Recent Projects

The Administrative Conference of the United States (ACUS) Committee on Judicial Review accepted a recommendation made by Policy Integrity on remand without vacatur.

Policy Integrity submitted comments on the draft statement by the Administrative Conference of the United States (ACUS) Committees on Administration and Management, and Regulation, for improving the timeliness, transparency, and effectiveness of the regulatory review process of the Office of Information and Regulatory Affairs (OIRA).

Policy Integrity submitted comments on draft recommendations by the Administrative Conference of the United States (ACUS) Committee on Judicial Review for remand without vacatur in which a court returns a regulation to an agency for revision. This is an improvement to the traditional approach of annulling an agency action outright, which can result in creating an antiregulatory bias. But the draft recommendations could be strengthened in three ways:

Policy Integrity, along with the Environmental Defense Fund, the Natural Resources Defense Council, and the Union of Concerned Scientists submitted comments opposing a petition for correction sent to the Office of Management and Budget (OMB) and the other agencies involved in the Interagency Working Group on the Social Cost of Carbon (IWG).

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

HUD has implemented several recommendations outlined in a regulatory report published by the Institute for Policy Integrity in the proposed Affirmatively Furthering Fair Housing rule. By incorporating our recommendations, HUD has more clearly defined its goals in “affirmatively furthering fair housing,” and has provided metrics and data that municipalities can use to measure their compliance.

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.

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.

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.