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Recent Projects

  • News

    Court Strikes Down Rule Refusing to Limit Cross-State Air Pollution

    October 1, 2019

    The U.S. Court of Appeals for the D.C. Circuit vacated EPA’s Close-Out Rule, which allowed upwind states to continue emitting ground-level ozone pollution that significantly contributes to downwind air quality problems. The agency justified the rule by falling back on its analysis from the Cross-State Update, a prior rule that had provided only a partial remedy to interstate emissions. We filed an amicus brief, which argued that EPA fundamentally misunderstood its job in analyzing and choosing between cost-effective options.

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  • Public Comments

    Comments to EPA on Rescinding Its “Once In, Always In” Policy

    September 24, 2019

    The Environmental Protection Agency (EPA) is proposing to abandon its longstanding “Once In, Always In” policy, in turn allowing “major sources” that reduce emissions below major source thresholds to reclassify as “area sources” subject to less stringent regulation. We submitted comments detailing inadequacies in EPA’s assessment of the rule’s costs and benefits. The agency fails to analyze the rule’s aggregate emissions impacts, conduct its illustrative analyses against an appropriate baseline, account for the possibility of inadequate state enforcement, and monetize the health and environmental effects of emissions changes.

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  • Public Comments

    Comments to USDA on Supplemental Nutrition Assistance Program

    September 23, 2019

    The Department of Agriculture (USDA) proposed revisions to eligibility for its Supplemental Nutrition Assistance Program, or SNAP. We submitted comments focusing on serious flaws in the agency’s analysis of the rule’s impacts.

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  • Court Filings

    Amicus Briefs on HHS Conscience Rule

    September 19, 2019

    The Department of Health and Human Services (HHS) recently finalized a rule that expands protections for healthcare workers who deny care based on moral or religious beliefs. We submitted amicus briefs in support of challenges to the rule filed by states, municipalities, medical organizations, and civil-rights advocates. Our argument details how HHS’s analysis of the rule’s economic impacts ignores significant costs while touting entirely speculative benefits. We submitted briefs to the Southern District of New York, Northern District of California, and the District of Maryland.

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  • Public Comments

    Comments on New Jersey’s Energy Master Plan

    September 16, 2019

    New Jersey’s 2019 Energy Master Plan (EMP) outlines how the state can achieve its emissions reduction target of 80% below 2006 levels, as well as 100% clean energy, by 2050. We submitted comments applauding improvements to the draft EMP and making further suggestions. Our comments encourage the state to establish a technology-neutral policy framework to achieve its emissions reduction goal, compensate distributed energy resources in a way that reflects their full social value, and implement reforms to advance related technological and regulatory frameworks. We also submitted comments last October, during the EMP scoping phase, that made suggestions on grid resilience, rate design, and energy storage incentives.

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  • Public Comments

    Petition to NHTSA for Reconsideration of Fuel Economy Penalties

    September 9, 2019

    We filed a petition requesting that the National Highway Traffic Safety Administration (NHTSA) reconsider and rescind a new rule reducing penalties for automobile manufacturers that fail to meet corporate fuel economy standards. Our petition explains how NHTSA’s analysis ignores financial and environmental benefits forgone by the rule and relies on flawed, even contradictory evidence. NHTSA’s weakened fuel economy penalties deprive the public of substantial benefits and should be rescinded.

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  • News

    Court Upholds 2015 Ozone Standards

    August 23, 2019

    A federal appeals court recently rejected industry and state challenges to a set of Obama-era air quality standards, which the Institute for Policy Integrity had filed an amicus brief defending. In 2015, the Environmental Protection Agency (EPA) strengthened National Ambient Air Quality Standards (NAAQS) for ground-level ozone, the primary ingredient in urban smog and the source of a variety of respiratory ills. The coal mining company Murray Energy Corporation, along with trade associations and several state attorneys general, brought suit in the U.S. Court of Appeals for the D.C. Circuit, arguing that the new standards were unnecessarily stringent and impossible to achieve. We filed an amicus brief in support of the standards.

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  • Public Comments

    Comments to DOE on Energy Conservation Standards for Metal Halide Lamps

    August 15, 2019

    The Department of Energy (DOE) recently asked for input on energy conservation standards for metal halide lamp fixtures. We submitted comments encourage DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

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  • Public Comments

    Comments to HHS on Proposed Weakening of Healthcare Nondiscrimination Rule

    August 13, 2019

    The Department of Health and Human Services (HHS) recently proposed a rule that would narrow the scope of civil rights protections for patients under the Affordable Care Act. We submitted comments that focus on serious flaws in HHS’s regulatory impact analysis for the proposal, which ignores potentially substantial costs to patients and makes unsupported claims regarding the proposal’s benefits.

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  • Public Comments

    Comments on Proposed Process Changes for Setting Energy Conservation Standards

    August 9, 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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