July 21, 2026

Congress Should Reject H.R. 6213 and Protect Workers from Extreme Heat

Dear Members of Congress:

The undersigned organizations urge the House Committee on Education and Workforce to reject H.R. 6213, the Heat Workforce Standards Act, at markup this Tuesday. The bill would prohibit the Secretary of Labor from finalizing, implementing, or enforcing a federal heat injury and illness prevention standard, or any substantially similar measure.

In the wake of a nationwide heat dome that sent workers to emergency rooms across the country just three weeks ago, the Committee is now considering legislation that would permanently prohibit federal workplace heat protections. Data from the Centers for Disease Control’s Heat and Health Tracker show that emergency department visits for heat-related illness rose sharply across the Midwest and Mid-Atlantic during the first week of July. Postal carriers, delivery drivers, warehouse workers, and manufacturing employees were hospitalized, and in some tragic cases, lost their lives.

By advancing this legislation, the Committee would permanently remove the federal government’s authority to address a workplace hazard that is already resulting in worker fatalities. The Bureau of Labor Statistics recorded 55 worker deaths from heat exposure in 2023, a number that safety researchers widely consider to be an undercount due to frequent misclassification or underreporting of heat-related illnesses and fatalities. More broadly, heat-related deaths in the United States have more than doubled since 1999, and extreme heat now claims more lives each year than any other weather-related hazard.
H.R. 6213 would permanently prohibit the Department of Labor from finalizing, implementing, or enforcing a federal heat standard. The bill includes no sunset provision, no mechanism for future reconsideration, and no opportunity for action as heat-related injuries and fatalities continue to increase.

This approach is especially difficult to justify considering the extensive process OSHA has already undertaken. The agency’s proposed heat injury and illness prevention standard is the result of research, stakeholder engagement, public hearings, and review of over 43,000 public comments. OSHA estimates the rule would protect approximately 36 million workers, and Public Citizen has previously estimated that a comprehensive federal heat standard could prevent at least 50,000 heat-related injuries and illnesses each year.

Supporters of H.R. 6213 argue that OSHA’s proposal would impose significant burdens on employers. However, the proposed standard establishes essential baseline protection while providing employers with flexibility in how they achieve compliance. Instead of mandating a single nationwide approach, the rule allows employers to tailor heat illness prevention programs to their specific operations and workforce. Employers with effective programs already in place would experience minimal additional requirements. The bill would prevent the establishment of a basic national standard for employers who currently offer no meaningful heat protection.

Workers have no control over extreme heat, and many are unable to refuse hazardous assignments without jeopardizing their livelihoods. Congress should not respond to an escalating occupational hazard by permanently removing the Department of Labor’s authority to address it.

For these reasons, the undersigned organizations urge the Committee to reject H.R. 6213 and to allow OSHA’s heat injury and illness prevention rulemaking to proceed.

Thank you for your attention to this critical matter. We are available to provide any additional information, data, or testimony that may assist the Committee in its deliberations.

Sincerely,

House: oppose HR 6955, bank deregulation

Honorable Members
United States House of Representatives
Washington, DC 20515M

Please vote NO on HR 6955, Main Street Capital Access Act

Dear honorable member,

On behalf of more than one million members and supporters of Public Citizen, we ask you to Vote NO on the Main Street Capital Access Act, HR. 6955.

This sprawling bill collects more than two dozen deregulatory measures considered by previous congresses that undermine bank safeguards, consumer protection, anti-discrimination measures and more. Most failed to gain any meaningful bipartisan support when considered individually. While Republican leadership baited this bill with a few Democrat-sponsored measures, responsible lawmakers must understand that the overwhelming majority of these policy changes endangers the financial system.

For example, Section 101 reduces solvency (capital) safeguards for new banks. Untested banks must be held to strict standards, not permitted to experiment recklessly with federally insured bank depositor money. Section 201 represents a paralyzing oversight measure by requiring all regulations to be tailored not only to the size of an institution, but its own particular risk profile. In practice, this would allow any bank to sue an agency for alleged breach of this tailoring injunction, which could bring supervision of banking to a standstill. Similarly, Section 205 increases three dozen regulatory thresholds that trigger oversight, from solvency standards, fair lending, community reinvestment and other worthy public policy goals. This invites small mid-sized banks to ignore sound policies adopted over decades. Section 204 raises from $250 billion to $370 billion the asset level that subjects banks to enhanced scrutiny. Already, the elevation of this asset threshold from the original $50 billion set by the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act led to irresponsible growth by certain regional banks that precipitated the crisis of 2023, which included three of the four largest bank failures in U.S. history. Section 307 removes “reputational risk” as a component of supervision. Reputation meaningfully impacts bank operations. For example, those banks that serviced convicted sex offender Jeffrey Epstein suffer frequent adverse media mention. Removal of reputational risk in supervision ignores a patent reality. Section 601 waives already insufficient review of bank merger applications for those with less than $10 billion in assets. This will lead to fewer community banks. Similarly, Section 604 limits the ability of the Federal Reserve to consider input from stakeholders during mergers. It also sets a 120-day deadline for automatic approval, even if a regulatory evaluation remains incomplete. This means ill-advised mergers may be consummated for lack of regulatory time. Section 801 expands merchant banking permissions. Merchant banking refers to commercial activities, long a sound policy prohibition. Banks should be lenders, not competitors of those to whom they might lend.

Again, we believe these serious assaults on basic bank safety and merger standards must compel lawmakers to reject this bill.

For questions, please contact Bartlett Naylor at bnaylor@citizen.org.

