in a tart press release that “if the regulation were applied to all of higher education, programs like a bachelor’s degree in journalism from Northwestern University, a law degree from George Washington University Law School and a bachelor’s degree in social work from Virginia Commonwealth University, would all be penalized.”

My reply to Gunderson would be that, well, yes, let’s penalize these programs too. It makes perfect sense to establish a regulatory floor to protect consumers from the least effective post-secondary programs, whether they’re at vocational schools or standard-issue colleges and universities.

Even if we denied federal financial aid dollars to these programs, however, we’d still have students in need of post-secondary education options. The for-profit higher education sector often emphasizes that it serves students that community colleges and private nonprofits fail to reach, like working adults who need flexible schedules. It could be that wiping out the low-performing vocational schools will allow a new wave of high-performing vocational schools to flourish. Yet it’s also possible that vocational schools will stay on the right side of the new regulations by refusing to take on challenging students.

There are two really deep problems that plague U.S. higher education. The first is the absence of useful and reliable data that students and parents can use to evaluate programs of all kinds. In “College Blackout: How the Higher Education Lobby Fought to Keep Students in the Dark,” Amy Laitinen and Clare McCann of the New America Foundation recount how the private nonprofit higher education lobby has fought against efforts to create a federal student unit record system.

As obscure as this sounds, the lack of such a system makes it extremely difficult for higher education consumers to answer basic questions like which schools do the best job of preparing their graduates for the workforce and which leave their students drowning in debt. Making this data easily accessible would force the weakest performing schools to either change their ways or face steep enrollment declines. But if the students who turn away from the bottom of the barrel have nowhere else to go, as the best schools have only so many seats, we’ll still find ourselves in a bind.

This leads us to the second problem. While transparency would help expose the worst schools, it won’t necessarily improve the average quality of America’s higher education institutions. It’s true that in a world of greater transparency, schools would be more likely to offer a high-quality education at an affordable cost, but that’s not enough.

Andrew Kelly of the conservative American Enterprise Institute has emphasized that we need a supply-side strategy designed to increase the availability of affordable, high-quality college opportunities. This could mean making it easier for new schools to gain accreditation, or incentivizing existing high-quality schools to become more inclusive rather than more selective. Over time, increasing the supply of affordable, high-quality college opportunities will raise the average quality of higher education by driving the worst schools out of business and forcing the best schools to continually raise the bar.

By combining these strategies — greater transparency plus more entry of good schools and exit of bad schools — we can see to it that our entire higher education sector, and not just the elite slice at the top, is one that we can be proud of. That change advances upward mobility for all.

Rand Paul: Yes, he’s really the frontrunner

March 17, 2014, 12:21 PM

Sen. Rand Paul, a first-term senator from Kentucky, surprised more than a few pundits when he topped one of the first major polls surveying voters’ feelings on the 2016 Republican presidential primary. This poll-leading position is something his father, Ron, a frequent candidate for president, never held. And, even though it’s still early, I think that there’s a good case that Paul’s early support may turn into something real. In other words, he’s a legitimate frontrunner.

Let me say first, however, that I’m not a Paul booster. As a hawkish sort, I’m skeptical of his foreign policy views. I also wish he would come out in support of marriage equality. And I think very little of his support for the gold standard. That said, I admire a lot of the work he has done on mandatory minimum sentences, government spending, privacy and government transparency. He’s someone I could certainly see myself supporting in a general election. I think a lot of other Republicans feel this way too. Getting national defense conservatives on his side, it’s true, is going to require some changes to his foreign policy positions and he’ll probably have to make it clear that he’s not serious about the gold standard to get real business community support, too.

