Beneath the Surface

The report asserts that the Environmental Protection Agency and Army Corps of Engineers failed to meaningfully assess the environmental harms resulting from two regulatory rollbacks of the Clean Water Act. It argues that the agencies' claims that compliance-cost savings outweigh environmental harms are based on severe methodological flaws, and that correcting these analyses would likely reveal the rollbacks are net costly to society, potentially depriving the public of billions of dollars in annual benefits.

• The Environmental Protection Agency and Army Corps of Engineers claim that the compliance-cost savings from two Clean Water Act regulatory rollbacks exceed the environmental harms, but the report asserts these analyses contain severe methodological flaws.
• Correcting the agencies' analyses would likely demonstrate that the rollbacks are net costly to society, with the public potentially losing billions of dollars in annual benefits.
• The failure of the agencies to meaningfully assess the substantial harms caused by the rollbacks is a violation of both legal obligations and regulatory precedent.

APA

Ph.D., B. D. N. P. H. P. M. S. J. S. A. J. S. (2020). Beneath the Surface. Institute for Policy Integrity. https://policyintegrity.org/publications/detail/beneath-the-surface

Chicago

Ph.D., Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader,. Beneath the Surface. Institute for Policy Integrity, 2020. https://policyintegrity.org/publications/detail/beneath-the-surface.

Wikipedia

{{cite report |last1=Ph.D. |first1=Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader, |title=Beneath the Surface |publisher=Institute for Policy Integrity |date=27 April 2020 |url=https://policyintegrity.org/publications/detail/beneath-the-surface |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{phd2020beneath, author = {Ph.D., Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader,}, title = {{Beneath the Surface}}, institution = {Institute for Policy Integrity}, year = {2020}, month = apr, url = {https://policyintegrity.org/publications/detail/beneath-the-surface}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }