Institute for Policy Integrity

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Publications

Viewing all publications in Transparency
  • Rethinking Health-Based Environmental Standards
    Academic Article/Working Paper

    Rethinking Health-Based Environmental Standards

    By Michael A. Livermore and Richard L. Revesz
    April 9, 2014

    In Whitman v. American Trucking, the Supreme Court interpreted the Clean Air Act to require the EPA to set the National Ambient Air Quality Standards (NAAQS), without considering costs. Instead, the agency must rely exclusively on health-related criteria. The authors argue that such health-based standards are problematic because there is no coherent way to set the permissible level of pollution based on health considerations alone and, ironically, the NAAQS have generally been set at levels that are inefficiently lax from an economic perspective. The authors urge a reinterpretation of the American Trucking case that would allow the EPA to consider costs-benefit analysis when it would lead to more stringent standards, as it currently does for most regulated pollutants.

  • Omitted Damages: What’s Missing from the Social Cost of Carbon
    Report

    Omitted Damages: What’s Missing from the Social Cost of Carbon

    By Peter Howard
    March 13, 2014

    The social cost of carbon is an estimate of the economic damage done by each ton of carbon dioxide spewed into the air. Howard examines the Integrated Assessment Models used to produce the social cost of carbon estimate and gives a comprehensive review of what each model accounts for and what each model misses.

  • Quantifying Regulatory Benefits
    Academic Article/Working Paper

    Quantifying Regulatory Benefits

    By Richard L. Revesz
    January 7, 2014

    The author responds to an argument made by Cass Sunstein that administrative agencies should use breakeven analysis when unable to quantify benefits of a specific regulation. Breakeven analysis seeks to determine how high nonquantifiable benefits of a regulation would have to be for the benefits to justify the costs. In this Comment, the author argues that breakeven analysis can be useful but is always a second-best technique. The first-best approach is to quantify the benefit.

  • Cost-Benefit Analysis and Agency Independence
    Academic Article/Working Paper

    Cost-Benefit Analysis and Agency Independence

    By Michael A. Livermore
    January 7, 2014

    In “Cost-Benefit Analysis and Agency Independence,” Professor Michael A. Livermore argues that cost-benefit analysis provides a standard that constrains the exercise of OIRA’s power, helping to preserve the autonomy of government agencies in the face of White House review. This argument challenges the prevailing view that cost-benefit analysis is a tool for the President to impose authority over executive agencies.

  • Regulatory Report

    Regulatory Report

    Affirmatively Furthering Fair Housing

    By Policy Integrity
    May 10, 2013

    Decades after the civil rights movement inspired the Fair Housing Act, HUD still has a long way to go before that law’s vision of fair housing is realized. The primary recommendations of this report to the Department of Housing and Urban Development (HUD) are to more clearly define fair housing goals and to measure the progress of locally-based housing providers in meeting the requirements of the 1960’s civil rights statute.