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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.

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.

Policy Integrity submitted comments on draft recommendations proposed by the ACUS (Administrative Conference of the United States) Committee on Regulation on the use of cost-benefit analysis at independent regulatory agencies.

Sadly, the idea that market forces can drive down the cost of public health regulation has lost favor in the past few years. The EPA’s long-delayed, first-ever greenhouse gas standards for new power plants (New Source Performance Standards or NSPS) offers an opportunity to make market mechanisms cool again.

Policy Integrity submitted comments to the Department of Energy (DOE) on its plan for periodic retrospective review pursuant to Executive Order 13563, which asks agencies to consider how best to promote retrospective analyses of existing rules. We found that the DOE’s plan could do a better job of updating and expanding regulations to enhance net benefits rather than just minimization of compliance burdens and administrative cost cutting, which the plan largely focuses on.

Policy Integrity submitted comments to ACUS (Administrative Conference of the United States) regarding various proposed recommendations to be considered at its 56th Plenary Session. As an independent federal agency that works to improve federal agency procedures, ACUS held its biannual assembly to discuss and vote on recommendations around issues such as regulatory analysis requirements, midnight rules, and coordination of multi-agency responsibilities.

Today we submitted comments in response to OIRA’s annual report to Congress. Among the several specific suggestions is that the employment impacts of regulations be integrated into cost-benefit analysis in a balanced, transparent way. We recommend that OIRA should be careful to avoid any language that reinforces the mistaken belief that regulations inevitably lead to unemployment and that any analysis should do its best to model net employment impact, not just one region or sector.

Today, Policy Integrity submitted public comments to the Administrative Conference of the United States regarding their Committee on Regulation’s proposed recommendations for review of regulatory analysis requirements.

Boiler MACT regulations will take harmful soot out of the air as well as mercury and other heavy metals. It will have a significant positive effect on respiratory and cardiovascular health. But EPA is currently reconsidering some of the rule it deems shaky.

Recently, women’s health has been a topic of national news. It’s also made headlines in Virginia where the state government has taken steps that could effectively shutter many women’s health clinics.