Institute for Policy Integrity

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What We Do

Project Updates

Viewing all updates in Public Comments
  • Public Comments

    Comments on Con Edison Storm Hardening and Resilience Collaborative Report

    January 10, 2014

    On January 10, Policy Integrity, along with New York University’s Guarini Center, submitted comments on Con Edison’s Storm Hardening and Resilience Collaborative Report. The comments urge New York’s Public Service Commission (PSC) to extend the charter of the cost-benefit analysis working group convened as part of the collaborative process surrounding Con Edison’s latest ratemaking proceeding.

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  • Public Comments

    ACUS Accepts Policy Integrity’s Recommendation on Remand Without Vacatur

    December 5, 2013

    The Administrative Conference of the United States (ACUS) Committee on Judicial Review accepted a recommendation made by Policy Integrity on remand without vacatur.

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  • Public Comments

    Comments on ACUS Draft Statement Regarding the OIRA Regulatory Review Process

    November 13, 2013

    Policy Integrity submitted comments on the draft statement by the Administrative Conference of the United States (ACUS) Committees on Administration and Management, and Regulation, for improving the timeliness, transparency, and effectiveness of the regulatory review process of the Office of Information and Regulatory Affairs (OIRA).

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  • Public Comments

    Comments on ACUS Draft Recommendations for Remand without Vacatur

    November 12, 2013

    Policy Integrity submitted comments on draft recommendations by the Administrative Conference of the United States (ACUS) Committee on Judicial Review for remand without vacatur in which a court returns a regulation to an agency for revision. This is an improvement to the traditional approach of annulling an agency action outright, which can result in creating an antiregulatory bias. But the draft recommendations could be strengthened in three ways:

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  • Public Comments

    Comments On the Social Cost of Carbon in DOE’s Refrigerator Rule

    November 12, 2013

    Policy Integrity, along with Environmental Defense Fund, Natural Resources Defense Council, and Union of Concerned Scientists, submitted comments on the social cost of carbon (SCC) within a rule proposed by the Department of Energy regarding energy conservation for commercial refrigeration equipment. The SCC calculation is an estimate of the damage caused by each ton of carbon emissions and used in the cost-benefit analyses of regulations with greenhouse gas emissions reductions.

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  • Public Comments

    Comments on the Social Cost of Carbon in Metal Halide Lamp Fixtures Rule

    October 21, 2013

    Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists, submitted comments on the social cost of carbon. The calculation—an estimate of the damage caused by each ton of carbon emissions—was used in a rule proposed by the Department of Energy regarding energy conservation from metal halide lamp fixtures. The joint comments show that according to cutting-edge economic research, the estimate used by the government may be too low.

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  • Public Comments

    Comments to HUD on Improving Approaches to Affirmatively Furthering Fair Housing

    September 17, 2013

    HUD has implemented several recommendations outlined in a regulatory report published by the Institute for Policy Integrity in the proposed Affirmatively Furthering Fair Housing rule. By incorporating our recommendations, HUD has more clearly defined its goals in “affirmatively furthering fair housing,” and has provided metrics and data that municipalities can use to measure their compliance.

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  • Public Comments

    Comments to OSHA on its Injury and Illness Prevention Program

    September 4, 2013

    The Obama Administration is poised to improve worker safety by establishing a nationwide Injury and Illness Prevention Program. But unless it is well designed, the program will leave too many vulnerable to unsafe work conditions.

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  • Public Comments

    Comments on OIRA’s 2013 Annual Report

    June 11, 2013

    The Institute for Policy Integrity submitted comments in response to OIRA’s 2013 draft report to Congress. We suggest that OIRA can make further improvements to its final report by adding the following: recommend the balanced, transparent integration of employment impacts into cost-benefit analysis; recommend using retrospective review to pursue balanced, evidence-based, data-driven decisionmaking—not just cost-cutting; and recommend agencies coordinate by standardizing methodological practices, and should address claims of regulatory conflict or incoherence.

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  • Public Comments

    Comments to Chugach National Forest on Revision of its Resource Management Plan

    April 29, 2013

    Policy Integrity submitted comments to the Chugach National Forest advocating for the use of cost-benefit analysis in the revision of the forest’s Resource Management Plan. The US Forest Service updated its rule last year on how individual forests should develop their management plans, eliminating an explicit requirement to study the net present value of management alternatives. The forests, though, were left with some discretion, which we think forests like Chugach should use to incorporate cost-benefit analysis into their planning.

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