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Bethany A. Davis Noll

Litigation Director

Bethany Davis Noll, now Policy Integrity’s Litigation Director, joined the institute in April 2017. Previously, she worked as Assistant Solicitor General in the New York Attorney General’s Office, Appeals and Opinions Division, where she filed briefs on behalf of a coalition of states in support of EPA’s Clean Power Plan. In 2016, she was awarded the Louis J. Lefkowitz Memorial Award for her work on several environmental appeals. Prior to working at the Attorney General’s Office, Bethany was a litigation associate at Debevoise & Plimpton LLP, where she led a team in a pro bono Clean Water Act enforcement suit. She was also an adjunct lecturer in law at Columbia Law School for four years, and she is a member of the Environmental Law Committee of the New York City Bar Association. She served as a clerk for the Honorable Chester J. Straub in the Second Circuit Court of Appeals and for the Honorable Shira A. Scheindlin in the District Court for the Southern District of New York. Bethany received a J.D. with distinction from Stanford Law School and a B.A., magna cum laude, from Barnard College.

Bar and Court Admissions: State Bar of New York, District of Columbia Bar (inactive) | U.S. Courts of Appeals for the D.C., Second, Fourth, and Ninth Circuits; U.S. District Courts for the Southern and Eastern Districts of New York and D.C.

Follow her on Twitter at @bdavisnoll, email her at bethany.davisnoll@nyu.edu, or call her at (212) 998-6239.

Litigation

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in California v. Interior – Northern District of California, 2018

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Bauer v. Devos – D.C. District Court, 2018

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in New York v. Pruitt – Southern District of New York, 2018

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Hudson River Sloop Clearwater vs. New York State Public Service Commission — Supreme Court of the State of New York County of Albany, 2018

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Natural Resources Defense Council v. National Highway Traffic Safety Administration — U.S. Court of Appeals for the Second Circuit, 2018

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Petitioners v. U.S. Department of the Interior – Wyoming District Court, 2017

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Coalition For Competitive Elec v. Zibelman – U.S. Court of Appeals for the Second Circuit, 2017

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Air Alliance Houston v. Environmental Protection Agency – D.C. District Court, 2017

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Wildearth Guardians v. Bureau of Land Management – D.C. District Court, 2017

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in California v. Bureau of Land Management – N.D. California, 2017

Brief of Amicus Curiae, Institute for Policy Integrity at New York University School of Law in Clean Water Action v. U.S. Environmental Protection Agency – D.C. District Court 2017

Academic Articles

Deregulation: Process and Procedures That Govern Agency Decisionmaking in An Era of Rollbacks, Energy Law Journal, Vol. 38, No. 2, 2017 (with Denise Grab).

Op-Eds

Pruitt’s Deregulation Spree Has Cut Corners – Slate, July 31, 2017

Trump Follows Through on Deregulation, but at What Cost? – The Hill, June 23, 2017

Stealth Repeal: Trump’s Strategy to Roll Back Regulations Through Delay – The Hill, May 2, 2017

Policy Briefs

Analyzing EPA’s Vehicle-Emissions Decisions: Why Withdrawing the 2022-2025 Standards Is Economically Flawed — May 2018

Media

Scott Pruitt’s Dirty Politics: How the Environmental Protection Agency became the fossil-fuel industry’s best friend — The New Yorker, April 2, 2018

For DOL, killing fiduciary rule easier said than done — BenefitsPRO, May 16, 2017

Select Public Comments

Comments to New York on Offshore Wind Program — June 2018

Comments on NHTSA’s Proposal to Rescind the 2016 Civil Penalty Adjustment – May 2018

Comments on the Clean Water Rule’s “Applicability Date” – December 2017

Comments on Carbon Pricing in Wholesale Electricity Markets to New York – November 2017

Comments on the Work Plan of the New York Carbon Pricing Task Force – November 2017

Reply Comments on Department of Energy Proposal for Grid Reliability and Resilience Pricing – November 2017.

Comments on Department of Energy Proposal for Grid Reliability and Resilience Pricing – October 2017.

Comments on the Federal Highway Administration’s Proposed Repeal of the Greenhouse Gas Measure, 82 Fed. Reg. 46,427 – October 2017

Comments on Delay of Department of Labor’s Fiduciary Rule – September 2017

Comments on EPA’s proposal to issue a second stay of the compliance deadlines in the Effluent Rule – July 2017

Comments on EPA’s Proposal to Further Delay the Amendments to the Risk Management Program – May 2017

Comments on the Office of Natural Resources Revenue proposal to repeal the July 1, 2016 Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform Rule – May 2017

Response to the Office of Natural Resources Revenue’s Advance Notice of Proposed Rulemaking requesting comments on whether revisions are necessary to the regulations governing coal, oil, and gas royalties – May 2017

Select Prior Litigation

Brief of Respondents by States, Utility Air Regulatory Group. v. EPA, Supreme Court, 2014

Brief for States and Reply Brief for States, EPA v. EME Homer City Generation, L.P., Supreme Court, 2014

Brief for State and Municipal Intervenors, West Virginia v. EPA, D.C. Circuit, 2016

Represented State of New York in Capruso v. Village of Kings Point, 2014

Represented State of New York in Natural Reources Defense Council, Inc. v. N.Y. State Department of Environmental Conservation, 2015.

Represented State of New York in Benali v. N.Y. State Department of Environmental Conservation, 2017

Represented State of New York in People ex rel. Baez v. Superintendent, Queensboro Corr. Facility, 2016.

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