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Court Filings
Amicus Brief on New Jersey’s Zero-Emissions Credits Program
In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.
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Court Filings
Amicus Brief on Dust-Lead Hazard Standards
The Environmental Protection Agency (EPA) finalized a rule revising standards for lead found in dust on floors, window sills, and in soil. Our amicus brief critiques the rule, which forgoes net beneficial options in favor of weaker standards that will cause significant harms to public health.
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Court Filings
Amicus Briefs on Homeland Security’s “Public Charge” Rule
In August, the Department of Homeland Security finalized the “public charge” rule, which seeks to deny lawful permanent residency to immigrants who have participated in public assistance programs like Medicaid, the Supplemental Nutrition Assistance Program, and the Section 8 housing voucher program. Multiple federal district courts have since enjoined the rule from taking effect and Policy Integrity filed amicus briefs supporting those injunctions on appeal. Our briefs explain how the Department failed to meaningfully assess many of the substantial social costs of the large-scale disenrollment from public assistance programs that will result from the rule, and also failed to identify any significant social benefits from the rule.
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Court Filings
Amicus Brief on NHTSA Rule Lowering Penalty for Violations of Fuel-Economy Standards
The National Highway Traffic Safety Administration (NHTSA) recently finalized a rule that significantly reduces the penalties that automakers pay for violating the corporate average fuel economy (CAFE) standards. In reducing the penalty, NHTSA rolled back an adjustment that had been made to the penalty under the Inflation Act, a statute requiring agencies to adjust civil monetary penalties to account for decades of inflation. We submitted an amicus brief in the Court of Appeals for the Second Circuit focusing on NHTSA’s faulty economic justifications for the rule, arguing that this repeal was unlawful.
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Court Filings
Amicus Briefs on HHS Conscience Rule
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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Court Filings
Title X Women’s Health - Ninth Circuit Amicus Briefs
In April, district courts in Washington State, Oregon, and California blocked a Trump administration rule that makes harmful changes to the federal funding of women’s health services. Those decisions were recently appealed in the U.S. Court of Appeals for the Ninth Circuit. We filed amicus briefs arguing that the preliminary injunctions should be affirmed.
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Court Filings
Amicus Brief on Repeal of Fracking Rule
In 2017, the Bureau of Land Management (BLM) repealed an Obama-era rule that tightens environmental regulations for fracking on public lands. We filed an amicus brief detailing BLM’s irrational analysis of the repeal, which erases the rule’s significant net benefits and flouts longstanding standard practices.
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Court Filings
Amicus Brief on HHS Conscience Rule
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.
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Court Filings
Amicus Brief on BLM’s Repeal of Waste Prevention Rule
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.
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Court Filings
Amicus Brief on Interstate Air Pollution
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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