Recent Projects

In February, the Food and Drug Administration (FDA) proposed a rule that would strengthen regulations for sunscreen products. We submitted comments explaining how FDA can improve its analysis of the rule’s impacts.

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 an amicus brief in support of challenges to the rule filed by states, municipalities, medical organizations, and civil-rights advocates. The brief details how HHS’s analysis of the rule’s economic impacts ignores significant costs while touting entirely speculative benefits.

Last year, the Bureau of Land Management (BLM) repealed its Waste Prevention Rule, undoing crucial regulations that reduce natural gas waste from venting, flaring, and leaks. We submitted an amicus brief focusing on the problematic aspects of the repeal: BLM’s false understanding of its role in waste prevention and its faulty analysis of climate impacts.

The Office of Surface Mining and Reclamation Enforcement (OSM) issued its environmental assessment of extending the Caballo Mine West Tract federal coal lease. The mining plan would extend the life of the mine by approximately nine years, from 2042-2051, and increase the amount of coal mined from an average of 10.1 million tons per year to approximately 13.5 tons per year. Despite quantifying over 23 million tons of yearly carbon dioxide equivalent emissions, OSM does not include a monetized estimate of the climate damages those emissions will produce. We submitted joint comments asking that OSM use the social cost of greenhouse gases to better weigh the real-world impacts of potential coal leasing.

The Bureau of Land Management (BLM) issued its environmental assessment of the Evans McCurtain coal lease in Oklahoma, which includes 3.28 million tons of recoverable coal. BLM quantifies around 9.6 million tons of carbon dioxide equivalent emissions from direct, upstream, and downstream sources over about eight years. The agency, however, does not provide a monetized estimate of the climate damages those emissions will produce. We submitted joint comments asking that BLM use the social cost of greenhouse gases to better weigh the real-world impacts of potential coal leasing.

The Bureau of Land Management (BLM) recently issued an Environmental Assessment (EA) for its decision to lift the Obama administration’s pause on the federal coal leasing program. We submitted comments explaining how the EA provides flawed and incomplete analysis of BLM’s legal authority, alternatives to resuming leasing, and environmental effects.

As part of EPA’s June 5-6 meeting of the Chartered Science Advisory Board (SAB), we submitted both oral and written input on several issues, including the Clean Water Rule, power-sector emissions of air toxics, vehicle emissions standards, and the Science Transparency Rule.

The Iowa Utilities Board is currently reviewing its policies on energy efficiency planning. We submitted comments supporting some of the suggestions made by stakeholders to better gauge the benefits of the energy efficiency programs.

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are proposing to weaken key fuel economy and greenhouse gas emissions standards for future vehicle models. In October, we highlighted our concerns with some of the economic analysis supporting the proposal. The Alliance of Automobile Manufacturers submitted comments that included economic analysis supporting the proposed rule prepared by NERA Economic Consulting and Trinity Consultants. In December, we wrote supplemental comments rebutting NERA and Trinity’s analysis, identifying serious flaws and unexplained departures from longstanding practices. NERA recently responded.

Our latest comments detail how NERA’s response does not address many of the problems we previously discussed. As our comments explain, the analysis relies on unreliable modeling and methodologies, for which NERA still has not provided critical details. NERA also misstates or fails to respond to our points on a number of topics, such as scrappage and fuel savings benefits. We point out the shortcomings in NERA’s response and provide more detail on each of the topics.