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The Institute for Policy Integrity asserts that the Bureau of Ocean Energy Management (BOEM) is incorrectly relying on a 2009 D.C. Circuit case, Center for Biological Diversity v. Department of the Interior (CBD), to claim it cannot consider downstream greenhouse gas emissions in its 2023–2028 leasing program. The brief argues that while CBD established that the Outer Continental Shelf Lands Act (OCSLA) does not require such consideration, it does not prohibit it, and that considering these effects aligns with OCSLA's text, legislative history, and regulatory history.

The author contends that the 'norm-breaking' regulatory tools used by the Trump Administration to undo previous policies—such as Congressional Review Act disapprovals and suspensions of final regulations—have been adopted and in some cases used more aggressively by the Biden Administration. This shift suggests that the ability of a president to implement durable regulatory policy has decreased, with the window of protection from a successor's undoing shrinking from approximately three-and-a-half years to about two years. This trend is critical because presidents currently rely on regulations as their primary means of implementing domestic policy due to congressional gridlock.

The report advocates for the EPA to improve its benefit analysis for power plant wastewater regulations, reviewing economic frameworks and literature from the Obama-era rule and the 2020 Steam Electric Reconsideration Rule to identify neglected impacts.

The article examines the use of the social cost of carbon (SCC) and marginal abatement cost (MAC) in climate policy, specifically addressing proposals to use MAC as an alternative to SCC in the United States. It argues that while MAC-based approaches are used in some jurisdictions like the U.K., MAC is not a substitute for the SCC. The text frames this discussion within the broader debate of prices versus quantities in policy formulation and the distinction between cost-benefit analysis and cost-effectiveness analysis.

The report advocates for FTC regulation to end "immortal accounts," where companies make account deletion difficult to maintain data profits and subscription fees, arguing that clear cancellation guidelines would protect consumers and competition.

The document argues for the necessity of specific regulatory updates to the National Environmental Policy Act (NEPA) framework to ensure federal agencies adequately assess how proposed actions contribute to climate change and how climate change impacts those actions.

The Institute for Policy Integrity argues that FERC's current process for certifying interstate pipelines is flawed and fails the public interest. The report recommends that FERC move beyond relying on shipper contracts to instead incorporate regional need analysis, coordination with electric transmission, climate-related transition risks and stranded asset costs, and monetized climate damage estimates.

The Institute for Policy Integrity supports the EPA's November 2021 proposed standards for methane emissions in the oil and natural gas sector but urges the agency to expand the scope of regulated sources to include abandoned wells and flares. The organization further recommends enhancing the EPA's regulatory analysis through distributional analysis, extended time frames, and the quantification of co-benefits. Additionally, it advocates for a more robust justification of discount rates and the inclusion of global damages within the social cost of greenhouse gases (SC-GHG), asserting that the SC-GHG represents a lower bound of climate impacts.

The report highlights a regulatory gap where residential fossil-fuel appliances emit significantly more nitrogen oxides than gas-fired power plants despite the latter being regulated. It asserts that the EPA can use Section 111(b) of the Clean Air Act to establish nationwide performance standards for these appliances, citing electric-heat-pump technology as a demonstrated means of emission reduction and suggesting a system of emissions averaging and trading for manufacturers.

The Institute for Policy Integrity is petitioning the Federal Trade Commission to ban 'drip pricing', a practice where sellers advertise low prices and reveal mandatory fees late in the transaction process. The petition argues that this practice, common in event tickets and vacation rentals, exploits cognitive biases and hinders comparison shopping. The proposal suggests requiring full price disclosure upfront and asserts that the Commission has the authority to ban the practice as a deceptive trade practice, unfair trade practice, or unfair method of competition.

The article examines the requirements for the Biden administration to successfully integrate environmental justice into regulatory decision-making, contrasting this with previous efforts under the Clinton and Obama administrations. It posits that a lack of standardized methodologies for distributional analysis contributed to past failures and asserts that agencies must rigorously analyze the distributional consequences of different regulatory alternatives to determine when such benefits can outweigh higher net benefits of other options.

A global survey of 738 economists who publish in top-tier academic journals reveals a strong consensus that the economic costs of climate inaction exceed the costs of action. The findings indicate that climate change will likely cause major GDP losses, reduce long-term economic growth, and increase economic inequality both within and between nations. Furthermore, the surveyed experts expressed optimism regarding the affordability of zero-emissions technologies and agreed that aggressive targets to achieve net-zero emissions by midcentury are economically justified.

The Institute for Policy Integrity argues that the EPA's benefit-cost analysis for the 2020 Steam Electric Reconsideration Rule is flawed because it failed to provide quantitative estimates for many harms resulting from steam electric power plant wastewater streams. The report suggests that these unquantified forgone benefits likely undervalued the rule's harms to a degree that would undermine the decision to finalize the rule.

The research finds that the "Clean Peak Standard" is largely ineffective at reducing emissions because it reinforces existing storage operator incentives and fails to account for high-frequency changes in marginal operating emissions rates. The authors suggest that alternative policies, such as a carbon tax, would be more effective.

The document argues that critical long-distance transmission can be developed using existing federal legal authorities, though state siting requirements remain a potential obstacle.

The document asserts that federal leadership has compromised the integrity of the regulatory review process coordinated by the Office of Information and Regulatory Affairs (OIRA), leading to deregulatory actions that harm public health, safety, the environment, and financial stability. It proposes a path forward that involves removing these distortions, reaffirming established best practices, and implementing corrections to ensure regulations maximize net social welfare.

The report advocates for the Federal Energy Regulatory Commission (FERC) to actively align its regulatory practices with climate policies, accelerate the development of transmission infrastructure, and reform energy market rules to support a clean energy transition.

The report outlines regulatory strategies for new U.S. administrations, including White House officials and agency transition teams. It specifically examines the tools used by the Trump administration to roll back Obama-era regulations and suggests these tactics will likely be employed by future administrations.

The text asserts that because electricity generation is a primary source of greenhouse gas emissions, the Federal Energy Regulatory Commission (FERC) should use its authority as an economic regulator to address the CO2 externality. It argues that carbon pricing is not merely an environmental issue but a core market concern necessary for a functional and efficient interstate transmission and wholesale electricity market.

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.