Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

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  • News

    Livermore Argues Offshore Leasing Case in DC Circuit Court

    September 12, 2014

    The government’s offshore leasing system fails to account for uncertainties about environmental harms—the system ignores “option value,” a well-established economic technique that quantifies the value of delaying decisions to acquire crucial information. As a result, the current leasing system leads to over-exploitation of natural resources and excessive environmental risk.

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  • Public Comments

    Tobacco Products and Consumer Welfare - Public Comments

    August 8, 2014

    Policy Integrity recently submitted public comments to the Food and Drug Administration (FDA) on its proposed rule to deem certain tobacco products, such as electronic cigarettes and cigars, subject to regulation. We believe the FDA may be dramatically understating the benefits from consumer behavior changes due to regulation of new tobacco products.

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  • News

    Comments Submitted to OMB in Support of the Social Cost of Carbon

    February 26, 2014

    Policy Integrity submitted comments to the Office of Management and Budget (OMB) voicing our support for the Administration’s continued use of the social cost of carbon (SCC) as it provides an important, if conservative, estimate of the costs of climate change and the benefits of reducing carbon pollution.

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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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  • News

    Comments on Petition for Correction on Social Cost of Carbon

    October 21, 2013

    Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists submitted comments opposing a petition for correction sent to the Office of Management and Budget (OMB) and the other agencies involved in the Interagency Working Group on the Social Cost of Carbon (IWG).

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  • Petitions

    Proposal for ACUS Project on Petitions for Rulemaking

    October 11, 2013

    Policy Integrity submitted a proposal to the Administrative Conference of the United States (ACUS) for the development of recommendations on citizens’ petitions for rulemaking.

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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 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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