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Recent Projects

Viewing recent projects in Environmental Health
  • Public Comments

    Comments on Reconsideration of NHTSA Rule to Update Civil Penalties

    October 10, 2017

    In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

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  • Reports

    The Falling Cost of Clean Power Plan Compliance

    October 2, 2017

    In 2015, the U.S. Environmental Protection Agency (EPA) released the Clean Power Plan, a Clean Air Act rule designed to address the threat of climate change by cutting carbon dioxide emissions from fossil fuel-fired power plants. As part of that rulemaking, the agency prepared an estimate of compliance costs, which it found would be far outweighed by the rule’s climate and health benefits. Since that time, changes in the electric sector have made it even cheaper to meet the rule’s emission targets than EPA anticipated. This report summarizes the findings of EPA’s 2015 Regulatory Impact Analysis; discusses subsequent market and policy developments that have lowered the cost of complying with the Clean Power Plan; and surveys more recent analyses by independent groups, which have estimated substantially lower compliance costs than EPA did.

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  • Public Comments

    Comments on Hydraulic Fracturing Rule Rescission

    September 25, 2017

    In proposing to rescind its two-year-old rule for managing hydraulic fracturing operations on federal and tribal lands, the Bureau of Land Management (BLM) fails to explain why the rescission’s estimated cost savings to industry justify the forgone benefits, such as environmental protection and increased worker safety. Our comments to BLM on the proposed rescission discuss the agency’s inadequate cost-benefit analysis, which does not sufficiently explain why changed circumstances in the past two years have altered the rule’s cost-benefit justification.

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  • Public Comments

    Comments to OSHA on Beryllium Standards Revocation

    August 28, 2017

    In public comments to the Occupational Safety and Health Administration, we highlight some critical problems with the agency’s cost-benefit analysis in its proposed revocation of standards to protect workers from exposure to beryllium. These ancillary standards were designed to protect workers in the construction and shipyard sectors.

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  • Public Comments

    Comments to EPA on Delaying Methane Rule

    August 9, 2017

    In 2016, EPA issued a rule to decrease methane and volatile organic compound emissions from new, modified, and reconstructed sources in the oil and natural gas sector. EPA has now proposed to suspend some of the rule’s compliance obligations for two years while the agency decides whether and how to revise those requirements. The U.S. Court of Appeals for the D.C. Circuit rejected an earlier attempt by EPA to stay the methane rule for 90 days, and our comments argue that the new proposal is similarly unlawful.

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  • Academic Articles/Working Papers

    Estimating the Health Benefits of Environmental Regulations

    August 4, 2017

    Regulating toxic pollutants benefits society by limiting public exposure to harmful pollution. By accurately quantifying these benefits, policymakers can improve the design of regulations that protect public health and better communicate the magnitude of these protections to the public. A new article in the journal Science examines how this process can be improved.

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  • Public Comments

    Comments on EPA’s Proposal to Issue a Second Stay of the Effluent Rule

    July 6, 2017

    Policy Integrity has filed comments opposing EPA’s proposal to issue a second stay of the compliance deadlines in the Effluent Rule—a rule that regulates toxic metal discharges from power plants. As we explained in our comments to EPA, EPA has no legal authority for the proposed stay. In addition, EPA failed to provide a reasoned explanation for the stay because it ignored the impact that the stay will have on the benefits of the Effluent Rule.

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  • Court Filings

    Challenging EPA’s Effluent Rule Suspension

    June 27, 2017

    EPA has suspended the compliance deadlines in a regulation on power plant wastewater discharges, which limits plants from releasing certain toxic metals into lakes and rivers. We submitted a “friend of the court” brief in the legal challenge to the suspension. Our brief argues that the decision to suspend the rule was arbitrary and capricious because EPA focused only on amorphous compliance costs and ignored the effects of pollution that will continue to be discharged while the rule is suspended. As we explain in the brief, it is fundamentally irrational to make a decision based on such a one-sided analysis, and the suspension should be vacated.

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  • Issue Briefs

    Irreplaceable: Why States Can’t Make Up for Inadequate Federal Enforcement of Environmental Laws

    June 6, 2017

    Budget cuts threaten EPA’s ability to enforce federal environmental laws, and states have neither the means nor the will to substitute for it. Our issue brief on EPA enforcement explores the financial and political constraints that state regulators already face when implementing federal environmental laws and how the Trump Administration’s budget cuts would exacerbate these problems.

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  • Public Comments

    Comments on EPA’s Proposal to Further Delay the Amendments to the Risk Management Program

    May 19, 2017

    We recently submitted comments on the Environmental Protection Agency’s proposal to delay the effective date of EPA’s amendments to the Risk Management Program for twenty more months and to put off the compliance deadlines indefinitely. The original rule was issued under section 112®(7)(A) of the Clean Air Act and updated chemical accident prevention rules at manufacturing plants, after a fatal explosion at a fertilizer plant in West Texas.

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