Recent Projects – Government Transparency

In 2023, EPA updated its emissions standards for heavy-duty engines and vehicles, but the agency now seeks to weaken many provisions of the 2023 Rule and spurns decades of agency practice and an enormous scientific record by declining to incorporate in its analysis any estimates of the impact of increased concentrations of particulate matter and ozone on human health. We submitted comments to EPA, along with our partners at Clean Air Task Force, Environmental Defense Fund, Montana Environmental Information Center, Natural Resources Defense Council, Sierra Club, and Union of Concerned Scientists, explaining that the agency’s new claim that these estimates are too uncertain is flawed for numerous reasons.

The Office of Management and Budget has proposed to revise guidance regarding how federal agencies manage federal financial assistance including grants, cooperative agreements, and other forms of support. This comment highlights that, as proposed, this rulemaking would violate the Paperwork Reduction Act. 

For nearly thirty years, EPA has quantified and monetized the harmful effects of particulate matter and ozone, two lethal pollutants that threaten human health. The Trump Administration has abandoned these estimates, rejecting decades of research and instead claiming without support that the estimates are too uncertain. In February, EPA finalized a rule rescinding key updates to protections for hazardous air pollutants from coal- and oil-fired electric utility steam generating units. Several groups filed a Petition for Reconsideration urging EPA to reconsider the rule. We submitted comments supporting the petition, which explain the extensive scientific record undergirding EPA's estimates and demonstrate that EPA's arguments for abandoning these estimates are flawed and arbitrary.

For nearly thirty years, EPA has quantified and monetized the harmful effects of particulate matter and ozone, two lethal pollutants that threaten human health. Claiming the effects of these pollutants are too uncertain, EPA has recently announced that it is abandoning these estimates. In effect, EPA now values the health effects of these pollutants at zero. Jointly with other environmental and scientific organizations, we submitted comments on a recent proceeding regarding pollution from marine tank vessel loading operations where EPA failed to quantify or monetize these harms.

The Department of Agriculture’s Food Safety and Inspection Services (FSIS) regulates safety at chicken and swine slaughter facilities. During the first Trump Administration, the agency sought to eliminate regulations governing line speeds, but faced judicial pushback because it failed to sufficiently consider the safety of facility employees working the lines. In February 2026, FSIS proposed to once again roll back its line-speed regulations, arguing that it is not required to consider workplace safety following the Supreme Court’s 2025 decision in Seven County Infrastructure Coalition v. Eagle County, Colorado. Our comments oppose FSIS’s analysis of Seven County and explain that agencies routinely consider indirect impacts in regulation—consistent with many court decisions—and that Seven County does not upend that body of law.

Policy Integrity filed amicus briefs in Supreme Court and Federal Circuit litigation over President Trump’s worldwide tariffs. The court decisions in both cases mirrored our articulation of the major questions doctrine and adopted key arguments that we raised.

In February 2026, EPA rescinded its 2009 finding that greenhouse gas emissions from motor vehicles contribute to air pollution that endangers public health and welfare. With that withdrawal, EPA repealed all greenhouse gas emission standards for cars and trucks. EPA primarily argues that the Clean Air Act provision authorizing vehicle emission standards does not extend to greenhouse gases. EPA also argues that regulation is unwarranted because U.S. vehicle emissions would have a relatively small impact on global temperature and sea-level rise. But EPA’s repeal is wrong on numerous accounts. As our resources explain, legal precedent and scientific and economic evidence justify U.S. climate regulations:

Section 401 of the Clean Water Act requires applicants for federal permits to conduct activities that “may result in any discharge into the navigable waters” to obtain a certification from the state where the discharge will originate. In January 2026, EPA proposed a rule that would restrict states’ ability to protect their water quality by narrowing states’ certification review to cover only projects’ discharges and not other water-quality impacts. Policy Integrity submitted a comment letter arguing that EPA’s proposed rule misapplies several Supreme Court precedents and mischaracterizes Section 401’s legislative history. In particular, the proposed rule is inconsistent with PUD No. 1 of Jefferson County v. Washington Department of Ecology, which upheld Section 401 conditions unrelated to discharges based on the Supreme Court's best reading of Section 401.