Sincerely,

Public Citizen

Rehearing Request of DOE Attempt to Evicerate Electricity Export Regulations

By Tyson Slocum

In a clumsy effort to try and resolve the conflict between Trump’s push to force consumers to bail out uneconomic coal power plants under Section 202c of the Federal Power Act, and its obligations to only authorize electricity exports to Canada/Mexico under 202e, the U.S. Department of Energy has issued a final rule eviscerating its electricity export application procedures. We have discussed this previously, and today we have petitioned for rehearing of the final rule.  You can access the rehearing request here: Rehearing petitionPublic CitizenElectricityExports

 

July 20, 2026

We Demand FERC Break up BlackRock

BlackRock's Attempt to Acquire Utility AES Must Be Stopped

By Tyson Slocum

Today before the Federal Energy Regulatory Commission in Docket EC26-99, Public Citizen joins with the Private Equity Stakeholder Project and Citizens Action Coalition of Indiana to stop BlackRock’s effort to buy utility AES, where we argue FERC must either reject the merger or require BlackRock to be broken apart.

On May 21, affiliates of BlackRock, Swedish private equity firm EQT, and the sovereign wealth fund of the Qatari monarchy filed an application with the Commission seeking permission to acquire AES Corporation for $33.4 billion (including debt). AES is the parent company of the franchised utilities Indianapolis Power & Light Company and Dayton Power & Light Company with nearly 1.1 million captive customers.

Under the proposed transaction, BlackRock affiliates would control 56.625% of AES (which includes BlackRock’s management of CalPERS’ stake); affiliates of EQT would control 33.375%; and 10% would be controlled by the sovereign wealth fund of Qatar, a monarchy where women and some other residents have limited rights.

Section 201 of the Federal Power Act declares “that the business of transmitting and selling electric energy for ultimate distribution to the public is affected with a public interest”. The Federal Power Act compels any entity seeking to acquire or control a public utility to first obtain permission from the Commission: “[n]o public utility shall, without first having secured an order of the Commission authorizing it to do so” allow a “change in control” until “it finds that the proposed transaction will be consistent with the public interest”.

The transaction’s involvement of BlackRock violates BlackRock’s blanket authorization and the public interest, and therefore the Commission must set the matter for evidentiary hearing to determine the required mitigation: the Commission must compel BlackRock to legally and fully separate its non-controlling asset management business from its active management of utilities. Otherwise, it must reject the application for failure to adhere to the public interest. Congress handed the Commission sweeping powers under the Federal Power Act to prioritize the protection of the public interest and captive consumers, so the proposed mitigation is within the Commission’s statutory authorities.

Read the full filing here: PESP PC CAC FERC BlackRock EQT AES protest 072026

July 17, 2026

Memo: Competition in the Digital Economy: Separating Fact from Big Tech Fiction

MEMORANDUM

To:	U.S. Congress
From:	Public Citizen
Date:	July 17, 2026
Re:	Competition in the Digital Economy: Separating Fact from Big Tech Fiction

Over the past few years, several countries have enacted or sought to enact digital competition/antitrust laws. Many of these laws bar various forms of harmful behaviour by dominant digital platforms and also impose competition-enhancing obligations on them.

These laws are necessary for a number of reasons, including:

• Significant harms to consumers and smaller businesses by vertical and horizontal bundling of services by dominant digital service providers;
• First mover advantage;
• Network effects;
• Access to data as a competitive advantage;
• Quick pace of technological change and the inability of legacy legal frameworks to keep pace;
• Economies of scale;
• Rapid growth of digital businesses through mergers and acquisitions.

Examples of such laws include:

• Enacted: the EU’s Digital Markets Act (DMA)^[1], the UK’s Digital Markets, Competition and Consumers Act, 2024 (DMCCA), Japan’s Smartphone Software Competition Promotion Act and Mobile Software Competition Act, and Nigeria’s Federal Competition and Consumer Protection Act.
• Proposed: India, Australia, South Africa, South Korea, Kenya, Brazil, Canada, Thailand, and Turkiye.

Big Tech has long opposed any form of digital economy regulation implemented both within and outside the U.S, including measures to promote and protect competition in online markets. More recently, Big Tech has sought to leverage its proximity to the Trump administration to target digital competition (and other) laws in several countries, as illustrated in industry comments submitted to the USTR’s reciprocal tariff and National Trade Estimates report consultations in 2025.

The primary arguments made against foreign digital competition laws are that:

• These laws discriminate against U.S. companies by using thresholds based on user and revenue base to determine applicability;
• Fines imposed on U.S. companies under such laws are excessive and disproportionate;
• Such laws expose the intellectual property (IP) of U.S. companies to misuse;
• Fines imposed under such laws are a “tariff” on U.S. companies and designed to “handicap” U.S. firms.

These claims are mistaken and misleading, given that:

• U.S. companies do in fact dominate and monopolize various sectors of the digital economy, implying that those dominant companies will naturally face greater antitrust scrutiny;
• Laws such as the EU’s DMA, the UK’s DMCCA and Brazil’s proposed Fair Competition Act for Digital Markets are neutral and do not only apply to U.S. companies. They apply irrespective of the country of origin;
• Thresholds in laws such as the DMA are based on quantitative criteria such as user base, economic scale, and market presence. This provides an objective assessment and proxy for the systemic risk posed by the platform to users and smaller businesses. Assessments may also consider qualitative structural characteristics such as network effects and data-driven advantages. This allows companies that meet the thresholds but are not structurally significant to be excluded from designation, while smaller companies that are structurally significant can be included. Similarly, thresholds in the DMCCA are based on market power, economic size, and digital activity in the UK;  
• The EU has designated non-U.S. firms as gatekeepers/very large online platforms, such as ByteDance, Alibaba, Ali Express, and Booking.com under the DMA/DSA. Enhanced obligations are equally applicable to all designated entities; 
• Enforcement actions in the EU are generally preceded by attempts to secure voluntary compliance, allowing the infringing entities to challenge designations/enforcement actions and appeal decisions. Several investigations under the DMA/DSA have been closed by the EU Commission following constructive dialogue. This illustrates the lack of political intent to discriminate against U.S. companies;
• The EU has often only imposed “modest” or “insufficient” fines on U.S. companies found to be in breach of the DMA/DSA;
• Competition and other regulatory authorities around the world have dealt with sensitive business information for decades, across multiple economic sectors. There is no reason why the intellectual property of tech companies will be exposed merely by requirements to cooperate with enforcement processes.

