Recent Projects

We filed an amicus brief explaining how NHTSA and EPA's decision to finalize a rule that, even under their own analysis, will be net-costly to society, is arbitrary and capricious. 

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, the Northern District of New York, the District of Massachusetts, and the District of Maryland.

Our comments on the Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS identify critical flaws in the proposal's design and regulatory impact analysis. The Environmental Protection Agency's (EPA) unreasonably low valuation of climate effects also contributes to its selection of an inefficient policy alternative. We submitted joint comments detailing how EPA's flawed analysis harms public health and the environment.

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.

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.

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.

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.

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.