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Publications

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

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

    By Bethany Davis Noll, Peter Howard, Jason Schwartz, and Avi Zevin
    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. 

  • What We Lose When They “Save”
    Policy Brief

    What We Lose When They “Save”

    The Administration’s Misleading Claims About Deregulatory Cost Savings

    By Bethany Davis Noll and Iliana Paul
    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.

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

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

    By Helia Bidad, Natasha Brunstein, Jayni Hein, and Alisa White
    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. 

  • Beneath the Surface
    Report

    Beneath the Surface

    The Concealed Costs of the Clean Water Rule Rollback

    By Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader, Ph.D.
    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.

  • Assessing the Rationale for the EPA’s Proposed Regulatory Science Rule
    Policy Brief

    Assessing the Rationale for the EPA’s Proposed Regulatory Science Rule

    By Madison E. Condon, Michael A. Livermore, Jeffrey G. Shrader
    December 19, 2019

    The U.S. Environmental Protection Agency (EPA) is considering a new policy that would prohibit the agency from issuing regulations that rely on studies whose underlying data are not publicly available. While the EPA claims it is pursuing this policy in the interest of transparency, we argue that such a prohibition would greatly hinder, rather than help, the rulemaking process and would likely result in undesirable regulatory outcomes that fail to maximize economic welfare.