Rather than targeting foreign countries for their legitimate enactment and enforcement of competition law in the digital ecosystem, the US should enforce digital antitrust laws domestically. There is bipartisan consensus that the dominance of Big Tech is a problem and harms users and small businesses and poses structural concerns to the economy and society more broadly. Indeed, the U.S. has previously taken similar antitrust action against Big Tech as is being taken and considered in various foreign jurisdictions.

• Framing these initiatives as “anti-U.S.” obscures their policy rationale and dismisses the sovereign right and responsibility of governments to regulate all companies operating within their borders that wield structural power over key sectors of the economy.  
• Using trade policy to attack foreign countries’ digital competition initiatives is both highly inappropriate and self-defeating. Competition policy is a core element of domestic economic governance, and countries must retain the policy space to address concentrated market power in ways suited to their own institutional and market realities.
• Pushing back against foreign digital competition law threatens similar U.S. policies and hurts small and medium enterprises in the U.S. and the world over. Notably, several small businesses expressed their support for the shift in the U.S. position on digital trade under President Biden, to enable countries to enforce digital competition and other public interest laws to create a fair and level playing field in the digital ecosystem.
  

Further Reading:

• Public Citizen, “Congressional Hearings Provide Megaphone for Big Tech Attacks on Global Anti-Monopoly Laws,” December 22, 2025, https://www.citizen.org/article/congressional-hearings-provide-megaphone-for-big-tech-attacks-on-global-anti-monopoly-laws/
• Public Citizen, “Don’t Fall for the Big Tech B.S.: The European Commission’s Fines Against Apple and Meta are not ‘Retaliatory Tariffs,’” April 24, 2025, https://www.citizen.org/article/dont-fall-for-the-big-tech-b-s-the-european-commissions-fines-against-apple-and-meta/
• Rethink Trade, “International Preemption by “Trade” Agreement: Big Tech’s Ploy to Undermine Privacy, AI Accountability, and Anti-Monopoly Policies,” March 15, 2023, https://rethinktrade.org/reports/international-preemption-by-trade-agreement/
• Coalition for App Fairness et al., “Letter to Ambassador Tai and Secretary Raimondo,” May 16, 2023, https://www.washingtonpost.com/documents/9ee18cda-efb8-44ac-a84d-b53b48534a91.pdf
• Joseph Stiglitz, “Big Tech Is Trying to Prevent Debate About Its Social Harms,” Foreign Policy, April 4, 2024, https://foreignpolicy.com/2024/04/04/big-tech-digital-trade-regulation/
• DeLauro et al., “Letter to President Biden,” February 12, 2024, https://rethinktrade.org/letters-filings/letter-88-democrats-rosa_delauro/
• Guilherme Ribas and Leonardo Danesi, “Brazilian Antitrust Authority may Become a Regulator for Digital Markets”, International Bar Association, March 26, 2026, https://www.ibanet.org/Brazilian-antitrust-authority-may-become-regulator
• Beatriz Kira, “Brazil’s Bill No. 4675/2025: Regulating Systemically Important Economic Actors,” January 22, 2026, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6113706

 

---

^[1] Also the Digital Services Act, which establishes ex ante safety and accountability norms for digital platforms, with enhanced obligations on “very large online platforms.”

Public Citizen Comment to USITC re China’s State Support and Pricing Practices in the Biotechnology Sector

On March 2, 2026, the U.S. International Trade Commission (USITC) initiated Investigation No. 332-610, Impact on U.S. Industry of China’s State Support and Pricing Practices in the Biotechnology Sector, to produce a report as directed by the U.S. Senate Committee on Appropriations reviewing the extent to which Chinese state support and pricing practices in the biotechnology sector may be affecting market share and competitiveness of the U.S. industry.

Public Citizen written submission to Investigation No. 332-610.

July 14, 2026

Mass Arbitration of Individual Claims: The Inevitable Result of Forced Arbitration

Forced Arbitration Keeps People from Accessing Justice

Many Americans assume that they have a constitutional right to bring legal disputes in court. The ability to access the courts is often critical for individuals and groups seeking relief from corporate or government wrongdoing. Because court proceedings are open to the public, the court system also helps to inform the public about wrongdoing against consumers, workers, and others. Pursuing claims in the judicial system, however, is increasingly out of reach because corporations have worked hard to shield themselves from the system by inserting forced arbitration clauses and class-action bans in a wide array of contracts.

Forced arbitration clauses allow corporations to deny consumers and workers their day in court, deter consumers from pursuing claims, keep misconduct out of public view, and limit accountability when a corporation’s actions have harmed large numbers of people. Corporations often insert these clauses into non-negotiable consumer and worker contracts, where many people do not discover them until after a dispute arises. These clauses require that any individual only use private arbitration, not the courts, to handle disputes, and the clauses frequently include provisions that ban class actions, thereby creating a significant barrier to challenging unlawful practices that impose small-value harm on large numbers of people. Because arbitration proceedings are generally private and decisions often remain hidden, forced arbitration also generally keeps corporate wrongdoing out of the public view.

Increasingly, corporations impose additional hurdles before arbitration can even begin, such as mandatory notice requirements, pre-dispute procedures, and forced mediation. A 2024 academic review found that nearly 80% of arbitration clauses analyzed require some form of pre-arbitration dispute resolution before a claim may proceed.

Because arbitration proceedings are generally secret and decisions often remain hidden, forced arbitration can shield corporate wrongdoing from public view and deny the transparency and accountability that a fair civil justice system requires. For example:

In 2020, Wells Fargo & Company agreed to pay $3 billion to resolve potential criminal and civil liability stemming from the creation of 5 million unauthorized bank and credit accounts and the misuse of consumer identities over approximately 14 years. As affected consumers began filing lawsuits against the bank, the bank relied on terms of service in customer agreements that imposed mandatory arbitration, out of public view, for disputes concerning accounts that customers had never consented to open.

