Institute for Policy Integrity logo

Twitter @policyintegrity

Recent Projects

Viewing recent projects in Transparency
  • Reports

    Shortchanged: How the Trump Administration’s Rollback of the Clean Car Standards Deprives Consumers of Fuel Savings

    June 4, 2020

    The Trump administration recently replaced the Obama administration’s strongest climate policy, the Clean Car Standards, with a significantly weaker rule. We explain how EPA and NHTSA, to justify the rollback, rely on an analytical gimmick that contravenes decades of agency practice across administrations as well as the principles of basic economics. 

    Read more

  • Policy Briefs

    What We Lose When They “Save”

    May 28, 2020

    The Trump administration regularly boasts about the cost savings of rolling back regulations, focusing on industry profits without considering significant negative impacts. This policy brief address and counters the administration's cost savings claims and demonstrates that they should not be taken at face value.

    Read more

  • Issue Briefs

    Understanding EPA’s Enforcement and Compliance Policy During the COVID-19 Pandemic

    May 21, 2020

    This issue brief summarizes EPA's enforcement and compliance policy in light of COVID-19, describing its significance and clarifying its contours. The policy opens the door to potentially problematic and harmful actions, especially on a short-term basis. 

    Read more

  • Public Comments

    Joint Comments to CTFC on Climate-Related Market Risk

    May 14, 2020

    The Commodity Futures Trading Commission (CTFC) 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.

    Read more

  • Public Comments

    Comments to SEC on Regulation S-K and Climate Risk

    April 28, 2020

    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.

    Read more

  • Reports

    Beneath the Surface

    April 27, 2020

    In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.

    Read more

  • News

    New Resource Tracking Reduced Enforcement of Environmental Laws in Response to COVID-19

    April 24, 2020

    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. 

    Read more

  • News

    Key Economic Errors in the Clean Car Standards Rollback

    April 1, 2020

    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

    Read more

  • Public Comments

    Comments to SEC on Shareholder Proposal Regulations

    February 3, 2020

    The Securities and Exchange Commission (SEC) proposed a rule that would limit investors’ ability to propose shareholder resolutions for a vote by fellow shareholders. The rule would raise requirements on the amount of stock required to be owned, impose requirements for the length of time the stock must have been held, and make it harder to resubmit resolutions that had failed to reach majority support in prior years. We submitted comments critiquing the rule, which will limit shareholder monitoring and likely have an outsized impact on shareholders’ role in environmental oversight.

    Read more

  • Public Comments

    Comments to EPA’s Chartered Science Advisory Board

    January 10, 2020

    We submitted four comments in advance of the Environmental Protection Agency’s (EPA) January 2020 meeting of its Chartered Science Advisory Board (SAB).

    Read more