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Amicus brief against hazardous trucking regulations
In November 2008, the Bush Administration finalized a regulation allowing truck drivers to spend more hours behind the wheel. To counter the deregulation, advocacy groups including Public Citizen filed suit against the Federal Motor Carrier and Safety Administration (part of the Department of Transportation) in March 2009.
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In the Regulatory Weeds of the Garden State
Lessons From New Jersey’s Administrative Process
There is a dearth of studies about the effects of the proceduralization of the rulemaking process on state regulations. In the Regulatory Weeds of the Garden State focuses on regulations promulgated in New Jersey, both prior to and following major procedural changes enacted in the state in 2001.
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The Other Side of the Coin
The Economic Benefits of Climate Legislation
This brief compiles estimates from several different federal agencies, and calculates that the economic benefits of the emissions cap in the Waxman-Markey bill likely dwarf the costs by as much as 9-to-1 or more. The benefit to cost ratio was determined using the EPA’s previously released (and peer reviewed) cost estimates and a newly released “social cost of carbon” estimate from an interagency process which provides a conservative dollar figure for the benefits of greenhouse gas reductions.
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Changes to EPA’s Cost-Benefit Guidelines
EPA has been quietly working on some serious changes to the guidelines it uses to conduct cost-benefit analysis. Tweaks to the powerful but low-profile Guidelines for Preparing Economic Analyses could have major impacts on the environment. The Guidelines is little known outside of the agency, but is used in the design of every major environmental regulation.
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Policy Integrity submits second round of offshore drilling comments
Before leaving office in early 2009, the Bush Administration released a draft offshore drilling plan that is being taken up by the Obama Administration.
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Legal petition to EPA to adopt cap-and-trade for vehicle emissions
Policy Integrity filed a legal petition with the EPA Administrator Lisa Jackson to propose and adopt regulations instituting a cap-and-trade system to control greenhouse gases emissions from fuels used in vehicles. This petition takes aim at emissions from all vehicles, which account for 36% of the total greenhouse gas emissions in the United States.
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Comments to EPA in support of emissions findings
Policy Integrity submitted comments to EPA in support of the agency’s proposed findings that motor vehicle emissions of greenhouse gases contribute to dangerous air pollution. The comments also highlight some important issues for the agency to consider as it moves forward and call EPA’s attention to some legal obligations that will not be satisfied by the proposed endangerment findings alone.
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No More Excuses
The Economic Case for Coal Ash Regulation
No More Excuses: The Economic Case for Coal Ash Regulation is a brief but careful analysis which reveals several compelling findings on the regulation of the toxic by-product of coal combustion. In broad strokes, it is clear that the benefits of regulating coal ash storage facilities would far outweigh the costs. The benefits of a regulation requiring coal ash to be stored in dry conditions and in synthetically-lined, covered facilities could save tens or even hundreds of millions of dollars per storage facility.
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Regulatory Cost-Benefit Analysis and Collective Action
In Regulatory Cost-Benefit Analysis and Collective Action, Daniel H. Cole describes the influence of cost-benefit analysis and explains how and why it is a politically useful tools for agencies, even when those agencies are not required by law to prepare regulatory cost-benefit analyses (RCBA). As Cole says in his introduction, “For better or for worse, RCBAs have significantly influenced policies for dealing with, or not dealing with, collective action problems ranging from airport enlargement to global climate change.”
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Federalism Accountability
“Agency Forcing” Measures
In Federalism Accountability: “Agency Forcing” Measures, author Catherine M. Sharkey advocates a variety of “agency-forcing” measures designed to enhance the ability of Congress, the executive, and especially the courts to ensure that agencies abide by executive mandates and other reforms, and to provide a check on overt politicization or inaction on agencies’ part.