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CEI Comments on California’s Advanced Clean Cars II Waiver Request
Thank you for the opportunity to comment[1] on the California Air Resources Board’s (CARB’s) request for a waiver under Section 209(b) of the…
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CEI comments on NHTSA’s proposed Corporate Average Fuel Economy Standards
Thank you for the opportunity to comment on the National Highway Traffic Safety Administration’s (NHTSA’s) proposed corporate average fuel economy (CAFE) standards for passenger cars…
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CEI Comments on Proposed NEPA Implementing Regulations
Thank you for the opportunity to comment on Phase 2 of the Council on Environmental Quality’s (CEQ’s) proposed revision of its National Environmental Policy Act…
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CEI Comments on the EPA’s CO2 Powerplant Emission Performance Standards
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA’s) proposed greenhouse gas (GHG) emission standards and guidelines for new and existing…
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Marlo Lewis CEI Comments on EPA’s Greenhouse Gas Motor Vehicle Standards
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA’s) proposed greenhouse gas (GHG) emission standards for model years (MYs) 2027-2032 passenger…
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CEI Comments on OMB’s Revision of Circular A-4 Regulatory Accounting Guidelines
Thank you for the opportunity to submit comments on the Office of Management and Budget’s (OMB’s) Draft for Public Review of its proposed update of…
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CEI Comments on EPA’s Reconsideration of National Ambient Air Quality Standards (NAAQS) for Fine Particulate Matter (PM2.5)
Dear Dr. Perlmutt,We appreciate the opportunity to submit this comment on the Environmental Protection Agency’s (EPA) proposed rule entitled “Reconsideration of the National Ambient Air…
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Comments to the Council on Environmental Quality, Proposed Guidance on Consideration of Greenhouse Gases and Climate Change
Thank you for the opportunity to comment on the Council on Environmental Quality’s (CEQ) National Environmental Policy Act (NEPA) guidance on consideration greenhouse gas (GHG)…
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CEI Comments on EPA Methane Emission Performance Standards for the Oil and Gas Sector
February 13, 2023 Docket No. EPA–HQ–OAR–2021–0317-1460 Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas…
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Comments to DOE: Energy Conservation Standards Program
Comments Submitted by the Competitive Enterprise Institute, Consumers’ Research, Center for the American Experiment, JunkScience.com, Project 21, Caesar Rodney Institute, Rio Grande Foundation, Committee for…
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CEI Comments on Proposed SEC Rule: Enhancement and Standardization of Climate-Related Disclosures for Investors
Comments submitted by the Competitive Enterprise Institute et al. June 17, 2022 In the matter of the proposed rule “The Enhancement and Standardization of Climate-Related…
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CEI Comments to Federal Energy Regulatory Commission: Docket No. PL21-3-000
Federal Energy Regulatory Commission, Order on Draft Policy Statements, March 24, 2022. Docket No. PL21-3-000 Comments submitted by Marlo Lewis, Patrick Michaels, and Kevin Dayaratna.
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CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gas Mitigation under Sections 3 and 7 of the Natural Gas Act.
Docket No. PL21-3-000 Comments submitted by Patrick Michaels, Kevin Dayaratna, and Marlo Lewis.[1] Thank you for the opportunity to respond to the questions posed…
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CEI Comments on Biden Administration Proposal to Revise National Environmental Policy Act (NEPA) Implementing Regulations.
