Letters
Coalition Letter on DCA Perimeter Rule
Dear Chairwoman Cantwell and Ranking Member Cruz: We write to inform you that we support expanding the number of flights permitted in and out of…
Comment
Comment on FTC Unfair or Deceptive Fees
Dear Commissioners, On behalf of the Competitive Enterprise Institute, I respectfully submit the following comments in response to the Federal Trade Commission’s proposed rulemaking concerning…
Comment
CEI comments on SEC’s proposed adoption of NYSE listing standards for “Natural Asset Companies”
TO: Securities and Exchange Commission FROM: Stone Allen Washington; Research Fellow at the Competitive Enterprise Institute RE: No. SR-NYSE-2023-09 To the Honorable Gary Gensler,…
Letters
Coalition Letter on American Consumer Institute – Risk Transfer
Chief Counsel’s Office Attention: Comment Processing, Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E–218 Washington, DC 20219 Ann E. Misback…
Comment
CEI Comments on SEC Proposed Rule Change to Amend the NYSE Listed Company Manual
January 17, 2024 Docket ID: Release Nos. 34-99225, File No. SR-NYSE-2023-09 Self-Regulatory Organizations; New York Stock Exchange LLC; Order Instituting Proceedings to Determine Whether…
Letters
Carbon Tariff Coalition Letter
Dear Members of Congress:As the Senate Environment and Public Works Committee is reportedly going to mark-up the PROVE IT Act (S. 1863) this week, the…
Letters
NTU Coalition Letter on Important Needed Tax Reforms
Dear Majority Leader Schumer, Speaker Johnson, Minority Leader McConnell and Minority Leader Jeffries, On behalf of the undersigned organizations who represent the interests of taxpayers,…
Comment
FCC: Safeguarding and Securing the Open Internet, Notice of Proposed Rulemaking, 88 Fed. Reg. 76048
The Competitive Enterprise Institute (“CEI”) respectfully submits these comments in response to the Notice of Proposed Rulemaking (“NPRM”) adopted on October 19, 2023, in the…
Comment
Comments to EPA SNPR for Power Plant Rule
Dear Mr. Fellner: I appreciate this opportunity to provide comments on the supplemental notice of proposed rulemaking for the proposed rule “New Source Performance Standards…
Comment
CEI Comments on Safeguarding and Securing the Open Internet
The Competitive Enterprise Institute (“CEI”) respectfully submits these comments in response to the Notice of Proposed Rulemaking (“NPRM”) adopted on October 19, 2023, in the…
Legal Brief
Reason Et Al. Netchoice Amicus Brief
INTRODUCTION AND INTEREST OF AMICI CURIAE Social media companies, large or small, offer privately owned and mediated spaces for people to associate and exchange ideas…
Comment
OMB Proposed Memorandum on Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence.
December 5, 2023 Docket ID: OMB–2023–0020 Proposed Memorandum for the Heads of Executive Departments and Agencies: Advancing Governance, Innovation, and Risk Management for Agency Use…
Comment
Comments on Proposed Memorandum for the Heads of Executive Departments and Agencies: Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence
To Shalanda D. Young, Director of the Office of Management and Budget: The Competitive Enterprise Institute (CEI) is a non-profit public interest organization committed to…
Comment
Comments RE: Docket No. FDA–2023–N–2177 for “Medical Devices; Laboratory Developed Tests
I am an attorney with the Competitive Enterprise Institute. The Competitive Enterprise Institute is a non-profit research and advocacy organization that focuses on regulatory policy.
Comment
Comment to FAST-41 Steering Council on reducing scope of mining industry
John G. CossaGeneral CounselFederal Permitting Improvement Steering Council1800 M St. NW, Suite 6006Washington, DC 20036 Submitted via Regulations.gov November 22, 2023 RE: Permitting Council Docket…
Letters
CEI Joins Letter on Joint Employer CRA
Dear Member of Congress, Small business needs protection. As you are aware, the National Labor Relations Board (NLRB) issued their final rule “Standard for Determining…
Testimony
Testimony before the Senate HELP Committee, November 14, 2023
Chairman Sanders, Dr. Cassidy, ladies and gentlemen of the committee, thank you for the opportunity to speak today. My name is Sean Higgins and I…
Comment
Comment on notice of proposed rulemaking: Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees
Dear Ms. DeBisschop: I am an attorney with the Competitive Enterprise Institute. I was a senior policy advisor in Department of Labor’s Wage and Hour…
Testimony
Ben Lieberman Testimony: Hearing on “Burdensome Regulations: Examining the Effects ofDepartment of Energy Regulations on America’s Job Creators.”
