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In February 2022, the Environmental Protection Agency (EPA) proposed: (1) to revoke its May 2020 finding that it is not appropriate and necessary to regulate coal- and oil-fired electric utility steam generating units (EGUs) under Clean Air Act (CAA) Section 112 (2020 Action), and (2) to reaffirm the Agency's April 2016 finding that it remains appropriate and necessary to regulate hazardous air pollutant (HAP) emissions from EGUs after considering cost (2016 Supplemental Finding). Our comments on the Proposal explain why EPA should finalize both these actions as consistent with the Clean Air Act, case law, executive directives, principles of sound economic analysis, and past agency practice.

The Environmental Protection Agency (EPA) recently proposed airplane pollution standards that will have no effect on emissions and require no technological improvements. We filed comments urging EPA to evaluate a full suite of regulatory alternatives, including more stringent standards that would reduce emissions, and recommend that EPA conduct a distributional analysis to evaluate the impacts of the Proposed Rule and the relative distributional consequences for each regulatory alternative.

These comments were co-written with Clinical Associates Jenna Pearlson and Tanya Shahjanian.

In November 2021, EPA proposed standards to regulate methane emissions from new and existing sources in the oil and natural gas sector. Policy Integrity submitted comments supporting the proposed standards, and recommending that EPA strengthen its proposal by regulating additional leaky sources; conducting a distributional analysis of the rule's expected impacts; extending the time frame of its analysis; quantifying co-benefits; and disaggregating costs and benefits to demonstrate that its proposed standards are both individually and cumulatively net beneficial.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of greenhouse gases (SC-GHG) in its proposed regulation, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SC-GHG, and affirm that the SC-GHG is a lower bound of projected climate impacts.

We submitted comments on the Environmental Protection Agency’s (“EPA”) notice of proposed rulemaking, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. Our comment urged EPA to: select the regulatory alternative that will maximize net social welfare and promote distributional justice; rely on legislative and regulatory history to help justify its aproach to lead time; and improve its modeling to more fully capture benefits of stronger standards.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of carbon (SCC) in its proposed regulation, recommending that the agency expand its justification its discount rates and inclusion of global damages in the SCC, and affirm that the SCC is a lower bound of projected climate impacts.

The Environmental Protection Agency is reconsidering its withdrawal of a waiver of preemption for California’s zero emission vehicle mandate and greenhouse gas emission standards. We submitted comments supporting the rescission of the waiver withdrawal.

In the Environmental Protection Agency's phasedown of HFCs under the new HFC legislation, the agency calculates a new set of social cost values for HFCs directly, using the same approach as for the social cost of methane. We submitted comments supporting EPA's methodology and encourage EPA to incorporate the SC-HFC into the IWG process going forward. 

In May, EPA announced its intention to rescind a 2020 rule entitled "Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process." Policy Integrity submitted comments in support of this decision based on the view that the 2020 rule is unnecessary, unsupported by any evidence of need, and inconsistent with best practices for cost-benefit analysis. We attached joint comments that Policy Integrity submitted during the original rulemaking which made these arguments in addition to demonstrating specifically how the rule broke from cost-benefit best practices by (1) devaluing indirect benefits, (2) subjecting benefit calculations to stricter standards than cost calculations, and (3) raising the bar for evidence of causality in a manner that excludes studies highly significant to EPA’s cost-benefit analysis.

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.

The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. We submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.

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.