Project Updates – Letters

  • Friday
    May 11th,
    2012

    Letter to OIRA on Interagency Coordination

    Policy Integrity submitted a letter to OIRA Administrator Cass Sunstein today with recommendations for how OIRA can improve interagency coordination. The letter focuses on two key areas: (1) concerns about regulatory conflict, and (2) potential for harmonization of cost-benefit analysis methodology.

    Our first recommendation is for OIRA to directly address criticism about the prevalence of conflicting, incoherent, and redundant regulations throughout the administrative state. OIRA should conduct an empirical investigation to assess the real scope of such a problem. Methodologies for this include surveying the academic literature, consulting with agencies, and soliciting comments to better understand the extent of conflicting regulations.

    OIRA can also improve interagency coordination by standardizing methodological practices related to cost-benefit analysis. Developing uniform standards for various aspects of regulatory analysis would create a more logical system with rules that could be easily compared across agencies. More specifically, we recommend that OIRA take the following actions: address the fact that disparate Values of Statistical Life are currently being used by different agencies; to require agencies to conduct distributional analysis of significant rules; to develop best practices for for labeling rules; and to address the need for standard cancer risk assessment protocols.

    Issue(s): Cost-Benefit Analysis   Type: Letters

  • Friday
    February 24th,
    2012

    Suggestions to the Small Business Administration on Regulatory

    This week, President Obama laid out his blueprint for lowering corporate taxes. The response from Republicans: small businesses will suffer.

    Taxes aren’t the only place where small businesses currently get a break, and in the regulatory context, sometimes the special treatment goes too far. Today we submitted suggestions to the Small Business Administration on how to avoid getting overzealous.

    SBA is charged with implementing requirements for agencies to look at alternatives to rules that would adversely affect small businesses. Under its watch, small businesses are shielded from the impacts of regulation through exemptions, lower standards, or longer compliance timelines.

    But it is not always a good idea to allow small businesses off the regulatory hook. If done incorrectly or haphazardly, the public can end up footing an oversized bill and larger companies can end up paying inefficiently high costs.

    If the goal is to maximize benefits to Americans, decisionmakers need to be careful not to go over the top in protecting small businesses. While enhancing small businesses competitiveness may be a good idea, it should not override the environment, public health, or basic economic principles.

    Ultimately, implementation of these small business requirements like the Regulatory Flexibility Act, needs refinement to ensure the American public isn’t hurt in the attempt to boost small businesses.

    Issue(s): Cost-Benefit Analysis   Type: Letters

  • Wednesday
    February 8th,
    2012

    Letter to BOEM regarding options value

    Currently, the federal government treats lease sales as a no-or-never decision. That’s an approach that leads to too many leases sold too quickly, at too low a price. Instead, BOEM should be waiting to sell these leases until the time is right—when they can get the highest possible price.

    Failing to do so means taxpayers are getting less than the leases are worth, a proposition that could mean hundreds of billions of dollars lost.

    To call attention to the matter, Policy Integrity sent a letter to the Bureau of Ocean Energy Management (BOEM) requesting that the agency incorporate options value into their assessments of offshore drilling lease sales. Michael Livermore’s working paper, Patience is a(n Economic) Virtue, was attached to the letter.

    Since, in its decisionmaking, BOEM must strive to consider all relevant factors, and to quantify all costs and benefits as fully and as accurately as possible—norms that are enshrined in legal precedents and executive orders—it is problematic that the agency does not currently take options into account at all.

    Issue(s): Energy and Environment   Type: Letters

  • Thursday
    January 26th,
    2012

    Letter 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

  • Wednesday
    January 18th,
    2012

    Letter 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