Flawed Foundations

The report argues that federal agencies are bypassing legal responsibilities for reasoned decisionmaking to advance a deregulatory agenda. It details ten specific analytical requirements for proper regulatory repeals, including the necessity of considering both costs and benefits, accounting for indirect and non-monetized effects, and avoiding the use of outdated data or discredited models.

• Federal agencies are increasingly failing to meet legal responsibilities for reasoned decisionmaking and procedural requirements by issuing regulations without sufficient analysis, justification, or public comment to accelerate a deregulatory agenda.
• Proper regulatory analysis for repeals requires agencies to evaluate both costs and benefits—including forgone benefits of the original rule—and to account for indirect, non-monetized, or unquantified effects, even in the face of uncertainty.
• Agencies must maintain analytical integrity by using current data and models, avoiding unexplained inconsistencies, including the original rule in baseline analyses, and demonstrating their work in both proposed and final rules.

APA

Welty, D. A. B. P. K. (2025). Flawed Foundations. Institute for Policy Integrity. https://policyintegrity.org/publications/detail/flawed-foundations

Chicago

Welty, Dena Adler, Bridget Pals, Kate. Flawed Foundations. Institute for Policy Integrity, 2025. https://policyintegrity.org/publications/detail/flawed-foundations.

Wikipedia

{{cite report |last1=Welty |first1=Dena Adler, Bridget Pals, Kate |title=Flawed Foundations |publisher=Institute for Policy Integrity |date=18 December 2025 |url=https://policyintegrity.org/publications/detail/flawed-foundations |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{welty2025flawed, author = {Welty, Dena Adler, Bridget Pals, Kate}, title = {{Flawed Foundations}}, institution = {Institute for Policy Integrity}, year = {2025}, month = dec, url = {https://policyintegrity.org/publications/detail/flawed-foundations}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }