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Proposal for ACUS Project on Petitions for Rulemaking
Policy Integrity submitted a proposal to the Administrative Conference of the United States (ACUS) for the development of recommendations on citizens’ petitions for rulemaking.
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Comments to HUD on Improving Approaches to Affirmatively Furthering Fair Housing
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.
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Policy Integrity Files Supreme Court Amicus Brief on EPA’s CSAPR
Today, Policy Integrity filed an amicus brief with the Supreme court which argues that in place of an established, relatively unchallenged understanding of EPA authority, a lower court substituted its preferred policy for that of the agency. In doing so, it acted inconsistently with core principles of American administrative law.
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Comments to OSHA on its Injury and Illness Prevention Program
The Obama Administration is poised to improve worker safety by establishing a nationwide Injury and Illness Prevention Program. But unless it is well designed, the program will leave too many vulnerable to unsafe work conditions.
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Environmental Awareness in the Atomic Age
Radioecologists and Nuclear Technology
Many biologists who conducted studies on nuclear fallout and waste for the Atomic Energy Commission began to develop concerns about radioactive pollution in the environment from the long-term, cumulative effects of nuclear waste disposal, the use of atomic bombs for construction projects, and the potential ecological devastation wrought by nuclear war. Their new environmental awareness prompted many Atomic Energy Commission ecologists to try to draw congressional attention to the dangers that nuclear technology posed to the environment. This article, published in Historical Studies in the Natural Sciences, highlights reforms in the education and training of ecologists to meet the challenges of the atomic age through the new subfield of “radioecology” as well as research into problems of environmental pollution more broadly.
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CEQ Changes to Water Resources Study Reflects Policy Integrity Recommendations
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.
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Comments on OIRA’s 2013 Annual Report
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.
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Policy Integrity sends Members of Congress a framework for addressing OIRA delays
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.
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Regulatory Report
Affirmatively Furthering Fair Housing
Decades after the civil rights movement inspired the Fair Housing Act, HUD still has a long way to go before that law’s vision of fair housing is realized. The primary recommendations of this report to the Department of Housing and Urban Development (HUD) are to more clearly define fair housing goals and to measure the progress of locally-based housing providers in meeting the requirements of the 1960’s civil rights statute.
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Revesz’s work on grandfathering cited in Federal Court Case
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.