Comments of the Competitive Enterprise Institute (CEI) Thank you for the opportunity to comment on the Council on Environmental Quality’s (CEQ) proposal to modify certain…
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CEI Comments on the National Highway Traffic Safety Administration’s Proposed Fuel Economy Standards for Model Year 2024-2026 Passenger Cars and Light Trucks
Comments submitted by Patrick J. Michaels, Kevin Dayaratna, and Marlo Lewis.[1] Thank you for the opportunity to comment on the National Highway Traffic Safety…
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CEI Comments on Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards Proposed Rule
Environmental Protection Agency, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, Proposed Rule, 83 FR 43726 (August 10, 2021) Docket ID:…
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CEI Comments on SAFE 1 Rule – Docket ID No. EPA-HQ-OAR-2021-0257
Thank you for the opportunity to submit comments on the Environmental Protection Agency’s (EPA) reconsideration[1] of Part One of the Trump administration’s Safer Affordable…
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Comments On OMB Technical Support Document on Social Cost of Carbon
View Full Document as PDF Office of Management and Budget Notice of Availability and Request for Comment on “Technical Support Document: Social Cost…
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Marlo Lewis Comment to the SEC on Climate Risk Disclosure
View Full Document as PDF Comments of the Competitive Enterprise Institute, Caesar Rodney Institute, Committee for a Constructive Tomorrow (CFACT), Energy and Environment…
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Docket No. NHTSA-2021-0030 Marlo Lewis CEI free market groups 6-11-2021
View Full Document as PDF Comments of the Competitive Enterprise Institute, American Energy Alliance, Americans for Tax Reform, Freedom Works, Caesar Rodney Institute,…
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CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gases in Natural Gas Facility Permitting
View Full Document as PDF Thank you for the opportunity to comment on the Federal Energy Regulatory Commission’s Notice of Inquiry (NOI) on…
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CEI Comments on FERC Proposed Wholesale Carbon Pricing Policy
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CEI Comments on BCA Rule
Thank you for the opportunity to comment on the Environmental Protection Agency’s proposed benefit-cost analysis (BCA) rule.[1] Codifying best practices for BCA, as…
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CEI Comments on EPA’s Proposed Review of the National Ambient Air Quality Standards for Particulate Matter
Thank you for the opportunity to comment on EPA’s review of the national ambient air quality standards (NAAQS) for particulate matter (PM). EPA proposes to…
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CEI Comments on NERA Petition Concerning Unlawful Wholesale Sales
The Competitive Enterprise Institute (CEI) is a public policy and analysis organization committed to advancing the principles of free markets and limited government. We are…
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CEI Comments on EPA’s Supplemental Notice of Proposed Rulemaking : EPA Transparency Rule
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) Supplemental notice of proposed rulemaking (SNPR)[1] on its proposal…
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CEI Comments on Proposed Updated NEPA Procedural Regulations
Thank you for the opportunity to comment on the Council on Environmental Quality’s (CEQ) proposed update of National Environmental Policy Act (NEPA) procedural regulations.
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Supplemental Testimony: “Trump’s Wrong Turn on Clean Cars”
Thank you, again, Chairman Rouda and Ranking Member Comer, for inviting me to testify at the Subcommittee’s October 29, 2019 hearing titled “Trump’s Wrong Turn…
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Trump’s Wrong Turn on Clean Cars
Chairman Rouda, Ranking Member Comer, and Members of the House Government Oversight Subcommittee on Environment, thank you for inviting me to speak today at this…
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CEI Comments on the Mercury Rule
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) reconsideration of its 2016 Supplemental Finding regarding the agency’s justification for its…
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CEI Comments on EPA’s Review of its Carbon Dioxide (CO2) Performance Standards for New Coal-fired Power Plants
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) review of its carbon dioxide (CO2) performance standards for new coal-fired power…
