Public Comments

The GW Regulatory Studies Center scholars independently pursue high quality research to illuminate regulatory theory, policy, and practice; the Center does not take institutional positions on issues. To maintain its independence and the quality and integrity of its products, the GW Regulatory Studies Center does not accept funding that stipulates predetermined results or that limits dissemination of its scholarly activity or research. While the Center files public comments on specific regulations, it does so from the perspective of the public interest, and will not accept direct funding for individual comments.

Sequoyah nuclear power plant

Public Comment: NRC's Financial Qualifications for Reactor Licensing

July 30, 2015

By Gerald W. Brock, Co-Director
The Nuclear Regulatory Commission published a draft regulatory basis for a proposed rulemaking that would amend the financial qualifications standard for new reactor licensing from the current "reasonable assurance" to the proposed "appears to be financially qualified." However, the proposed standard is unnecessary because there is a market test of financial qualifications that is more accurate than regulatory review. While the proposed new financial qualification standard is better than the current financial qualification standard, simply abolishing the financial qualifications requirement for licensing would be an improvement over the proposed new standard.

EPA flag

Public Comment: EPA's Proposed Renewable Fuel Standards for 2014, 2015, and 2016

July 24, 2015

By Sofie E. Miller, Senior Policy Analyst
The Renewable Fuel Standard program is mandated by Congress to increase the production and use of renewable fuels, such as corn ethanol, in gasoline and diesel. However, the availability of new scientific, technical, and economic information shows that the RFS program does not work as it was intended to, and is likely causing significant environmental harm through increased greenhouse gas emissions and damage to waterbodies and ecosystems. In this proposed rule, EPA appropriately uses its waiver authority to set renewable fuel standards below those prescribed by statute. Given the environmental damage and the large economic impact of the standards, EPA should update its benefits analysis and consider using its waiver authority to further reduce the standards. Responsibility rests with Congress to reevaluate the effects of the statutes it authorized, which are now causing economic and environmental harm.