In a few cases, courts have found that a forced arbitration provision creates such a significant hurdle to accountability as to be unconscionable, based on the specific facts of the case. For example, in some cases, the costs of arbitration have been so high as to effectively prevent the consumer from pursuing the dispute. In employment cases, courts have held that arbitration agreements cannot “require the employee to bear any type of expense that the employee would not be required to bear if he or she were free to bring the action in court.” In response, some corporations insert language into their employment contracts making the company responsible for paying initial arbitration filing fees.

Public Citizen has a long history of fighting companies’ use of forced arbitration in the courts and advocating in Congress for legislation that would give workers and consumers the right to decide after a dispute arises whether to bring their claims before a court or an arbitrator.

Mass Arbitration of Individual Claims

“Mass arbitration” refers to a situation in which large numbers of consumers file claims in individual arbitration proceedings arising from the same underlying company action. For example, 1,000 people may file claims against the same credit card company concerning an allegedly unlawful overcharge. Mass arbitration is a foreseeable consequence of corporations making forced arbitration a standard provision in consumer and worker contracts. What would be one class action, had corporations not imposed forced arbitration and class-action bans; may, not surprisingly, now be thousands of individual arbitration proceedings.

Corporations complain about mass arbitration filings by individuals, especially when the corporations are responsible for paying initial filing fees, a responsibility that they have tried to evade. For example:

In 2020, facing 5,010 individual claims by gig economy workers seeking overtime pay and minimum wage, DoorDash tried to avoid paying arbitration fees and instead proceeded in court. The court ordered the company to pay the $9.5 million in arbitration fees. The judge rightly observed that “[]in irony upon irony, DoorDash now wishes to resort to a class-wide lawsuit, the very device it denied to the workers, to avoid its duty to arbitrate. This hypocrisy will not be blessed, at least by this order.”

Rather than acknowledging that corporate wrongdoing can affect large numbers of people, leading to numerous individual claims, supporters of forced arbitration criticize mass arbitration as an abuse by consumers’ lawyers. This criticism disregards the principal cause of mass arbitration: companies’ insistence that claims be brought in arbitration rather than in court, and their practice of revising the terms of consumer contracts at will to make it more difficult for consumers and workers to bring claims in court.|

Batch Arbitration: Yet Another Corporate Tool to Circumvent Accountability

As discussed above, mass arbitration is a predictable consequence when arbitration is the only option available to individuals seeking remedies for corporate wrongdoing that affects a large number of people. When that happens, claimants, the company, and the arbitrator may look for efficient ways to address the claims. Some corporations, however, attempt to do so in ways that create additional hurdles for people seeking a resolution, much less relief.

One technique is referred to as “batch arbitration”, where the company requires that similar claims submitted to arbitration be considered in groups—say, for example, 30 at a time—and allows the next batch to be heard only after the first batch is resolved. The same 2024 study found that more than 40% of the arbitration clauses studied require proceedings that employ some form of batch arbitration.

Batch arbitration guarantees delays – and allows corporations to postpone or even evade liability – because individual claimants in later batches must wait years before their claims can be heard, let alone have any chance of receiving relief. Under batch arbitration, the more customers a company injures, the longer the queue of case batches will stretch, and the longer all but a few lucky customers will have to wait for relief. And batch arbitration offers none of the advantages present in multi-district litigation (MDL), where the court may first try a “bellwether” case, or representative lawsuit, from among a large group of cases in the MDL to give the parties on both sides a chance to see how their legal positions and factual presentation fare at trial, before other cases proceed.

Delays required by batch arbitration provisions are not accidental; they are built into the system. And they inevitably block timely resolution for aggrieved consumers and workers. For example, in a case involving one thousand injured customers, and given data showing that the median time for a claim to proceed through arbitration is approximately 9.5 months, a batching provision requiring that no other batch of cases proceed until each assigned arbitrator decides each of twenty cases in a batch would mean that some claimants would wait as much as 40 years for their claims to reach an arbitrator.

Some batching provisions further limit people’s ability to use the lawyer of their choice. Typically, batching provisions consist of a “minimum number of similar claims, usually at least twenty-five. Filed by the same counsel or a coordinated set of counsel.” These restrictions interfere with claimants’ right to counsel by barring individual claimants pursuing their own rights in individual arbitration from retaining attorneys who specialize in matters and who may also be able to manage other similar, but individual, cases efficiently and at a lower cost. Furthermore, the limitation makes it less feasible to represent consumers with low-dollar claims. And those who require counsel due to disability or accessibility concerns are even less likely to file a claim at arbitration without representation.

Corporations and Arbitrators Update Their Rules to Favor Corporations

Corporations weaponize their power against consumers and workers, actively rewriting nonnegotiable contracts in their favor. When their initial efforts don’t produce the results that corporations seek, corporations and arbitration providers update mass arbitration rules in response to corporate concerns.

Corporations regularly take advantage of their power to actively update their terms of service to insert language that usurps consumers’ and workers’ ability to hold them accountable. For example, sometimes they will update their terms of service in anticipation of a legal dispute, allowing them to adopt more favorable terms for themselves while providing limited – and sometimes no – prior notice to the consumers or workers affected by the change in terms. Recently, at a time when customers are facing rising costs and federal regulators have abandoned their role in holding corporations accountable, Bank of America re-adopted a forced arbitration clause in its terms of service after 17 years of not imposing forced arbitration on its customers.

Where corporations are unable to adopt contractual language addressing pressing concerns, such as steep initial filing fees in arbitration, arbitration providers have stepped in and updated their mass arbitration rules in ways responsive to corporate concerns. In 2024, the leading arbitration providers in the United States, including the American Arbitration Association (AAA), with 88% of the market share, and JAMS, with approximately 12% of the market share, updated their mass arbitration rules, procedures, and fee schedules in a manner that shifts the burden of initial mass arbitration filing fees away from the corporation. For example, AAA’s mass arbitration rules replaced individual filing fees with a flat $11,250 initiation fee, and other related fees were also capped to reduce corporations’ financial exposure from mass arbitration filings.

