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…
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…
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…
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…
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…
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,…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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,…
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…
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…
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…
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…
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…
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.
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…
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…
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…
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…
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…
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,…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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,…
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…
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…
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…
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,…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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,…
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).
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…
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…
Letters
Coalition Urges Congress to Reauthorize FCC’s Spectrum Authority
We, the undersigned, write this letter to express our support for H.R. 7624, the Extending America’s Spectrum Auction Leadership Act of 2022, which would…
Letters
CEI Leads Coalition Opposing the Confirmation of Joseph Goffman as EPA’s Assistant Administrator for Air and Radiation
Dear Chairman Carper, Ranking Member Capito, and Members of the Senate Committee on Environment and Public Works: The undersigned organizations and individuals write…
Letters
CEI Joins Coalition Letter on Proposed Antitrust Bills that Would Harm Consumers
We, the undersigned economic, legal, and public policy experts, write to express concern overlegislative and executive branch proposals aimed at dramatically expanding government antitrustand…
Legal Brief
CEI Files Brief of Amici Curiae in Louisiana v. Department of Energy
In Louisiana v. Department of Energy, CEI attorneys argued that the Department of Energy’s rescission of a rule prescribing an energy conservation standard for…
Comment
CEI Comments on FDA Proposed Menthol Standard
Center for Tobacco U.S. Food and Drug Administration 10903 New Hampshire Ave Silver Spring, MD 20993 Re: Tobacco Product Standard…
Legal Brief
Brief of Amicus Curiae in West Virginia v. EPA
INTEREST OF AMICUS CURIAE1 The Competitive Enterprise Institute (“CEI”) is a nonprofit 501(c)(3) organization incorporated and headquartered in Washington, D.C., dedicated to…
Testimony
CEI Expert Testimony at Legislative Hearing to Strengthen Energy Infrastructure, Efficiency, and Financing
House Subcommittee on Energy 2123 Rayburn House Office Building June 22, 2022 Legislative Hearing to Strengthen Energy Infrastructure, Efficiency,…
Comment
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…
Letters
Coalition Opposes SEC’s Proposed Rule: Enhancement and Standardization of Climate-Related Disclosures for Investor
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-0609 The undersigned individuals and organizations strongly…
Comment
CEI Comments to SEC on Proposed Climate-Related Disclosures Rule
Comment letter submitted by the Competitive Enterprise Institute, et al. June 2022 In the matter of the proposed rule “The Enhancement…
Comment
CEI Comments to Senate Banking Committee on JOBS Act 4.0
Senator Pat ToomeyRanking Member, Senate Banking Committee455 Dirksen Senate Office BuildingWashington, D.C 20510Dear Senator Toomey,On behalf of the Competitive Enterprise Institute (CEI), it is…
Comment
CEI Comments to the National Telecommunications and Information Administration Regarding Report on Competition in the Mobile App Ecosystem
Alex Reinauer, Research Fellow, Competitive Enterprise Institute Comment Period Closes: May 23, 2022 Comment Submitted: May 23, 2022 Docket No. NTIA-2022-0001…
Comment
CEI Letter Opposing the Department of Labor’s Proposed Changes to the Davis-Bacon Act
Via Regulations.Gov Hon. Marty Walsh Secretary of Labor United States Department of Labor 200 Constitution Ave NW Washington, DC…
Letters
36 Organizations Sign Coalition Letter Condemning Menthol Prohibition Proposal
We, the undersigned 36 organizations, representing millions of taxpayers and consumers across the United States, strongly urge you to reject any proposed ban on…
Letters
CEI Leads Coalition Letter on Kigali Amendment to the Montreal Protocol on Substances That Deplete the Ozone Layer
Comment
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,…
Comment
Joint Comments on the Securities and Exchange Commission’s Incursion into Private Markets.
RE: Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (SEC Release Nos. IA-5955; File No. S7-03-22) Dear Ms. Countryman:…
Legal Brief
Brief of Amicus Curiae – Case No. 22-60008
UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT Case No. 22-60008 Consumers’ Research, et al., v. Federal Communications…
Comment
Comments to the Consumer Financial Protection Bureau on its Request for Information on “Junk Fees”
Dear Director Chopra: On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to the Consumer Financial…
Letters
CEI Joins Coalition Letter on FDA Ban on Synthetic Nicotine
Dear Commissioner Califf, We write to you in opposition to a new regulation signed into law by Congress that will effectively ban vapor…
Letters
CEI Joins Coalition Opposing Weaponizing Antitrust Law
Dear Senator, Despite full control of Congress and President Joe Biden in the Oval Office, the Democratic Party finds many of its top…
Comment
Comments to the Federal Trade Commission Regarding Forthcoming Merger Guideline Revisions
Comment Period Closes: April 21, 2022 Comment Submitted: April 3, 2022 Docket No. FTC-2022-0003-0001 On behalf of the Competitive Enterprise Institute…