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Changes to EPA’s Cost-Benefit Guidelines
EPA has been quietly working on some serious changes to the guidelines it uses to conduct cost-benefit analysis. Tweaks to the powerful but low-profile Guidelines for Preparing Economic Analyses could have major impacts on the environment. The Guidelines is little known outside of the agency, but is used in the design of every major environmental regulation.
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Legal petition to EPA to adopt cap-and-trade for vehicle emissions
Policy Integrity filed a legal petition with the EPA Administrator Lisa Jackson to propose and adopt regulations instituting a cap-and-trade system to control greenhouse gases emissions from fuels used in vehicles. This petition takes aim at emissions from all vehicles, which account for 36% of the total greenhouse gas emissions in the United States.
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Request for cost-benefit analysis of Waxman-Markey bill
During the congressional debate over the climate legislation proposed by Reps. Waxman and Markey, the EPA published several costs estimates for the bill. But the agency was never asked to estimate the corresponding benefits.
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Letter in support of the Cap and Dividend Act
Policy Integrity released a letter of support for HR 1862. This bill, known as the Cap and Dividend Act of 2009, proposes a system of curbing greenhouse gas emissions that auctions carbon allowances and refunds the proceeds to American households.
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Motion for leave against hazardous truck driver rules
In November 2008, just weeks before President Obama took office, the Bush Administration finalized a rule increasing the amount of time truck drivers can spend behind the wheel—creating a possible public health and safety hazard. The rule allows truck drivers to drive for 11 hours, one more hour than they were allowed before 2003, and allows them to drive as many as 77 hours in seven days or 88 hours in eight days, over 25 percent more than previously allowed by federal law.
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Policy Integrity’s recommendations incorporated into EECA report
Today, Policy Integrity received favorable feedback on comments we submitted on draft EPA Guidelines for Preparing Economic Analyses supporting positive changes made in the new draft and suggest additional improvements. The document has been an influential resource for EPA’s consideration of regulatory costs and benefits.
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Legal memorandum on stopping midnight regulations
Shortly after his inauguration, President Obama took steps to halt the adoption or implementation of regulations that went into the pipeline during the final days of the Bush Administration.
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Letter to the EPA re: easing of restrictions on mountaintop coal mining
As part of a raft of midnight regulations, the U.S. Department of the Interior and the Environmental Protection Agency worked together to finalize regulations that ease restrictions on mountaintop coal mining—in particular how and when mining operations can deposit waste, rocks, and soil in or near streams.
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Letter to the OMB re: refusal of health care services on moral grounds
In August 2008, the Department of Health and Human Services (HHS) proposed a regulation that would expand protections for medical professionals who refuse to provide health care services that they object to on moral grounds. Policy Integrity worked with a coalition of women’s health organizations to oppose the rule based on its finding that HHS ignored the negative consequences this policy could have on access to care, especially for women seeking reproductive health services.
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Statement of Principles for HEAP energy relief efforts
Economists know that when the cost of basic goods like energy increase, quality of life of decreases most for people with lower incomes. This is an important issue that government agencies should consider when estimating the effects of regulations.
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