-
Comments to CFTC on Voluntary Carbon Credit Derivatives Guidance
In December 2023, the Commodity Futures Trading Commission (CFTC) proposed guidance that identifies key features of high-integrity voluntary carbon credits (VCCs) for exchanges that list certain VCC derivatives. The Institute for Policy Integrity submitted comments that highlight additional sources of CFTC legal authority over these derivatives and suggest improvements to the proposed guidance’s discussions of additionality, leakage risk, quantification, risk of reversal, and exchanges’ discretion to set stringent standards. Finally, our comments recommend that the CFTC explore whether it has other authority to address issues with VCC integrity and whether to seek additional authority from Congress.
-
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.
-
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.
-
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.
-
The Continued Need for SEC Action on Climate-Related Disclosures
How New California and E.U. Requirements Reinforce the Economic Case for the SEC’s Proposed Rule
On March 21, 2022, the Securities and Exchange Commission (SEC) proposed a rule that would require SEC registrants (both domestic and foreign) to provide climate-related disclosures in certain SEC filings. Since the release of the SEC Proposal in March 2022, other jurisdictions, including California and the European Union, have adopted climate-related disclosure regimes. Like many federal rules, the SEC Proposal included an assessment of its costs and benefits. This report examines how the California and E.U. disclosure regimes may affect the baseline for that cost-benefit analysis and, consequently, the SEC’s assessment of the incremental costs and benefits of its proposal. Overall, we find that the new disclosure regimes do not undermine the economic case for the SEC Proposal; if anything, they bolster it.
-
Comments to PHMSA on Proposed Pipeline Safety Initiatives
In September 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed a regulation to improve the safety of certain gas pipelines. The standards include a suite of reforms to help prevent incidents like the catastrophic 2018 gas pipeline explosions in Merrimack Valley, Massachusetts. In a comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis are well grounded in applicable statutes and guidance, PHMSA should take further steps to bolster its analysis.
-
Policy Integrity Work Shapes FTC Ban on Hidden Fees
In October 2023, the Federal Trade Commission (FTC) released a proposed rule that bans the use of “junk fees” in transactions including hotel reservations, vehicle rentals, and event ticket purchases. The proposed rule references Policy Integrity and our work more than a dozen times, including both our 2021 petition for rulemaking and our 2023 comment letter supporting the FTC’s authority to issue this regulation.
-
Comments to EPA on GHG Regulations for Fossil Fuel-Fired Power Plants
In May 2023, 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. This proposal included revisions to strengthen the limits for new gas fired-plants and to establish limits for existing coal-fired plants and some of the largest, existing gas-fired plants. To determine the stringency of these limits, EPA identified “best systems of emission reduction” (BSERs). In our comments we explain how EPA’s has selected BSERs that are traditional in scope and consistent with the legal pathway left intact by the Supreme Court’s decision in West Virginia v. EPA. We also recommend that EPA strengthen the design of the rule to ensure it best fulfills its goal to reduce GHG emissions, which endanger public health and welfare, in a manner that avoids creating perverse incentives.
-
Comments to EPA on Proposal to Strengthen the Mercury and Air Toxics Standards
In April 2023, the Environmental Protection Agency (EPA) proposed to strengthen and update the National Emission Standards for Hazardous Air Pollutants for coal- and oil-fired power plants, also known as the Mercury and Air Toxics Standards (MATS). In this proposal, EPA clearly explained why it revised the technology review conducted in 2020 and made the emissions standards more stringent on the basis of developments in control technologies. In our comments, we recommended improvements to the proposed update and highlighted areas where EPA's analysis succeeded. -
Comments to EPA on Proposed Rule to Strengthen Power Plant Effluent Guidelines
In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits.
Viewing recent projects in Consumer and Healthcare Protection