Chair Williams, ranking member Velazquez, and members of this committee, thank you for the opportunity to testify today. My name is Ben Lieberman and I…
Comment
Comment on WHD NPRM on executive, administrative, and professional exemption
Amy DeBisschop Division of Regulations, Legislation, and Interpretation Wage and Hour Division, U.S. Department of Labor 200 Constitution Ave. NW, Room S–3502, Washington, D.C. 20210…
Letters
Coalition Letter to End IRA Prescription Drug Price Controls
October 31, 2023 Dear Members of Congress, When the Inflation Reduction Act was passed and signed into law a year ago, the legislation granted the…
Testimony
Regulatory streamlining in Pennsylvania would boost opportunities for state residents
Introduction Good morning, members of the Senate Majority Policy Committee. My name is James Broughel and I am a senior fellow at the Competitive Enterprise…
Legal Brief
Brief of Amicus Curiae : SEC v. Jarkesy
In Securities and Exchange Commission v. Jarkesy, CEI attorneys argued that the SEC’s practices could not be reconciled with a proper understanding of the Seventh…
Comment
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…
Comment
Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers
October 10, 2023 Docket ID: Release Nos. 34-97990, IA-6353, File No. S7-12-23 To the Honorable Gary Gensler, Chair of the Securities and Exchange Commission, and…
Comment
CEI Comments on National Environmental Policy Act Implementing Regulations Revisions Phase 2
To Brenda Mallory, Chair of the Council on Environmental Quality: The Competitive Enterprise Institute (CEI) is a non-profit public interest organization committed to advancing the…
Comment
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…
Comment
Comments on the Department of Energy’s Proposed Energy Conservation Standards for Residential Water Heaters
I. INTRODUCTION The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are…
Comment
Comments of the Competitive Enterprise Institute
September 26, 2023 RE: Premerger Notification; Reporting and Waiting Period Requirements Docket ID No.: FTC-2023-0040-0001 On behalf of the Competitive Enterprise Institute (CEI), we respectfully…
Comment
CEI’s James Broughel Comments on Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis
September 18, 2023 Docket ID: OMB–2022–0016 Request for Comments on Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis Comments Prepared…
Comment
CEI Comments on FTC-DOJ Merger Guidelines
September 15, 2023 RE: FTC-DOJ Merger Guidelines Matter No.: P859910 The authors of this submission first want to thank the Federal Trade Commission (FTC) and…
Testimony
CEI’s Marlo Lewis testifies before Natural Resources subcommittee on examining systemic government overreach at CEQ
Testimony of Marlo Lewis, Jr.Senior Fellow in Energy and Environmental Policy Competitive Enterprise Institute (CEI)on“Examining Systemic Government Overreach at CEQ” before Natural Resources…
Testimony
CEI’s Ben Lieberman testifies before Energy and Commerce Committee on DOE efficiency standards for home appliances
Committee on Energy and Commerce Subcommittee on Energy, Climate, and Grid Security U.S. House of Representatives 2123 Rayburn House Office Building…
Testimony
The Disproportionate Burden of Federal Regulation on Small Businesses
Submission to the U.S. Senate Committee on Small Business & Entrepreneurship Hearing on “One Size Does Not Fit All: Understanding the Importance of Rightsizing Regulations…
Letters
Dismantling the Inflation Reduction Act green Subsidies Coalition Letter
August 16, 2023Dear Members of Congress:On the first anniversary of enactment of the so-called Inflation Reduction Act (IRA), the undersigned organizations strongly urge you to…
Comment
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…
Legal Brief
Brief of Amicus Curiae : Loper Bright Enterprises v. Raimondo
Comment
Procedures for Previously Exempt State and Local Government Employee Complaints of Employment Discrimination under Section 304 of the Government Employee Rights Act of 1991, RIN 3046-AB09
Submitted via Regulations.gov RE: Procedures for Previously Exempt State and Local Government Employee Complaints of Employment Discrimination under Section 304 of the Government Employee Rights…
Comment
Comment on Energy Conservation Standards for Dishwashers
I. SUMMARY The proposed rule would tighten the energy and water efficiency standards for residential dishwashers, despite the fact that the standards currently in effect…
Letters
Letter of Support on the Small Business Regulatory Reduction Act and the POST IT Act
Letters
CEI Co-Leads Coalition Letter on Railroad Safety Act
Dear Members of Congress: The undersigned individuals write to express concerns with the Railway Safety Act (S. 576). Safety advancement in any mode of…
Letters
Letter of Support on H.R. 890 and H.R. 3230
Comment
Energy Conservation Program: Energy Conservation Standards for Dishwashers; Notice of proposed rulemaking and request for comment
Action Notice of proposed rulemaking and request for comment. Summary The Energy Policy and Conservation Act, as amended (“EPCA”), prescribes energy conservation standards for various…
Comment
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…
Comment
Comment Extension Request, OMB-2022-0014
Dear Administrator Revesz:The Competitive Enterprise Institute (CEI) respectfully requests that the Office of Information and Regulatory Affairs (OIRA) extend the comment period by at least…
Letters
CEI Joins Coalition Letter in Opposition of S. 1838 and H.R. 3881 Credit Card Competition Act (CCCA)
Dear Members of Congress: We, the undersigned organizations and individuals, oppose the inaccurately named Credit Card Competition Act of 2023 (S. 1838 and H.R.