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CEI Comments on EPA ACE Rule
Among the CPP’s multiple legal flaws, one stands out as most bizarre. The CPP purports to establish carbon dioxide (CO2) emission performance guidelines for existing…
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CEI Comments on Joint DOT/EPA Proposed SAFE Vehicles Rule
The Competitive Enterprise Institute hereby submits these comments on the joint DOT/ EPA proposed SAFE Vehicles Rule. We support this proposal, which would (1) reduce…
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CEI Comments In Support of EPA Transparency Rule
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CEI Comments on The Federal Energy Regulatory Commission’s Notice of Inquiry Regarding the Certification of New Natural Gas Facilities
This comment letter addresses questions C3, C4, C6, and C7, which concern whether, and if so how, FERC should take into account greenhouse gas (GHG)…
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CEI Comments on EPA’s Proposed Rule to Repeal the Clean Power Plan
View Full Document as PDF Docket ID No. EPA–HQ–OAR–2017–0355 Thank you for the opportunity to comment on the Environmental…
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Comments of Marlo Lewis on a Potential Clean Power Plan Replacement Rule
View Full Document as PDF Thank you for the opportunity to submit comments on the Environmental Protection Agency’s (EPA) advance notice of…
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Comments to the EPA on Renewable Fuel and Diesel Standards for 2019
View Full Document as PDF Thank you for the opportunity to submit comments[1] on the Environmental Protection Agency’s (EPA)…
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CEI Comments on EPA & NHTSA Reconsideration of Fuel Economy Standards
View Full Document as PDF The Obama EPA’s final Mid-Term Evaluation (MTE) is arbitrary, capricious, and an abuse of discretion. Reconsideration is…
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Options for Addressing President Trump’s Paris Climate Pact Promise
View Full Document as PDF This memo analyzes two principal options for dealing with the Paris Climate Agreement, U.S. participation in which…
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Comments to the EPA on Clean Energy Incentive Program
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Comments on the Clean Energy Incentive Program Design Details
View Document as PDF Twenty-eight States joined by numerous industry and non-profit groups are challenging the legality of EPA’s carbon dioxide (CO2)…
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CEI Issues Comment to EPA on Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles
View Document as PDF Comments Submitted by Marlo Lewis (Senior Fellow, Competitive Enterprise Institute), Wayne Brough (Chief Economist and Vice President of…
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Regulatory comments on NEPA Review of Project-Related Greenhouse Gas Emissions
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Free Market Organizations’ Letter to Office of Management and Budget on Social Cost of Carbon
CEI and Freedom Action, along with members of the Cooler Heads Coalition, on February 26, 2014 submitted a public comment to the Office of Management…
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Comment Letter on LLF Petition for Reconsideration, Docket No. EERE-BT-PET-0043, September 16, 2013
Full Document Available in PDF On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues, I am pleased…
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CEI Public Comment concerning Department of Energy’s final rule establishing Energy Conservation Standards for Standby Mode and Off Modefor Microwave Ovens
On behalf of the Competitive Enterprise Institute, Marlo Lewis submitted this comment in support of the Landmark Legal Foundation’s petition for reconsideration of the Department…
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Comment Letter on Third Upton Waxman White Paper
This comment letter addresses Question 1(a) of your Renewable Fuel Standard (RFS) White Paper on Greenhouse Gas Emissions and Other Environmental Impacts, which asks: “Is…
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CEI Comment Letter on Second Upton-Waxman White Paper
Full Document Available in PDF Dear Sirs, Again, thank you for organizing this important and timely review of the Renewable Fuel Standard…
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Comment Letter on Upton-Waxman White Paper
Full Document Available in PDF Dear Sirs, Thank you for organizing this important and timely review of the Renewable Fuel Standard (RFS).
