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Regulatory Comments

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Issue Areas

Comment

CEI comments advising DOT to rescind Biden administration SAFE 1 Repeal Rule

  • By: Marlo Lewis, Jr.
  • 05/06/2025

Dear Mr. Cohen, On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit these comments responsive to the Department of Transportation’s request for information…

Transportation

Comment

CEI Comments on Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers

  • By: Ben Lieberman, Marlo Lewis, Jr.
  • 09/27/2024

Department of Energy, Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers; Notification of Data Availability and Request for Comment Docket Number…

Energy and Environment

Comment

CEI Comments on California’s Advanced Clean Cars II Waiver Request

  • By: Marlo Lewis, Jr.
  • 02/27/2024

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…

Energy

Comment

CEI comments on NHTSA’s proposed Corporate Average Fuel Economy Standards

  • By: Marlo Lewis, Jr.
  • 10/16/2023

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…

Energy and Environment

Comment

CEI Comments on Proposed NEPA Implementing Regulations

  • By: Marlo Lewis, Jr.
  • 09/29/2023

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…

Energy and Environment

Comment

CEI Comments on the EPA’s CO2 Powerplant Emission Performance Standards

  • By: Marlo Lewis, Jr.
  • 08/08/2023

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…

Energy and Environment

Comment

Marlo Lewis CEI Comments on EPA’s Greenhouse Gas Motor Vehicle Standards

  • By: Marlo Lewis, Jr.
  • 07/05/2023

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…

Energy and Environment

Comment

CEI Comments on OMB’s Revision of Circular A-4 Regulatory Accounting Guidelines

  • By: Marlo Lewis, Jr.
  • 06/20/2023

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…

Energy and Environment

Comment

CEI Comments on EPA’s Reconsideration of National Ambient Air Quality Standards (NAAQS) for Fine Particulate Matter (PM2.5)

  • By: Daren Bakst, Marlo Lewis, Jr.
  • 03/28/2023

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…

Energy and Environment

Comment

Comments to the Council on Environmental Quality, Proposed Guidance on Consideration of Greenhouse Gases and Climate Change

  • By: Marlo Lewis, Jr.
  • 03/10/2023

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)…

Climate

Comment

CEI Comments on EPA Methane Emission Performance Standards for the Oil and Gas Sector

  • By: Marlo Lewis, Jr.
  • 02/13/2023

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…

Energy and Environment

Comment

Comments to DOE: Energy Conservation Standards Program

  • By: Marlo Lewis, Jr.
  • 10/05/2022

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…

Energy

Comment

CEI Comments on Proposed SEC Rule: Enhancement and Standardization of Climate-Related Disclosures for Investors

  • By: Marlo Lewis, Jr., Patrick Michaels
  • 06/17/2022

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…

Energy and Environment

Comment

CEI Comments to Federal Energy Regulatory Commission: Docket No. PL21-3-000

  • By: Marlo Lewis, Jr., Patrick J. Michaels
  • 04/25/2022

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.

Energy and Environment

Comment

CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gas Mitigation under Sections 3 and 7 of the Natural Gas Act.

  • By: Marlo Lewis, Jr., Patrick J. Michaels
  • 01/07/2022

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…

Energy

Comment

CEI Comments on Biden Administration Proposal to Revise National Environmental Policy Act (NEPA) Implementing Regulations.

  • By: Marlo Lewis, Jr.
  • 11/22/2021

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…

Energy

Comment

CEI Comments on the National Highway Traffic Safety Administration’s Proposed Fuel Economy Standards for Model Year 2024-2026 Passenger Cars and Light Trucks

  • By: Marlo Lewis, Jr., Patrick J. Michaels
  • 10/26/2021

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…

Energy and Environment

Comment

CEI Comments on Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards Proposed Rule

