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Recent Projects

Viewing recent projects in Consumer and Healthcare Protection
  • Regulating New Fossil-Fuel Appliances Under Section 111(b) of the Clean Air Act Cover

    Regulating New Fossil-Fuel Appliances Under Section 111(b) of the Clean Air Act

    This report finds that EPA has authority under Section 111(b) of the Clean Air Act to set nationwide performance standards for new residential and commercial fossil-fuel appliances and that multiple means of reducing emissions from such appliances are adequately demonstrated, including the use of electric-heat-pump technology.

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  • Comments to DOE on Conservation Standards for Furnaces and Water Heaters

    In August 2021, DOE proposed to return to holding less-efficient gas furnaces to the same standard as other gas furnaces. We filed comments supporting the proposal, while cautioning DOE against making unnecessary statements that might hinder its ability in the future to set standards that would encourage consumers to switch from gas-fired appliances to electric appliances.

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  • Comments to EPA on New Clean Car Standards

    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.

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  • Comments to NHTSA on Rescinding CAFE Penalties Interim Final Rule

    The National Highway Traffic Safety Administration ("NHTSA") sets corporate average fuel economy ("CAFE") standards for light-duty vehicles, and penalizes automobile manufacturers who fail to meet applicable standards. In January 2021, NHTSA issued an Interim Final Rule repealing the inflation-adjusted penalty increase for Model Years 2019-2021, which we commented was untimely and disregarded critical environmental harms. 

    In August 2021, NHTSA proposed to rescind the Interim Final Rule. We filed comments supporting the proposal for complying with inflation-adjustment obligations, driving fuel savings, and reducing pollution.

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  • Comments to EPA and USACE on Clean Water Protections

    The Environmental Protection Agency (EPA) and Army Corps of Engineers (USACE) have expressed the intention to repeal the Navigable Waters Protection Rule, which removed critical federal protections on many waterways and has been vacated by a federal court for violating the Clean Water Act. In comments filed to the agencies, we welcome the decision to replace the rule but encourage strong justification for reversing course and point to flaws in the economic analysis for the earlier rule that can support the case for replacing it.

    We previously commented on the rule and its flawed economic justification, published a report on its concealed costs, and filed amicus briefs in court cases that challenged it.

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  • Regulating Risk from Toxic Substances Cover

    Regulating Risk from Toxic Substances

    Best Practices for Economic Analysis of Risk Management Options Under the Toxic Substances Control Act

    This report identifies best practices EPA should adopt to holistically assess and weigh the costs and benefits of risk management options, allowing the agency to meet its statutory obligations and best enhance public welfare.

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  • Amicus Brief on Borrower Defense Rule

    We filed a brief in the U.S. District Court for the Southern District of New York supporting a challenge to the Department of Education’s replacement for a 2016 regulation known as the Borrower Defense Rule. The replacement rule makes it much harder for student borrowers who have been defrauded by for-profit colleges to get their loans discharged. We later filed a brief in the Second Circuit Court of Appeals after SDNY upheld the rule.

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  • Petition for Rulemaking for the Federal Trade Commission to Ban Drip Pricing

    Drip pricing is a strategy used by some sellers to lure in consumers by advertising deceptively low prices, only to reveal hidden mandatory fees after the consumer is on the verge of completing a transaction. We submitted a petition to the Federal Trade Commission formally calling for a new rule banning the use of drip pricing.

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  • Comments to New York PSC on Climate Change Vulnerability Assessments

    We submitted comments to the New York Public Service Commission to voice our support for a petition concerning the impacts of climate change on utility infrastructure. Our comments emphasize that it is imperative for public utilities to identify and assess the risks that climate change poses to their assets and operations.

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  • Comments to SEC on Climate Change Disclosure

    Climate change presents grave risk across the U.S. economy, including to corporations, their investors, the markets in which they operate, and the American public at large. The Securities and Exchange Commission (SEC) recently requested public input on climate change disclosures, posing several questions related to the development of new disclosure regulations and the enforcement of existing regulations. We worked with several partners to submit comments to the SEC, providing 15 major recommendations.

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