Recent Projects

In August, the Federal Trade Commission released an advance notice of proposed rulemaking seeking comment on avenues to regulate commercial surveillance and data security practices that harm consumers. Policy Integrity submitted comments recommending that the FTC regulate “immortal accounts,” a practice by which entities make it difficult or impossible to delete a consumer account in order to retain and profit from the user’s data and continue charging subscriptions. Our comments were based on a report that we recently published establishing the Commission’s authority to regulate this pervasive practice.

Policy Integrity submitted comments to the Centers for Medicare & Medicaid Services (CMS) in support of its proposed rule to streamline applications and eligibility determinations for Medicaid, the Children's Health Insurance Program, and the Basic Health Program. Our comments encourage CMS to strengthen the Proposed Rule's cost-benefit analysis by describing the many health and economic benefits that result from increased access to healthcare and engaging in a more robust distributional analysis.

Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for consumer furnaces. 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 expand upon DOE's justifications for adopting a global damages valuation and for the range of discount rates it applies to climate effects.

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.

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.

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.

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.

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.