Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

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  • Court Filings

    Brief on Wyoming Natural Gas and Oil Leases

    October 25, 2017

    Wildearth Guardians and Physicians for Social Responsibility recently sued the Bureau of Land Management over its leasing of lands in Wyoming for natural gas and oil extraction. In our amicus brief in support of the legal challenge, we argue that the agency’s decision to trumpet the benefits of the leasing decisions while also failing to quantify the greenhouse gas emissions that will result from these leases (and failing to use the social cost of carbon to assess the impact of those emissions on society) violated the National Environmental Policy Act.

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  • Public Comments

    Comments to the Federal Energy Regulatory Commission on Grid Reliability and Resilience Pricing

    October 23, 2017

    Energy Secretary Rick Perry’s controversial proposal to subsidize coal and nuclear plants could have terrible consequences for consumers and public health, as our recent comments and op-ed in US News highlight. In September, Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee coal and nuclear plants their full costs plus a profit, so long as they keep 90 days of fuel on site. Perry claims that these “fuel-secure” plants ensure grid reliability and resilience, but neither he nor FERC adequately define these terms or explain why such a measure is justified.

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  • Public Comments

    Comments on Reconsideration of NHTSA Rule to Update Civil Penalties

    October 10, 2017

    In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

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  • Public Comments

    Public Comments on Regulatory Review (CFTC, CPSC, Department of Education, PBGC, USDA)

    October 4, 2017

    Many federal agencies are requesting the public’s suggestions for rules to repeal or reform, tacitly implying that most regulations stifle economic growth. In comments to several agencies, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries, and should prioritize review of rules for which actual costs and benefits diverge significantly from predicted costs and benefits.

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  • Public Comments

    Joint Comments on Fuel Economy Standards and the Social Cost of Greenhouse Gases

    September 25, 2017

    Vehicle fuel economy standards set by the National Highway Traffic and Safety Administration (NHTSA) help reduce greenhouse gas emissions in the United States by making cars more fuel efficient. Our comments on the reconsideration argue that NHTSA should value the social cost of those emissions as robustly as possible, as they have done in the past. We encourage NHTSA to consider the social cost of greenhouse gases in both the rule’s Environmental Impact Statement and Regulatory Impact Analysis, and that it should use estimates considering global damages of climate change using a three percent or lower discount rate.

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  • Public Comments

    Comments on Delay of Department of Labor’s Fiduciary Rule

    September 15, 2017

    The Department of Labor’s Fiduciary Rule requires investment advisors to serve the best interests of their retiree clients. In August 2017, Labor proposed to stay the rule’s enforcement provisions. In our comments on the proposed delay, we argue that the delay violates basic administrative law principles.

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  • Public Comments

    Comments to OSHA on Beryllium Standards Revocation

    August 28, 2017

    In public comments to the Occupational Safety and Health Administration, we highlight some critical problems with the agency’s cost-benefit analysis in its proposed revocation of standards to protect workers from exposure to beryllium. These ancillary standards were designed to protect workers in the construction and shipyard sectors.

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  • Public Comments

    Public Comments on Regulatory Review (Treasury, GSA, FEMA, State, DOJ, FCA, Interior)

    August 15, 2017

    Many federal agencies are requesting the public’s suggestions for rules to repeal or reform, tacitly implying that most regulations stifle economic growth. In comments to several agencies, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries, and should prioritize review of rules for which actual costs and benefits diverge significantly from predicted costs and benefits.

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  • Public Comments

    Comments on FEMA’s Proposal on Public Petitions

    August 14, 2017

    The Federal Emergency Management Agency (FEMA) is proposing to update its regulations on the rulemaking process, which include amendments to how it accepts and considers public petitions for rulemaking. While the proposed changes are all appropriate, we offer additional changes that would increase government transparency in our comments to the agency.

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  • Public Comments

    Comments to the Department of Energy on Regulatory Burden

    July 10, 2017

    Following an Executive Order on reducing federal regulatory burden, the Department of Energy (DOE) is requesting the public’s suggestions for rules to repeal or reform. In our comments to DOE’s request for information, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries.

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