Letters
CEI Joins Coalition Opposing the Protecting the Right to Organize (PRO) Act
Dear Chairman Sanders; Ranking Member Cassidy; and Members of the Senate Committee on Health, Education, Labor and Pensions – On behalf of the millions of…
Comment
CEI Comments on Proposed OMB Circular No. A-4
RE: Request for Comments on Proposed OMB Circular No. A-4, “Regulatory Analysis”, 88 FR 20915 (Apr. 7, 2023), Docket OMB-2022-0014 Dear Mr. Revesz, I am…
Comment
OMB’s Problematic Circular A-4 Rewrite
OUTLINE Discard the pro-regulatory bias of the federal government Restore regulatory streamlining prior to Circular A-4 rewrite Restore the $100 million threshold for regulation…
Comment
CEI Comments on Proposed Circular A-4, Regulatory Analysis
Dear Administrator Revesz: I appreciate this opportunity to provide comments on the proposed Circular A-4, “Regulatory Analysis.”1 The focus of my comments is on the…
Comment
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…
Letters
CEI Joins Coalition Letter Supporting Efforts to Stop Tobacco Prohibitions in Ag Approps Bill
Chairwoman Granger and Ranking Member DeLauro, The undersigned organizations representing millions of consumers and taxpayers support Sections 768 and 769 of the Fiscal Year 2024…
Comment
Comments to the Office of Management and Budget on the proposed draft update to Circular A-4: Regulatory Analysis
The Competitive Enterprise Institute (CEI) is a non-profit public interest organization committed to advancing the principles of free markets and limited government. CEI has a…
Legal Brief
Moore v. United States Reply Brief
No. 22-800 In The Supreme Court of the United States CHARLES G. MOORE and KATHLEEN F. MOORE, Petitioners, v. United States of America, Respondent. On…
Comment
CEI Comments on Docket ID No. EPA–HQ–OAR–2018–0794
Dear Ms. Benish: I appreciate this opportunity to submit comments on the proposed Mercury and Air Toxics Standards (MATS) for power plants. Attached please find…
Testimony
Testimony of Wayne Crews: Removing the Burdens of Government Overreach
I appreciate the opportunity to discuss issues surrounding Removing the Burdens of Government Overreach, and I thank Chairman Arrington, Ranking Member Boyle, and Members of…
Testimony
Testimony of Ben Lieberman : Examining the Biden Administration’s Regulatory Assault on Americans’ Gas Stoves
Introduction Chair Fallon, Ranking Member Bush, and members of this Subcommittee, thank you for the opportunity to testify today on an issue few if any…
Comment
Comments of CEI and Michael Mannino on Dept. of Energy’s Conservation Standards for Residential Clothes Washers
I. SUMMARY The proposed rule would tighten the energy and water efficiency standards for residential clothes washers, despite the fact that the standards currently in…
Testimony
CEI’s Myron Ebell Testifies Before House Budget Committee on “Exposing the Woke, Wasteful, and Bloated Bureaucracy”
May 11, 2023 (Video of Myron Ebell’s congressional testimony can be watched here.) Chairman Arrington, Ranking Member Boyle, and Members of the Budget Committee,…
Letters
CEI Joins Coalition Letter on H.R. 1525, the FAIR Act (Civil Asset Forfeiture Reform)
Dear Chairman Jordan and Ranking Member Nadler, On behalf of the undersigned organizations dedicated to the protection of civil liberties and property rights, we ask…
Comment
CEI leads comments on CFPB’s $8 price controls on credit card late fees
In the matter of the proposed rule“Credit Card Penalty Fees (Regulation Z)”Consumer Financial Protection BureauDocket No. CFPB–2023–0010; RIN 3170–AB15 Prepared by: John BerlauDirector of Finance…
Letters
CEI Co-Leads Coalition Letter Calling For External Audit of Fed on Bank Failures
As the Federal Reserve (Fed) readies its internal review of its actions leading up to the Silicon Valley Bank (SVB) collapse, we the undersigned organizations…
Comment
CEI Comments on Non-Compete Clause Rule
On behalf of the Competitive Enterprise Institute (CEI), we respectfully submit comments regarding the Federal Trade Commission’s (FTC) proposed ban of non-compete agreements in employment…
