Recent Projects

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.

The Institute for Policy Integrity is tracking altered enforcement of environmental laws by federal and state agencies in response to the COVID-19 pandemic. In connection with the crisis, several agencies have issued waivers or announced plans to stop enforcing key environmental laws and regulations. 

Last year, the Environmental Protection Agency (EPA) replaced the Obama Administration’s Clean Power Plan, which sought substantial cuts in greenhouse gas emissions from power plants, with the so-called Affordable Clean Energy (ACE) rule, a far weaker policy that will, at best, yield modest reductions below business-as-usual emissions and, at worst, increase pollution from the electric sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit highlighting three key errors in EPA’s rationale for repealing the Clean Power Plan. Specifically, we explain, EPA misstates regulatory precedent and Clean Air Act legislative history supporting the Clean Power Plan and disregards the substantial harms that the ACE Rule will cause.