Additional updates to mass arbitration rules go a step further by sanctioning anti-consumer practices, similar to batch arbitration, that create further delays and barriers for consumers and workers. For example, AAA’s 2024 Supplementary Mass Arbitration Rules define mass arbitration as “twenty-five or more [c]onsumer or [e]mployment/[w]orkplace similar [d]emands for [a]rbitration [] filed against or on behalf of the same party or related parties;” and “where representation of all parties is consistent or coordinated across the cases.”

Other procedural updates to mass arbitration rules proffered by AAA and JAMS offer additional protective mechanisms for corporations, and in response to criticism of mass arbitration, which include requiring filing attorneys to submit an affirmation, or sworn declaration, stating that the information provided in each case is “true and correct” under threat of sanctions. Moreover, both AAA and JAMS mass arbitration rules allow for the appointment of a process arbitrator (AAA) or a process administrator (JAMS), who is granted broad decision-making power over whether the mass arbitration will be allowed to move forward. They also hear and determine matters, including whether the parties have met the filing requirements and which demands, among others.

Recommendations

Forced arbitration, not mass arbitration, is a problem that calls for reform. Decision-makers at the federal and state levels must oppose efforts to limit harmed consumers’ and workers’ ability to file their arbitration cases expeditiously and simultaneously through mass arbitration.

To truly protect consumers and employees, lawmakers should support legislation that would ban the use of forced arbitration in consumer and worker contracts.

Contact
Martha Perez-Pedemonti
Access to Justice and Consumer Rights Counsel
Congress Watch, Public Citizen
mperezpedemonti@citizen.org

Public Citizen Files FOIA Request Seeking GSA Records on Grok AI Deployment

July 14, 2026

 

U.S. General Services Administration
FOIA Requester Service Center (LG)
1800 F Street, NW, 7308
Washington, DC 20405-0001

Via web portal

 

Re: Freedom of Information Act Request — GSA OneGov/xAI (Grok) Agreement, Compliance Determinations, and Interagency Coordination

Dear General Services Administration Freedom of Information Act officer:

On behalf of Public Citizen, pursuant to the Freedom of Information Act, 5 U.S.C. § 552, I request copies of all final records created, received, or maintained by General Services Administration (“GSA”) from January 1, 2023, to the present, related to the artificial intelligence system known as Grok, developed by xAI, as follows:

1. All final compliance determinations and completed reviews of Grok, including, but not limited to, those related to AI governance, privacy, cybersecurity, supply-chain or vendor risk assessments, civil rights, equity, and algorithmic impact.
2. All memoranda, guidance, or other final documents related to federal agency use of Grok.
3. All records reflecting GSA’s role in approving, authorizing, or clearing federal acquisition or deployment of Grok.
4. All communications regarding Grok that transmit, memorialize, implement, or communicate final GSA decisions between GSA and:
   • Office of Management and Budget (OMB);
   • Office of Science and Technology Policy (OSTP);
   • Department of War (formerly Department of Defense);
   • Department of Homeland Security, including CISA;
   • Department of Energy, including Lawrence Livermore National Laboratory.

5. All communications between GSA and xAI (or its representatives, affiliates, or contractors) regarding the use or potential use of Grok by federal agencies or employees.

 

Please search all record systems reasonably likely to contain responsive federal records including but not limited to:

• Official email systems;
• Official calendars;
• Microsoft Teams
• Official text messaging systems;
• Archived messaging platforms used for official government business;
• Document management systems
• Electronic shared drives;

If it is your position that responsive records exist but that those records (or portions of those records) are exempt from disclosure, please identify the records that are being withheld and state the basis for the denial for each record being withheld. In addition, please note that Public Citizen seeks each record in its entirety. Accordingly, please provide all nonexempt portions of the records, without redacting portions of any record as “non-responsive,” “out of scope,” or the like.

I request that any records produced in response to this request be provided in electronic form wherever possible.

 

Fee Waiver Request

Public Citizen requests that all fees in connection with this FOIA request be waived in accordance with 5 U.S.C. § 552(a)(4)(A)(iii) because Public Citizen does not seek the records for a commercial purpose and disclosure “is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government.” Disclosure of the requested records is likely to contribute significantly to the public’s understanding of the operations and activities of the federal government because the records concern the federal government’s approval, procurement, and deployment of one of the nation’s most prominent generative artificial intelligence systems for use across executive branch agencies.[1]

GSA plays a central role in establishing government-wide policy governing the acquisition, deployment, and oversight of artificial intelligence systems. The requested records will shed light on how GSA implemented those responsibilities with respect to Grok, including what final compliance determinations, completed reviews, procurement approvals, implementation requirements, and interagency coordination preceded the system’s deployment within the federal government. These records will help the public understand how the federal government evaluates emerging AI technologies before making them available for government use and what safeguards, if any, were ultimately adopted.

The requested records concern matters that have generated substantial public attention.[2] The federal government’s increasing adoption of generative artificial intelligence has been the subject of significant national news coverage, congressional oversight, and public debate because these systems may affect government decision-making, cybersecurity, privacy, procurement integrity, civil rights, and the delivery of government services.[3] News organizations have reported on the federal government’s efforts to expand access to commercial AI systems through government-wide acquisition vehicles, including agreements involving xAI’s Grok, reflecting widespread public interest in how these technologies are being evaluated and deployed across federal agencies.[4]

Disclosure is particularly important because GSA plays a central role in the federal government’s acquisition, deployment, and management of technology, including artificial intelligence systems used across agencies. The requested records will enable the public to evaluate how GSA assessed, approved, and oversaw one of the first frontier AI systems made broadly available for federal use, and whether the agency’s procurement and implementation decisions were consistent with applicable legal requirements, federal AI policies, and its responsibilities to promote the secure, responsible, and effective use of AI across the government.

To Public Citizen’s knowledge, GSA has not publicly released the final compliance determinations, completed governance reviews, implementation guidance, procurement approvals, or other records requested herein. Although public reporting has described the existence of federal efforts to make Grok available to agencies, little information has been publicly disclosed regarding the official government records documenting GSA’s final actions, completed reviews, implementation requirements, or coordination with other federal agencies.[5] Disclosure through FOIA would therefore contribute significant new information that is not presently available to the public.

