Institute for Policy Integrity

Twitter @policyintegrity

Bethany A. Davis Noll

Litigation Director

Bethany Davis Noll joined Policy Integrity as a Senior Attorney 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. She can be reached at


Public Comments

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


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


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


For DOL, killing fiduciary rule easier said than done – BenefitsPRO, May 16, 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.