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Regulatory Support
for Homeland Security

ICF International's staff produce the regulatory, economic, and technical analyses homeland security decision-makers need to develop and improve their diverse regulatory programs on issues such as immigration, food safety, bioterrorism, border control, and transportation. The U.S. federal regulatory process is complex and can be time consuming. Resource constraints and legally binding deadlines can complicate an agency's task of taking critical regulatory action.

ICF International helps clients overcome these obstacles by providing cost-effective regulatory support services and tools. Our policy analysts, economists, lawyers, scientists, transportation analysts, and emergency management experts have an exceptional grasp of the regulatory process and can support all phases of individual rulemakings, as well as improvements to managing the regulatory development process.

Our Solutions
Selected Projects

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Regulatory Support
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Our Approach

We understand the rulemaking process—the requirements of the U.S. Administrative Procedure Act and applicable executive orders and statutes. We understand that an agency may confront challenges that are not typical, so we take time to listen to our clients and learn the nuances of each project.

ICF International is alert to the risks inherent in the rulemaking process:

  • multiple layers of internal agency review
  • unanticipated delays in achieving consensus
  • unexpectedly high volumes and complexity of comments
  • delays in external review and coordination
  • other unanticipated events

We use a project structure that allows us to identify and respond quickly to events that may threaten effective and timely completion of the project. Our managers maintain close and frequent contact with the client to ensure that we remain substantively on target and on schedule. Our capabilities and experience in providing rulemaking support range across the following activities:

  • Selecting a Regulatory Approach—We help clients identify and describe problems, characterize affected stakeholders, and develop options and conduct tradeoff analyses.

  • Drafting Preambles and Rules—We prepare plain language drafts of preambles and rules.

  • Performing Regulatory Analyses—We estimate costs, benefits, and cost-effectiveness of regulatory approaches (e.g., market-based, performance-based), analyzing paperwork burdens, and preparing support documentation (e.g., regulatory support analyses (RSA), environmental impact statements (EIS), and information collection requests (ICRs)).

  • Managing Stakeholder Involvement—We facilitate stakeholder participation and summarize and develop responses to public comments.

  • Implementing Regulatory Decisions—We help develop implementation strategies, provide outreach and training support, and evaluate the progress of implementation.

Learn more about our comprehensive Regulatory Support services.

ICF CONSULTING'S REGULATORY TOOLS

CommentWorksSM
ICF International offers a Web-based system to streamline the management and analysis of public comments on proposed agency actions. It allows users to post public comments and other material to an agency Web site; categorize and sort comments; draft, edit, and approve comment summaries and responses; conduct full-text searches of comments and other documents. CommentWorksSM supports rulemakings of any size, but adds greatest value for controversial proposals. It has been used by U.S. federal agencies such as the Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA), former Immigration and Naturalization Service (INS), Department of Energy (DOE), Nuclear Regulatory Commission (NRC), Environmental Protection Agency (EPA), and Department of Labor (DOL).

Training on the Regulatory Process
ICF International provides training for the rulemaking process—from a statutory mandate or agency initiative to a fully developed rule of general applicability and legal effect. The course follows a multistep process from initial decisions to final rule publication, giving attendees a road map to successful completion of rulemaking projects.

Reg Map for Informal Rulemaking
ICF International developed a map of the informal rulemaking process, depicting in nine steps the general requirements for developing an informal rule. Order your free copy now.

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SELECTED PROJECTS
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DETAILS OF SELECTED PROJECTS
Support for Development of Bioterrorism Rule, U.S. Centers for Disease Control and Prevention (CDC)

ICF International is supporting the U.S. Centers for Disease Control and Prevention's (CDC) preparation of a rule captioned "Possession, Use, and Transfer of Select Agents and Toxins" to implement provisions of the Public Health Security and Bioterrorism Protection Act of 2002. ICF International helped draft an interim final rule, conducted analyses required by Executive Order 12866 to reflect the economic impact of the interim final rule on affected entities, reviewed the requirements of other applicable Executive Orders, and provided logistical support for the public meeting held to discuss the rule. We provide support for managing responses to public comments and will assist in developing the final rule.

Fitness for Duty Regulation, U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Security and Incident Response and Office of Nuclear Reactor Regulation

ICF International supports the U.S. Nuclear Regulatory Commission (NRC) in developing comprehensive revisions to the regulations specifying drug and alcohol testing, criminal background checks, and other investigations necessary to ensure that individuals who are granted unescorted access to nuclear power plant protected areas or who guard or transport certain categories of nuclear material are trustworthy and reliable. We are also analyzing the costs and impacts of the requirements.

