Menu
Institute for Policy Integrity logo

Recent Projects

Viewing recent projects in Government Transparency
  • Implementing NEPA in the Age of Climate Change Cover

    Implementing NEPA in the Age of Climate Change

    Published in the Michigan Journal of Environmental & Administrative Law

    Under the National Environmental Policy Act, agencies must consider the environmental impacts of major federal actions before they can move forward. But agencies frequently downplay or ignore the climate change impacts of their projects in NEPA analyses, citing a slew of technical difficulties and uncertainties. This article, published in the Michigan Journal of Environmental & Administrative Law, aims to highlight best practices so that agency offices can learn from one another, fulfill NEPA’s mandate, and begin to provide leadership in the fight against climate change.

    Read more

  • A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship Cover

    A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship

    This report discusses how an administration that begins a new term can navigate regulatory strategy. It offers advice on navigating this terrain for White House officials, the Office of Information and Regulatory Affairs, transition teams at agencies, and advocates. The report also contains a section on how an incoming administration can roll back the prior administration’s rules if there is an inter-party transition.

    Read more

  • Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act

    We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

    Read more

  • Weakening Our Defenses Cover

    Weakening Our Defenses

    How the Trump Administration’s Deregulatory Push Has Exacerbated the Covid-19 Pandemic

    The failure of the federal government to adequately safeguard the health, environment, and economy of the United States with efficient regulatory protections is not a new phenomenon. For over three years now, the Trump administration has systematically delayed, undermined, and erased key regulations that protect our health, our environment, our workplaces, our living conditions, and our economy. The steady erosion of regulatory safeguards has severely compromised our baseline defenses against Covid-19.

    Read more

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

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

    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

  • What We Lose When They "Save" Cover

    What We Lose When They “Save”

    The Administration’s Misleading Claims About Deregulatory Cost Savings

    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

  • Understanding EPA's Enforcement and Compliance Policy During the COVID-19 Pandemic Cover

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

    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

  • Joint Comments to CFTC on Climate-Related Market Risk

    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.

    Read more

  • Comments to SEC on Regulation S-K and Climate Risk

    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

  • Beneath the Surface Cover

    Beneath the Surface

    The Concealed Costs of the Clean Water Rule Rollback

    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