Letters
CEI Joins Coalition Letter Opposing New Broadband Middle Mile Funding
Dear Member of Congress, On behalf of the millions of members and supporters of the undersigned organizations, we write in opposition to any legislation that…
Comment
CEI Comments to Department of Energy on Proposed Stove Regulation
INTRODUCTION The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often…
Letters
Coalition Letter Re: Opposition to Enhanced Deposit Insurance
Dear Members of Congress: We, the undersigned organizations, and individuals, oppose any legislative or regulatory action that would increase the deposit insurance cap or fully…
Letters
Coalition Letter Supporting H.R. 2700, the “Employee Rights Act”
Letters
CEI Joins Coalition Letter in Support of Uniform Public Expression Protection Act (UPEPA)
The undersigned organizations support strong anti-SLAPP laws protecting free speech and commend Texas for having one of the best in the nation. We are concerned…
Testimony
Testimony of Ben Lieberman Before the Senate Committee on Commerce, Science, and Transportation
Chair Cantwell, Ranking Member Cruz, and members of this Committee, thank you for the opportunity to testify today. My name is Ben Lieberman and I…
Comment
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…
Letters
Coalition Letter on TPA BEAD funding oversight
The Honorable John Thune Ranking Member, Subcommittee on Communications, Media, and Broadband Committee on Commerce, Science, and Transportation United States Senate 511 Dirksen Senate Office…
Comment
CEI Comments on FCC’s Preventing Digital Discrimination Noticed of Proposed Rulemaking
Before the Federal Communications Commission Washington, D.C. 20024 Comments of the Competitive Enterprise Institute In the Matter of))Federal Communications Commission)FCC-22-98)GN Docket No. 22-69)Preventing Digital…
Letters
Coalition Letter Opposing Railway Safety Act of 2023
We write you to urge your opposition to the Railway Safety Act of 2023. Introduced following the horrible accident in East Palestine, Ohio, the legislation…
Comment
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)…
Testimony
Testimony of Devin Watkins before the House Financial Services Committee on 03/09/23
Introduction Chairman Barr, Ranking Member Foster, and Members of this Subcommittee, I appreciate the opportunity to speak to you today. My name is Devin Watkins.
Testimony
QFR Answers from Marlo Lewis Regarding the Senate Budget Committee Hearing on 03/03/23
Dear Senator Grassley, Thank you again for inviting me to present testimony at the Senate Budget Committee’s March 1, 2023 hearing “Rising Seas, Rising Costs:…
Letters
Coalition Letter to Members of the North Dakota House Finance & Taxation Committee, RE: SB 2217
Chair Headland, Vice Chair Hagert, and Members of the Committee, The undersigned organizations write in opposition to Senate Bill 2217. This legislation would prohibit interchange…
Testimony
Testimony of Marlo Lewis, Ph.D., Senior Fellow in Energy and Environmental Policy, Competitive Enterprise Institute
Chairman Whitehouse, Ranking Member Grassley, and honorable members of this Committee, thank you for the opportunity to present testimony on behalf of the Competitive Enterprise…
Comment
CEI Comments on the Proposed Regulation on Digital Discrimination of Access
Introduction. On behalf of the Competitive Enterprise Institute (CEI), we respectfully submit the following comments in response to the Federal Communications Commission’s (FCC) notice of…
Testimony
Written Testimony Regarding the Senate Committee on Commerce, Science, and Transportation hearing on February 16, 2023 titled “Bringing Transparency and Accountability to Pharmacy Benefit Managers”
The Honorable Maria Cantwell ChairCommittee on Commerce, Science, and TransportationU.S. Senate Washington, D.C. 20510 The Honorable Ted Cruz Ranking MemberCommittee on Commerce, Science, and TransportationU.S.
