Institute for Policy Integrity logo

Twitter @policyintegrity

Recent Projects

Viewing recent projects in Environmental Health
  • 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.

    Read more

  • 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.

    Read more

  • 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.

    Read more

  • 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.

    Read more

  • Court Filings

    Amicus Brief on the Good Neighbor Provision of the Clean Air Act

    April 5, 2019

    The Clean Air Act includes a Good Neighbor Provision, which requires states to prohibit their own sources of pollution from emitting in quantities that “contribute significantly” to another state’s inability to achieve national ambient air quality standards. When upwind states fail to abide by this requirement, the Act authorizes downwind states to petition the Environmental Protection Agency (EPA) for relief.

    In 2018, EPA denied five such petitions filed by Maryland and Delaware, which sought tighter limits on ozone-forming emissions from power plants in Indiana, Kentucky, Ohio, Pennsylvania, and West Virginia. Maryland and Delaware, supported by other states and a coalition of environmental groups, have now challenged those denials in the U.S. Court of Appeals for the D.C. Circuit. In our amicus brief supporting the challenges, we focused on EPA’s erroneous claim that no further emission reductions at the specified plants would be cost-effective.

    Read more

  • Public Comments

    Comments to the FCC on Regulation of Space Debris

    April 5, 2019

    The Federal Communications Commission (FCC) is seeking comments on economic approaches that might be feasible and effective in reducing the negative impacts of orbital debris in space. We submitted comments offering initial suggestions for what the Commission might consider in choosing a market-based regulation. We also recommend that any impact assessment of the regulation takes into account the full range of direct and indirect benefits.

    Read more

  • Public Comments

    Comments to EPA on Delay of Emissions Rule for Wood Heaters

    January 14, 2019

    The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices. This change would allow retailers to sell non-compliant wood heaters for two years past the original 2020 compliance date. We submitted comments explaining that the proposed rule imposes net costs on society and is not justified by EPA’s faulty analysis.

    Read more

  • Public Comments

    Comments to EPA on Delay of Landfill Emission Guidelines

    January 3, 2019

    In 2016, EPA finalized Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills. Once implemented, the regulation will deliver significant net benefits from reducing pollution that contributes to climate change and other harmful impacts to human health. EPA, however, is proposing to substantially delay the implementation of these protections. We submitted comments that point out how EPA fails to justify the proposed delay and assess its social costs.

    Read more

  • Public Comments

    Comments on EPA Rollback of Refrigerant Substitutes Regulation

    November 15, 2018

    EPA recently proposed rolling back regulatory provisions that curb emissions of refrigerant substitutes, which are highly potent greenhouse gases. The agency admits that the rescissions would significantly increase the release of refrigerator hydrofluorocarbons (HFCs) but fails to monetize the climate damages caused by forgone emissions reductions. We submitted comments explaining how EPA should value the climate damages of these greenhouse gases.

    Read more

  • Reports

    Deregulation Run Amok

    November 13, 2018

    Our report provides a survey of the legality of Trump Administration’s regulatory suspensions. Looking at a number of cases, we discuss the administration’s disregard for notice-and-comment requirements, statutory restrictions, and the reasoned explanation requirement. We also lay out some of the challenges facing advocates, and the strategies by which agencies have evaded review.

    Read more