The requested records therefore concern identifiable government activities, are likely to contribute meaningfully to public understanding of those activities, and are not sought for any commercial purpose. Rather, Public Citizen seeks these records to inform policymakers, journalists, researchers, and the general public regarding the federal government’s implementation of AI governance policies and its oversight of emerging artificial intelligence technologies.

Public Citizen is a nonprofit research, litigation, and advocacy organization that represents the public interest before Congress, the executive branch, and the courts. Public Citizen has considerable expertise in the issues relevant to this records request—including Artificial Intelligence governance, technology policy, and government transparency. Public Citizen is a national leader in artificial intelligence policy, producing influential research on AI chatbots, corporate AI lobbying, autonomous weapons, and other emerging technologies. Its experts have testified before Congress and state legislatures while advising policymakers on AI governance, consumer protection, civil rights, and accountability.[6]

Public Citizen has a strong record of effectively conveying information to the public, including information obtained through Public Citizen’s use of FOIA, and Public Citizen intends to share the information received from this request with the public free of charge. Public Citizen distributes information through its website,[7] Facebook, ^[8] Bluesky,[9] and email listservs. It also maintains multiple blogs,[10] publishes a bi-monthly newspaper,[11] and issues frequent press releases.[12] Many of Public Citizen’s reports, petitions, or other research products grab headlines in major newspapers, broadcast media, social media, and academic journals.[13] Nearly every day, print and broadcast  media around the world mention Public Citizen or quote its experts.[14] Public Citizen also makes its experts available to speak to the media, to speak at conferences, and to testify before Congress.

Accordingly, I request that you waive all fees for locating and duplicating the requested records because Public Citizen is entitled to a public interest fee waiver. If, however, a waiver is not granted, please advise me of the amount of any proposed search, review, and reproduction charges before you conduct those activities.

I expect a response within 20 working days as provided by law. If you have any questions regarding this request, please contact me by phone at (202) 454-5131 or by e-mail at jbranch@citizen.org.

Thank you very much for your attention to this matter.

 

 

Sincerely,

J.B. Branch
Director of Federal AI Governance and Technology Policy
On behalf of Public Citizen

 

[1] Reuters, Musk’s xAI to Provide Grok Chatbot to U.S. Federal Agencies, Reuters (Sept. 25, 2025), https://www.reuters.com/world/us/musks-xai-provide-grok-chatbot-us-federal-agencies-2025-09-25/

[2] Id.

[3] Konstantin Toropin & David Klepper, Pentagon Embraces Musk’s Grok AI Chatbot as It Draws Global Outcry, Associated Press (Jan. 13, 2026), https://www.pbs.org/newshour/world/pentagon-embraces-musks-grok-ai-chatbot-as-it-draws-global-outcry; Dareen Toro, Grok Isn’t a Glitch—It Is a Regulatory Reckoning, RAND (Feb. 9, 2026), https://www.rand.org/pubs/commentary/2026/02/grok-isnt-a-glitch-it-is-a-regulatory-reckoning.html; J.B. Branch, The Case for Suspending Grok’s Federal Deployment, Yale J. on Regul.: Notice & Comment (Jan. 23, 2026) https://www.yalejreg.com/nc/the-case-for-suspending-groks-federal-deployment-by-j-b-branch/

[4] Id.; Rebecca Heilweil & Madison Alder, Elon Musk’s Grok Is Now Working with the U.S. Government, FedScoop (July 14, 2025), https://fedscoop.com/elon-musk-grok-us-government-deal/

[5] Id.

[6] Rick Claypool, Chatbots Are Not People: Designed-In Dangers of Human-Like Anthropomorphic A.I. Systems, Public Citizen (Sept. 26, 2023), https://www.citizen.org/article/chatbots-are-not-people-dangerous-human-like-anthropomorphic-ai-report/; Robert Weissman & Savannah Wooten, A.I. Joe: The Dangers of Artificial Intelligence and the U.S. Military, Public Citizen (Feb. 29, 2024) https://www.citizen.org/article/ai-joe-report/; Public Citizen, Tracker: Legislation on Deepfakes in Elections, Public Citizen, https://www.citizen.org/article/tracker-legislation-on-deepfakes-in-elections/

[7] See https://www.citizen.org.

[8] See https://www.facebook.com/publiccitizen (Public Citizen’s Facebook page). Public Citizen’s Facebook page has more than 141,000 followers.

[9] See https://web-cdn.bsky.app/profile/did:plc:mt3o2cf5fqpyqbyalwkegzef (Public Citizen’s Bluesky page). Public Citizen’s Bluesky page has more than 66,000 followers.

[10] See, e.g., Public Citizen: Consumer Law & Policy Blog, https://clpblog.citizen.org.

[11] See, e.g., Public Citizen News, November/December 2025,  https://www.citizen.org/wp-content/uploads/Nov-PC-News-2025-final.pdf .

[12] See Public Citizen, Press Releases, https://www.citizen.org/news/type/press/.

[13] See, e.g., Mikella Schuettler, White-Collar Enforcement Sinks Under Trump, Group Says, Bloomberg (Jan. 15, 2026), https://www.bloomberg.com/news/articles/2026-01-15/white-collar-enforcement-sinks-under-trump-public-citizen-says?embedded-checkout=true; Jacob Gardenswartz, Trump promised to ‘drill, baby, drill.’ But Americans’ gas costs are up, new report finds, Scripps News (Dec. 16, 2025), https://www.scrippsnews.com/politics/trump-promised-to-drill-baby-drill-but-americans-gas-costs-are-up-new-report-finds; Jonathan Edwards, Report: Donors to Trump’s White House ballroom have $279B in federal contracts, Wash. Post (Nov. 3, 2025), https://www.washingtonpost.com/politics/2025/11/03/trump-ballroom-donors-contracts-enforcement/; More than 40 Trump administration picks tied directly to oil, gas and coal, analysis shows, The Guardian (Oct. 9, 2025), https://www.theguardian.com/us-news/2025/oct/08/trump-administration-fossil-fuels-climate.