But neither his positions nor his current position in the very early polls mean much. Plenty of initial frontrunners for presidential nominations (Howard Dean and Rudy Giuliani) have flamed out on the campaign trail. Plenty of candidates who seemed to have “perfect” positions very much in line with the party base have also failed to get their parties nominations. But at least on the Republican side, something has mattered a lot more: having a political network. Except in 1964 — when Lyndon Johnson trounced Barry Goldwater — every Republican who has won an open nomination in anything like a modern primary process has had a preexisting state network of contacts in place. In most cases, they’ve built such networks through a previous run for president — Richard Nixon, Ronald Reagan, George H.W. Bush, Bob Dole, John McCain, Mitt Romney, and all had previous campaigns under their belts. George W. Bush, meanwhile, had access to his father’s preexisting political network.

The democratic, grassroots nature of the Republican nominating process means that even candidates willing to spend essentially limitless sums of money (i.e. Steve Forbes) just can’t gain traction or win states. To make a very broad generalization, the organizations that have power in the conservative movement are small and local. The groups that make up the Democratic coalitions — unions, government workers, business that relies on the government, environmentalists — tend to have central leadership and even formal organizations like the League of Conservation voters and AFL/CIO that decide who they will throw their muscle behind. The ones that are most important in the Republican primaries — churches, local business groups, small and medium-sized businesses — tend to be decentralized. There are, of course, exceptions to this: the NRA, for example, provides a central nexus of information and influence to (mostly Republican) gun rights supporters that’s far more influential amongst their constituency than any environmental organization is amongst environmentalists. But the broad generalization does hold up.

And Ron Paul, if nothing else, did build a network of county, city and ward leaders all over the country. It’s one his son can tap. Indeed, there’s a good case that only one other likely candidate, Rick Santorum, can claim a similar state-by-state network. And he’s far behind Paul in any poll. That puts Rand Paul in very good shape. There’s a real chance that he and a chosen running mate could command the top of the ballot in 2016.

7 reasons we’ll never solve the software patent wars

March 14, 2014, 3:18 PM

From NetworkWorld:

As I’ve noted in other posts, the SXSW conference is generally an optimistic event, so it was no surprise to see a panel called How to Fix Patent: Trolls, Innovators & Reform. Unfortunately, actually attending the panel left me with a very different impression… more along the lines of “abandon hope all ye who enter here.” 

The panelists – Julie Hopkins, Intellectual Property Practice Chair & Partner at the law firm of Tydings & Rosenberg LLP; Google senior counsel Lee Dunn; Russ Merbeth, chief policy counsel for Intellectual Ventures (the patent house headlined by former Microsoftie Nathan Myrhvold); and moderator Reihan Salam, senior fellow at the R Street Institute think tank – came from such vastly different perspectives that it seemed impossible they could ever find common ground.

Patents involve conflicts between legitimate needs: On the one hand, the goal of patent law is to protect inventors and spur innovation, but it also wants to protect the rights of patent holders. Worse, the players’ needs can change over time. “Small entities have one set of interests,” said Salam, “but when you become large entity, your interests change.” Google’s Dunn agreed: “Your perspective has to change when you’re sued, as often as we are.” Google started with many innovations that were open source, she added, but “we’ve been forced to become more defensive, as everyone has.”

Vapers, know your e-cig ingredients: propylene glycol

March 14, 2014, 3:07 PM

A common knock against e-cigarettes is that we don’t know the long-term health effects of consuming nicotine vapor.  The fact is that while it’s impossible to have complete knowledge about a novel form of tobacco use, scientists already know a great deal about propylene glycol (PG), a key ingredient of the vapor in e-cigarettes.

A comprehensive 2012 PG toxicology review, authored by members of the Cosmetics Ingredient Review (CIR) expert panel, appeared in the International Journal of Toxicology.

