Looking at Federal Environmental Regulating Agencies
Through eight analyses, Resources for the Future offers a road map for institutionalizing retrospective analysis as a standard component of regulatory evaluation.
Resources for the Future (RFF) has developed seven analyses addressing key challenges in advancing retrospective analysis of environmental regulations. These efforts focus on three central themes: exploring institutional pathways to expand the use of retrospective analysis, including potential legislative and executive measures; demonstrating its application through new quantitative studies across various US Environmental Protection Agency (EPA) regulatory domains; and evaluating how the EPA incorporates environmental justice considerations into its regulatory assessments. This type of backward-looking study can underline the effects of a given regulation on different communities, regions, and industries and highlight adverse outcomes and conflicts with other federal regulations.
Although much of the current work centers on regulations under the Clean Air Act, interest has been growing in applying retrospective analysis to areas such as the evaluation of toxic substances in drinking water. However, the lack of a mandatory framework has led to inconsistent implementation, often influenced by discretionary priorities and variable academic funding.
Whereas the US Congress previously had viable prospects to mandate a formal program for retrospective analysis, such prospects have diminished more recently. Nevertheless, the authors who contributed to this body of work have examined a range of administrative pathways, from incremental legislative actions to initiatives that could be pursued by the current administration without congressional involvement.
- “Consideration of Environmental Justice in EPA’s Regulatory Analyses: A Review and Assessment,” a working paper that explores the number, accuracy, and impact of environmental justice analyses undertaken during the EPA rulemaking process.
- “A Retrospective Analysis of Heavy-Duty Vehicle Tailpipe Nitrogen Oxides Emissions Standards,” which presents a retrospective analysis of the EPA 2007 regulations targeting nitrogen oxide emissions from heavy-duty vehicles.
- “Geographic Resolution in Environmental Policy: EPA’s Shift from Regions to Counties Under the Clean Air Act,” which analyzes how EPA’s definition of nonattainment status under the Clean Air Act affects measurements of regulatory stringency and the implications for policy design in terms of determining the appropriate geographic level of regulating air pollution.
- “What Are the Effects of Early-Childhood Exposure to Environmental Lead on Personality?,” which examines whether lead exposure itself leads to personality change, as previous studies suggest, taking into account various other factors.
- “Congress’s Role in Promoting Environmental Policy Evaluation,” which identifies a set of 10 interrelated barriers that have inhibited the development of a robust practice of evaluating environmental policy at federal agencies based on a series of interviews with senior government officials with decades of experience in environmental policymaking.
- “Are “Killer Trees” Helpful for Understanding the Effects of the NOx Budget Program?,” which evaluates how the effectiveness of the NOx Budget Trading Program in reducing secondary pollutants depends on local atmospheric conditions, providing options for designing air quality policies that account for interactions between pollutants and environmental factors.
- “Administrative Initiatives to Advance Retrospective Analysis,” which outlines executive actions that a new administration could take to advance retrospective analysis, including several approaches to initiate specific retrospective projects at select regulatory agencies.
- “Impacts of the US Safe Drinking Water Act Arsenic Rule on Arsenic Occurrence,” which provides the first retrospective analysis of the causal impacts of the 2001 US Safe Drinking Water Act (SDWA) Arsenic Rule on arsenic occurrence in public drinking water systems.
Working Paper — Dec 9, 2024
Consideration of Environmental Justice in EPA’s Regulatory Analyses: A Review and Assessment
Consideration of Environmental Justice in EPA’s Regulatory Analyses: A Review and Assessment
Journal Article — Oct 24, 2025
A Retrospective Analysis of Heavy-Duty Vehicle Tailpipe Nitrogen Oxides Emissions Standards
This article presents a retrospective analysis of the Environmental Protection Agency’s (EPA) 2007 nitrogen oxides regulations for heavy-duty vehicles and finds that EPA underestimated emissions by 0.12 million tons.
Working Paper — Nov 3, 2025
Geographic Resolution in Environmental Policy: EPA’s Shift from Regions to Counties Under the Clean Air Act
This paper evaluates how the US Environmental Protection Agency’s 1978 shift to county-level enforcement under the Clean Air Act enhanced the policy’s effectiveness in improving air quality and reshaping industrial activity.
Journal Article — Feb 11, 2025
What Are the Effects of Early Childhood Exposure to Environmental Lead on Personality?
This article examines whether lead exposure itself leads to personality change as previous studies suggest, taking into account various other factors.
Working Paper — Nov 3, 2025
Congress’s Role in Promoting Environmental Policy Evaluation
This paper identifies ten key barriers hindering robust environmental policy evaluation in federal agencies and, drawing on ex-post review experience, analogous efforts, and interview insights, proposes a range of congressional reforms at varying levels o
Working Paper — Nov 3, 2025
Are “Killer Trees” Helpful for Understanding the Effects of the NOx Budget Program?
This paper examines how preexisting air quality affects the ability of air pollution policies to reduce ground-level ozone, which has variety of health impacts, especially on vulnerable populations.
Working Paper — Nov 3, 2025
Administrative Initiatives to Advance Retrospective Analysis
This paper outlines five possible approaches that a new administration could take to advance retrospective analysis.
Journal Article — Oct 10, 2025
Impacts of the US Safe Drinking Water Act Arsenic Rule on Arsenic Occurrence
This article conducts a retrospective analysis of the 2001 US Safe Drinking Water Act Arsenic Rule and finds that annual mean arsenic concentrations in public drinking water have decreased by around 38 percent.
The RFF project to promote retrospective analysis of environmental regulations adds to a growing effort to introduce greater rigor and accountability in the federal regulatory process.
At an RFF webinar in February 2025, these papers were presented, featuring researchers as they examined a variety of rules affecting major industrial sectors and proposed possible arrangements to more consistently embed retrospective analysis within federal agencies’ standard practice.