[14] See, e.g., In the News, Public Citizen, https://www.citizen.org/news/type/in-the-news/.

FOIA Request Seeks OMB Records on Grok AI’s Use by the Federal Government

July 14, 2026

Office of Management and Budget
FOIA Requester Service Center
725 17th Street NW, Suite 9272
Washington, DC 20503

Via web portal

 

Re: Freedom of Information Act Request — Final OMB Determinations, Implementation Records, and Interagency Coordination Regarding xAI’s Grok

 

Dear Office of Management and Budget Freedom of Information Act officer:

On behalf of Public Citizen, pursuant to the Freedom of Information Act, 5 U.S.C. § 552, I request copies of all final records created, received, or maintained by the Office of Management and Budget (“OMB”) from January 1, 2023, to the present, related to the artificial intelligence system known as Grok, developed by xAI, as follows:

1. All final compliance determinations and completed reviews of Grok, including, but not limited to, those related to AI governance, privacy, cybersecurity, supply-chain or vendor risk assessments, civil rights, equity, and algorithmic impact.
2. All memoranda, guidance, or other final documents related to federal agency use of Grok.
3. All records reflecting OMB’s role in approving, authorizing, or clearing federal acquisition or deployment of Grok.
4. All communications regarding Grok that transmit, memorialize, implement, or communicate final OMB decisions between OMB and:
   • General Services Administration (GSA);
   • Office of Science and Technology Policy (OSTP);
   • Department of War (formerly Department of Defense);
   • Department of Homeland Security, including CISA;
   • Department of Energy, including Lawrence Livermore National Laboratory.

5. All communications between OMB and xAI (or its representatives, affiliates, or contractors) regarding the use or potential use of Grok by federal agencies or employees.

 Please search all record systems reasonably likely to contain responsive federal records including but not limited to:

• Official email systems;
• Official calendars;
• Microsoft Teams
• Official text messaging systems;
• Archived messaging platforms used for official government business;
• Document management systems
• Electronic shared drives;

If it is your position that responsive records exist but that those records (or portions of those records) are exempt from disclosure, please identify the records that are being withheld and state the basis for the denial for each record being withheld. In addition, please note that Public Citizen seeks each record in its entirety. Accordingly, please provide all nonexempt portions of the records, without redacting portions of any record as “non-responsive,” “out of scope,” or the like.

I request that any records produced in response to this request be provided in electronic form wherever possible.

 

Fee Waiver Request  

Public Citizen requests that all fees in connection with this FOIA request be waived in accordance with 5 U.S.C. § 552(a)(4)(A)(iii) because Public Citizen does not seek the records for a commercial purpose and disclosure “is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government.” Disclosure of the requested records is likely to contribute significantly to the public’s understanding of the operations and activities of the federal government because the records concern the federal government’s approval, procurement, and deployment of one of the nation’s most prominent generative artificial intelligence systems for use across executive branch agencies.[1]

OMB plays a central role in establishing government-wide policy governing the acquisition, deployment, and oversight of artificial intelligence systems. The requested records will shed light on how OMB implemented those responsibilities with respect to Grok, including what final compliance determinations, completed reviews, procurement approvals, implementation requirements, and interagency coordination preceded the system’s deployment within the federal government. These records will help the public understand how the federal government evaluates emerging AI technologies before making them available for government use and what safeguards, if any, were ultimately adopted.

The requested records concern matters that have generated substantial public attention.[2] The federal government’s increasing adoption of generative artificial intelligence has been the subject of significant national news coverage, congressional oversight, and public debate because these systems may affect government decision-making, cybersecurity, privacy, procurement integrity, civil rights, and the delivery of government services.[3] News organizations have reported on the federal government’s efforts to expand access to commercial AI systems through government-wide acquisition vehicles, including agreements involving xAI’s Grok, reflecting widespread public interest in how these technologies are being evaluated and deployed across federal agencies.[4]

Disclosure is particularly important because OMB serves as the government’s central management and budget agency with responsibility for issuing government-wide AI governance policies and overseeing their implementation.[5] The requested records will enable the public to evaluate whether those policies were implemented as intended and how OMB exercised its oversight responsibilities with respect to one of the first frontier AI systems made available for broad federal use.

To Public Citizen’s knowledge, OMB has not publicly released the final compliance determinations, completed governance reviews, implementation guidance, procurement approvals, or other records requested herein. Although public reporting has described the existence of federal efforts to make Grok available to agencies, little information has been publicly disclosed regarding the official government records documenting OMB’s final actions, completed reviews, implementation requirements, or coordination with other federal agencies.[6] Disclosure through FOIA would therefore contribute significant new information that is not presently available to the public.

The requested records therefore concern identifiable government activities, are likely to contribute meaningfully to public understanding of those activities, and are not sought for any commercial purpose. Rather, Public Citizen seeks these records to inform policymakers, journalists, researchers, and the general public regarding the federal government’s implementation of AI governance policies and its oversight of emerging artificial intelligence technologies.

Public Citizen is a nonprofit research, litigation, and advocacy organization that represents the public interest before Congress, the executive branch, and the courts. Public Citizen has considerable expertise in the issues relevant to this records request—including Artificial Intelligence governance, technology policy, and government transparency. Public Citizen is a national leader in artificial intelligence policy, producing influential research on AI chatbots, corporate AI lobbying, autonomous weapons, and other emerging technologies. Its experts have testified before Congress and state legislatures while advising policymakers on AI governance, consumer protection, civil rights, and accountability.[7]

Public Citizen has a strong record of effectively conveying information to the public, including information obtained through Public Citizen’s use of FOIA, and Public Citizen intends to share the information received from this request with the public free of charge. Public Citizen distributes information through its website,[8] Facebook, ^[9] Bluesky,[10] and email listservs. It also maintains multiple blogs,[11] publishes a bi-monthly newspaper,[12] and issues frequent press releases.[13] Many of Public Citizen’s reports, petitions, or other research products grab headlines in major newspapers, broadcast media, social media, and academic journals.[14] Nearly every day, print and broadcast  media around the world mention Public Citizen or quote its experts.[15] Public Citizen also makes its experts available to speak to the media, to speak at conferences, and to testify before Congress.

