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Recent Projects

  • News

    Roundup of Trump-Era Deregulation in the Courts

    December 10, 2018

    The Trump administration has undertaken numerous deregulatory actions through rule suspensions; repeals; rescissions; efforts to weaken regulations through guidance, memoranda, amendments, or replacements; and more. Many of these actions have been challenged in court and decisions have been reached in several cases.

    The Institute for Policy Integrity maintains a publicly available list of those decisions. This “Roundup,” which we update regularly, has been cited by the New York Times, the Wall Street Journal, and the Brookings Institution.

    The Roundup provides an overview of each court decision, with relevant links to the government actions and court rulings. It also tallies the successful and unsuccessful outcomes for the administration for ease of reference. Updates should be submitted to bethany.davisnoll@nyu.edu.

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  • Public Comments

    Comments on Environmental Impact Statement for Changes to Grand Staircase-Escalante Monument

    November 30, 2018

    The Bureau of Land Management (BLM) recently released an Environmental Impact Statement (EIS) for the Grand Staircase-Escalante Monument and Kanab-Escalante Planning Area. We submitted comments explaining why the agency should analyze the impacts of each land management alternative using Social Cost of Greenhouse Gases estimates.

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  • Public Comments

    Comments on EPA Rollback of Refrigerant Substitutes Regulation

    November 15, 2018

    EPA recently proposed rolling back regulatory provisions that curb emissions of refrigerant substitutes, which are highly potent greenhouse gases. The agency admits that the rescissions would significantly increase the release of refrigerator hydrofluorocarbons (HFCs) but fails to monetize the climate damages caused by forgone emissions reductions. We submitted comments explaining how EPA should value the climate damages of these greenhouse gases.

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  • Public Comments

    Comments on Environmental Impact Statement for Changes to Bears Ears Monument

    November 15, 2018

    The Bureau of Land Management and U.S. Forest Service recently released a Draft Environmental Impact Statement (EIS) on their land management proposal for the Bears Ears National Monument. The EIS does not consider the environmental impacts of shrinking the monument’s boundaries. We submitted comments explaining why the agencies are responsible for providing detailed environmental analysis of their proposal to alter the Bears Ears planning area.

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  • Reports

    Deregulation Run Amok

    November 13, 2018

    For the first year and a half of the Trump administration, deregulatory efforts focused on suspending regulations across many agencies. But those suspensions flouted public input requirements, ignored statutory mandates, and failed to fully and honestly address the impact of the delays on the valuable benefits conferred by the original regulations. As a result, many have been struck down in court.

    Our report provides a survey of the legality of Trump administration’s regulatory suspensions. Looking at a number of cases, we discuss the administration’s disregard for notice-and-comment requirements, statutory restrictions, and the reasoned explanation requirement. We also lay out some of the challenges facing advocates, and the strategies by which agencies have evaded review. It is worth reflecting on the era of suspensions as the administration moves into repealing rules. The legal principles that applied to suspensions will also apply to repeals, and the same flaws are already appearing in many of the proposals to repeal regulations.

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  • Public Comments

    Comments on the Family Detention Rule

    November 6, 2018

    A recently proposed rule would allow the Department of Homeland Security to indefinitely detain immigrant children who enter the U.S. in the company of a parent or guardian. Under current law, such children must be released or transferred to a non-secure, state-licensed facility within 20 days. We filed comments critiquing the Department’s assessment of the costs and benefits of this policy change.

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  • Public Comments

    Comments on FERC’s Potential Reforms to PJM Capacity Market

    November 6, 2018

    After suggesting that state policies subsidizing clean energy are distorting capacity markets, the Federal Energy Regulatory Commission (FERC) is exploring reforms to the capacity market in PJM – the grid operator serving 13 states and Washington D.C. FERC’s reforms have the potential to undermine state policies that address climate change, such as Renewable Energy Credits and Zero Emissions Credits (we discuss this issue in depth in a recent report). We submitted comments to FERC and reply comments on the proposals.

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  • Public Comments

    Comments on Carlsbad Region Fossil Fuel Leasing

    November 5, 2018

    We submitted two sets of comments to the Bureau of Land Management (BLM) in response to their Draft Resource Management Plan (RMP), which focuses on mineral development potential in the Carlsbad region of New Mexico. Our comments recommend that BLM not offer more lands for fossil fuel leasing, but instead consider alternatives with the greatest amount of conservation and wildlife protection. In particular, we focus on shortcomings in the RMP’s analysis and its failure to monetize climate damages.

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  • Public Comments

    Comments on Proposed Clean Power Plan Replacement

    October 31, 2018

    EPA recently issued a proposal to replace the Clean Power Plan (CPP) with a far weaker rule that will increase greenhouse gas and soot- and smog-forming emissions from the electric sector. Our comments explain why repealing the CPP is unnecessary, irrational, and harmful.

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  • Public Comments

    Comments on Proposed Weakening of Vehicle Emissions Standards

    October 26, 2018

    In August 2018, the Trump administration issued a proposal to dramatically weaken federal emissions standards for cars and light trucks, and to revoke the waiver that allows California to set its own standards. Federal emissions standards have been enormously successful at reducing greenhouse gas pollution and lowering fuel costs for consumers, and we recently submitted five separate sets of comments detailing the flaws with the Trump administration’s proposal.

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