Recent Projects

Policy Integrity filed comments on the Consumer Product Safety Commission's (CPSC) Proposed Rule for custom window coverings, which would require safety features to reduce the strangulation risk from window covering cords. We argue that adding a child premium to the value of statistical life (VSL) is consistent with federal guidance and international regulatory practice. However, if the CPSC chooses to apply a child premium, it should offer a theoretical justification that does not rely on life-years. We also argue that the CPSC has the authority to consider unquantified benefits and should consider avoided parental grief as a benefit of the Proposed Rule, but only to the extent it is not already captured in a child VSL premium. Furthermore, the CPSC should consider avoided litigation costs and recall costs as a quantified or unquantified benefit of the Proposed Rule and use a break-even analysis to better incorporate unquantified benefits.

The Office of the Comptroller of the Currency (OCC) has issued Draft Principles for Climate-Related Financial Risk Management for Large Banks. Along with partner organizations, we submitted comments supporting the OCC's Draft Principles and offering potential next steps for the OCC.

The Emergency Temporary Standard (ETS), which directs large employers to require COVID-19 vaccines or testing, represents an important step toward reducing the virus in the workplace. While the agency offers numerous compelling justifications for the proposed rule, this comment highlights several additional rationales regarding the legislative and regulatory history of the Occupational Safety and Health (OSH) Act. A blog post on the issue by comment co-authors and NYU Law students Nina Henry and Alex Jonlin is available here.

We submitted comments to the Department of Health and Human Services (HHS) supporting its proposed repeal of the SUNSET Rule, which retrospectively and prospectively established an "expiration date" for thousands of HHS regulations. We explain why the SUNSET Rule is arbitrary and capricious, echoing our earlier comments, and and propose ways that HHS can strengthen its justification for repealing the rule.

We submitted comments in response to the Federal Transit Administration's (FTA) request for information on updating its Title VI Circular, which lays out nondiscrimination requirements for transit providers who receive funding from the agency. Our comments encourage FTA to require the nondiscriminatory distribution of clean vehicles across transit systems and to create the appropriate reporting requirements that would allow the agency to monitor this.

We submitted joint comments with partners from the Environmental Defense Fund and the Initiative on Climate Risk and Resilience Law supporting the Department of Labor’s (DOL) revision of Trump-era restrictions on ESG investing by retirement plans.

Policy Integrity encouraged the Department of Homeland Security to supplement its justification for the rule by quantifying and monetizing key unquantified benefits in the RIA, such as improvements in mental health, increased belonging, and hope for the future. The comments also recommended that DHS offer more evidence that the DACA program has no significant effect on legal or illegal immigration and more thoroughly address litigation risk and case-by-case enforcement arguments for rescinding the program.

Policy Integrity submitted comments to the U.S. Department of Health & Human Services (“HHS”)'s request for input on its proposed repeal of the Trump Administration’s Good Guidance Practices Rule (“GGP Rule”). The rule would have increased administrative complexity in ways that harmed HHS programs and public health. Our comments explain why the rule's costs justify HHS's repeal and offer ways the department can sterngthen its justification for repeal by taking note of the aggregate costs and benefits of repealing the GGP Rule and incorporating public comments on the GGP Rule into the record.

Insurers face and create climate risk as underwriters, investors, and risk-carriers. We submitted comments to the Federal Insurance Office (FIO) explaining how the office could use its authority to reduce these marketplace risks and to protect the affordability and accessibility of insurance.

We submitted comments on NHTSA's proposed car standards, recommending ways that the agency could improve its modeling and address inconsistences between its and EPA's analyses. We also submitted joint comments on NHTSA's use of the social cost of carbon, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SCC.