The report was an update of a 1994 assessment which concluded that PG was “safe for use in cosmetic products at concentrations up to 50.0%” – the cosmetic industry standard at the time.    By 2012, PG was used in 9,094 of 34,391 cosmetic and personal care formulations.  One of the most interesting passages in the 1994 document was a description of aerosolized PG in hair sprays:

Propylene glycol is used in hair sprays, and its effects on the lungs that may be induced by aerosolized products containing this ingredient may be of concern.  The aerosol properties that determine deposition in the respiratory system are particle size and density.  The parameter most closely associated with deposition is the aerodynamic diameter, da, defined as the diameter of a sphere of unit density possessing the same terminal settling velocity as the particle in question.  In humans, particles with an aerodynamic diameter of < 10 um [micrometers] are respirable. Particles with a da from 0.1 to 10 um settle in the upper respiratory tract and particles with a da < 0.1 um settle in the lower respiratory tract.  Particle diameters of 60 to 80 um and > 80 um have been reported for anhydrous hair sprays and pump hairsprays, respectively.  In practice, aerosols should have at least 99% of their particle diameters in the 10 to 110 um range and the mean particle diameter in a typical aerosol spray has been reported as ~ 38 um.  Therefore, most aerosol particles are deposited in the nasopharyngeal region and are not respirable.

In contrast, PG aerosols generated by e-cigarettes appear to be smaller, in the range of 0.1 to 0.4 um, according to a study published last year. So, while it likely that most e-cigarette vapor is settling in the upper respiratory tract, some small aerosol particles are likely reaching deeper lung tissue.

The 2012 CIR panel also commented about PG as a food additive:

According to the Joint FAO/WHO Expert Committee on Food Additives (JECFA), the acceptable daily intake of PG is 25 milligrams per kilogram of body weight per day.  In Japan, the Ministry of Health, Labour, and Welfare (MHLW) specified that according to the food sanitation law, PG has no potential to cause harm to human health.

The CIR panel also reviewed numerous animal studies regarding potential problems.  They concluded:

Both PG and PPGs [polypropylene glycols] were not considered to be acute or chronic toxicants in oral or dermal studies, were not genotoxic or carcinogenic, and were not reproductive or developmental toxicants, supporting that their use in cosmetics would be safe in regard to these end points. 

The CIR was established in 1976 by an industry association with the support of the FDA and the Consumer Federation of America; it reviews and assesses the safety of ingredients used in cosmetics.  University faculty, industry representatives and the director of the Office of Cosmetics and Colors at the FDA participate in the reviews, which are conducted according to published procedures. The CIR appears to be an excellent example of cooperation between federal regulators and the industry they regulate; it might serve as a template for cooperation among the FDA Center for Tobacco Products and tobacco manufacturers.

The FDA has thus far taken an aggressively antagonistic approach in its regulatory procedures, some of which are dictated by the 2009 enabling legislation.  For example, the legislation prohibits members of the FDA Tobacco Product Scientific Advisory Committee (TPSAC) from having any relationship with the tobacco industry in the 18 months preceding their appointment. This is in direct contrast to all other federal advisory committees (including expert CIR panels), in which an industry conflict of interest for a qualified candidate is reportable but not prohibited.

The CIR serves the public interest in producing an informative PG safety review; it also serves as a role model for constructive government-industry interaction.

This work is licensed under a Creative Commons Attribution-NoDerivs 3.0 Unported License.

Good News: The government will no longer make you put your house on stilts

March 14, 2014, 1:04 PM

From Businessweek:

Praise didn’t come from all quarters. Andrew Moylan, a senior fellow at R Street Institute, a Washington think tank that was involved in drafting the 2012 overhaul, says Congress’s decision to undo the earlier law shows the power of “a small group of vocal homeowners” scaring Congress. “It rebreaks the flood insurance program,” he says.

Phila. lawmakers move toward ban of e-cigarettes in public places

March 14, 2014, 12:20 PM

From CBS Philly:

But many speakers spoke in opposition. Among them was Dr. Joel Nitzkin, speaking for what he described as a libertarian think tank called the  R Street Institute.

“E-cigarette vapor contains no products of combustion and only the tiniest traces of other toxic substances,” he said.  “E-cigarettes pose a risk well below two percent of the risk posed by regular cigarettes, and for all practical purposes, no risk to bystanders.”

