Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Environmental Health
  • Comments to EPA on Reconsideration of Mercury and Air Toxics Standards

    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

  • Comments on the Replacement of the Clean Water Rule

    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

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

    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

  • Comments to the FCC on Regulation of Space Debris

    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

  • Comments to EPA on Delay of Landfill Emission Guidelines

    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

  • Comments on EPA Rollback of Refrigerant Substitutes Regulation

    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

  • Deregulation Run Amok Cover

    Deregulation Run Amok

    Trump-Era Regulatory Suspensions and the Rule of Law

    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

  • Comments on California’s Proposed State-Specific Vehicle Emissions Regulations

    We recently submitted comments to the California Air Resource Board (CARB) on its proposal to maintain existing statewide vehicle emission regulations. In coming years, the National Highway Traffic Safety Administration and Environmental Protection Agency plan to weaken federal environmental regulations. CARB is aiming to hold California vehicle emissions at current standards to avoid the effects of weakened regulations. Our comments support the feasibility of California’s current standards and encourage CARB to improve its economic impact assessment by accounting for new federal proposals and a broader range of effects.

    Read more

  • Brief on the Clean Water Rule’s “Applicability Date”

    The Environmental Protection Agency and Army Corp of Engineers were sued for suspending implementation of the Clean Water Rule through the addition of an “applicability date” to the Clean Water Rule. Our brief to the U.S. District Court for the Southern District of New York in that case argues that the court should vacate the Suspension Rule because the agencies improperly ignored the forgone benefits of suspending the Clean Water Rule.

    Read more

  • Comments to EPA on Coal Combustion Residuals Rule

    In 2015, the United States Environmental Protection Agency (EPA) established minimum criteria for the safe disposal of coal combustion residuals. At the time, EPA projected that the new rule would yield substantial health and environmental benefits. EPA now proposes to weaken the requirements of the 2015 rule but insists that doing so “will not change risks to human health and the environment” and thus will have no effect on the projected benefits of the 2015 rule. Our comments explain why EPA cannot reasonably assume that its proposed changes will have no effect on the 2015 rule’s projected benefits.

    Read more