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Viewing recent projects in Public Comments
  • Comments to NHTSA on Delay of CAFE Penalties Increase

    The National Highway Traffic Safety Administration's interim final rule delays the application of its 2016 inflation adjustment of the penalty for violating the corpoate average fuel-economy (CAFE) standards. We submitted comments explaining that the rule is untimely under the Inflation Adjustment Act, whose deadlines to amend the intial catch-up inflation adjustment expired years ago.

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  • Comments on OCC’s Fair Access Financial Services Rule

    The Office of the Comptroller of the Currency (OCC) proposed a rule that would preclude banks from taking climate risks into account when making decisions regarding the provision of financial services. We submitted joint comments explaining how OCC fails to consider or justify serious costs imposed by the rule. Climate risks pose a significant threat to the economic and operational health of firms in the energy sector and to the stability of the financial system as a whole.

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  • Comments to HHS on Affordable Care Act Proposal

    The Department of Health and Human Services (HHS) proposed Patient Protection and Affordable Care Act benefit and payment parameters for the 2022 coverage year that could cause significant health costs. We submitted comments on several elements of the proposed rule, including (1) its authorization of entirely privatized insurance marketplaces; (2) its promotion of the use of private enrollment websites by enrollment assisters; (3) its reduction of marketplace user fees; and (4) its continued reliance on a 2019 change to the formulas used to calculate premium-adjustment percentages and cost-sharing limits for consumers.

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  • Comments to EPA on Cross-State Air Pollution Rule

    Our comments on the Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS identify critical flaws in the proposal's design and regulatory impact analysis. The Environmental Protection Agency's (EPA) unreasonably low valuation of climate effects also contributes to its selection of an inefficient policy alternative. We submitted joint comments detailing how EPA's flawed analysis harms public health and the environment.

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  • Comments on HHS’s Sunset Rule

    The Department of Health and Human Services (HHS) has proposed to retrospectively and prospectively establish an "expiration date" for each of its regulations. Under the proposed rule, regulations would be automatically rescinded unless HHS first completes a restrospective review of the regulation's effects on small entities pursuant to the Regulatory Flexibility Act. We submitted comments criticizing the proposal, which is neither lawful nor rational.

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  • Comments and Reply Comments on FERC’s Carbon Pricing Policy Statement

    The Federal Energy Regulatory Commission proposed a policy statement on carbon pricing in organized wholesale electricity markets. We submitted comments encouraging FERC to strengthen its proposal by making specific clarifications. We later submitted reply comments addressing points made by other commenters and providing further guidance on how FERC can improve its final policy statement.

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  • Comments to FERC on Clean Resources’ Participation in NYISO’s Capacity Market

    Complainants in an ongoing proceeding ask that the Federal Energy Regulatory Commission (FERC) make changes to the New York Independent System Operator (NYISO)'s capacity market that would impose offer floors on all capacity market bids by state-supported renewables. We submitted comments showing why the complaint's arguments and evidence fall short of the legal standards required for FERC to make the findings and grant the relief requested.

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  • Comments to New York DEC on the Value of Carbon

    New York State's Department of Environmental Conservation (DEC) has adopted a damage-cost approach to valuing carbon dioxide pollution. We submitted comments on the DEC's draft guidance supporting the policy. Our comments also raise points about the appropriate use of discount rates, calculating damages for other greenhouse gases, inclusion of co-benefits in analysis, and further considerations for a marginal abatement cost approach.

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  • Comments to ONRR on Its New Proposal to Roll Back the Valuation Rule

    ONRR has proposed to roll back large portions of the Valuation Rule, after previously failing in court to both suspend the rule and repeal the rule.  We submitted comments explaining that the agency has failed yet again to provide a reasoned explanation for the rollback. 

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  • Comments to BLM on December 2020 Lease Sale in Colorado

    A proposed oil and gas lease sale in Colorado would offer over 45,000 acres in areas valuable for recreation, wildlife, environmental conservation, and tourism. We submitted comments explaining how the Bureau of Land Management’s (BLM) environmental assessment neglects its duties to manage public lands for multiple uses and consider more limited leasing scenarios.

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