Criminal-justice reform and federal funding

March 13, 2014, 2:16 PM

If you need evidence of how much conservative thinking about crime has changed over the past few decades, look no further than the crowd gathered for last week’s CPAC panel on criminal-justice reform, featuring such stalwart conservatives as Grover Norquist and Texas Gov. Rick Perry

Rather than focusing solely on locking people up (still a good thing to do in many cases), conservatives have taken the lead in efforts to encourage businesses to hire more ex-offenders and improve drug treatment behind bars. Thus far, most of these efforts have been focused at the state level, since states enforce the great bulk of criminal laws and imprison most inmates.

While this approach has served the burgeoning movement well, in the long run, conservative criminal-justice reformers will need to grapple with federal policy, as well. Thanks to roughly a dozen federal grant programs of various scopes and sizes, federal policies influence nearly every aspect of local police and corrections practice. But given conservatives’ general skepticism about almost any federal role in local law enforcement (a skepticism I share), few on the right have made constructive proposals for reform at the national level.

This is a mistake. There are some federal law-enforcement programs — such as ones involving border security, technological development and anti-terrorism efforts — that it makes sense for conservatives to support. In other areas, existing federal programs encourage localities to do the wrong things, with funds tied to locking up more offenders and making more arrests. These incentives lead to more spending and bigger government.

Like much of what government does, the inefficient and misguided programs have proven nearly impossible to kill, so ignoring them really isn’t an option. Instead, the right should look to craft its own reform program, while building on to what’s good that has come from the left.

In particular, New York University’s Brennan Center has given a lot of deep thought to ways to fix the largest single police-facing federal program, the Edward A. Byrne Justice Assistance Grant Program. Instead of simply rewarding police for making more arrests and issuing more warrants, the Brennan Center team proposes rewarding localities for reducing violent crime, diverting non-violent drug offenders to treatment rather than prison and otherwise policing smarter. These ideas, packaged under the rubric of “success-oriented funding,” make a lot of sense.

There’s reason to think the federal government should vastly reduce its role in criminal justice. But if federal programs are to continue, we have to stop them from doing harm. The Brennan Center’s proposals offer one potential path for moving in the right direction.

Judiciary Committee hears Internet sales tax testimony

March 13, 2014, 11:17 AM

From Heartlander:

Andrew Moylan of the R Street Institute. His testimony favored origin-sourcing, the concept of taxing sales based on where the seller is located rather than where the customer is located. Origin-sourcing reconfigures the sales tax from a consumption tax to a business activity tax, which is revolutionary. The most common critique of origin-sourcing is that it would lead to online sellers clustering in states with no sales tax, which is questionable.


House looks for best way to ‘level the playing field’ with online sales taxes

March 13, 2014, 11:15 AM

From National Journal:

“Simply treating remote sales in the same way that we already treat brick-and-mortar sales would level the playing field in an honest way,” said the R Street Institute’s Andrew Moylan.

 

US House considers alternatives to Internet sales tax bill

March 13, 2014, 10:30 AM
From PC World:

An online sales tax based on the seller’s location would work much like brick-and-mortar sales taxes do today, added Andrew Moylan, outreach director at the R Street Institute, a think tank advocating for free markets. If a Washington, D.C., resident shops in Virginia, she pays Virginia’s sales tax, he noted.

But Stephen Kranz, a partner in the McDermott Will & Emery law firm and a member of the Streamlined Sales Tax Governing Board, said a tax system based on the seller’s location would be easy to game and would likely drive Internet retailers to relocate or set up ghost headquarters in the handful of states without sales taxes.

The proposals from Moylan and Cox would create “a race to the bottom” in state tax rates, added Representative Jerrold Nadler, a New York Democrat.

Origin sourcing takes a beating at congressional hearing

March 13, 2014, 10:27 AM

From Digital Marketing News:

Another proponent of origin sourcing, Andrew Moylan, senior fellow of R Street, argued that MFA would hinder economic growth by penalizing the rampant growth of Internet businesses. “Origin sourcing truly levels the playing field,” he told the committee. “The MFA would erase the physical presence standard for remote sales while ostensibly maintaining it for brick-and-mortar sales.”

