Project Updates
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Thursday
January 26th,
2012Letter to U.S. Parole Commission on Responding to Parole Violators
The United States Parole Commission, the board responsible for granting parole and supervising parolees in its jurisdiction, is considering a proposal to improve its procedures for determining how to respond when released offenders violate the terms of their parole.
Policy Integrity recently submitted a detailed letter urging the Parole Commission to rely upon evidence-based analysis and empirical research in modifying its procedures. Some of the most compelling studies demonstrate that parole programs that impose swift yet proportional responses to minor parole violations end up reducing the number of people who end up back in prison for new crimes, and are otherwise benefit-cost justified.
In most cases, if a parolee commits a technical violation or fails a drug test, he knows in advance what the consequence will be (such as a short return to prison). Studies in several states have shown that this approach, when combined with additional programs that support offenders as they transition from prison to society, can sharply reduce the likelihood future parole violations and recidivism. When more parolees are successfully reintegrated into their communities, it benefits society while simultaneously decreasing the public cost of re-incarceration.
The Parole Commission is developing these regulations as part of a broader effort to incorporate retrospective review—also known as regulatory “look backs” at existing regulatory programs—into its institutional processes. Policy Integrity suggests implementing individually-tailored release plans, and using a data-management system to track the success of efforts to ensure parolees stay out of prison.
Issue(s): Cost-Benefit Analysis Type: Letters
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Wednesday
January 18th,
2012Letter to HUD on Homelessness
The Dept. of Housing and Urban Development has issued two proposals that would significantly alter the way the government handles homelessness and institute major improvements to the agency’s work; Policy Integrity recently submitted a letter on both.
One proposal, named the Emergency Solutions Grant (ESG) program, would shift the focus of government programs away from providing short-term emergency housing toward providing long-term homelessness prevention. The other proposal would improve HUD’s Homeless Management Information Systems (HMIS) and related procedures for collecting and tracking data related to homelessness.
The letter guides HUD in evaluating the performance of its restructured ESG program, with an eye toward sponsoring the collection and analysis of relevant data at the local and national levels. Our recommendations include using evidence-based decision-making to evaluate ESG grants and funded programs, in line with the requirements of the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act), under which both proposals are being promulgated.
HUD is modifying the HMIS regulations in order to require the collection of new information; this update will help ensure that HMIS is the central repository for all information about homeless individuals who participate in a “continuum of care,” meaning that they receive various types of public aid related to their housing, such as rental assistance along with other social services. The letter recommends that HUD modify the regulations to providing additional encouragement guidance for local data collection and to requiring the collection of both pre-intervention and post-intervention data in order to better monitor the long-term effects of ESG funded programs.
Furthermore, the regulations should be modified to enhance the ability of localities to link up their databases and to share information with researchers; this is necessary so that researches do not need to rely solely on self-reporting by clients of homelessness prevention programs for data collection. HUD should also implement standards for national data collection to facilitate nationwide research on homelessness prevention and to provide a more user-friendly and information-rich framework for analysis—as it stands, current regulations require to obtain HMIS data from individual local studies.
Issue(s): Health and Human Services Type: Letters
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Friday
December 23rd,
2011DOT Announces New Regulations on Truckers’ Hours of Service
The U.S. Department of Transportation announced new restrictions to the amount of time truckers can spend behind the wheel. DOT maintained an 11-hour limit on truck drivers’ hours, scaling back a proposal to give them more rest. The rule does introduce some new limits, including a reduction a driver’s maximum work week by 12 hours to 70 hours.
The regulations maintain the limit set in late 2008 by the Bush Administration that increased the amount of time truck drivers can spend behind the wheel to 11 hours per day. That’s like driving from Washington, D.C. to Atlanta in one stretch–and research shows it’s simply not healthy or safe.
Over-tired drivers are more likely to get into dangerous accidents. But too-long driving shifts also put truckers’ health in jeopardy – chronic fatigue, sedentary lifestyles, and exposure to diesel exhaust can lead to serious health issues. Chopping even an hour off their long hauls would have massive health and public safety benefits.
In March 2011, we called for consideration of a more fundamental revision to the rule, informed by developments in the industry and new information about health risks. Important considerations include increasing compliance, educating truckers on health risks and safety practices, and the use of heuristics to encourage these behaviors.
Consumer groups who are disappointed by the less-stringent regulation plan to continue the push to reduce the driving limit to 10 hours per day.
Issue(s): Energy and Environment, Safety
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Wednesday
December 21st,
2011EPA Releases New Mercury and Air Toxics Standards
Today, the Environmental Protection Agency released air pollution regulations to lower emissions of 84 different toxic chemicals, including mercury.
Overall, the rule remains largely unchanged from the its proposed version that was issued for public comment in March. It will provide strong protection for the American public, as the regulations will reduce birth defects as well as asthma, heart disease, and premature death. The benefits of the new rules outweigh their costs at least 3 to 1 – and perhaps as high as 9 to 1. Anyone who says otherwise is blatantly ignoring the price we pay from mercury-related health problems.
Since proposing the rule, EPA has responded to industry’s complaints without substantial sacrifices to public health. To the extent there will be delays in compliance, there will be costs paid by the public in exchange for giving certain facilities extra time to comply with the rule. Waiting one year to implement controls means premature deaths and childhood mercury exposure that could have been avoided. But EPA has said this exception will be used sparingly.
This rule is eminently achievable and despite industry claims to the contrary, there is no real threat of reliability issues. America has a robust system in place to ensure the ample capacity of the nation’s electricity grid. Nothing in this rule will undermine that. Existing technology to cut pollution, new power generation in the pipeline, and flexibility provisions in the rule are more than adequate to ensure that the lights stay on.
Policy Integrity submitted comments on the proposed rule in August.
Issue(s): Energy and Environment
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Friday
December 2nd,
2011EPA releases new Boiler MACT proposed rule
Today the EPA released a new proposal to curb air pollution from industrial boilers. It’s an update on a version released in March of 2010, but never finalized.
The agency appears to have made industry-contouring tweaks to the rule but none that have a major or overarching effect. There is a slight improvement in the health benefits of the rule—annual benefits would rise by $5 billion per year, the delay of the rule cancels some of that out. The EPA estimates that the old rule, would have provided $22 billion in health benefits in the year 2014 while the new version will earn $27 billion a year later, in 2015.
Delay is almost always costly to public health so a better path would have been to implement the rule as it was in 2010, and made these minor tweaks later.
Another important note is that the health benefits of mercury emissions reductions were never quantified so the allowance for increased mercury emissions in this new version of the rule is not accounted for in the costs. That change could be significantly worse for public health. Without that information, it’s hard to say which version would really give more net benefits.
Policy Integrity submitted public comments to the 2010 proposed rule and will be submitting updated comments to the revised version.
Issue(s): Energy and Environment