Diversion Control Rules, U.S. Drug Enforcement Administration (DEA)

ICF International is supporting the U.S. Drug Enforcement Administration (DEA) in a comprehensive program to update and streamline regulations. We are helping with policy notices, draft preambles, rule language, and economic analyses. We have drafted notices on Internet sales of controlled substances, security controls for over-the-counter drugs containing listed chemicals, and electronic commerce initiatives. We also have helped draft proposed rules on importing controlled substances for personal use and conducted research on the import, export, and internal market for precursor chemicals.

Hours of Service (HOS) Regulation, U.S. Federal Motor Carrier Safety Administration (FMCSA)

ICF International is preparing an economic analysis of proposed changes to the U.S. Federal Motor Carrier Safety Administration (FMCSA) regulations that govern Hours of Service (HOS) for truck drivers. The proposed rule principally affects long-haul trucking operations, both private fleets and for-hire carriers. The work includes revising existing models and developing new algorithms relating rest cycles and crashes. Our analysis compares the value of reducing crashes to the costs of employing additional drivers, when longer breaks are required. We are also analyzing energy effects and preparing an environmental assessment.

Regulatory Support, U.S. Farm Service Agency (FSA)

Working closely with U.S. Farm Service Agency (FSA) management and staff, ICF International condensed more than a thousand pages of rules to 200 pages by clarifying policies, deleting non-regulatory procedures, and using plain language. We helped devise streamlined procedures to implement the new rules and drafted a series of handbooks to assist field implementation. FSA completed the first phase of this effort, giving farmers better access to guaranteed credit. FSA compiled our regulatory work into a second proposed rulemaking on direct loans.

Emergency Response Program Support, U.S. Environmental Protection Agency (EPA)

Beginning in the 1980s, ICF International assisted EPA in technically assessing Superfund or Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and developing regulatory reporting triggers for releases of those substances. We performed several regulatory assessments of the Clean Water Act (Section 311) and the Oil Pollution Act of 1990 (OPA 90), including evaluating spill prevention, reporting, and cleanup procedures.

Chemical Emergency Preparedness and Prevention Activities Support, U.S. Environmental Protection Agency (EPA)

ICF International supported this program for more than 15 years, following the tragic chemical accident in Bhopal, India. We developed guidance for the original program office at EPA and, after the enactment of the Emergency Planning and Community Right-to-Know Act (EPCRA), assisted in the development of a detailed implementation strategy.

Counter Terrorism Program Support, U.S. Environmental Protection Agency (EPA)

For more than six years, ICF International supported the development and ongoing activity of EPA's Counter Terrorism (CT) program for preparedness and response for chemical, biological, radiological, and nuclear weapons of mass destruction. Support included developing a budget initiative for the CT program, preparing an annual report on EPA's counter-terrorism activities and accomplishments, developing briefings for personnel within and outside EPA, and facilitating the development and completion of EPA's CT program workplan.

Emergency Planning and Community Right-to-Know Act (EPCRA) Grants to State, Tribal, and Local Governments, U.S. Environmental Protection Agency (EPA)

ICF International assisted EPA in developing an Emergency Planning and Community Right-to-Know Act (EPCRA) implementation grant program for state, tribal, and local government projects related to community right-to-know and chemical emergency preparedness issues.

National Oil and Hazardous Substances Pollution Contingency Plan (NCP) Support, U.S. Environmental Protection Agency (EPA)

For more than 15 years, ICF International supported EPA in revising the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)—first under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), followed by amendments as a result of the Emergency Planning and Community Right-to-Know Act (EPCRA), and then to incorporate Oil Pollution Act of 1990 (OPA 90) revisions. Learn more about EPA Oil Program Regulatory Support.

Oil Program Regulatory Support, U.S. Environmental Protection Agency (EPA)

Since the 1980s, ICF International has provided regulatory support, technical analysis, research, and outreach for EPA's Oil Program on all major oil spill rules including the:

We prepared technical background documents and issue papers outlining various regulatory strategies, environmental effects of oil spills, and economic impact analyses of regulatory provisions. In addition, ICF International has been involved in numerous studies of trends in oil spill risks in U.S. waters.

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Contact us via e-mail at info@icfi.com Contact us by phone at 1.703.934.3603