Regulatory Reform Where It Matters Most: How CRF Advanced Affordability and Economic Dominance This Week

Last week, the Center for Regulatory Freedom (CRF) was deeply engaged across several of the most consequential regulatory fronts facing American households, businesses, and property owners. From energy reliability and housing costs, to communications markets, to vehicle affordability and trade competitiveness, CRF’s work focused on a unifying principle: regulatory discipline is not an abstraction—it is a prerequisite for affordability, growth, and U.S. economic dominance.

These were not symbolic filings. They were substantive interventions aimed at ensuring that federal regulation supports—rather than undermines—the economic foundations of American prosperity. Nowhere was that clearer than in CRF’s comments on the Environmental Protection Agency’s proposed update to the definition of “waters of the United States.”

WOTUS: The Most Important Pro-Property-Rights Rulemaking of the Second Trump Administration

CRF’s comments on the updated definition of “waters of the United States” (WOTUS), issued jointly by the Environmental Protection Agency and the U.S. Army Corps of Engineers, addressed what is arguably the most consequential property-rights and land-use rulemaking of the Trump Administration’s second term.

For decades, WOTUS has been the paradigmatic example of regulatory overreach: a vague statutory phrase stretched through administrative interpretation into a sweeping federal land-use regime. Farmers, ranchers, homebuilders, local governments, and ordinary landowners were left guessing whether dry ditches, seasonal streams, or isolated wetlands would suddenly trigger federal permitting requirements—often backed by severe civil and criminal penalties.

The proposed rule arrives after two landmark Supreme Court decisions that fundamentally reset the legal landscape. Those decisions made clear that federal agencies do not have open-ended authority to define the scope of their own jurisdiction, and that “waters of the United States” must be understood in a clear, physical, and commonsense way. CRF’s comments urged EPA and the Corps to fully internalize that shift—not merely in rhetoric, but in regulatory structure.

This matters profoundly for affordability and economic dominance. Land-use uncertainty suppresses investment, delays development, and raises the cost of everything from housing and infrastructure to energy and agriculture. When property owners cannot predict whether federal permits will be required, projects are delayed or abandoned, capital is sidelined, and costs are passed through to consumers.

CRF emphasized that a durable WOTUS definition must draw bright lines, respect federalism, and explicitly foreclose the return of rejected theories through guidance or enforcement discretion. The goal is not weaker environmental protection, but lawful, predictable governance—one that allows states to exercise their traditional authority and landowners to invest with confidence. In that sense, this rulemaking is not merely about water policy; it is about restoring constitutional boundaries and unlocking economic activity that has been frozen for decades by regulatory ambiguity.

Energy Reliability, Construction Costs, and the CCR Rule

CRF also submitted comments to EPA on its proposal to extend the alternative closure deadline for certain coal combustion residual (CCR) surface impoundments. At first glance, this may appear to be a narrow waste-management issue. In reality, it sits at the intersection of energy reliability, supply-chain resilience, and household affordability.

CRF emphasized that CCR surface impoundments at legacy coal plants are not passive waste repositories—they are operational infrastructure. For many facilities, forcing premature closure of these impoundments effectively forces plant shutdowns, regardless of emissions performance or grid need. In an era of rising electricity demand and documented reliability risks, such regulatory-driven retirements impose real costs on consumers.

Beyond electricity, CCRs are critical industrial feedstocks. Fly ash is a key input for concrete, lowering construction costs and improving durability. Flue-gas desulfurization gypsum is essential for domestic drywall manufacturing. Curtailing these materials through misaligned regulatory timing increases construction costs, exacerbates housing affordability challenges, and weakens domestic supply chains.

CRF supported EPA’s recognition that timing matters—and urged the Agency to explicitly account for downstream affordability and reliability impacts. Disciplined implementation of environmental law can protect health and safety without turning waste rules into de facto energy or industrial policy. That balance is essential to sustaining U.S. energy dominance and economic resilience.

Robocalls: Consumer Protection Without Regulatory Overcorrection

CRF’s comments to the Federal Communications Commission addressed a problem every American understands: unwanted robocalls and scam calls. CRF acknowledged the real consumer harm caused by fraudulent calling practices, but cautioned against prescriptive mandates that could create new harms in the name of protection.

Robocalls are an incentives and information problem, not merely a technical one. Static, technology-specific mandates are quickly arbitraged by bad actors, while imposing lasting compliance costs on legitimate providers. Overly rigid rules risk over-blocking lawful calls—healthcare notifications, financial alerts, and small-business communications—undermining consumer trust rather than restoring it.

CRF urged the FCC to focus on guardrails, enforcement against fraud, and incentive-aligned safe harbors, rather than micromanaging network architecture. A light-touch, flexible framework better protects consumers, preserves innovation, and avoids regulatory accumulation that ultimately raises costs and reduces competition. Once again, the throughline was affordability: compliance costs embedded in communications networks eventually show up in consumer bills and reduced service quality.

Vehicle Affordability and Trade Discipline Under USMCA

Finally, CRF submitted comments to the Office of the United States Trade Representative on the operation of USMCA with respect to automotive goods. CRF’s focus was not on the agreement as promised, but on the agreement as implemented—and how implementation choices affect vehicle affordability and U.S. economic dominance.

CRF highlighted how USMCA’s automotive rules of origin function as embedded industrial policy, introducing compliance friction through complex sourcing, labor, and documentation requirements. Evidence suggests that these costs are material: some manufacturers opt to pay tariffs rather than comply, indicating that administrative burdens can outweigh nominal trade preferences.

These effects matter for consumers. Constraints on new-vehicle production today ripple into used-vehicle markets tomorrow, raising prices and limiting access—particularly for lower- and middle-income households. When trade compliance costs stack atop domestic regulatory mandates, the result is reduced supply elasticity and higher prices, even absent overt protectionism.

CRF urged USTR to treat affordability and supply responsiveness as central metrics of trade policy success. Economic dominance is not achieved through managed trade and regulatory accumulation, but through flexible, predictable frameworks that allow markets to adapt, invest, and grow.

Regulatory Reform as an Affordability Strategy

Taken together, CRF’s work last week underscores a core insight: regulatory policy is economic policy. Whether the issue is land use, energy, communications, or trade, poorly disciplined regulation raises costs, constrains supply, and erodes competitiveness. Conversely, regulatory clarity, restraint, and fidelity to statutory limits unlock growth and relieve cost-of-living pressures without new spending or subsidies.

Affordability is not achieved by administrative fiat. It is achieved by allowing supply to respond, investment to flow, and innovation to flourish. That requires a regulatory state that knows its limits—and respects them.

The Center for Regulatory Freedom will continue to engage where it matters most: inside the administrative process, on the rules that quietly but decisively shape the American economy. Because restoring affordability and securing U.S. economic dominance depends not on slogans, but on disciplined governance.