Recent Projects

Last year, the Trump administration finalized its Title X “gag rule,” which prohibits funded family planning service providers from referring clients for abortion and requires Title X facilities to be physically separate from facilities that provide abortion. We’ve filed two briefs in the U.S. Court of Appeals for the Fourth Circuit in the ongoing challenge of the rule.

The Institute for Policy Integrity is tracking altered enforcement of environmental laws by federal and state agencies in response to the COVID-19 pandemic. In connection with the crisis, several agencies have issued waivers or announced plans to stop enforcing key environmental laws and regulations. 

Last year, the Environmental Protection Agency (EPA) replaced the Obama Administration’s Clean Power Plan, which sought substantial cuts in greenhouse gas emissions from power plants, with the so-called Affordable Clean Energy (ACE) rule, a far weaker policy that will, at best, yield modest reductions below business-as-usual emissions and, at worst, increase pollution from the electric sector. We filed an amicus brief in the U.S. Court of Appeals for the D.C. Circuit highlighting three key errors in EPA’s rationale for repealing the Clean Power Plan. Specifically, we explain, EPA misstates regulatory precedent and Clean Air Act legislative history supporting the Clean Power Plan and disregards the substantial harms that the ACE Rule will cause.

Coal combustion residuals, commonly known as coal ash, are the residual substances that remain after burning coal. They contain several chemicals that are toxic to human health, including arsenic, boron, lead, and mercury. The Environmental Protection Agency (EPA) proposed a rule that amends the regulatory framework for the disposal of coal ash. We submitted comments in January detailing how EPA fails to analyze the forgone benefits of the regulatory changes, which extend deadlines and eligibility for facilities that lack appropriate disposal capacity. We also submitted comments in April focusing on the second part of EPA's proposal, which fails to assess the forgone benefits of allowing facilities to seek approval for alternative basin liners. 

The federal Clean Car Standards promised steadily increasing fuel efficiency and lower vehicle emissions. The National Highway Traffic Safety Administration and the Environmental Protection Agency have now rolled back those standards, eviscerating important public health benefits and fuel savings for consumers. But the agencies’ own analysis shows that the rollback will cause more harm than good for society. And even the slight benefits that the agencies find under certain assumptions are premised on a flawed economic analysis that is riddled with problems.

We released a resource that explains the main economic problems with the rollback’s justification, identifying several critical errors and detailing how they invalidate the agencies' own claims

The Environmental Protection Agency (EPA) proposed revisions to the National Primary Drinking Water Regulation for lead and copper. Our comments ask EPA to more fully monetize the benefits and better assess the significance of non-monetized benefits of the proposal. We also submitted a letter to EPA’s Science Advisory Board (SAB) summarizing our comments and encouraging the SAB to consider our points during its review of the proposed revisions.

The Department of Housing and Urban Development (HUD) has proposed to repeal and replace the 2015 Affirmatively Furthering Fair Housing rule, which sought to improve the process by which state and local governments that receive HUD funding identify and mitigate impediments to fair housing in their communities. We submitted comments detailing deficiencies in the Department’s regulatory impact analysis for the proposal. Specifically, we explain how HUD (1) ignores benefits of the 2015 rule that will be forgone under the proposed replacement, and (2) overestimates cost savings that will result from the proposed replacement.

The Transportation and Climate Initiative called for public input on a Draft Memorandum of Understanding, which lays out a proposal for a Northeast and Mid-Atlantic regional program to establish a cap on carbon pollution from transportation and invest in further emissions reductions, cleaner fuels, and infrastructure. We submitted comments on the proposal suggesting that TCI adjust its definition of affected fuels, set the emissions cap to better reflect external damages from carbon emissions, implement the banking of allowances carefully, and verify that all offsets are real, permanent, and additional.

The Office of Management and Budget (OMB) requested input on the possibility of including an estimate of the social cost of taxation, known as marginal excess tax burden (METB), in regulatory-cost accounting for transfer rules under Executive Order 13,771. We submitted comments responding to OMB claims and providing further information about METB.