  • By: Marlo Lewis, Jr., Patrick J. Michaels
  • 09/27/2021

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:…

Energy

Comment

CEI Comments on SAFE 1 Rule – Docket ID No. EPA-HQ-OAR-2021-0257

  • By: Marlo Lewis, Jr.
  • 07/06/2021

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…

Energy

Comment

Comments On OMB Technical Support Document on Social Cost of Carbon

  • By: Marlo Lewis, Jr., Patrick J. Michaels
  • 06/21/2021

View Full Document as PDF Office of Management and Budget Notice of Availability and Request for Comment on “Technical Support Document: Social Cost…

Energy

Comment

Marlo Lewis Comment to the SEC on Climate Risk Disclosure

  • By: Marlo Lewis, Jr.
  • 06/11/2021

View Full Document as PDF Comments of the Competitive Enterprise Institute, Caesar Rodney Institute, Committee for a Constructive Tomorrow (CFACT), Energy and Environment…

Energy and Environment

Comment

Docket No. NHTSA-2021-0030 Marlo Lewis CEI free market groups 6-11-2021

  • By: Marlo Lewis, Jr.
  • 06/11/2021

View Full Document as PDF Comments of the Competitive Enterprise Institute, American Energy Alliance, Americans for Tax Reform, Freedom Works, Caesar Rodney Institute,…

Innovation

Comment

CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gases in Natural Gas Facility Permitting

  • By: Marlo Lewis, Jr.
  • 04/26/2021

View Full Document as PDF Thank you for the opportunity to comment on the Federal Energy Regulatory Commission’s Notice of Inquiry (NOI) on…

Energy

Comment

CEI Comments on FERC Proposed Wholesale Carbon Pricing Policy

  • By: Marlo Lewis, Jr.
  • 11/11/2020

Thank you for the opportunity to comment on the Federal Energy Regulatory Commission’s proposed policy statement on carbon pricing in wholesale electricity markets organized by…

Comment

CEI Comments on BCA Rule

  • By: Marlo Lewis, Jr.
  • 08/05/2020

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…

Energy and Environment

Comment

CEI Comments on EPA’s Proposed Review of the National Ambient Air Quality Standards for Particulate Matter

  • By: Marlo Lewis, Jr.
  • 06/30/2020

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…

Energy and Environment

Comment

CEI Comments on NERA Petition Concerning Unlawful Wholesale Sales

  • By: Ben Lieberman, Marlo Lewis, Jr.
  • 06/16/2020

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…

Energy and Environment

Comment

CEI Comments on EPA’s Supplemental Notice of Proposed Rulemaking : EPA Transparency Rule

  • By: Marlo Lewis, Jr.
  • 05/19/2020

Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) Supplemental notice of proposed rulemaking (SNPR)[1] on its proposal…

Energy and Environment

Comment

CEI Comments on Proposed Updated NEPA Procedural Regulations

  • By: Ben Lieberman, Marlo Lewis, Jr.
  • 03/10/2020

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.

Energy and Environment

Comment

Supplemental Testimony: “Trump’s Wrong Turn on Clean Cars”

  • By: Marlo Lewis, Jr.
  • 11/06/2019

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…

Energy and Environment

Comment

Trump’s Wrong Turn on Clean Cars

  • By: Marlo Lewis, Jr.
  • 10/29/2019

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…

Climate

Comment

CEI Comments on the Mercury Rule

  • By: Marlo Lewis, Jr.
  • 04/18/2019

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…

Energy and Environment

Comment

CEI Comments on EPA’s Review of its Carbon Dioxide (CO2) Performance Standards for New Coal-fired Power Plants

  • By: Marlo Lewis, Jr.
  • 03/19/2019

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…

Energy

Comment

CEI Comments on EPA ACE Rule

  • By: Marlo Lewis, Jr.
  • 11/01/2018

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…

Energy and Environment

Comment

CEI Comments on Joint DOT/EPA Proposed SAFE Vehicles Rule

  • By: Devin Watkins, Marlo Lewis, Jr., Sam Kazman
  • 10/29/2018

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…

Energy and Environment

Comment

CEI Comments In Support of EPA Transparency Rule

  • By: Marlo Lewis, Jr.
  • 08/16/2018

Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) proposal to strengthen transparency in regulatory science.[1] The comments…