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Marlo Lewis – 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards
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Comment Letter in Support of Renewable Fuel Standard Waiver Petitions
Full Document Available in PDF On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues,…
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Comment Letter on EPA’s Carbon Pollution Standard
CEI's Marlo Lewis' comments submitted to the EPA on the agency's proposed "Carbon Pollution Standard."…
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Comment Letter on Greenhouse Gas Emissions and Fuel Economy Standards
Full Document Available in PDF Re: 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards and Corporate Average Fuel Economy…
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Marlo Lewis Testimony Before House Oversight & Government Reform Committee on CAFE Standards, EPA Power Grab
Full Document Available in PDF In the aftermath of a deal between the Obama administration…
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Statement of Marlo Lewis On S. 388 Before the Committee on Energy and Natural Resources
Thank you, Mr. Chairman and Members of the Committee, for the opportunity to submit testimony on S. 388, the Climate Change Technology Deployment and Infrastructure…
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Request for comment on the Voluntary Reporting of Greenhouse Gases Program,
On February 14, 2002, President Bush directed the Secretary of Energy, in consultation with other department and agency heads, to propose improvements in the 1605(b)…
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Specific Comments on Menendez Climate Change Amendment Findings
Finding (1) Evidence continues to build that increases in atmospheric concentrations of man-made greenhouse gases are contributing to global climate change. This statement is pure…
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Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles
Full Document Available in PDF On behalf…
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Response to the Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule
Full Document Available in PDF In…
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Marlo Lewis Comment on EPA’s Proposed Greenhouse Gas Motor Vehicle Standards
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Comments on “Charting the Course for Ocean Science” submitted to the Office of Science and Technology Policy
Re: Update of Charting the Course for Ocean Science in the United States for the Next Decade: An Ocean Research Priorities Plan and Implementation Strategy…
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Comment on Endangerment Proposal
CEI advises EPA not to adopt Endangerment Proposal…
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CEI Comment on EPA’s Reconsideration of California’s Request for a Waiver to Establish Emission Standards for new Motor Vehicles
Full Document Available in PDF EPA should stick…
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Free market groups submit a joint comment on EPA’s ANPR on Greenhouse Gas Regulation under the Clean Air Act
CEI’s Marlo Lewis and representatives of 28 other free market and conservative organizations filed this joint comment urging EPA not to make an endangerment finding with…
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Comments on EPA’s ANPR on Greenhouse Gas Regulation Under the Clean Air Act
In this comment on the Environmental Protection Agency’s Advanced Notice of Proposed Rulemaking (ANPR) on greenhouse gas (GHG) regulation under the Clean Air Act (CAA),…
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Testimony before the Senate Environment and Public Works Committee on Greenhouse Gas Regulation under the Clean Air Act
My name is Marlo Lewis. I am a senior fellow at the Competitive Enterprise Institute, a free-market, non-profit public policy group. I have been active…
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Testimony before the House Permanent Select Committee on Intelligence
Introduction Chairman Markey, Chairman Eshoo, Ranking Member Sensenbrenner, Ranking Member Issa, and Committee Members: Thank you for the opportunity to share my views on global…
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Brief of Amici Curiae In the Matter of Deseret Power Electric Cooperative
Before the Environmental Appeals Board United States Environmental Protection Agency Washington, DC In the matter of:…
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Oral Testimony before the United States Senate Committee on Environment and Public Works
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Testimony before the United States Senate Committee on Environment and Public Works on global warming issues in the power plant
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Testimony on Global Warming before the Republican Study Committee of Colorado
Full Document Available in PDF…
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Comments submitted to the Fish and Wildlife Service regarding its proposal to list the polar bear as a threatened species under
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Response to Questions Posed by Senators Domenici and Bingaman in “Design Elements of a Mandatory Market-Based Greenhouse Ga
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Letter to House Regulatory Affairs Subcommittee Chairwoman Candice Miller
Dear Chairwoman Miller: Thank you again for giving me the opportunity to present testimony on congressional regulatory reform initiatives. After further reflection, I…
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Written Statement of Marlo Lewis: U.S. House of Representatives Committee on Government Reform Subcommittee on Regulatory Affair
Full…
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Statement of Marlo Lewis Before the Committee on Energy and Natural Resources
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AB 1493 Draft Proposal Comments
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Letter to DOE on the Risks of Kyoto Risk Insurance
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Marlo Lewis Debates Smog Standards on CNN
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CEI Comments on EPA’s Draft Strategic Plan
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CEI Comments On The Department Of Energy’s Voluntary Greenhouse Gas Reporting Proposal
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An Open Letter To Selected Senators On Their Support For The Renewable Portfolio Standard
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Precautionary Foolishness
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Testimony on Why Kyoto Is Not an Insurance Policy, House Small Business Committee
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Testimony before the Committee on Small Business, Hearing on the Kyoto Protocol
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