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  • Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance

    The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies on monitoring, reporting and verification (MRV) programs; project prioritization; and other topics.

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  • Comments to HHS on Proposed Repeal of the SUNSET Rule

    We submitted comments to the Department of Health and Human Services (HHS) supporting its proposed repeal of the SUNSET Rule, which retrospectively and prospectively established an "expiration date" for thousands of HHS regulations. We explain why the SUNSET Rule is arbitrary and capricious, echoing our earlier comments, and and propose ways that HHS can strengthen its justification for repealing the rule.

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  • Valuing the Future: Legal and Economic Considerations for Updating Discount Rates Cover

    Valuing the Future: Legal and Economic Considerations for Updating Discount Rates

    Yale Journal on Regulation, Forthcoming

    This article explores the legal and economic considerations for updating discount rates and details the compelling economic evidence for lowering the current default rates for regulatory analyses. It argues that a declining discount rate framework can consistently harmonize agency practices and so put agencies on sound legal footing in their approach to valuing the future.

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  • Poisoning America Cover

    Poisoning America

    A “Reasoned Consistency” Response to the Trump Administration’s Regulatory Shell Game

    Published in the NYU Environmental Law Journal, the article analyzes the inconsistent manner in which the Trump administration dealt with cost-benefit analysis, federalism, and the treatment of dirty, old sources of pollution in the design of environmental policy. The article finds that though inconsistencies across different regulations— as opposed to inconsistencies within a single regulation—have not been a core concern of the Administrative Procedure Act, its prohibition on “arbitrary and capricious” agency action is sufficiently capacious to embrace egregious inconsistencies.

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  • Making Regulations Fair Cover

    Making Regulations Fair

    How Cost-Benefit Analysis Can Promote Equity and Advance Environmental Justice

    To achieve the Biden administration’s ambitious commitments to equity and environmental justice, agencies will need guidance on how to assess and weigh the distributional effects of policy options. This report recommends steps that the Office of Management and Budget (OMB) can take to mainstream equity into agencies’ decisionmaking.

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  • Comments on FERC’s Office of Public Participation

    The Federal Regulatory Energy Commission (FERC) solicited comment from interested parties on how the Commission should structure their Office of Public Participation to facilitate public engagement. We submitted comments highlighting the potential benefits of public participation by environmental justice communities and identifying best practices that FERC’s Office of Public Participation (OPP) should adopt.

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  • Comments to ACUS on Periodic Review of Agency Regulation

    The Committee on Regulation of the Administrative Conference of the United States requested input on best practices for agencies in undertaking periodic review of their existing regulations. We submitted comments providing a number of recommendations.

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  • Comments to ACUS on Regulatory Alternatives

    The Committee on Regulation of the Administrative Conference of the United States requested input on how agencies should solicit public input on alternatives to rules under consideration. We submitted comments providing a number of recommendations.

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  • Comments on HHS’s Sunset Rule

    The Department of Health and Human Services (HHS) has proposed to retrospectively and prospectively establish an "expiration date" for each of its regulations. Under the proposed rule, regulations would be automatically rescinded unless HHS first completes a restrospective review of the regulation's effects on small entities pursuant to the Regulatory Flexibility Act. We submitted comments criticizing the proposal, which is neither lawful nor rational.

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  • Presidential Transition Guidance

    As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.

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