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Does Process Matter
Regulatory Procedure and Regulatory Output in the States
Rulemaking in the states has become much more widespread than it was when many state legislatures began to pass their administrative procedures acts more than 40 years ago. A wide diversity of rulemaking procedures presents a natural laboratory in which to study several questions that have long interested scholars of the regulatory process. This paper finds that the level of rulemaking is more closely correlated to the lawmaking activity in the state rather than proceduralization which suggests no disrespect for the law, as Churchill argued, but rather that the lawmakers themselves have given rise to the thousands of regulations in the states.
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Amicus Brief on Tailpipe Rule
Policy Integrity submitted an amicus brief today on a federal court case challenging the EPA’s ability to regulate emissions from motor vehicles. Some industry groups and states are contesting the validity of the EPA and NHTSA’s (National Highway and Traffic Safety Administration) “Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards” finalized last year.
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DOE’s Final policy on fuel cycle fuel analysis
The U.S. Department of Energy (DOE) recently announced its final policy on incorporating full fuel cycle analysis. This form of analysis expands on the current way of estimating the energy savings of appliances by including the costs of everything from fuel extraction to distribution and also estimating the greenhouse gas impacts of the machine.
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Can Cost-Benefit Analysis of Environmental Policy Go Global?
The use of cost-benefit analysis of environmental policy is spreading from the United States, where it has the longest tradition, to other parts of the globe. This paper discusses the challenges posed for cost-benefit analysis as it spreads, and how it can evolve to meet those challenges.
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Comments to EPA on Proposed Cooling Rules
Policy Integrity submitted comments to the EPA on its proposed rules for cooling water intake structures, required under the Clean Water Act. These rules would affect practices at power plants that mean death for thousands of fish boiled or pinned by screens and intake pipes.
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Comments to EPA on Utility Mact and Utility NSPS
The EPA released proposed regulations earlier this year in May to curb hazardous air pollutants, including mercury, from electric utility steam generating units (EGUs). Policy Integrity submitted comments today to the EPA on improving the efficiency of these rules, known as Utility MACT and Utility NSPS. They are both expected to be finalized later this year.
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Prevailing Academic View on Compliance Flexibility under Section 111 of the Clean Air Act
EPA will soon propose performance standards under Section 111 of the Clean Air Act for greenhouse gas pollution. Many argue that to be effective and efficient, the standards should incorporate compliance flexibility. This repport finds widespread agreement in the academic community that § 111 authorizes the use of many types of flexible approaches.
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Valuing the Clean Air Act
How Do We Know How Much Clean Air is Worth?
EPA recently released a study evaluating the costs and benefits of amendments to the Clean Air Act between 1990 and 2020 to see what cleaner air means for human health and the economy. Holladay’s analysis of EPA’s numbers shows that they’re based on sound science.
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Letter to HHS on Proposed Transparency Reporting Rule
Policy Integrity submitted a letter today to the Department of Health and Human Services on its upcoming Transparency Reporting rule, mandated by the Affordable Care Act of 2010. The rule would develop uniform disclosure standards for group health plans and health insurance issuers, requiring them to provide consumers with new, more detailed information on likely co-pays for particular plans or treatments; providers would also have to provide consumers with a document that summarizes benefits and explains coverage clearly in four pages or less.
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Comments on Preliminary Plans for Periodic Retrospective Reviews of Existing Regulations
In January, President Obama issued a call for all federal agencies to review their existing regulations, looking for rules that had grown outdated, ineffective, or insufficient over time. Back then, there was much discussion over whether the move was a gift to business or a robust defense of strong protections even in a downturned economy.