Free-marketeers, tree huggers join in opposition to dredging at Port of Palm Beach

March 12, 2014, 8:09 AM

From Palm Beach Post:

The group, calling itself the Green Scissors Coalition, wrote a letter to the U.S. Army Corps of Engineers opposing the project. The Green Scissors Coalition members describe themselves thus: “Friends of the Earth is a progressive environmental group, Taxpayers for Common Sense is a budget watchdog and R Street is a conservative think tank.”

An Army Corps of Engineers analysis projects the dredging would create “net annual benefits” of $3.98 million, but the Green Scissors Coalition is skeptical.

“Palm Beach is a small port that has rarely shown profits and is located between two much larger ports,” they write. “There is little chance that a modest expansion will have a significant economic impact in any case.”

Sea level rise predictions have little effect on Florida real estate

March 12, 2014, 8:06 AM

From WBUR Radio:

RUNDLET: Whether or not your property will be here 30 years from now, Johnson says it may be the insurance issue that determines real estate prices. After all the payouts following Hurricane Sandy, the National Flood Insurance Program went into debt by more than $20 billion. While the price of flood insurance will always be a factor for folks living in known flood zones, Eli Lehrer says there’s another more urgent problem beside sea level rise. Lehrer is the president of a Washington, D.C. think tank called the R Street Institute. It focuses on the insurance industry.

ELI LEHRER: Storm surge is a larger and more imminent problem than is sea level rise. Sea level rise is projected to be somewhere between two and five feet over the next century. Storm surge is going to be six feet from a category 1 hurricane, and the chances that a category 1 hurricane hitting Florida are virtually 100 percent.

R Street testifies on alternatives to Internet sales tax

March 12, 2014, 8:05 AM

WASHINGTON (March 12, 2014) – Allowing states to apply sales taxes where a retailer is located, rather than where a consumer lives, offers a fairer and more efficient alternative to misguided Internet sales tax legislation passed last year by the U.S. Senate, R Street Institute Senior Fellow Andrew Moylan told the House Judiciary Committee this morning.

Testifying at a hearing on alternatives to S. 743, the Marketplace Fairness Act, Moylan said “origin sourcing” collection standards already in use to collect sales tax for brick-and-mortar sales should be the norm for remote sales as well. By contrast, he noted, “destination sourcing” standards such as those imposed by the S. 743 would undermine basic principles of sound tax policy, impose unequal collection burdens on businesses and constitute a substantial burden on interstate commerce.

“Extending the existing origin sourcing collection standards would ensure that all retail sales are governed by the same straightforward rules, requiring tax collection based on the physical location of the business, not the residence of the buyer,” said Moylan. “This solution also meets Internet sales tax principles laid out by Chairman Goodlatte late last year.”

Moylan also stressed that the Marketplace Fairness Act is extremely unpopular. In a poll commissioned last year by R Street and the National Taxpayers Union to test public attitudes on Internet sales tax issues, 57 percent said they opposed a Marketplace Fairness Act-type of plan.

“No Congress should govern by poll alone, but this data proves that not only is a destination-sourcing scheme like the MFA bad policy, it is profoundly bad politics as well,” cautioned Moylan. “That should send a strong message to this committee that America is engaged on this issue and that only something like an origin-sourcing rule to truly level the playing field can pass muster with them.”

Testimony to House Judiciary Committee on Internet sales tax

March 12, 2014, 8:00 AM

In March 12 testimony before the House Judiciary Committee, R Street Institute Senior Fellow Andrew Moylan noted that S. 743, the so-called Marketplace Fairness Act (MFA), would undermine basic principles of sound tax policy, impose unequal collection burdens on businesses and constitute a substantial burden on interstate commerce.

