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Presidential Transition Guidance
As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.
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Comments to FWS on Critical Habitat Designations
The Fish and Wildlife Service (FWS) proposed amendments to its regulations for designating critical habitat. Several of FWS’s changes are inconsistent with the best practices for weighing the costs and benefits of agency action. We submitted comments explaining how the proposal is flawed in multiple ways and should not be finalized.
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Comments to EPA on Proposed Dust-Lead Pollution Rules
The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate.
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Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act
We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.
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Amicus Briefs on Navigable Waters Protection Rule
In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed briefs in the Northern District of California and District of South Carolina focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms. We later filed in the Tenth Circuit Court of Appeals and the Northern District of New York.
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Weakening Our Defenses
How the Trump Administration’s Deregulatory Push Has Exacerbated the Covid-19 Pandemic
The failure of the federal government to adequately safeguard the health, environment, and economy of the United States with efficient regulatory protections is not a new phenomenon. For over three years now, the Trump administration has systematically delayed, undermined, and erased key regulations that protect our health, our environment, our workplaces, our living conditions, and our economy. The steady erosion of regulatory safeguards has severely compromised our baseline defenses against Covid-19.
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Comments to BLM on September 2020 Lease Sale in Utah
A proposed oil and gas lease sale in Utah would offer over 100,000 acres located in areas valuable for recreation, wildlife, environmental conservation, cultural use, and tourism. We submitted comments detailing how the Bureau of Land Management’s environmental assessment neglects its duties to manage public lands for multiple use and consider more limited leasing scenarios. BLM also ignores the option value of delaying the leasing decision and, therefore, is unlikely to obtain fair market value for the nominated land parcels.
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Comments to EPA on Delay of Emissions Rule for Wood Heaters
The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices, purporting to respond to retailer needs in the wake of the COVID-19 pandemic. Our comments detail how how the proposal contradicts the Clean Air Act’s mandate and longstanding agency guidance. The proposed rule will, even under the agencies’ own analysis, cause net harms to the public without providing any reasonable justification.
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Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic
This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis.
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Beneath the Surface
The Concealed Costs of the Clean Water Rule Rollback
In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.
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