Accordingly, I request that you waive all fees for locating and duplicating the requested records because Public Citizen is entitled to a public interest fee waiver. If, however, a waiver is not granted, please advise me of the amount of any proposed search, review, and reproduction charges before you conduct those activities.

I expect a response within 20 working days as provided by law. If you have any questions regarding this request, please contact me by phone at (202) 454-5131 or by e-mail at jbranch@citizen.org.

Thank you very much for your attention to this matter.

 

 

Sincerely,

J.B. Branch
Director of Federal AI Governance and Technology Policy
On behalf of Public Citizen

 

[1] Reuters, Musk’s xAI to Provide Grok Chatbot to U.S. Federal Agencies, Reuters (Sept. 25, 2025), https://www.reuters.com/world/us/musks-xai-provide-grok-chatbot-us-federal-agencies-2025-09-25/

[2] Id.

[3] Konstantin Toropin & David Klepper, Pentagon Embraces Musk’s Grok AI Chatbot as It Draws Global Outcry, Associated Press (Jan. 13, 2026), https://www.pbs.org/newshour/world/pentagon-embraces-musks-grok-ai-chatbot-as-it-draws-global-outcry; Dareen Toro, Grok Isn’t a Glitch—It Is a Regulatory Reckoning, RAND (Feb. 9, 2026), https://www.rand.org/pubs/commentary/2026/02/grok-isnt-a-glitch-it-is-a-regulatory-reckoning.html; J.B. Branch, The Case for Suspending Grok’s Federal Deployment, Yale J. on Regul.: Notice & Comment (Jan. 23, 2026) https://www.yalejreg.com/nc/the-case-for-suspending-groks-federal-deployment-by-j-b-branch/

[4] Id.; Rebecca Heilweil & Madison Alder, Elon Musk’s Grok Is Now Working with the U.S. Government, FedScoop (July 14, 2025), https://fedscoop.com/elon-musk-grok-us-government-deal/

[5] U.S. Gen. Servs. Admin., GSA & xAI Partner to Accelerate Federal AI Adoption (Sept. 25, 2025), https://www.gsa.gov/about-gsa/newsroom/news-releases/gsa-xai-partner-to-accelerate-federal-ai-adoption-09252025

[6] Id.

[7] Rick Claypool, Chatbots Are Not People: Designed-In Dangers of Human-Like Anthropomorphic A.I. Systems, Public Citizen (Sept. 26, 2023), https://www.citizen.org/article/chatbots-are-not-people-dangerous-human-like-anthropomorphic-ai-report/; Robert Weissman & Savannah Wooten, A.I. Joe: The Dangers of Artificial Intelligence and the U.S. Military, Public Citizen (Feb. 29, 2024) https://www.citizen.org/article/ai-joe-report/; Public Citizen, Tracker: Legislation on Deepfakes in Elections, Public Citizen, https://www.citizen.org/article/tracker-legislation-on-deepfakes-in-elections/

[8] See https://www.citizen.org.

[9] See https://www.facebook.com/publiccitizen (Public Citizen’s Facebook page). Public Citizen’s Facebook page has more than 141,000 followers.

[10] See https://web-cdn.bsky.app/profile/did:plc:mt3o2cf5fqpyqbyalwkegzef (Public Citizen’s Bluesky page). Public Citizen’s Bluesky page has more than 66,000 followers.

[11] See, e.g., Public Citizen: Consumer Law & Policy Blog, https://clpblog.citizen.org.

[12] See, e.g., Public Citizen News, November/December 2025,  https://www.citizen.org/wp-content/uploads/Nov-PC-News-2025-final.pdf .

[13] See Public Citizen, Press Releases, https://www.citizen.org/news/type/press/.

[14] See, e.g., Mikella Schuettler, White-Collar Enforcement Sinks Under Trump, Group Says, Bloomberg (Jan. 15, 2026), https://www.bloomberg.com/news/articles/2026-01-15/white-collar-enforcement-sinks-under-trump-public-citizen-says?embedded-checkout=true; Jacob Gardenswartz, Trump promised to ‘drill, baby, drill.’ But Americans’ gas costs are up, new report finds, Scripps News (Dec. 16, 2025), https://www.scrippsnews.com/politics/trump-promised-to-drill-baby-drill-but-americans-gas-costs-are-up-new-report-finds; Jonathan Edwards, Report: Donors to Trump’s White House ballroom have $279B in federal contracts, Wash. Post (Nov. 3, 2025), https://www.washingtonpost.com/politics/2025/11/03/trump-ballroom-donors-contracts-enforcement/; More than 40 Trump administration picks tied directly to oil, gas and coal, analysis shows, The Guardian (Oct. 9, 2025), https://www.theguardian.com/us-news/2025/oct/08/trump-administration-fossil-fuels-climate.

[15] See, e.g., In the News, Public Citizen, https://www.citizen.org/news/type/in-the-news/.

July 13, 2026

Public Citizen Comment on Proposed Regulation for Federal Financial Assistance

Docket Number OMB-2026-0034

In June 2026, the Office of Management and Budget issued proposed revisions to its Uniform Guidance for Federal Financial Assistance. Forty-one other agencies issued proposed conforming changes to their own regulations on grantmaking.

Public Citizen submitted a comment to address the catastrophic impacts the proposed changes would have on the enterprise of medical research in the United States. The comment explained that, if adopted, the changes to the Uniform Guidance would disrupt ongoing grant-funded research, jeopardize future research, and impede the dissemination of research findings.  Each of these effects alone would be reason enough to reject the proposed rule. In tandem, these effects would devastate the development of scientific knowledge in this country, waste American taxpayer resources, and threaten the health and wellbeing of the American people. We asked the agencies to withdraw the proposed rule in its entirety.