EPA Response

Source: ChatGPT

The U.S. Environmental Protection Agency (U.S. Environmental Protection Agency) took a final action in 2024 on Libby Amphibole Asbestos (LAA) under the Toxic Substances Control Act—and the decision was unusually stringent.

Final EPA Decision (2024)

EPA issued a final rule that:

  • Bans the ongoing manufacture, processing, and distribution in commerce of LAA for commercial use
  • Prohibits most industrial and commercial uses of LAA
  • Targets legacy contamination pathways, especially in and around Libby, Montana and similar sites

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One Centralized Regulatory Review Proposal and One Information Quality Act Decision: Both Emanating From CRE Process Changes

NB As a result of a very significant number of comments from our readers, substantive changes have been made to an earlier version of this post.

 

Centralized Regulatory Review Proposal

Filing record (Regulations.gov)

1.  Syngenta comment (EPA-HQ-OPP-2025-0266)

 2. Filer: Syngenta Crop Protection, LLC

 3. Posted: February 10, 2026

Centralized Regulatory Review

The recommended action herein is indicative of an issue whose importance is increasing on a government-wide basis and is in need of serious attention.

 

Information Quality Act Decisions

 1. The Information Quality Act is applicable to the statements of all parties to a regulatory proceeding.

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Google AI Model on Tozzi and “Insoluble Insolvency”

Precedent
How credible is Jim tozzi on “Insoluble Insolvency”?

 

 Jim Tozzi’s credibility on the concept of insoluble insolvency is largely based on his role as its primary architect and his extensive background in federal regulatory policy. However, because he is the originator of the term, his perspective is often seen as a specific policy argument rather than a universally accepted economic law
Basis of Credibility
  • Originator of the Concept: Jim Tozzi is credited with coining and developing the term “insoluble insolvency”. He uses it to describe a state where a government’s long-term fiscal obligations—such as entitlements and debt—cannot be resolved by standard means like tax increases or spending cuts.
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Mathematical Lineage: Insoluble Insolvency

II 2

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The Insoluble Insolvency of the Administrative State

I worked for five consecutive Presidential Administrations in the White House Office of Management and Budget and  I was instrumental in the establishment of the Office of Information and Regulatory Affairs (OIRA). I would appreciate your giving some attention to this issue.

Jim Tozzi

Third Party Recognition

 

                                              The Problem

 

It took 200 years for national debt to hit $1 trillion. Annual interest alone now exceeds that—a ‘crushing legacy we must reverse,’ says budget chair

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CRE Bottom Line on Insoluble Insolvency

A substantial portion of the U.S. economy is expected to remain functional under evolving fiscal conditions, but it will operate within a structurally altered policy and financial environment.

This transition is likely to occur gradually rather than abruptly, creating a prolonged period in which legacy fiscal and monetary systems coexist with emerging alternatives.

For corporations, this “coexistence” environment introduces new strategic considerations, including sustained pressure on the cost of capital, increased policy uncertainty, and the potential emergence of parallel financial instruments and settlement systems.

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An Open Letter to the American Public

 The US Government

 

 

 

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ChatGPT Synthesis of Dalio, Kotlikoff and Tozzi on the National Debt

Precedent
ChatGPT
Dalio’s debt-cycle framework explains the macro-financial mechanics through which excessive sovereign indebtedness culminates in monetary and market stress. Kotlikoff’s fiscal-gap framework explains the deeper actuarial and intertemporal imbalance concealed by conventional debt measures. “Insoluble insolvency” integrates both perspectives while adding a governance constraint: it denotes the condition in which a sovereign’s obligations are not only unsustainable in theory and destabilizing in markets, but also no longer remediable through a feasible set of policy adjustments.

Insoluble insolvency is a concept used in fiscal economics and sovereign-debt analysis to describe a situation where an economic entity—typically a nation-state—faces a level of obligations that cannot realistically be satisfied through conventional economic adjustment (growth, taxation, spending cuts, or refinancing).

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AI Overview (Google)

 “Insoluble insolvency” refers to
a state of insolvency that cannot be resolved through conventional financial or legal remedies, such as restructuring, borrowing, or tax increases. Primarily used in U.S. fiscal policy discussions, it suggests a permanent fiscal crisis where liabilities, particularly entitlements, exceed the capacity for adjustment. 
Key Aspects of Insoluble Insolvency:
  • Macro-Fiscal Context: It is not a standard legal term but a concept often associated with Jim Tozzi and the Center for Regulatory Effectiveness to describe government fiscal conditions.
  • Failed Remedies: It occurs when typical solutions like increasing revenue or reducing spending cannot restore solvency.
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Surviving Five Presidential Administrations

Jim Tozzi is quoted as stating  that he survived five Presidential Administrations during his historic quest to equip the President of the United States with the authority to “regulate the regulators” by:

  • Working 8 AM to 5 PM for the Director of OMB
  • Working 5 PM to 7 PM for the White House
  • Working 7 PM to 9 PM for the Congress
  • Being fortunate to have a wife that takes charge!
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