Institute for Policy Integrity logo

Twitter @policyintegrity

Recent Projects

Viewing recent projects in Jobs and Regulation
  • Court Filings

    Amicus Brief on Navigable Waters Protection Rule

    May 21, 2020

    In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed a brief in the Northern District of California focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms.

    Read more

  • Issue Briefs

    Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic

    May 21, 2020

    This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis. 

    Read more

  • Public Comments

    Comments to New Jersey BPU on Resource Adequacy Alternatives

    May 20, 2020

    The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.

    Read more

  • Public Comments

    Joint Comments to CTFC on Climate-Related Market Risk

    May 14, 2020

    The Commodity Futures Trading Commission (CTFC) requested public input on issues relevant to its Climate-Related Market Risk Subcommittee. We submitted joint comments highlighting the significant financial risks that climate change poses and emphasizing that an economy-wide price on carbon emissions is the regulatory tool that will be the most effective in mitigating a climate-related financial crisis.

    Read more

  • Public Comments

    Comments to PHMSA on Data Collection from Pipeline Accidents

    May 8, 2020

    The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.

    Read more

  • Public Comments

    Comments to SEC on Regulation S-K and Climate Risk

    April 28, 2020

    The Securities and Exchange Commission (SEC) proposed a rule modifying Regulation S-K, which governs reporting requirements for public companies. We submitted comments focusing on the SEC’s failure to require disclosure of risks relating to climate change. Climate risks are economy-wide impacts in which the future increasingly diverges from past experience, and predicting such risks requires more granular data than is typically disclosed in financial reporting. We suggest that the SEC adopt a more specific line-item approach to climate risk reporting, similar to the framework suggested under the Task Force on Climate-Related Financial Disclosures.

    Read more

  • Court Filings

    Fourth Circuit Amicus Briefs on Title X Rule

    April 28, 2020

    Last year, the Trump administration finalized its Title X “gag rule,” which prohibits funded family planning service providers from referring clients for abortion and requires Title X facilities to be physically separate from facilities that provide abortion. We’ve filed two briefs in the U.S. Court of Appeals for the Fourth Circuit in the ongoing challenge of the rule.

    Read more

  • Reports

    Beneath the Surface

    April 27, 2020

    In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.

    Read more

  • News

    New Resource Tracking Reduced Enforcement of Environmental Laws in Response to COVID-19

    April 24, 2020

    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. 

    Read more

  • Court Filings

    Amicus Brief on EPA’s Clean Power Plan Replacement Rule

    April 23, 2020

    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.

    Read more