Recent Projects

Under recent revisions to the Supplemental Nutrition Assistance Program, nearly 700,000 current beneficiaries would lose eligibility—harming the health of those individuals and likely causing economic disruption in the food sector. We filed an amicus brief in a federal lawsuit challenging the rule, detailing how the Department of Agriculture’s analysis fails to assess the profound and widespread costs of substantial disenrollment from SNAP assistance. Our brief was cited several times in the State Plaintiffs' reply brief to support their argument that the federal government did not adequately consider the indirect costs of the rule. 

The Oklahoma Health Care Authority has requested permission from the U.S. Department of Health and Human Services to change the state’s Medicaid program in a variety of ways—including by introducing work requirements and premium payments for some beneficiaries. We filed comments opposing the request and explaining why the benefits, if any, of work and cost-sharing requirements are unlikely to justify the accompanying health and administrative costs.

The New England Ratepayers Association (NERA) recently petitioned the Federal Energy Regulatory Commission (FERC) to effectively overturn net metering policies nationwide. While FERC has previously and definitively answered the jurisdictional question concerning net metering, NERA asserts without evidence that controversy persists. We submitted comments describing the flaws of NERA’s argument and urging FERC to reject the petition.

The Department of Health and Human Services (HHS) asked for public input on a forthcoming report to Congress regarding strategies for ensuring an adequate blood supply during public health emergencies. Our comments recommended that the report endorse elimination of the Food and Drug Administration’s deferral policy for donations from men who have sex with men. The policy, which bars gay and bisexual men from donating blood for three months from the date of their last sexual contact, relies on outdated science regarding HIV transmission risk, stigmatizes gay and bisexual men, and increases the likelihood of blood shortages.

The Commodity Futures Trading Commission (CFTC) requested public input on issues relevant to its Climate-Related Market Risk Subcommittee. We submitted joint comments highlighting the significant financial risks that climate change poses and emphasizing that an economy-wide price on carbon emissions is the regulatory tool that will be the most effective in mitigating a climate-related financial crisis.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.

The Securities and Exchange Commission (SEC) proposed a rule modifying Regulation S-K, which governs reporting requirements for public companies. We submitted comments focusing on the SEC’s failure to require disclosure of risks relating to climate change. Climate risks are economy-wide impacts in which the future increasingly diverges from past experience, and predicting such risks requires more granular data than is typically disclosed in financial reporting. We suggest that the SEC adopt a more specific line-item approach to climate risk reporting, similar to the framework suggested under the Task Force on Climate-Related Financial Disclosures.