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Viewing recent projects in Public Comments
  • Comments to FTC on Proposed Rule on Unfair or Deceptive Fees

    In 2021, Policy Integrity submitted a petition for rulemaking to the Federal Trade Commission (FTC) calling for a ban on the use of drip pricing. After granting the petition, the FTC in 2023 proposed a Trade Regulation Rule on Unfair or Deceptive Fees (Proposed Rule). The Institute for Policy Integrity submitted comments with suggested edits and additions to the regulatory text to ensure that the Proposed Rule fully codifies FTC's stated objectives. Our comments also suggest several actions to strengthen FTC's breakeven and cost-benefit analyses. 

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  • Comments to DOE and CPO a National Definition for a Zero Emissions Building

    The Department of Energy (DOE) and the Office of Domestic Climate Policy (CPO) published a Request for Information on a National Definition for a Zero Emissions Building. The Institute for Policy Integrity at New York University School of Law (Policy Integrity) submitted comments through DOE and CPO's question-and-answer textbox format. 

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  • Comments to EPA on Draft Revision of Technical Guidance for Assessing Environmental Justice in Regulatory Analysis

    EPA seeks comments on the it's Draft Revised EJ Technical Guidance, which highlights technical approaches that analysts can use to evaluate environmental justice concerns in regulatory actions. The Institute for Policy Integrity's comments to the agency advocate for enhanced documentation and transparency in environmental justice assessments.

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  • Comments to CEQ on Phase One of the Environmental Justice Scorecard

    The Council on Environmental Quality (CEQ) recently published Phase One of the Environmental Justice Scorecard (Scorecard), which evaluates federal agencies' progress on advancing the Justice40 Initiative, implementing and enforcing environmental and civil rights laws, and institutionalizing environmental justice. CEQ sought public feedback on the Scorecard’s usability and potential qualitative and quantitative metrics to improve future iterations of the Scorecard. The Institute for Policy Integrity submitted comments recommending several changes to enhance transparency, accountability, and comprehensiveness.

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  • Comments to FAA on Proposed Rule to Limit Orbital Debris

    In September 2023, the Federal Aviation Administration (FAA) proposed a regulation that would require commercial space operators to limit or dispose of their launches’ orbital debris within 25 years. While the Proposed Rule and its accompanying regulatory impact analysis reasonably explain why orbital debris is a problem and why regulation will help address it, we explain in our comment letter that FAA should take further steps to bolster its analysis.

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  • Supplemental Comments to EPA on Reliability & the Proposed GHG Regulations for Fossil Fuel-Fired Power Plants

    In May 2023, the Environmental Protection Agency (EPA) proposed a package of regulations to limit greenhouse gas emissions from fossil fuel-fired power plants under Section 111 of the Clean Air Act. EPA subsequently issued a supplemental notice of proposed rulemaking, re-opening its comment period and soliciting comment on whether to include additional mechanisms to address potential reliability issues. In these comments, we explain why EPA has engaged in reasoned rulemaking and developed a robust administrative record comporting with its mandate to reduce power sector pollution. It remains the Federal Energy Regulatory Commission’s (FERC’s) responsibility to ensure reliable bulk-power system (BPS) operations and to use its corresponding tools to address the wider reliability challenges of the clean energy transition, in coordination with other reliability-related entities.

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  • Comments to EPA on Proposed Regulation of Trichloroethylene (TCE)

    In October, EPA issued proposed restrictions on the manufacture, processing, and distribution of a chemical called trichloroethylene (TCE). We argue in comments that aspects of the agency’s Economic Analysis of the proposed restrictions could be clarified or expanded upon to better inform policymakers and the broader public about the benefits of ending TCE use.

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  • Supplemental Comments to NHTSA on Proposed Vehicle Fuel-Economy Rule

    In August, the National Highway Traffic Safety Administration (NHTSA) proposed to strengthen vehicle fuel-economy standards. Since then, the Environmental Protection Agency has finalized its update to the social cost of greenhouse gases and the Office of Management and Budget has finalized its revisions to Circular A-4. In light of these updates, we submitted a supplemental comment letter reasserting our call for NHTSA to assess regulatory impacts using the best available economics.

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  • Supplemental Comments to CEQ on Climate Change Guidance

    Earlier this year, the Council of Environmental Quality (CEQ) published interim guidance on analyzing climate change effects under the National Environmental Policy Act in which it endorsed using the social cost of carbon in environmental analysis. In this supplemental comment letter, we suggest that CEQ specifically endorse the Environmental Protection Agency’s newly-updated climate-damage values when it finalizes the interim guidance.

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  • Comments to EPA on the Proposal to Limit Emissions from Reclassified Major Sources of Air Toxics

    In November 2020, EPA finalized a rule withdrawing the “Once-in, Always-in” Policy, under which facilities that are “major sources” of emissions at the first compliance date for the applicable standard must comply permanently with the requirements for a major source. This 2020 Rule allows major sources of toxic air pollution to reclassify as area sources, which are subject to less stringent or no emission control requirements. The 2020 Rule therefore creates the potential for very large increases in toxic air pollution. In September 2023, EPA proposed new safeguards to prevent increased emissions from sources that reclassify and restores federal enforceability requirements for potential to emit limits. We submitted comments on the analysis underlying the proposed new safeguards.

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