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  • Comments on FERC’s Office of Public Participation

    The Federal Regulatory Energy Commission (FERC) solicited comment from interested parties on how the Commission should structure their Office of Public Participation to facilitate public engagement. We submitted comments highlighting the potential benefits of public participation by environmental justice communities and identifying best practices that FERC’s Office of Public Participation (OPP) should adopt.

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  • Comments to ACUS on Periodic Review of Agency Regulation

    The Committee on Regulation of the Administrative Conference of the United States requested input on best practices for agencies in undertaking periodic review of their existing regulations. We submitted comments providing a number of recommendations.

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  • Comments to ACUS on Regulatory Alternatives

    The Committee on Regulation of the Administrative Conference of the United States requested input on how agencies should solicit public input on alternatives to rules under consideration. We submitted comments providing a number of recommendations.

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  • Comments on HHS’s Sunset Rule

    The Department of Health and Human Services (HHS) has proposed to retrospectively and prospectively establish an "expiration date" for each of its regulations. Under the proposed rule, regulations would be automatically rescinded unless HHS first completes a restrospective review of the regulation's effects on small entities pursuant to the Regulatory Flexibility Act. We submitted comments criticizing the proposal, which is neither lawful nor rational.

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  • Presidential Transition Guidance

    As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.

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  • Enhancing the Social Benefits of Regulatory Review Cover

    Enhancing the Social Benefits of Regulatory Review

    Rethinking OIRA for the Next Administration

    In recent years, federal leadership has distorted the practice of regulatory analysis and has eroded the integrity of the government’s regulatory review structure as coordinated by the Office of Information and Regulatory Affairs (OIRA). The result has been a torrent of deregulatory actions that have worked against the best interests of the American people and their health, safety, environment, and financial well-being. Our report details the path forward on regulatory review, which is to first surgically excise recent distortions, and then to reaffirm the best principles and practices from the past, while adding key corrections and enhancements. Implementing the reforms recommended in this report will refocus OIRA on helping agencies once again use regulations to maximize net social welfare.

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  • Fighting for the Full Valuation of Climate Damages

    As the climate crisis intensifies, it is crucial that we effectively contextualize and consider how policies affect our climate. We have worked hard to ensure that governments, regulators, and courts account for the social cost of carbon in policy and decisionmaking—and a string of recent policy outcomes has created positive momentum.

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  • Implementing NEPA in the Age of Climate Change Cover

    Implementing NEPA in the Age of Climate Change

    Forthcoming in the Michigan Journal of Environmental & Administrative Law

    Under the National Environmental Policy Act, agencies must consider the environmental impacts of major federal actions before they can move forward. But agencies frequently downplay or ignore the climate change impacts of their projects in NEPA analyses, citing a slew of technical difficulties and uncertainties. This article, forthcoming in the Michigan Journal of Environmental & Administrative Law, aims to highlight best practices so that agency offices can learn from one another, fulfill NEPA’s mandate, and begin to provide leadership in the fight against climate change.

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  • A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship Cover

    A Roadmap to Regulatory Strategy in an Era of Hyper-Partisanship

    This report discusses how an administration that begins a new term can navigate regulatory strategy. It offers advice on navigating this terrain for White House officials, the Office of Information and Regulatory Affairs, transition teams at agencies, and advocates. The report also contains a section on how an incoming administration can roll back the prior administration’s rules if there is an inter-party transition.

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  • Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act

    We submitted joint comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.

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