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Recent Projects

Viewing recent projects in Consumer and Healthcare Protection
  • Joint SC-GHG Comments on DOE Standards for Pool Pump Motors

    Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for dedicated purpose pool-pump motors. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also encourage DOE to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

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  • Comments to SEC on ESG Disclosures

    The SEC has proposed a series of new disclosures for investment companies regarding their Environmental, Social, and Governance (ESG) activities. These disclosures would reduce "greenwashing" - a practice where companies misrepresent the sustainability of their investments in order to advertise to investors looking to invest in green funds - by providing investors with comparable and decision-useful information about fund practices. We submitted comments on the SEC's economic analysis of the Proposed Rule. We commend the Commission for complying with relevant case law and internal guidance on cost-benefit analysis and recommend steps that the SEC could take in the final rule to provide additional clarity and context regarding its findings.

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  • Comments to SEC on Investment Company Names

    The SEC has proposed a rule that would better align the names of investment companies with investor expectations, including for Environmental, Social, and Governance (ESG) investment funds, by requiring portfolio distribution requirements for funds whose name connotes a particular investment strategy. We submitted comments on the SEC's economic analysis of the Proposed Rule. We commend the Commission for complying with relevant case law and internal guidance on cost-benefit analysis and recommend steps that the SEC could take in the final rule to provide additional clarity and context regarding its findings.

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  • Joint SC-GHG Comments on Commercial Water Heating Equipment

    Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for commercial water heating equipment. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also encourage DOE to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

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  • Joint Comments to SEC on its Proposal to Enhance and Standardize Climate-Related Disclosures

    Together with the Environmental Defense Fund and Professor Madison Condon of Boston University School of Law, we submitted three sets of comments to the Securities and Exchange Commission (SEC) in support of its Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposed Rule). The Proposed Rule would require publicly traded companies to disclose important information about the extent to which climate change is already affecting their financial performance, their approach to climate-related risk management, their climate-relevant governance structures, and their greenhouse gas emissions, which serve as a proxy for exposure to risk from policy- and market-driven shifts to a clean-energy economy.

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  • Regulating Immortal Accounts Cover

    Regulating Immortal Accounts

    How the FTC Can Limit Unwanted Data Retention

    The report argues that an FTC rule requiring reasonable cancellation practices for all market actors and providing clear and specific guidelines would address the harms of immortal accounts. Such regulation would fall under the FTC’s authority and advance the Commission’s mission to protect consumers and competition by preventing deceptive, unfair, and anticompetitive business practices.

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  • Comments to EPA on Proposal to Reaffirm “Appropriate-and-Necessary” Finding for Regulating Hazardous Air Pollution from Power Plants

    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.

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  • The Emissions in the Kitchen Cover

    The Emissions in the Kitchen

    How the Consumer Product Safety Commission Can Address the Risks of Indoor Air Pollution from Gas Stoves

    Gas stoves are found in over a third of American homes, and these appliances generate dangerous indoor levels of nitrogen dioxide (NO2) and fine particulate matter (PM2.5) within just a few minutes of cooking. This report suggests several ways the Consumer Product Safety Commission (CPSC) can and should take action to address the unreasonable health risks posed by gas stove emissions.

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  • Comments to EPA on Proposed Particulate Matter Standards for Aircraft Emissions

    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.

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  • Comments on the CPSC’s Proposed Rule for Custom Window Coverings

    Policy Integrity filed comments on the Consumer Product Safety Commission's (CPSC) Proposed Rule for custom window coverings, which would require safety features to reduce the strangulation risk from window covering cords. We argue that adding a child premium to the value of statistical life (VSL) is consistent with federal guidance and international regulatory practice. However, if the CPSC chooses to apply a child premium, it should offer a theoretical justification that does not rely on life-years. We also argue that the CPSC has the authority to consider unquantified benefits and should consider avoided parental grief as a benefit of the Proposed Rule, but only to the extent it is not already captured in a child VSL premium. Furthermore, the CPSC should consider avoided litigation costs and recall costs as a quantified or unquantified benefit of the Proposed Rule and use a break-even analysis to better incorporate unquantified benefits.

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