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Comments to FDA on Health Warning Labels for Cigarettes
The Food and Drug Administration (FDA) is proposing to place new, more effective health warning labels on cigarette packages and advertisements. We submitted comments supporting the proposal and suggesting ways the agency can strengthen its assessment of the new labels’ costs and benefits.
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Comments to EPA on Coal Combustion Residuals Rule
The Environmental Protection Agency (EPA) recently proposed to significantly weaken requirements for the disposal of coal combustion residuals from coal-fired power plants. We submitted comments focusing on inadequacies in EPA’s assessment of the rule’s costs and benefits.
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Court Strikes Down Rule Refusing to Limit Cross-State Air Pollution
The U.S. Court of Appeals for the D.C. Circuit vacated EPA’s Close-Out Rule, which allowed upwind states to continue emitting ground-level ozone pollution that significantly contributes to downwind air quality problems. The agency justified the rule by falling back on its analysis from the Cross-State Update, a prior rule that had provided only a partial remedy to interstate emissions. We filed an amicus brief, which argued that EPA fundamentally misunderstood its job in analyzing and choosing between cost-effective options.
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Comments to USDA on Supplemental Nutrition Assistance Program
The Department of Agriculture (USDA) proposed revisions to eligibility for its Supplemental Nutrition Assistance Program, or SNAP. We submitted comments focusing on serious flaws in the agency’s analysis of the rule’s impacts.
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Amicus Briefs on HHS Conscience Rule
The Department of Health and Human Services (HHS) recently finalized a rule that expands protections for healthcare workers who deny care based on moral or religious beliefs. We submitted amicus briefs in support of challenges to the rule filed by states, municipalities, medical organizations, and civil-rights advocates. Our argument details how HHS’s analysis of the rule’s economic impacts ignores significant costs while touting entirely speculative benefits. We submitted briefs to the Southern District of New York, Northern District of California, and the District of Maryland.
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Comments to HHS on Proposed Weakening of Healthcare Nondiscrimination Rule
The Department of Health and Human Services (HHS) recently proposed a rule that would narrow the scope of civil rights protections for patients under the Affordable Care Act. We submitted comments that focus on serious flaws in HHS’s regulatory impact analysis for the proposal, which ignores potentially substantial costs to patients and makes unsupported claims regarding the proposal’s benefits.
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Comments to EPA on New York’s Clean Air Act Petition
The Environmental Protection Agency (EPA) proposed to deny New York’s Clean Air Act Section 126 Petition seeking reductions in pollution from upwind sources that significantly impede the state’s attainment of ozone pollution standards. We submitted comments explaining how EPA’s justification for the decision is flawed.
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Comments to HUD on Housing Assistance Restrictions for Immigrant Families
The Department of Housing and Urban Development (HUD) recently proposed a rule that would deny housing assistance to some immigrant households. We submitted comments focusing on serious flaws in HUD’s analysis of the rule’s impacts.
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Title X Women’s Health - Ninth Circuit Amicus Briefs
In April, district courts in Washington State, Oregon, and California blocked a Trump administration rule that makes harmful changes to the federal funding of women’s health services. Those decisions were recently appealed in the U.S. Court of Appeals for the Ninth Circuit. We filed amicus briefs arguing that the preliminary injunctions should be affirmed.
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Comments to FDA on Sunscreen Products
In February, the Food and Drug Administration (FDA) proposed a rule that would strengthen regulations for sunscreen products. We submitted comments explaining how FDA can improve its analysis of the rule’s impacts.
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