However, Moylan added that extending simple “origin sourcing” collection standards already in use nationwide for brick-and-mortar sales to all remote sales as well would address the concern that current law is inadequate, maintain important tax policy protections and meet Internet sales tax principles laid out by Chairman Goodlatte late last year. This shift would ensure that all retail sales are governed by the same straightforward rules, requiring tax collection based on the physical location of the business, not the residence of the buyer.

Bipartisan agreement to keep subsidizing seaside homes

March 11, 2014, 4:11 PM

From the Washington Examiner:

R Street, a free-market insurance think tank, blasted the House vote. Taxpayers for Common Sense also inveighed against it.

Venice Beach to get millions for renourishment

March 11, 2014, 1:58 PM

From the Herald-Tribune:

The R Street Institute, a nonpartisan organization in Washington, D.C., is an especially vocal critic of federally funded beach renourishment.

“Beach renourishment is an enormous waste of federal tax money,” institute founder Eli Lehrer said Thursday. “There isn’t a case for federal involvement.”

If localities want to rebuild their beaches, they should have the local economy pay for it, Lehrer said.

Regardless, he considers such projects as needlessly wasteful. “We’re dumping sand in places where any 5-year-old could tell you that, if you build a sandcastle there, it will only wash away.”

House votes to reinstate flood insurance subsidies, limit premiums

March 11, 2014, 1:55 PM

From SNL Financial

The next phase of the flood battle will be to see if the Senate goes along with the offset to cover “their foolish choice to dismantle flood insurance reform,” said Andrew Moylan, a senior fellow at the R Street Institute. “We’ll be arguing on the side of a surcharge or other policy to prevent taxpayers from having to shoulder more burdens as a result of this broken program,” he told SNL.

R Street and Ellis’ group are members of SmarterSafer.org, a coalition that also includes environmental groups. Insurance industry members include Chubb Corp., Liberty Mutual Holding Co. Inc. and United Services Automobile Association.

This Week in Tech: House panel eyes online sales tax

March 11, 2014, 1:23 PM

From The Hill:

Witnesses for Wednesday’s hearing include Chris Cox, counsel at NetChoice, which represents companies such as eBay; Joe Crosby, principal at MultiState Associates; and Andrew Moylan, senior fellow at the R Street Institute. The committee will also hear testimony from sales tax attorneys.

Green Scissors letter on expansion of Port of Palm Beach

March 11, 2014, 1:18 PM

Col. Alan M. Dodd
District Engineer
Jacksonville District
United States Army Corps of Engineers 
701 San Marco Blvd
Jacksonville, FL  32207-8175

RE:  Response to Final Integrated Feasibility Report and Impact Statement
EIS#  20140025

March 7, 2014

Dear Col. Dodd,

As the members of the Green Scissors Coalition, Friends of the Earth, Taxpayers for Common Sense and the R Street Institute wish to state our opposition to proposals to expand the Port of Palm Beach.  While all three groups have different missions, visions and ideologies—Friends of the Earth is a progressive environmental group, Taxpayers for Common Sense is a budget watchdog and R Street is a conservative think tank—all three are united in their opposition to projects that are wasteful and environmentally harmful. The proposed port expansion in Palm Beach is one such project.

The EIS you are considering has severe flaws. Among other things, the purpose and need as put together is an exercise in question begging that’s tailored to result in the Corps’ conclusion. The EIS also fails to address many legitimate environmental concerns or consider less environmentally harmful ways that the same economic benefits might well be achieved.  The proposed expansion may also serve to intensify storm surge inland following major hurricanes.

There are also strong common sense reasons to be skeptical of this port expansion proposal: Palm Beach is a small port that has rarely shown profits and is located between two much larger ports. There is little chance that a modest expansion will have a significant economic impact in any case.

In short, we urge you to study this situation further and hold off on any effort to expand the Port of Palm Beach.

Respectfully submitted,

The Green Scissors Coalition

Friends of the Earth
Taxpayers for Common Sense
R Street Institute

Contact: Eli Lehrer (202)525-5717 – elehrer@rstreet.org