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Recent Projects

  • 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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  • News

    Opening Brief Filed in Offshore Drilling Lawsuit

    October 23, 2013

    Policy Integrity, on behalf of the Washington, D.C.-based Center for Sustainable Economy, filed the opening brief in a lawsuit to halt illegal practices at the Bureau of Ocean Energy Management. The brief argues that incomplete and flawed economic analysis leads BOEM to sell new offshore leases too quickly and too cheaply, potentially costing the American public hundreds of billions of dollars.

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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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  • 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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  • News

    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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  • Court Filings

    Policy Integrity Files Supreme Court Amicus Brief on EPA’s CSAPR

    September 11, 2013

    Today, Policy Integrity filed an amicus brief with the Supreme court which argues that in place of an established, relatively unchallenged understanding of EPA authority, a lower court substituted its preferred policy for that of the agency. In doing so, it acted inconsistently with core principles of American administrative law.

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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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  • News

    CEQ Changes to Water Resources Study Reflects Policy Integrity Recommendations

    June 25, 2013

    The President’s Council on Environmental Quality (“CEQ”) has implemented several changes to the Proposed National Objectives, Principles and Standards for Water and Related Resources Implementation Studies that are consistent with recommendations Policy Integrity made in comments on the 2009 draft.

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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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