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Recent Projects

  • Public Comments

    Comments on Repeal of Payday Lending Rule

    May 14, 2019

    The Consumer Financial Protection Bureau is proposing to repeal a rule that protects borrowers from exploitative payday lending practices. We submitted comments focusing on CFPB’s failure to provide a reasoned explanation for reversing key legal and economic conclusions of the rule.

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  • Public Comments

    Mitigating Space Debris—Reply Comments to the FCC

    May 13, 2019

    The Federal Communications Commission (FCC) called for input on possible market-based approaches to regulating orbital debris, like small but dangerous fragments from the launch, operation, and disintegration of satellites. We previously submitted comments that included an initial discussion of what the FCC might consider in choosing a market-based regulation. Our reply comments expand on this discussion, outlining specific steps the FCC can take to assess implementing a market-based solution.

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  • Public Comments

    Comments on Proposed Process Changes for Setting Energy Conservation Standards

    May 6, 2019

    The Department of Energy (DOE) recently proposed changes to its process for prescribing energy conservation standards for consumer products and commercial/industrial equipment. We submitted comments explaining how DOE’s proposed energy savings thresholds and consumer test are unjustified and will reduce important consumer and environmental benefits.

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  • News

    Court Blocks Rule Making Harmful Changes to Title X Women’s Health Services

    April 26, 2019

    The Institute for Policy Integrity helped contribute to a significant legal victory, as district courts in Washington State, Oregon, and California blocked a Trump administration rule that makes harmful changes to federally-funded women’s health services. In February, the Department of Health and Human Services (HHS) announced onerous restrictions to its Title X program, likely forcing the shutdown of some family planning clinics and closing off access to others for low-income women. We submitted comments on the rule and amicus briefs supporting requests for preliminary injunction in four court cases. The Eastern District of Washington refers to our brief in the reasoning for its decision to grant an injunction. The Northern District of California’s ruling cites our brief and devotes a lengthy discussion to the arguments we advanced.

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  • Court Filings

    Amicus Brief on Interstate Air Pollution

    April 26, 2019

    The Environmental Protection Agency (EPA) recently finalized the “Close-Out Rule,” a rule refusing to impose any additional reductions in interstate ozone air pollution under the Good Neighbor Provision of the Clean Air Act. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit explaining how EPA’s decision to not require pollution reductions is irrational and devoid of adequate analysis.

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  • News

    Testimony to New Jersey Legislature on Valuing Climate Impacts

    April 25, 2019

    Peter Howard and Denise Grab both provided testimony at an April 25 New Jersey State Legislature hearing on climate change mitigation and what the state can do to address greenhouse gas emissions. They discussed how New Jersey can contextualize and weigh climate impacts by using the social cost of greenhouse gases.

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  • Public Comments

    Comments to BLM on Environmental Impacts of Federal Oil and Gas Leases

    April 22, 2019

    In response to a District Court order, the Bureau of Land Management (BLM) recently prepared a Supplemental Environmental Assessment (EA) for five federal oil and gas leasing decisions issued in 2015 and 2016. We submitted comments that focus on the agency’s failure to adequately quantify greenhouse gas emissions and monetize their climate impacts.

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  • Public Comments

    Comments to EPA on Reconsideration of Mercury and Air Toxics Standards

    April 17, 2019

    The Environmental Protection Agency (EPA) is proposing to withdraw a prior finding that it is “appropriate and necessary” to regulate power-sector emissions of mercury and other “air toxics” under the Clean Air Act. We submitted comments arguing that EPA has failed to provide a reasoned explanation for this change of course.

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  • Public Comments

    Comments on California Public Utilities Commission’s New Analysis Framework

    April 15, 2019

    We recently encouraged the California Public Utilities Commission (CPUC) to clarify aspects of its new process for evaluating the social costs and benefits of energy resources. As we discussed in prior comments, the proposed analysis framework, the Societal Cost Test (SCT), will help the Commission to make investments that provide the greatest welfare benefits. Our new comments ask CPUC to provide some additional information in the SCT proposal.

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  • Public Comments

    Comments on the Replacement of the Clean Water Rule

    April 15, 2019

    The Environmental Protection Agency (EPA) and Army Corps of Engineers are proposing to replace the 2015 Clean Water Rule with a new rule that would harm many waterways by removing critical federal protections. We submitted comments detailing how the agencies provide flawed analysis in support of the proposal. Dr. Peter Howard and Dr. Jeffrey Shrader also submitted an expert report detailing the flaws in the agencies’ new valuation of wetland benefits.

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