Recent Projects

In February, the Consumer Financial Protection Bureau proposed a rule that would regulate overdraft lending by very large financial institutions. Overdraft fees amount to billions of dollars a year, and those costs are disproportionately borne by low-income households. The Proposed Rule would narrow regulatory exemptions that previously enabled banks extending overdraft credit to avoid complying with the regulatory requirements otherwise imposed on credit products. The Proposed Rule reflects a well-reasoned approach to correct market failures in the overdraft credit market, mitigating harms to consumers. We submitted comments suggesting how CFPB should improve its analysis. 

In January 2024, the Environmental Protection Agency (EPA) proposed a regulation under the Clean Water Act that would impose new effluent limitations guidelines and standards for the meat and poultry products point source category. As EPA documents, the proposed standards would help improve health and water quality near these slaughterhouse facilities. It would also carry benefits stemming from better-protected habitats for a variety of wild animals. In our comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis reasonably explain many of these benefits, EPA should take further steps to ensure the complete presentation of regulatory benefits and costs, along with their distribution, and to present its decisionmaking factors transparently.

In January, the White House announced a pause on LNG export approvals for the Department of Energy to update its underlying analyses for authorizations, which underpin its public interest determinations. In particular, the announcement notes that DOE’s economic and environmental analyses are outdated and calls for them to be updated. This letter offers recommendations for updating DOE’s analyses.

In February 2024, EPA finalized amendments to its Risk Management Program (RMP), under Section 112(r) of the Clean Air Act, to better protect vulnerable communities from chemical disasters that release toxic air pollution. In line with Policy Integrity’s recommendations, the final rule has been strengthened relative to the proposal and includes considerably more attention to the issues of underreporting, unquantified benefits, and the risks of catastrophic incidents. EPA has further improved the final rule to include consideration of climate change-related hazards in line with Policy Integrity’s recommendation to cover climate change-exacerbated hazards in addition to climate change-caused hazards. This will be increasingly important as the risks and magnitude of future chemical incident damages will likely only grow as climate change exacerbates severe weather that can spur power outages and chemical disasters.

In January, the Department of Energy proposed to strengthen its energy efficiency standards for fans and blowers, which would save consumers in energy costs and reduce pollution that harms public health and exacerbates climate change. Our comment offered several suggestions to improve the rule and accompanying analysis.