Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

Viewing all updates in Public Comments
  • Public Comments

    Comments on ACUS Committee on Regulation Recommendations on CBA

    March 27, 2013

    Policy Integrity submitted comments on draft recommendations proposed by the ACUS (Administrative Conference of the United States) Committee on Regulation on the use of cost-benefit analysis at independent regulatory agencies.

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  • Public Comments

    Comments to EPA on Adding Flexibility to Greenhouse Gas Rules

    June 25, 2012

    Sadly, the idea that market forces can drive down the cost of public health regulation has lost favor in the past few years. The EPA’s long-delayed, first-ever greenhouse gas standards for new power plants (New Source Performance Standards or NSPS) offers an opportunity to make market mechanisms cool again.

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  • Public Comments

    Comments to DOE on Retrospective Review

    June 19, 2012

    Policy Integrity submitted comments to the Department of Energy (DOE) on its plan for periodic retrospective review pursuant to Executive Order 13563, which asks agencies to consider how best to promote retrospective analyses of existing rules. We found that the DOE’s plan could do a better job of updating and expanding regulations to enhance net benefits rather than just minimization of compliance burdens and administrative cost cutting, which the plan largely focuses on.

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  • Public Comments

    Comments to ACUS on its 56th Plenary Session

    June 13, 2012

    Policy Integrity submitted comments to ACUS (Administrative Conference of the United States) regarding various proposed recommendations to be considered at its 56th Plenary Session. As an independent federal agency that works to improve federal agency procedures, ACUS held its biannual assembly to discuss and vote on recommendations around issues such as regulatory analysis requirements, midnight rules, and coordination of multi-agency responsibilities.

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  • Public Comments

    Comments to OIRA on their 2012 Annual Report

    June 11, 2012

    Today we submitted comments in response to OIRA’s annual report to Congress. Among the several specific suggestions is that the employment impacts of regulations be integrated into cost-benefit analysis in a balanced, transparent way. We recommend that OIRA should be careful to avoid any language that reinforces the mistaken belief that regulations inevitably lead to unemployment and that any analysis should do its best to model net employment impact, not just one region or sector.

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  • Public Comments

    Public Comments to the Administrative Conference of the United States

    May 2, 2012

    Today, Policy Integrity submitted public comments to the Administrative Conference of the United States regarding their Committee on Regulation’s proposed recommendations for review of regulatory analysis requirements.

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  • Public Comments

    Comments to EPA on reconsideration of Boiler MACT

    February 21, 2012

    Boiler MACT regulations will take harmful soot out of the air as well as mercury and other heavy metals. It will have a significant positive effect on respiratory and cardiovascular health. But EPA is currently reconsidering some of the rule it deems shaky.

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  • Public Comments

    Comments to the Virginia Board of Health on Access to Health Care

    February 15, 2012

    Recently, women’s health has been a topic of national news. It’s also made headlines in Virginia where the state government has taken steps that could effectively shutter many women’s health clinics.

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  • Public Comments

    Comments to EPA and DOT on CAFE Standards for Model Years 2017-2025

    February 13, 2012

    Cars that hit the streets in 2017 through 2025 will run on far less fuel than they do now. Last summer, the Obama Administration announced a deal with automakers aiming to up the average to 56 miles per gallon and EPA-DOT proposed a new rule that would hold them to that standard.

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  • Public Comments

    Comments to EPA on NSPS review for Nitric Acid Plants

    November 28, 2011

    Policy Integrity submitted comments to the Environmental Protection Agency (EPA) urging updates to its New Source Performance Standards (NSPS) program standards for nitrogen oxide (NOx ) and nitric acid plants, which can emit dangerous air pollutants that can cause illness and alter the climate. Though a statute requires the EPA to review and revise related regulations every eight years, the rules governing these plants have not been updated in four decades.

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