Comment
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…
Testimony
Written testimony on amendment to HB 593 (forfeiture reform)
In the statement below, I discuss several ways that the proposed amendment to HB 593 will improve New Hampshire’s justice system. The House Committee on…
Legal Brief
Kathleen and Charles Moore Prepare to take their Fight Against Taxing Unrealized Gains to Supreme Court
In 2017, Congress passed the Tax Cuts and Jobs Act. The new law was a reform of the federal tax code, but also included a…
Testimony
CEI’s John Berlau Testifies Before House Financial Services Committee: Hearing: “Revamping and Revitalizing Banking in the 21st Century”
Chairman Barr, Ranking Member Foster, and honorable members of this Subcommittee, thank you for this opportunity to present testimony on behalf of my organization,…
Comment
Comment to EPA on AIM Act Restrictions on the Use of Certain Hydrofluorocarbons
INTRODUCTION The undersigned free-market organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often neglected by agencies…
Letters
Coalition Letter to Congress in Support of H. R. 21, the Strategic Production Response Act
Dear Member of Congress: We, the undersigned organizations and individuals, write to express our strong support for H.R. 21, the Strategic Production Response Act,…
Comment
Ofcom Consultation: Net Neutrality Review
Introduction On behalf of the Competitive Enterprise Institute (CEI), I welcome the opportunity to submit the following comments in response to the Office of Communication…
Letters
CEI Joins Coalition Letter Rejecting Building American Energy Security Act of 2022
Dear Majority Leader Schumer, Minority Leader McConnell, Speaker Pelosi, and Minority Leader McCarthy: The undersigned organizations write to express our strong opposition to Senator Joe…
Comment
CEI Comments on Proposed Rulemaking in the Matter of Trade Regulation Rule on Commercial Surveillance and Data Security
Introduction On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to the Federal Trade Commission’s (FTC) advanced notice…
Letters
Climate Crisis Select Committee Coalition Letter
Dear Leader McCarthy, We, the undersigned organizations, write to urge you to disband the Select Committee on the Climate Crisis when Republicans take back control…
Legal Brief
CEI et al. Opening Brief in CEI v. EPA
CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES Pursuant to Circuit Rule 28, petitioners American Fuel & Petrochemical Manufacturers, Clean Fuels Development Coalition, Competitive Enterprise …
Letters
Coalition Letter in Opposition to Credit Card Regulation Amendments
Dear Member of Congress: We, the undersigned organizations, oppose the inaccurately named Credit Card Competition Act of 2022 (S. 4674) as filed as Senate amendment 6201 to the…
Comment
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…
Comment
Comments Regarding Energy Conservation Standards for Consumer Furnaces
The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often neglected…
Letters
Coalition Letter Opposing Freight Rail Shipping Fair Market Act
Dear Member of Congress: We, the undersigned individuals and organizations, oppose the inaccurately named Freight Rail Shipping Fair Market Act. It will cause significant harm…
Comment
Comments to the Federal Trade Commission Regarding the Motor Vehicle Dealers Trade Regulation Rule
Comment Submitted: September 12, 2022 Docket No. FTC-2022-0046-0001 On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to…
Comment
Coalition Comments on Proposed Determination to Prohibit Disposal Sites in Pebble Deposit Area
Comments of the Competitive Enterprise Institute, 60 Plus Association, Heritage Action for America, Freedom Works, Project 21, Reaching America, American Lands Council, American Business…
Letters
CEI Joins Coalition Opposing Credit Card Competition Act
Dear Member of Congress: We, the undersigned organizations, oppose the inaccurately named Credit Card Competition Act of 2022 (S. 4674). The bill is…
Comment
CEI Comment on SEC ‘Investment Company Names’ Rule
Introduction The Competitive Enterprise Institute (CEI) is pleased to have the opportunity to comment on the Securities and Exchange Commission’s (SEC) current notice of proposed…
Comment
CEI Comments to EPA Regarding Environmental Protection Agency, Clean Water Act Section 401 Water Quality Certification Improvement Rule, Proposed Rule
INTRODUCTION The Competitive Enterprise Institute is a policy and analysis organization committed to advancing the principles of free markets and limited government. We are particularly…