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.

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Public Interest Comment: EPA's Proposed “Affordable Clean Energy” (ACE) Rule

October 31, 2018

By Brian F. Mannix
The proposed “Affordable Clean Energy” (ACE) rule rests on a stronger legal foundation and a sounder economic analysis than the stayed Clean Power Plan (CPP). In particular, the choice of a “best system of emissions reduction” (BSER) based on heat-rate efficiency, a measure of CO2 intensity, is much more consistent with the Clean Air Act than was the CPP’s statewide budget approach, as is the decision to use domestic benefits to justify the rule. The proposed reforms to section 111(d) procedures and to the New Source Review criteria are both important and stand on their own right.

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Public Interest Comment: SAFE Vehicles Rule

October 25, 2018

By Julian Morris
Executive Director of the International Center for Law & Economics and a Senior Fellow at the Reason Foundation - provides insights on the effects of the Safer Affordable Fuel-Efficient Rule and the preliminary regulatory impact analysis thoroughly completed by the EPA and NHTSA. This public interest comment discusses the likely effects of the rule on vehicle fuel economy, fuel consumption, the cost of new and used vehicles, safety, and the environment. The author's findings suggest that the new rule will save billions of dollars in economic costs, potentially decrease traffic fatalities, and is unlikely to have a significant negative effect on the environment.

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Public Interest Comment: IRS's Proposed Rule on SALT Credits

October 12, 2018

By Jerry Ellig
The Internal Revenue Service (IRS) has proposed a regulation that would prevent all individual taxpayers from claiming a federal charitable deduction if the taxpayer received a state tax credit equivalent to more than 15 percent of the donation. This comment explains why the proposed regulation is much broader than necessary to address the real problem the IRS seeks to solve: state tax credit programs designed explicitly to aid taxpayers in avoiding the cap on deductibility of state and local taxes.