Recent Projects

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

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.

In advance of nomination hearings for OIRA administrator appointee, Howard Shelanski, Policy Integrity sent a one-pager to members of Congress to give them a framework for addressing delays that sometimes occur in the regulatory review process.

The U.S. Court of Appeals for the Sixth Circuit, citing Richard Revesz’s work with co-author Jonathan Nash on “grandfathering” power plants, recently reversed a district court order and sided with the EPA in its case against DTE Energy Corp. The court ruled that the Clean Air Act grants the EPA the power to review projections of future emissions resulting from a facility modification without having to wait for data from the completed project.

Policy Integrity submitted a letter to OIRA on its long delay in reviewing two rules from the Department of Labor. The rules, Occupational Exposure to Crystalline Silica and Occupational Injury and Illness Recording and Reporting Requirements, have been under review for 764 and 483 days, respectively. OIRA review of rules from the Department of Labor since 1994, the first full year of review under the 90-day framework established by Executive Order 12866, has lasted an average of only 60 days.

Michael Livermore, director of Policy Integrity, presents testimony today on the Affordable Care Act’s Summary of Benefits and Coverage (SBC) rule to the Senate Committee on Commerce, Science, and Transportation. The testimony will be featured in a hearing entitled, “The Power of Transparency: Giving Consumers the Information They Need to Make Smart Choices in the Health Insurance Market.”

Policy Integrity is winding down its energy tax breaks wiki after over a year of compiling the expertise of lawyers, economists, tax professionals, and concerned citizens to catalog tax breaks received by the fossil and renewable energy industries.

Policy Integrity submitted a petition today urging the EPA to fulfill its obligation under Section 115 of the Clean Air Act to instruct all fifty states to cut greenhouse gas emissions. If EPA ignores or denies the petition, Policy Integrity can pursue appropriate legal action to force the agency to respond.

Policy Integrity, along with environmental attorney Steven Sugarman, are counsel to the Center for Sustainable Economy (CSE) in their lawsuit against the Bureau of Ocean Energy Management (BOEM) to halt the agency’s first five-year outer continental shelf oil and gas leasing program approved since the Gulf oil disaster.

Today we submitted a notice of intent to sue EPA for failing to take certain actions to guard against climate change. In 2009, we asked the EPA to limit the carbon emissions that come from mobile sources like cars, boats and planes. The agency did not respond, as it is legally required, so we will now take the next step in notifying them of our intention to sue.