Comment

CEI Comments on The Federal Energy Regulatory Commission’s Notice of Inquiry Regarding the Certification of New Natural Gas Facilities

  • By: Marlo Lewis, Jr.
  • 06/21/2018

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)…

Energy

Comment

CEI Comments on EPA’s Proposed Rule to Repeal the Clean Power Plan

  • By: Marlo Lewis, Jr.
  • 04/26/2018

View Full Document as PDF Docket ID No. EPA–HQ–OAR–2017–0355 Thank you for the opportunity to comment on the Environmental…

Energy and Environment

Comment

Comments of Marlo Lewis on a Potential Clean Power Plan Replacement Rule

  • By: Marlo Lewis, Jr.
  • 02/26/2018

View Full Document as PDF Thank you for the opportunity to submit comments on the Environmental Protection Agency’s (EPA) advance notice of…

Energy and Environment

Comment

Comments to the EPA on Renewable Fuel and Diesel Standards for 2019

  • By: Marlo Lewis, Jr.
  • 10/20/2017

View Full Document as PDF Thank you for the opportunity to submit comments[1] on the Environmental Protection Agency’s (EPA)…

Energy and Environment

Comment

CEI Comments on EPA & NHTSA Reconsideration of Fuel Economy Standards

  • By: Marlo Lewis, Jr., Sam Kazman
  • 10/06/2017

View Full Document as PDF The Obama EPA’s final Mid-Term Evaluation (MTE) is arbitrary, capricious, and an abuse of discretion. Reconsideration is…

Energy and Environment

Comment

Options for Addressing President Trump’s Paris Climate Pact Promise

  • By: Christopher C. Horner, Marlo Lewis, Jr.
  • 05/02/2017

View Full Document as PDF This memo analyzes two principal options for dealing with the Paris Climate Agreement, U.S. participation in which…

Energy and Environment

Comment

Comments to the EPA on Clean Energy Incentive Program

  • By: Marlo Lewis, Jr.
  • 11/01/2016

View Full Comments Introduction: Twenty-eight States joined by numerous industry and non-profit groups are challenging the legality of EPA’s carbon dioxide (CO2)…

Comment

Comments on the Clean Energy Incentive Program Design Details

  • By: Marlo Lewis, Jr.
  • 09/29/2016

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)…

Energy and Environment

Comment

CEI Issues Comment to EPA on Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles

  • By: Marlo Lewis, Jr.
  • 10/01/2015

View Document as PDF Comments Submitted by Marlo Lewis (Senior Fellow, Competitive Enterprise Institute), Wayne Brough (Chief Economist and Vice President of…

Energy and Environment

Comment

Regulatory comments on NEPA Review of Project-Related Greenhouse Gas Emissions

  • By: Marlo Lewis, Jr.
  • 03/25/2015

Read the full comment letter here The comment letter responds to the White House Council on Environmental Quality’s Draft Guidance on National…

Comment

Free Market Organizations’ Letter to Office of Management and Budget on Social Cost of Carbon

  • By: Marlo Lewis, Jr.
  • 02/27/2014

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…

Climate

Comment

Comment Letter on LLF Petition for Reconsideration, Docket No. EERE-BT-PET-0043, September 16, 2013

  • By: Marlo Lewis, Jr.
  • 09/18/2013

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…

Energy

Comment

CEI Public Comment concerning Department of Energy’s final rule establishing Energy Conservation Standards for Standby Mode and Off Modefor Microwave Ovens

  • By: Marlo Lewis, Jr.
  • 09/17/2013

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…

Climate

Comment

Comment Letter on Third Upton Waxman White Paper

  • By: Marlo Lewis, Jr.
  • 05/24/2013

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…

Energy and Environment

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