Recent Projects

EPA revised the National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM) in March. The state of Kentucky and others filed a lawsuit in the D.C. Circuit arguing that EPA should have considered costs when setting its 2024 NAAQS for PM. We filed an amicus brief explaining that EPA appropriately assessed costs in its separate regulatory impact analysis, that considering regulatory costs would not lead to a less stringent standard, and that there is no history of EPA considering costs when revising the NAAQS.

EPA's Science Advisory Board (SAB) sought comments on its draft peer review report on EPA’s Draft Revised Environmental Justice Technical Guidance (EJTG). This report reviews the methods and procedures described in EPA’s Draft Revised EJTG for evaluating environmental justice concerns in regulatory actions. The Institute for Policy Integrity submitted comments making three key recommendations that the SAB can use to advise EPA.

In April 2024, EPA proposed retaining the secondary national ambient air quality standards (NAAQS) for nitrogen oxides (NOx) and particulate matter (PM) and setting a new annual average standard for sulfur oxides (SOx). Policy Integrity submitted comments arguing that although the Proposed Rule begins to assess the various adverse welfare effects of SOx, NOx, and PM emissions and depositions that different populations may face, EPA should assess, consider, and present more information regarding both distributional impacts and future risks. 

In March 2024, a set of states and industry groups asked the U.S. Court of Appeals for the District of Columbia Circuit to stay the implementation of EPA’s rule to limit methane emissions from the oil and gas sector. Our Economics Director, Peter Howard, authored an expert declaration defending the agency's development and use of new values for the social cost of methane in the rule.

In May 2024, the Environmental Protection Agency (EPA) issued a request for input on reducing greenhouse gas (GHG) emissions from existing fossil fuel-fired stationary combustion turbines. The Institute for Policy Integrity submitted comments to EPA, providing recommendations on key issues for the agency to consider as it develops new regulations.

In January 2024, the Environmental Protection Agency (EPA) proposed a regulation under the Clean Water Act that would impose new effluent limitations guidelines and standards for the meat and poultry products point source category. As EPA documents, the proposed standards would help improve health and water quality near these slaughterhouse facilities. It would also carry benefits stemming from better-protected habitats for a variety of wild animals. In our comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis reasonably explain many of these benefits, EPA should take further steps to ensure the complete presentation of regulatory benefits and costs, along with their distribution, and to present its decisionmaking factors transparently.

In February 2024, EPA finalized amendments to its Risk Management Program (RMP), under Section 112(r) of the Clean Air Act, to better protect vulnerable communities from chemical disasters that release toxic air pollution. In line with Policy Integrity’s recommendations, the final rule has been strengthened relative to the proposal and includes considerably more attention to the issues of underreporting, unquantified benefits, and the risks of catastrophic incidents. EPA has further improved the final rule to include consideration of climate change-related hazards in line with Policy Integrity’s recommendation to cover climate change-exacerbated hazards in addition to climate change-caused hazards. This will be increasingly important as the risks and magnitude of future chemical incident damages will likely only grow as climate change exacerbates severe weather that can spur power outages and chemical disasters.

On February 23rd, Policy Integrity submitted comments to EPA on its draft Scientific Integrity Policy. The draft Policy appropriately clarifies that economic analyses are protected by the same integrity policies as other scientific assessments, but it currently cites EPA's 2010 Guidelines for Performing Economic Analyses as the only example of a best-practice document that "should be followed" when assessing benefits, costs, and economic impacts. Several key elements of those 2010 guidelines are out of date, notably the recommendations on discount rates. Our comments offer a simple redline to ensure that other documents that meet the standards for objectivity--like the updated Circular A-4, or the pending ecosystem service guidance--could also fall under the Policy's proposed protections.